⚖️ INTERNAL POLICY — PM-COC-001
Codes of Conduct for Senior Managers
Promise Codes of Conduct for Senior Managers and Individuals
Document Reference: PM-COC-001 Version: v1.4 Owner: Compliance Team — Promise Money Next Review Date: [To be confirmed]
| Codes of Conduct Rules | Codes of Conduct Rules |
|---|---|
| Individual Conduct Rules – Tier 1 | Individual Conduct Rules – Tier 1 |
| • | Individuals must act with integrity in carrying out their function. |
| • | Individuals must act with due skill, care and diligence in carrying out their function. |
| • | Individuals must be open and cooperative with the FCA, the PRA and other regulators |
| • | Individuals must pay due regard to the interests of customers and treat them fairly. |
| • | Individuals must observe proper standards of market conduct |
| New Rule 6: You are required to act to deliver good outcomes for retail customers with obligations to act in good faith towards retail customers (a standard of conduct characterised by honesty, fair and open dealing and acting consistently with the reasonable expectations of retail customers); avoid causing foreseeable harm to retail customers; and enable and support retail customers to pursue their financial objectives. | |
| Senior Manager Conduct Rules – Tier 2 | |
| • | Senior Managers must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively |
| • | Senior Managers must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system |
| • | Senior Managers must take reasonable steps to ensure that any delegation of their responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively |
| • | Senior Managers must disclose appropriately any information of which the FCA would reasonably expect notice |