The term reasonable steps is used in the first three SMF conduct rules: 

• You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively. 
• You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with relevant requirements and standards of the regulatory system. 
• You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegate’s responsibility effectively. 

But what does the term ‘reasonable steps’ imply? 

The Culpability Standard:
The regulator has stated that “A person will only be in breach of any of the rules in COCON where they are personally culpable". Personal culpability arises where: 

• A person’s conduct was deliberate; or 
• The person’s standard of conduct was below that which would be reasonable in all circumstances”. 

This workshop aims to unravel the confusion that lies around this terminology and shed light on the regulator’s expectations.

Workshop overview:

• Gain awareness of the type of evidence the regulator expects to see.
• See examples of reasonable steps aligned to prescribed and other responsibilities.
• Understand when the requirement to take “extra notes” might arise.
• Understand the need for evidence post leaving a senior management function role.

Take this training in-house:

This workshop is also available as an in-house programme, which means you can tailor it to exactly what you and your colleagues require. Pricing for in-house will depend on what is required. Enquire about this option by contacting our training team.