Senior Management Arrangements Systems and Controls SYSC | Quality Assurance and Performance Policy and Procedures | Mortgage Conduct of Business MCOB | Template for FCA Applications and Authorised Firms

Quality Assurance & Performance Policy & Procedures

1. Purpose

Quality Assurance is defined as ‘the maintenance of a desired level of quality in a service or product, especially by means of attention to every stage of the process of delivery or production.’

The purpose of this Quality Assurance Policy & Procedure document is to provide the company’s aims, objectives and measures for the quality control of our products, services and staff performance. Our aim is to maintain a high standard of quality in the services that we deliver, customer outcomes, staff support and training and regulatory compliance.

Through the company’s quality standards and objectives, we have implemented a framework that defines what is acceptable and not acceptable from the services that we provide. These standards enable us to audit, measure, review and assess all services and outcomes against a set of targets and objectives and to act where a service or outcome does not meet the required standards.

It is the company’s aim and responsibility to ensure that the desired level of quality assurance is always maintained through audits and monitoring and that all employees are made aware of the policy and procedures, as well as understanding the quality definitions and how those standards are met and maintained.

2. Policy Statement

The company is committed to ensuring that it delivers the highest level of quality in the services that it delivers. To do this, we will ensure that we implement and maintain an effective and efficient quality assurance process and that all services, products, customer outcomes, treatment of customers, management and staff functions are included in the quality control and audit processes.

We have created this policy and associated set of procedures to support and achieve our quality standards and objectives, which have been created with the aim of: –

• Remaining compliant with legal and regulatory requirements
• Eliminating deficiencies and inaccuracies in our services and staff performance
• Ensuring high quality standards are achieved and maintained
• Customer outcomes are always above the desired level of quality
• Desired quality of service can be maintained as an ongoing concern

3. Scope

The policy and the associated procedures apply to all staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the company in the UK or overseas) within the organisation.

The Compliance Officer has overall responsibility for ensuring that quality controls and measures are in place and that all staff are made aware of them and understand the quality assurance standards.

Records are to be kept of all quality audits, customer outcomes, complaints and staff training and performance to ensure there is adequate and relevant management information available to carry achieve the desired level of quality assurance.

4. Objectives

The company conducts internal staff audits on performance and service levels to ensure that the desired standards of quality assurance are being met and maintained. Our approach to audits and monitoring follows the Plan, Do, Check and Act (PDCA) approach, enabling us to systematically monitor our staff and service levels against regulatory and our own objectives and standards.

We use the data collected during monitoring and audits to collate management information and reporting data to maintain our high standards and ensure compliance with legal and regulatory requirements.

The main objectives of our quality assurance and staff internal audit procedure are to: –

• ensure that we have robust and structured processes, policies, procedures and controls in place for providing the services that we offer
• ensure compliance with regulatory, legal and contractual rules
• ensure good and satisfactory customer outcomes
• operate within the parameters of the TCF principles
• identify and manage vulnerable customers
• assess personal and financial circumstances where applicable
• promote a culture of assessment, review and action to maintain growth and efficiency
• maintain consistency in work methods throughout the organisation
• monitor and assess staff performance and service levels
• ensure staff professional development and continued learning & competency
• implement root cause analysis to carry out improvements
• to provide management information for assessing customer outcomes

5. Staff Monitoring

As a regulated firm, the company understands how important it is to monitor the service and advice that our staff are providing and to ensure that we comply with all aspects and requirements set out in the FCA handbook.

