University | International Compliance Association(ICA) |
Subject | IBF Level 1: Leveraging Data for Business Advantage |
Core Module 3 – Developing a Compliance Culture
Question 1.
a) You have recently been involved in reviewing a sample of the business submitted to the firm, as part of a thematic review. One case that you review involves a product sold to Mr Lee. You believe that the product sold to Mr Lee is not the best product from the range available. Although it does meet some of his stated needs, there is another product that is clearly better suited to his requirements. The product he has been sold pays the relationship manager (RM) over double the amount of commission that the other product would have paid. Your manager agrees with your findings and asks you to document your proposed course of action. Produce a note of your recommendations.
b) You are called to a meeting with your manager, the RM and the regional sales manager (RSM).
The RSM explains to you and your manager that Mr Lee is a new customer to the firm. He is the owner of a large company in Singapore and is about to make introductions to his board members and senior managers that may lead to a substantial business stream. The RM states that any suggestion at this initial stage that he has been mis-sold will put all that future revenue in jeopardy. The RM states that the client is so wealthy that the additional charges under this contract are of no consequence to him. The RSM asks that you are pragmatic and business focused and allow this sale to continue. He guarantees that there will be no complaint from the client.
What action do you propose be taken?
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Question 2.
Your firm recently required staff to watch a video dealing with anti-bribery and corruption (ABC) and then answer 10 multiple-choice questions based on the content of the video. The results of the assessment revealed that a very high proportion of staff could not get at least 7 of the 10 questions correct.
The evidence clearly indicates that this form of training is not effective and interviews with some of the staff who failed the assessment record that they would welcome a better approach to the provision of training.
Discussions with other parts of the business reveal that they have also tried this training approach with little success. It is evident that a review of the firm’s training delivery is necessary, and you have been asked to produce a note that:
a) documents the various stages that you will consider when reviewing, re-designing and delivering training
b) identifies how you will measure the success of the revised programme.
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Question 3.
‘Ethics and ethical behaviour must be embedded within a regulated firm’.
Analyse and elaborate on this statement.
Question 4.
Implementing changes required by new or amended regulation can be a challenge. Articulate how you propose that such changes are communicated to the affected groups of stakeholders in a way that ensures that they are kept informed, addresses their concerns and interests and identifies how any conflict will be managed, including an escalation process.
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