Fitness & Probity - Last Warning

The ‘Dear CEO Letter’ on Fitness & Probity issued by the CBI earlier this week (17th November) follows their previous Dear CEO letter on the same subject issued in April 2019. With the regime in place now for almost 10 years, the most recent letter has a clear undertone of disappointment on the one hand and warning on the other.

There is a sense of ‘last chance saloon’ on this topic. The fitness and probity regime is not complex in its requirements but does need a systematic approach to its implementation. To achieve effective company-wide implementation of the requirements, engagement is required by the Board, the Compliance Function, the HR Function, Outsource Supplier Managers, and the Internal Audit Function.

With a collective, project type, approach, involving each of the above functions, the requirements can be appropriately embedded in the processes of the organisation. Assigning responsibility only to the Head of Compliance will invariably lead to the types of issues outlined by the CBI in their letters.

It is definitely time for a re-set on the fitness & probity processes and procedures in your firm. This should be completed against the full set of requirements in the original standard and validated against the various guidelines and findings issued by the CBI since, including the most recent letter. A GAP analysis against this letter may not be enough. The tone of this most recent letter from CBI suggests that the window for taking action on the topic is short.

Seamus@GovernanceMatters.ie