Our staff monitoring controls and procedures utilise: –

• Call Monitoring Checklists (live & recorded)
• KPI Performance Management
• Target Achievement Levels
• Treating Customers Fairly Audits
• Vulnerable Customer Audits
• Data Protection Audits
• Competency Tests
• Adherence to Script Prompts
• [Add/delete as applicable]

The main areas that we monitor and assess for staff service and performance are: –

• TCF Outcomes (through calls, emails, letters and account working)
• Adherence to Data Protection Act and standards
• Customer Advice (quality, appropriate, affordable and sustainable)
• Service Solutions offered
• Vulnerable Customer standards
• Customer Satisfaction
• Quality of Calls and Emails (advice, etiquette etc)
• Transparency & Disclosure
• Cross-selling
• Financial Promotions
• Staff Incentives & Bonus Schemes
• Complaints
• [Add/delete as applicable]

6. Methods and Audit Procedures

The company’s aims to meet the above objectives in relation to quality assurance by using the Plan, Do, Check and Act (PDCA) method. Staff and process audits are planned by assessing the desired outcomes, quality and regulatory compliance that the task/service must conform to and then using the Staff Monitoring Form (Appendix A) for recording.

The ‘Do’ stage involves the actual provision of the service that we offer and monitoring the outcomes against a set of pre-defined standards.

The advice or performance level being monitoring is checked against the Staff Monitoring Form standards and any failings or shortcomings are processed to the ‘Act’ stage which involves a period or review with the staff member and compliance officer and measures being put into place to prevent further quality assurance breaches. Such actions include: –

• Additional Staff Training
• Changing the Existing Procedure (to better meet the regulatory requirements & desired outcomes)
• Improving a Process
• [Add/delete as applicable]

The methods of internal audits and checks include: –

• Call Monitoring – listening to staff calls, both internal and external and auditing against written call procedures and compliance requirements.
• Physical Audit – the auditor carries out the activity themselves to evaluate the process/system involved in the audit and to ensure compliance and functionality.
• Monitored Audit – the auditor assesses an employee carrying out a business activity to assess staff adherence to company procedures and regulatory compliance.
• Email Reviews – a sample of internal and external emails are reviewed to ensure compliance with business processes and compliance requirements.
• Employee Interviews – staff are involved in discussions about business activities and systems to ensure their knowledge and competence are at an acceptable level for the hired role.
• Document Control – existing procedures and policies are reviewed by the auditors to ensure they are fit for purpose, efficient and effective and that they adhere to regulatory requirements.
• Risk Assessment – mitigating strategies associated with each business activity are reviewed and followed to ensure that they mitigate against the associated risk and are fit for purpose.
• [Add/Delete]

6.1 Audit Procedures

All staff monitoring audits (calls, accounts, performance, advice etc) are completing using the Staff Monitoring Form. This allows for the quality assurance objectives to be assessed and management information to be collated on customer outcomes.

• The auditor must plan the area or staff member to be monitoring and ensure that adequate time and resources are available to enable a thorough audit
• A Staff Monitoring Form must be completed for every audit carried out
• Live or pre-recorded call monitoring must also utilise the Call Monitoring Audit Form
• Where live account, email or call audits are carried out, staff are not to be advised of the monitoring prior to it taking place
• When monitoring staff service levels and/or performance, account history, call recordings and email/letter correspondence must be monitored and reviewed to ensure a full audit is carried out
• After the Staff Monitoring Form has been completed, root causes of any failings must be logged and reported to the Directors and Compliance Officer
• Changes to any processes must immediately follow any root cause identification, including additional staff training and/or temporary suspension from job role
• Procedure or control changes must be disseminated throughout the organisation with a full explanation on why the changes have occurred and how they better meet the desired quality assurance objectives.

7. Role & Responsibilities

The company’s roles and responsibilities as they relate to quality assurance and internal staff audits are to: –

• review and assess the effectiveness and adequacy of procedures, internal controls and systems
• check for compliance breaches or risk-based divergence from SOP’s
• ensure that the desired level of quality assurance is maintained
• ensure that staff are offering the accurate, appropriate and compliant advice, products and services
• ensure that customer risks are identified and mitigated against

The Compliance Officer has overall responsibility for the QA process and associated audits; however, all managers must take accountability for their own staff and department areas and follow a consistent program of staff monitoring and training.