The monitoring of professional standards is closely aligned to the implementation process, with both working together to create a cycle of continuous improvement. Guidance material is developed for each professional standard and provides further detail on monitoring activity. Further Guidance is available to member firms via the Member Firm Toolkit.
Monitoring by CB:PSB Firms
CB:PSB firms are required to establish an Internal Monitoring Team comprised, for example, of internal audit, compliance, HR or risk functions to monitor implementation of the CB:PSB’s professional standards on an annual and on-going basis. As well as ensuring implementation is progressing effectively, monitoring helps identify best practice which can be shared across CB:PSB firms.
The Internal Monitoring Team is expected to ensure that implementation and achievement of professional standards is carried out correctly and consistently. To do this, monitoring may include sampling or spot checks, as well as reporting on findings.
In addition, CB:PSB firms, in many cases through their internal monitoring and conduct risk teams, monitor the day-to-day activities and behaviours of individuals. Where individuals’ behaviours fall short of those expected by the CB:PSB, firms are required to have systems and processes in place to identify these and, where appropriate, withdraw the achievement of a standard(s).
Annual Progress Review
In addition to internal monitoring of professional standards implementation, CB:PSB firms are required to take part in a progress review of implementation conducted annually by the Professional Standards Team.
The progress review comprises a self-evaluation completed by CB:PSB firms’ Internal Monitoring and Implementation Teams, and an external review completed by the Professional Standards Team:
|a) Self – Evaluation|
|Step 1||A designated member of the Implementation Team (Implementation Lead) completes a survey which evaluates the organisation’s commitment and strategic approach, implementation of professional standards, monitoring and enforcement activity and support for the CB:PSB’s overarching aims. The survey may be ‘themed’ in specific areas, to focus on areas of strength or weakness, to support effective embedding of professional standards.|
|Step 2||The Internal Monitoring Team critically evaluates the survey, independent of the Implementation Team, to assess its accuracy.|
|Step 3||The Implementation Lead, a representative from the Internal Monitoring Team and an authorised senior executive sign the completed survey confirming its content, and submit the survey to the Professional Standards Team.|
|b) External Progress Review|
|Step 4||The Professional Standards Team review the completed survey and advise the member firm of supporting evidence required. Evidence may be from organisational and/or individual sources.|
|Step 5||The Professional Standards Team conducts a site visit to each CB:PSB firm to review supporting evidence and sample data to verify individuals have met the requirements of the standard.|
|Step 6||The Professional Standards Team produce a detailed written report (Draft Report) for each CB:PSB firm, highlighting any development areas and potential risks, and issue to the CB:PSB firm.|
|Step 7||The CB:PSB firm and Professional Standards Team discuss the Draft Report and where development areas and risks have been identified, action plans are jointly agreed to support CB:PSB firms in implementing professional standards.|
|Step 8||The Professional Standards Team issue an agreed Final Report to the CB:PSB firm.|
|Step 9||An Executive Summary, setting out CB:PSB firms’ performance against the CB:PSB’s aims is prepared by the Professional Standards Team and circulated to the Board and the Independent Monitoring Panel. The Executive Summary describes the extent to which the CB:PSB’s aims have been achieved, areas of good practice and highlights deficiencies through action planning.|