I need to understand and explain to our senior management team how well our SMCR programme is delivering. How should I be measuring success?
It is possible to measure success within SMCR in quite different ways. On the one hand you can take a fairly “defensive” approach and measure the extent to which you have completed (and continue to stay on top of) all the tasks that required to implement SMCR.
These range from having up to date Statements of Responsibility for all senior managers, completing all regulatory reference requests on time, staying on top of fitness and propriety, training your staff in the conduct rules etc. Clearly, there is a lot to do and measuring how well you are executing these tasks will be critical.
On the other hand, SMCR is supposed to deliver a change in culture that leads to improved individual accountability. This is a much “softer” objective of SMCR, it is undoubtedly important but it is harder to measure in a concrete or quantitative way.
Our recommendations
Start with measuring delivery – any other measures are irrelevant if you are not in control of all the tasks that need completing in order to stay on top of SMCR. Much of delivering SMCR is about taking individuals through a process so start by defining the core end to end processes (senior managers, certification, conduct rules) and then have measures that provide you up to date information on how individuals are passing through those processes. This should quickly expose vulnerabilities in any of those processes – for example, it could be handling situations where individuals fail fit and proper assessments.
Study breaches – you can learn a lot about the effectiveness of your SMCR implementation by looking at breaches over time. It is not just how many breaches are occurring but also the nature of the breaches that do occur and how that is changing over time. Conduct rules training, for example, should have a direct impact on the number and type of breaches.
Ask your employees – conduct periodic surveys of your employees to understand how they see the impact of SMCR on them as individuals. These surveys need to be carefully constructed but done well, they can expose hugely valuable information about people’s engagement with SMCR and the extent to which it is bringing additional clarity around accountability.