CTRL 3.1.21 Specific obligations — independence of certain employees

(1) An authorised firm’s governing body must ensure that each employee to whom a responsibility is allocated within the firm’s internal controls framework is sufficiently free from influence for the framework to be effective in achieving its purposes.
(2) The requirement in subrule (1) is satisfied if reasonable measures have been taken to ensure that:
(a) no such employee is remunerated in a way that would tend to undermine his or her independence and objectivity in performing his or her duties;
Note For the requirements relating to a firm’s remuneration policy, see rule 3.1.16.
(b) no such employee is involved in performing a function that generates, or is intended to generate, revenue for the firm;
(c) no such employee is limited or restricted as to the matters that he or she can investigate or report on in the exercise of his or her function;
(d) the reports and conclusions of such an employee can be honest and candid, without fear of reprisal; and
(e) pressure or influence is not applied to such an employee to modify his or her reports or conclusions.


Derived from QFCRA RM/2020-4 (as from 1st July 2021)