ZYC-FIT-001 Fit & Proper (SMCR) Policy
Purpose
To ensure that all Zeyro staff — particularly Senior Management Function (SMF) holders — remain fit and proper in line with the Senior Managers and Certification Regime (SMCR) and FCA FIT guidance.
Scope
Applies to:
Senior Management Function holders (SMF 16, SMF 17, and directors)
Certified staff performing controlled functions
Any other person whose role could cause significant harm to clients or the firm.
Policy Statement
Zeyro requires all staff to demonstrate integrity, competence, and financial soundness. Fitness and propriety are assessed at recruitment, annually thereafter, and whenever a material event occurs (e.g. change of role or regulatory concern).
The MLRO (SMF 16/17) is responsible for managing the certification process and maintaining records of each assessment in Confluence. The Board provides oversight and confirms continued fitness of senior managers at least annually.
Fit & Proper Criteria
1. Integrity
Act honestly, ethically, and with due regard for client and regulatory obligations.
Disclose any criminal convictions, regulatory sanctions, or disciplinary issues.
Report immediately any conflicts of interest or external business appointments.
2. Competence & Capability
Maintain the knowledge, skills, and experience required for each role.
Participate in ongoing training under ZYC-TRN-001 Training & Competence Policy.
Demonstrate sound judgment and understanding of Zeyro’s systems, risks, and obligations.
3. Financial Soundness
Maintain personal financial responsibility; disclose any bankruptcy or IVA proceedings.
The MLRO may conduct financial-check verification where appropriate.
Certification and Records
All fitness and propriety checks are documented and reviewed annually.
SMF and Certified Persons complete an annual self-attestation confirming no material change.
Evidence (references, qualifications, declarations) is stored securely in Confluence.
Any change that might affect fitness or propriety is reported immediately to the MLRO and the FCA if required.
Roles and Responsibilities (RACI)
Role
Responsibility
Accountability
Consulted / Informed
MLRO (SMF 16 & 17)
Conduct fit and proper assessments; maintain records; submit notifications to FCA.
Board
All staff
Board
Approve this policy; review annual fitness of SMFs; ensure adequate governance.
—
MLRO
Operational Management
Support certification process; ensure role profiles remain current.
MLRO
Board
All Staff
Disclose relevant changes promptly; uphold fitness and propriety standards.
MLRO
Board
Controls risk: ensures accountability for maintaining fitness and propriety in line with SMCR principles.
Review
This policy is reviewed annually or earlier if FCA rules or firm structure change materially.
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