Treating Customers Fairly
The Team Administrator must have a clear understanding of the concept of Treating Customers Fairly (TCF) and how Personal Touch seeks to comply with this FCA requirement.
Responsibility, both individually and jointly with the other managers of the Personal Touch Management Group for ensuring that at all times the firm and the network treat their customers fairly (TCF) in accordance with the FCA Principle 6.
The Team Administrator will be responsible to the Credit Control and Solvency Manager for ensuring that any and all processes and procedures within his/her remit complies fully with Personal Touch’s TCF policy.
Three Lines of Defence Model
The Personal Touch Group operates a “three lines of defence” controlled environment as described below:
|First Line of Defence
|Second Line of Defence
|Third Line of Defence
|Approved Persons and Senior
Managers in all Business Areas
|Risk and Compliance Team
The promotion of the fair treatment of customers at all times
Having sufficient resource and competent personnel to carry out risk assessment(s) and mitigate risk effectively
Having adequate systems and controls to support the Risk Management Framework
Having appropriate quality assurance and governance arrangements in place to detect and mitigate emerging risk issues
Where mitigation of risk depends on other business areas or third parties, obtaining effective “buy in” from other business areas/third parties
All risk decision making
Identifying and managing
risks and Incidents via the Personal Touch risk framework
Maintenance of Risk Management Framework document
Providing challenge to first line of defence business areas on the effectiveness of their risk assessments and mitigating actions
Oversight of the management to ensure that risks and incidents are identified appropriately
Monitoring the FCA Conduct
Risk horizon and alerting the business to issues that may impact Personal Touch
Undertake periodic risk
assessments and compliance monitoring reviews to assess the effectiveness of the systems and controls and
to ensure the business is regulatory compliant
Conducting audits of the first and second line of defence to assess the effectiveness of the Risk Management Framework
Note: The Board supported by Internal Audit and both the Audit and Risk Committees monitor the overall risk profile of the firm, and ensure that adequate financial resources are maintained.
This role is confirmed to be in the first line of defence.