Delegation

How do you delegate compliance compliantly?

You may pass on responsibility for company compliance to someone who is more hands on with the day-to-day procedural aspects of running your business. Or, as the Principal/Director, you may do the complete opposite and take it on yourself.

Whilst you need to take the route that works for your firm, as the company’s Principal/Director, you should be involved in how your company is compliant and proving compliance. Otherwise, how will you be able to fulfil your obligations under the Apportionment and Oversight control function (CF8)?

‘Apportionment’ does enable you to distribute the work, but it does not mean you can dispense with your responsibility. And if we consider ‘Oversight’, how can you supervise and control compliance if you do not know what is in place to review it?
It will be difficult to demonstrate compliance to the Senior Management Arrangements, Systems and Controls (SYSC) sourcebook if you have no clear role in your firm’s compliance. If the whole structure and compliance undertaking is being run by one individual, what happens when that person is absent from work in the short or medium term or, indeed, indefinitely?

If as Principal/Director you decide instead to take full responsibility for all the compliance related work, this too can have its pitfalls. However, if you are the only person who understands compliance, the firm is vulnerable when you are not there.

So what is a good balance? This does depend on your firm but, for compliance to be an integral part of your business this task shouldn’t fall to just one person.

This sounds straight forward. So why, as managers, are we reluctant to let go and delegate work? We all know what delegation means, but actually doing it is something different.

Can you relate to any of the following, as reasons for not wanting to delegate?

• It takes time to train someone else to do the work, and so you may as well do it yourself.
• Someone else never quite does it the way you would have done it.
• If you are not involved in the work, you may lose control over it.
• One of your employees will start to know more than you do – yet as a manager you should know it all.
• You actually enjoy doing the work (well, some of it!).

All of these are valid reasons why you may not want to delegate, but are not necessarily reasons why you shouldn’t do it.
One of the first areas on which to focus is the structure of your organisation. Delegate the specific work areas to your managers, and let them in turn delegate components of that function to their teams.

When delegating, try to follow this route:

Prepare:

• Consider and determine what work can be delegated and what cannot, and subsequently list the areas that you wish to apportion to others.
• Next to each one detail the skills that are required in order to carry out each function.

Match skills:

• Determine which employees are most suited to each of the work functions. Consider their knowledge, experience, skills, strengths and preferences (don’t forget this one - people tend to produce better and more effective results when conducting work they enjoy).

Meet with the employee:

• Communicate with your management/supervisory team what you are trying to achieve, and why it is important for work functions to be allocated amongst them.
• Ensure each person is clear on what they are responsible for and what work they are required to do.
• Set objectives with criteria:
• One main reason a piece of work will not be conducted effectively is because the individual did not understand what was required, or did know what your expectations were.
• Ensure objectives clearly state the ‘end result’ you are looking for.

Test competency:

• Make sure they are competent, and can prove they are competent, to do the job they have been allocated.
• Arrange training to fill in any knowledge or skill gaps and ensure they are supervised in carrying out their role until they have demonstrated competence.
• Delegate the task – not the process.
• Telling someone what they need to do and how they should do it has a number of consequences:
• You are not allowing them to make their own decisions about the way they conduct ‘their’ work.
• It is not much fun doing it someone else’s way, especially if you have sufficient skills to complete the task in a way that suits you.
• You may find they do it better!

Document it:

• Document the structure detailing the apportionment of work and make it available to all employees.
• Ensure it is communicated so that reporting lines, responsibilities and work allocation is clearly understood.

Test it:

• Review it to make sure it is, and remains, workable and effective; that is, it does its job.

If you try to delegate without following these disciplines, you may be accused of ‘dumping’ work, as opposed to entrusting them to do it on your behalf. If it is done correctly, delegation should demonstrate to the employee that they are valued, trusted and are being developed in their role.

Unless you’ve got lots of spare time and no clients to see (which is unlikely!), you can’t expect to be a ‘jack of all trades’ and a master of them too. And you’d need to work hard to convince the FSA why it’s good practice to have all your compliance eggs in one basket. If you don’t fancy your chances with this, then delegation may well be for you!

An edited version of this article was published in Insurance Times

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