Programme Governance Manager, Banking Reform Act

Standard Chartered Bank
29 Jul 2017
15 Aug 2017
Contract Type

The BRA-IA originates from the UK regulators and a recommendation from the UK Parliamentary Commission on Banking Standards ("PCBS") that a new framework for regulating individuals involved in banking was required to strengthen individual accountability and standards of conduct. The PCBS's recommendations were implemented through the Financial Services (Banking Reform Act) 2013 (the "Act"), which received Royal Assent in December 2013. Although it is UK regulation, aspects of it apply across SCB and subsidiaries.

The new "Individual Accountability" framework came into effect on 07 March 2016 and comprises two new regimes and revised Rules of Conduct:

  • A Senior Managers Regime ("SMR") which imposes new obligations on individuals performing senior management functions and is aimed at the most senior decision-makers in a bank.
  • A Certification Regime ("CR") for certain employees who fall outside the SMR, but whose actions or behaviour could significantly harm a bank, its reputation or its customers.
  • Rules of Conduct that apply to all senior managers and certified staff, as well as the majority of UK employees which are only effective from 2017

The aims of the Regime are:

  • Transforming the culture and raising standards of conduct in banking, by increasing clarity of who within an organisation is responsible for what.
  • Improvement in bank governance: the regime requires robust and well evidenced governance frameworks, including clear articulation of committee structures and the roles and responsibilities of managers.
  • Upgrade data, systems and technology: increased focus on evidentiary requirements will require improved management information and ensuring coherent policies and internal frameworks.

The Programme Governance Manager for the Banking Reform Act will work closely with the Working Groups, aligned projects (such as the Financial Crime Risk Mitigation Programme and Competency Assessment projects) and Technology partners, as well as the Program Lead for Processes and Change Management / Communications. The Programme Governance Manager will work with stakeholders to ensure collaboration and resolution on tasks and obstacles. The Programme Governance Manager will be responsible for managing project artefacts, ensuring all project strategy and activities are accurately recorded and represented in documentation.

The Fit & Proper Annual Certification process requires that line managers of Senior Managers and Certified Persons sign off on the satisfactory disposition of their direct reports for each of the following components:

  • Background screening
  • Job Description
  • Competency Assessment
  • Group Code of Conduct
  • Mandatory Learning Courses
  • P3 (performance management) processes

The Programme Governance Manager will play a key role in ensuring that all line manager certifications related to the above activities are executed in a timely fashion in order to meet regulatory requirements.


  • Project documentation: proactively understand changes to project strategy, design and phasing, status of activities and deliverables and update documentation accordingly. Ensure documentation is useful and accurate at all times.
  • Analysis: Deliver timely, insightful analysis in the form of status and other reports through proactive collaboration with stakeholders
  • Setting up and managing working groups. Facilitate resolution of issues and encourage collaboration by setting up and facilitating
  • Collaboration: Understand and collaborate with other related and relevant projects to update dependencies and ensure delivery of synergies.
  • Facilitate the effective running of the team by tracking actions, risks, issues and decisions.
  • Work closely with the Technology Workstream and manage Annual Certification Tool UAT
  • Communication and scheduling. Review the communications of the team to ensure activities are aligned with project priorities. Ensure meetings are scheduled according to project plan / requests / meeting minutes
  • Resourcing requirements - overseeing resource requirements for Workstreams for discussion with Program Lead
  • Facilitate and document meetings with Working groups
  • Annual Fit & Proper Certification cycle (November - February)
    • Prepare data packs for line managers of Senior Managers and Certified Persons to assist in their decision making
    • Work with Compliance teams, HR Business Partners, and Corporate Secretary's office to ensure that Senior Managers and Certified Persons complete the F&P annual certification on time
    • Manage weekly and daily reporting to track and report overall certification progress
    • Assist in Quality Assurance meetings to ensure fair and consistent application of Fit & Proper standards and thresholds