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The Four Pillars.









We use the Four Pillars to profile specific solutions and help our clients review their overall SMCR implementation. 
Our clients want to...
Use automation to speed up and streamline processes and deliver consistent outcomes across all employees.
Make it easy to collect and organise evidence to support all decisions and prove reasonable steps have been taken.
Be agile enough to deliver against a firm’s unique requirements and to adapt to changing circumstances.
Help to ensure employee engagement and therefore support the behaviour and culture change required for successful SMCR implementation.
4 pillars summary

why do the pillars Matter?


"It always felt like we were on our back foot with our fit and proper tests  – there was so much information to gather about each person”.

  • Efficiency – SMCR processes such as fit and proper assessments consume a lot of resource. Well designed, automated workflows can save a firm a lot of time and money.

  • Risk – we are all fallible, repetitive tasks can be dull and mistakes can get made. Automation can significantly reduce SMCR error rates and ensure that nothing gets forgotten.

  • Consistency – inconsistent application of SMCR across employees risks demotivation, loss of talent and even legal action. Automation can help to embed consistent processes and consistent application of rules across a firm ensuring that employees are all treated the same.


“It’s not about always making the right decision, but it is about having the evidence to show why you have made a decision”.

  • Risk – gaps or weaknesses in evidence collected. A firm is open to considerable risk if it cannot support all SMCR decisions with clear evidence that shows reasonable steps have been taken. One badly evidenced decision can have a major impact on an individual’s career or a firm’s reputation.

  • Risk – evidence not easy to retrieve and present. Evidence should be wrapped around all key decisions and should be able to be understood in the context of those decisions. It should not be fragmented across emails, hard drives etc.


“We soon discovered what should be obvious, change happens. Our SMCR software couldn’t adapt with us as our business grew and our services changed”.

  • Risk – the regulation changes or your firm changes but your SMCR solution cannot change easily. This will create cost (manual workarounds, software development) and risk (gaps in your SMCR operation)

  • Risk – your SMCR solution is good at handling “standard” processes and individuals but cannot handle outliers. These are the 5% that can take up 80% of your time if you are not prepared for them.

  • Risk – your SMCR solution cannot integrate easily with your existing systems (HR, governance etc). This will lead to software development costs, process breakdowns and potential data risks.

  • Risk – your conduct rules training cannot be tailored to individual roles. The FCA focus closely on conduct rules training and regard relevance and context as critical.


“We know the FCA are interested in healthy cultures but not sure how we might go about changing our firm’s culture or if we actually need to.”

  • Risk – you deliver a tick box implementation of SMCR that does not satisfy FCA requirements around healthy, purposeful culture.

  • Risk – your SMCR solution is “one way”, it imposes SMCR on your staff. This can lead to demotivation, poor performance and the loss of talent.

  • Opportunity – your SMCR solution empowers employees by involving them in the process of clarifying their roles and responsibilities and agreeing the skills and competencies they need to perform.

  • Opportunity – your SMCR solution improves decision making by bringing clarity to roles and processes.

Want to know more?

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