Skilled Person Report relating to governance and due diligence approaches of a UK pension provider
The UK regulator had a concern over the skills, experience and capability within the firm and whether they were adequate to be able to manage the business effectively whilst meeting regulatory and legal obligations. In addition there was a concern over the effectiveness of due diligence carried out on introducers, advisors and investments by the firm.
The regulator required a Skilled Person to report on governance arrangements; skills, experience and capabilities; and due diligence arrangements.
We assembled a team based on the specific nature of the regulator concern. This team included several senior staff with extensive experience of areas such as:
– UK pensions regulations;
– UK general corporate governance guidance and best practice;
– UK financial services regulatory governance requirements;
– assessment of skills, experience and capabilities; and
– design and operational evaluation of due diligence policies and procedures.
We adopted a strictly evidence-based approach to the assessment, which included document review; interviews with key officers, managers and staff; live observation of Board and governance committee meetings; operational process walkthroughs; sample testing of due diligence carried out on introducers, advisors and investments. We focussed on all areas in evaluating the business including leadership, operations, finance, systems (as technology platforms were critical for resilience), risk and compliance.
We triangulated the results of these various sources of evidence to arrive at robust conclusions supported by clear evidence.
Our review identified a number of key areas of enhancement across the firm that needed rectifying in order to fulfil the regulatory standards. The report and the resulting recommendations allowed the firm to develop a comprehensive, practical and fit for purpose remediation plan that would enable it to enhance overall governance, management, effectiveness of the board, skills and capabilities and introducer, advisor and investment due diligence.
