PAY AND BONUSES
✔ Companies must have remuneration policies that
keep in mind clients’ interests and ensure they are
✔ Remuneration policies must not create a conflict of
interest for a person to favour their own interests
over a client’s.
✔ Senior management are responsible for the
day-to-day remuneration policy and monitoring
compliance risks relating to the policy.
✔ Pay structures should not be based purely on
quantitative commercial criteria and should include
metrics on regulations, client treatment and quality
✔ There should be a balance between fixed and
variable remuneration components.
✔ Firms must have clear procedures for handling
complaints – not just from clients but potential
✔ The complaints management policy should be
up-to-date and endorsed by management.
✔ Clients and potential clients should be able to
✔ A ‘complaints management function’ should be
established at all firms.
✔ This individual/team should keep a log of
complaints data for the compliance team.
✔ Senior management need to periodically review the
effectiveness of policies to address deficiencies.
✔ Specific responsibility for each of the requirement
areas should be allocated to a member of senior
management. The responsibility should be
documented and a record kept.
✔ Senior management must be aware of any remedial
measures that have been taken as a result of
problems discovered by the audit, risk or
✔ There should be a ‘supervisory function’ within the
firm that keeps watch over the senior management.
✔ Firms shall put in place arrangements to prevent
people making personal transactions based on the
misuse of confidential information.
✔ Company employees must not disclose delicate
information to others, knowing that they or one of
their associates would enter into a financial
transaction benefitting them.
✔ Firms must ensure they chart and record personal
transactions of staff.
✔ Outsourced firms must keep records of their staff’s