Hybrid Working Solutions

Given publications and subsequent hybrid working model guidance issued by the FCA and financial institutions, we believe companies carrying out regulated activities, who are embracing this new working landscape, should periodically visit any part-time or full-time remote working environment in order to assess its suitability and compliance with said guidelines.

The FCA can request to visit hybrid working sites, and in our opinion, without an annual assessment, no regulated company can be certain that they are truly fulfilling their obligations.

Whilst there is no doubt the hybrid working model can benefit both the company and employee alike, the sheer scale of this requirement for compliance departments already likely operating at full capacity, will make this annual task almost impossible unless accompanied by an increase in resources. It should be noted that no employee disclaimer can replace the company's obligation to fulfil their oversight obligations, nor do we believe it would be an acceptable defence to a breach of the FCA guidance

The FCA is clear in its guidance relating to the responsibilities and obligations of regulated firms, stating the importance of the firm having a “plan in place” and that the firm has “reviewed it before making any temporary arrangements permanent.” Further, that “the firm reviews it periodically to identify new risks”. Furthermore, the FCA have started to reference home working arrangements in recent regulatory actions.

We at Hybrid Working Solutions offer bespoke inspections to assist in overcoming these challenges. We are currently working with firms to integrate these inspections as part of their annual compliance monitoring and planning

Our Services

• Remote working environment inspections and assessments.
• Final assessment report detailing any remediation recommendations.

Additional Services

• Asset data collection to assist with accurate and up to date reporting of company equipment for maintenance and accounting purposes.
• Compilation of energy use and carbon emission data to enable review and, if required, reporting of the ESG impact of hybrid working arrangements.

At Hybrid Working Solutions we have over 60 years of combined front office and operational expertise along with Global Financial Compliance qualifications and vast experience in creating solid hybrid working setups and disaster recovery sites.

Resources

https://www.fca.org.uk/firms/remote-hybrid-working-expectations