Focus on the individual, says Elizabeth Mills

Making sure that your T&C scheme achieves a beneficial outcome and is not done simply because the FSA has told you to do it can reap rewards.

So, where do you start? A scheme does not have to be complex to be valuable. The more workable a system is, the easier to understand and therefore apply.

The FSA has recognised that there are additional T&C commitments for retail staff, so why not apply the same high standard across the board? A consistent approach may well make things much simpler to manage.

Start with your job descriptions. Remember the job description is not personal to an individual - it describes the actual job, regardless of who is doing it. Designing these will give you a clear summary of what responsibilities and duties are required of each role, so keep them generic and to the point. There is no need to produce a list of every item of work that a job encompasses.

Next, consider what level of performance you expect from each individual. A job description is geared around the actual role, but performance expectations can be tailored to the individuals you have working in your team.

Having simple and clear objectives, or KPIs (key performance indicators) will enable you to define your expectations of each individual. While the job descriptions for your commercial account handlers will be the same, the KPIs may well be quite different, allowing you to 'target' your staff in accordance with your business plan and their own individual strengths and preferences.

KPIs/objectives should be agreed with each individual, on at least an annual basis, so they can be adapted to reflect changes.

When you have a clear idea of what the job is and the performance standards required, you can then consider whether each individual can competently carry out the requirements of the role. Ask whether they are fully equipped and able to meet their KPI's/objectives this year, or do they need further development.

Whether your staff will meet their business targets/objectives for the year is an important consideration. Employees must be equipped to meet the objectives and targets they have been set. They must feel they are benefiting from continued personal development.

Turning to the assessment of competency, assessment is a word that conjures up thoughts of exams and somebody ticking boxes to confirm that you are compliant. But there are a number of methods you can use to demonstrate competence, so consider carefully how this can be achieved.

Try to conduct competency assessments in a learning environment, rather than a testing one. The culture within an organisation directly contributes to the success of assessment.

Even if you feel that staff are 100% competent to carry out their role, don't assume T&C does not apply. The FSA will want to see your staff demonstrating their competence, so you need to prove it. And if an individual has proved themselves to be competent, this must be maintained. After all, there are two parts to T&C, so just because the competence part may be satisfied, don't forget the training element in order to ensure further development. And having carried out assessments, training, development and review work, don't forget to document it.

Finally, own the scheme and be proud of the training, learning and development you offer. Use it to attract new staff - after all, on more and more occasions, prospective employees will be asking the question of what induction training will be received and what training and development will be offered.

  • Elizabeth Mills is head of HR compliance & training at The Broker Network
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