Management Information Policy | Template for FCA Applications

1 SCOPE
The policy relates to all HIRETT LTD staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with HIRETT LTD in the UK or overseas) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.

2 POLICY STATEMENT
HIRETT LTD has robust Management Information (MI) and internal reporting procedures to ensure that frequent MI is provided to the Senior Managers and Directors on an ongoing basis. Such information is indicative of our business objectives and regulatory requirements and aids us in ensuring compliance, providing gap analysis and keeping those in AP and SMF roles apprised of our current progress and ongoing aims. Our MI is gathered through audits, reviews, assessments, ongoing analysis and management feedback and enables HIRETT LTD to assess compliance, meet our objectives, analyse any gaps and meet our regulatory obligations. Such information is used to review and renew our procedures, activities, aims, training provisions and keep the management team updated and aligned with our objectives. We aim with our MI to be active as oppose to reactive, working on future solutions and provisions oppose to fixing issues as and when they occur. This better enables effective risk management and assessment and helps to prevent compliance breaches and impacts on customers.

Our management information comes from:

• Account data analysis
• Business objective analysis
• Training and competence records
• Staff assessments and feedback
• Customer feedback
• Complaint reports
• Compliance reports
• Audit checklists and monitoring assessments

3 PURPOSE
The purpose of this policy is to outline HIRETT LTD’s objectives and obligations with regards to internal and external management information (MI). MI is an important and mandatory part of our business function and ensures that all staff with a role to play in keeping our business and services compliant, are aware of our progress, activities and intentions. MI provides valuable information to senior management, Directors and those performing Approved Persons and/or SMF roles within HIRETT LTD and better enables us to serve the interests of our customers whilst ensuring that we are and remain compliant with the regulatory system and our own business objectives. HIRETT LTD is also dedicated to the TCF ethics and principles, of which MI plays and important role. Gathering the right MI enables us to see areas of good and poor practice with regards to customer treatment and service and provides necessary gap analysis data for procedures that need to be reviewed and updated. As TCF must be embedded into all areas of our business to work effectively, most MI reports will contain elements of the TCF principles, by which they will be measured.

4 FCA REPORTS
HIRETT LTD submits a wide range of MI and reports to the FCA as part of our regulatory obligations, however all such reports, except for compliance reports, are beyond the scope of this policy and staff are directed to refer to the FCA Handbook for further guidance and information.

Compliance Reporting
As part of its regulatory oversight functions, the FCA review and analyse information about HIRETT LTD’s records of compliance with the regulatory requirements, to ensure that we are meeting our obligations in each area. HIRETT LTD keep records of all compliance audits and assessments that show our compliance with the regulatory, statutory and legal requirements placed upon us and that these records are kept and shared with our regulators, in an open, transparent and cooperative manner.

5 MANAGEMENT INFORMATION
HIRETT LTD collects, uses, reports on and retains all Management Information (MI) through our usual periods of business activity and daily tasks. Our MI provides us with valuable and necessary data with which to improve our business functions and customer service as well as reducing the risks to both areas. MI is obtained from all areas of the business, from initial sales and on-boarding, through to our accounting procedures and complaint records. More than just a set of numbers and data, MI provides useful and constructive information for our management, Directors and regulators.

To ensure that HIRETT LTD gets the most out of our MI, we ensure that it follows the FCA’s guidance for being:

• Accurate – the correct numbers with any commentary contributed by the right people.
• Timely – available sufficiently quickly after the relevant business activity to enable managers to act.
• Relevant – displaying what a manager can directly influence or something that they may need to escalate to someone who can take the necessary action.
• Consistent – consistent on a period-to-period basis to allow managers to spot trends and make sound decisions.

For all instances of Management Information (MI) we follow the regulatory guidelines when collecting, using and recording the data to ensure that we are compliant and it is effective:

• Seen – an appropriate level of management receives, understands and reviews the MI
• Challenged – anomalous or unexpected results are challenged
• Analysed and Monitored – the right messages and conclusions are drawn from the data
• Acted On – where appropriate, actions are taken to remedy the situation, to investigate further and to follow up on those actions
• Recorded – records are made of what is done and information is subsequently gathered to enable the success of those actions to be assessed.

6 OBJECTIVES
HIRETT LTD has laid out the below objectives and aims that ensure we comply with and adhere to all regulatory and legal requirements as well as meeting our own internal business obligations and aims. MI reports and schedules are recorded on a separate reporting document along with audit and monitoring schedules and data.

With regards to Management Information, HIRETT LTD ensures that:

• We operate a scheduled MI gathering system that is adhered to by all staff. MI reports are run at specific times and intervals to allow for the best data analysis to be conducted.
• MI is analysed and reviewed by an appropriate person/s who has the knowledge and skill to interpret and report on the content effectively and sufficiently.
• MI gathering is conducted at consistent intervals to allow any trends and patterns to be identified and sound decisions to be made.
• All MI reported on is compliant with regulatory and legal requirements and meets the expected standards of the FCA.
• MI adequately covers the needs and functions of the business and ensures that all areas are assessed and reviewed on a continual basis.
• Staff are part of the MI reporting structure, including their training, competency, understanding and adherence to compliance.
• MI is gathered in a timely manner; ensuring that all data is up-to-date and relevant when reviewed and reported on.
• MI reports are always acted upon and the data used to improve business decisions and procedures.
• MI measures our performance as well as helping us to identify potential risks before they happen.

7 RESPONSIBILITIES
HIRETT LTD ensures that all staff are provided with the time, training and support to learn, understand and help to the objectives in this Management Information Policy, to comply with our own internal aims and obligations and to meet and continue to achieve the legal and regulatory requirements. Senior Management and those holding Approved Persons and Senior Management Function roles are responsible for ensuring that this policy and its agenda is complied with and enforced throughout the organisation.