The Individual Accountability Framework

Supporting our clients in ensuring a positive and customer-focused culture

What do RFSPs need to do?

Implementing the Individual Accountability Framework, and driving the culture changes necessary to embed new processes within an organisation is likely to be a multi-year project.

What can they do now?

Implementation is likely to be some time away, but small steps now are needed to prepare.

Put SEAR on the agenda

Consider your existing culture and what may need to change to comply with the SEAR and Individual Accountability Framework proposals.

Pick your team

Establish a cross-functional SEAR implementation group (regulatory, compliance, legal, HR, and other relevant stakeholders). This group should board led or have board access.

Assess the landscape

Identify those carrying senior executive functions in your organisation and prepare an initial Responsibility Map based on existing job descriptions. This will help you to identify any existing gaps in responsibilities or any activity for which no identified role is currently responsible.


Collate your existing regulatory and HR policies and template contracts of employment identify areas that will need to be updated during the course of your SEAR project. Raise awareness regarding SEAR, and its implications and timeline, within the RFSP, initially within the leadership team.

Start high level engagement
with stakeholders

Consider engaging with your Directors & Officers Insurance provider with a view to assessing the level of cover that would be available to individuals arising from alleged breaches of conduct standards.

Mary Brassil | Partner

RFSPs and senior executives need to be aware that this is happening, so that they can take steps to ensure that their organisational controls are fit for purpose when the new regime and Conduct Standards come into effect.

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