Compliance

The Firm’s CMP has been designed to detect risk of failure by the Firm to comply with its obligations under the regulatory system. The CMP represents a programme of areas and topics that have been compiled by adopting a proportionate risk-based approach taking into account business operations, procedures and controls. This involves reviewing the Firm’s policies and procedures, testing the Firm’s compliance with all applicable laws and regulations on a proportionate risk-based approach, taking into account the business, operations and systems and controls.

The systems and controls which have been implemented within CIM have been designed with the business in mind and are deemed to be proportionate to the nature, scale and complexity of the business and its activities. These arrangements are reviewed regularly and are signed off by the Management Committee, as a minimum, on an annual basis.

CIM has implemented and maintains robust governance arrangements, which include a clear organisational structure with well defined, transparent and consistent lines of responsibility, effective processes to identify, manage, monitor and report the risks it is, or might be exposed to, and internal control mechanisms, including sound administrative and accounting procedures and effective controls and safeguarding arrangements for information processing systems. The Management Committee understands its responsibilities around the organisation of the firm, the adherence by the firm to the risk tolerance set by the governing body and the construction and implementation of a remuneration policy that encourages responsible business practices and fair treatment of clients.

CIM’s business continuity policy is documented in the Compliance Policies and Procedures Manual (“CPPM”) and was designed to ensure continuity and regularity in the performance of its regulated activities. In particular it ensures, in the case of an interruption to the Firm’s systems and controls, that any losses are limited, essential data and functions are preserved, and regulated activities are maintained, or where this is not possible, the timely recovery of such data and timely resumption of regulated activities. The business continuity policy is the responsibility of the Compliance Officer and the testing of arrangements is carried out on an annual basis.

The Management Committee is made up of experienced professionals who possess the knowledge, skills and experience to perform their duties and, collectively, to understand the Firm’s activities, including the main risks faced by the Firm. They reflect an adequately broad range of experiences, are of sufficiently good repute and act with honesty, integrity and independence of mind to effectively oversee and monitor decision-making. The Management Committee is provided with training on a periodic basis, are made up of sufficiently diverse educations and professional backgrounds to present a variety of views and experiences and commit sufficient time to perform their functions.

CIM has a rigorous recruitment process, which aims to ensure its personnel have the skills, knowledge and expertise necessary for the discharge of their responsibilities. Most members of staff are also subject to annual internal competency assessments to ensure they maintain a high level of competency. Subject to the discretion of the Compliance Officer, particularly where a recruit has no background in working in financial services, CIM may require its recruits to have sat and passed appropriate exams. All staff receive training at least semi-annually on the Firm’s internal compliance policies and procedures, as well as on financial crime, covering areas including, but not limited to: anti-corruption and anti-bribery, insider dealing and market abuse, fraud and anti-money laundering.

CIM has implemented policies and procedures to enable it to identify, assess, monitor and manage money laundering risk. These are contained in the Firm’s CPPM and the Financial Crime Risk Assessment.

CIM pays due regard to the interests of clients and aims to treat them fairly at all times. The Firm has implemented systems and controls to identify, monitor and manage conflicts of interest. Whilst Civitas takes all appropriate steps to avoid conflicts of interest this may not always be possible. In those instances, CIM will manage conflicts of interest fairly, both between itself (including its partners, staff and any person linked to the Firm directly or indirectly by control) and its client and between two or more clients.

CIM is committed to maintaining the highest standards of honesty, openness and accountability and recognises that all members of staff have an important role to play in achieving this goal. Members of staff will usually be the first to know when someone inside or connected with an organisation may be doing something improper, but may feel apprehensive about voicing their concerns. This may be because they feel that speaking up would be disloyal to their colleagues or the Firm itself. It may also be because they do not think that their concerns will be taken seriously or because they are afraid that they will be penalised in some way. However, CIM does not believe that it is in anyone's interest for a member of staff with knowledge of wrongdoing to remain silent. CIM takes all malpractice very seriously, whether it is committed by senior managers, staff, suppliers or contractors. CIM has a whistleblowing procedure which staff should follow to report their concerns. This can be found in the CPPM.

As a MiFID Investment Firm, CIM is required to comply with the FCA Rules set out in the Prudential sourcebook of the FCA Handbook (“MIFIDPRU”).

Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) requires the Firm to publish disclosures detailing its compliance with the prudential requirements. These disclosures must be published on an annual basis, on the date the Firm publishes its annual financial statements. The latest disclosure can be found here.