ZYC-TRN-001 Training & Competence Policy
Purpose
To ensure all Zeyro staff and senior managers are competent to perform their roles and remain so, in line with FCA SYSC 5.1 and the UK MiFID framework. This policy defines how competence is assessed, maintained, and recorded across the firm.
Scope
Applies to all employees, directors, and contractors involved in Zeyro’s activities, including:
Financial-promotion approval (cryptoasset and OFR)
Facilities services (MiFID arranging)
Compliance, risk, and operational functions
Policy Statement
Zeyro is committed to maintaining a skilled, knowledgeable, and compliant workforce. All staff must have the technical knowledge, regulatory understanding, and ethical awareness required for their roles.
Training and competence are overseen by the MLRO (SMF 16 & 17) and form part of Zeyro’s fit-and-proper and conduct frameworks.
Training Framework
1. Recruitment & Induction
Candidates’ qualifications and experience are verified during recruitment.
All new employees complete Compliance Induction Training and role-specific training within two weeks of joining.
Induction completion is logged in Confluence under the Training Register.
2. Ongoing Competence
Competence is reviewed through twice-yearly check-ins and an annual appraisal.
Each role has a Knowledge Roadmap maintained in Confluence, showing required skills and completed training.
Supervisors ensure that individuals working toward competence are appropriately supervised.
3. Role-Specific Knowledge
MiFID arranging staff must demonstrate understanding of client categorisation, COBS, market abuse, and best-execution principles.
Cryptoasset promotion staff must understand cryptoasset classifications, FSMA s.21 requirements, and ASA/FCA advertising rules.
These expectations are defined in the firm’s Knowledge Requirement Matrices (MiFID and Cryptoasset) stored in Confluence.
4. Maintaining Competence
Annual needs analysis identifies training requirements across the firm.
Training may include internal sessions, FCA updates, or external CPD via CISI or equivalent providers.
All staff complete annual refreshers on:
AML / CTF
Financial promotions compliance
Data protection and information security
5. Record Keeping
All training completion, progress tracking, and knowledge updates are recorded in Confluence.
Confluence serves as the firm’s Training Register and competence record.
Records are retained for at least five years and reviewed annually by the MLRO for completeness and alignment.
Roles and Responsibilities (RACI)
Role
Responsibility
Accountability
Consulted / Informed
MLRO (SMF 16 & 17)
Owns training framework; identifies needs; approves and tracks completion; reports to Board.
Board
Line managers
Line Managers / Supervisors
Ensure staff complete required training; assess on-the-job competence.
MLRO
Staff
All Staff
Complete mandatory training; maintain awareness of current rules.
MLRO
Line manager
Board
Reviews annual competence summary and approves this policy.
—
MLRO
Controls risk: ensures all staff maintain competence for their regulated activities and that oversight is documented and auditable.
Review
This policy is reviewed annually or after any regulatory, business, or role-structure change affecting competence requirements.
Last updated