The FCA doesn't just regulate what your people do — it regulates whether they should have been hired in the first place. Under SM&CR, fitness and propriety assessment begins at recruitment. A firm that hires an SMF holder without FCA register searches, regulatory history verification, and properly documented reference checks hasn't just made a poor hire — it has failed a specific regulatory requirement. Add Equality Act vicarious liability, UK GDPR data processing obligations, and Consumer Duty capability standards, and a recruitment policy that amounts to "we advertise, interview, and hire the best candidate" isn't a compliance framework — it's a liability. The FCA doesn't wait.
A properly structured Recruitment Policy from a consultant typically costs £3,000–£6,000. This template — built by compliance and regulatory experts with over 150 years of combined experience across some of the world's most reputable financial services firms — gives you the same rigour at a fraction of the cost, ready to implement today.
What's included:
Full regulatory mapping: SM&CR, FCA FIT requirements, SYSC 3, TC Sourcebook, Consumer Duty, Equality Act 2010, UK GDPR/DPA 2018, and AML/CTF
Three-tier approval governance: SMF roles (Board/FCA notification), Certification Functions (CEO), and Standard Roles (department head/Finance)
Fitness and propriety assessment: FCA register searches, regulatory history verification, enhanced DBS checks, and declarations of proceedings
Financial crime safeguards: identity verification, sanctions screening, adverse media searches, and financial integrity assessments at recruitment stage
Equality Act compliance: inclusive advertising, protected characteristics across all stages, and reasonable adjustments framework with 5-day response requirement
UK GDPR data retention matrix: successful candidates (employment + 6 years), unsuccessful candidates (6 months), and interview notes (6 months)
Non-compliance framework: Compliance investigation triggers, disciplinary proceedings, and FCA notification where customer outcomes are compromised
+ much more
Who is this for?
Compliance Officers, HR Directors, SMF holders, and hiring managers at FCA-regulated firms who need a complete, board-approved Recruitment Policy that makes every hire a documented, auditable, regulatorily-compliant process.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
The FCA doesn't just regulate what your people do — it regulates whether they should have been hired in the first place. Under SM&CR, fitness and propriety assessment begins at recruitment. A firm that hires an SMF holder without FCA register searches, regulatory history verification, and properly documented reference checks hasn't just made a poor hire — it has failed a specific regulatory requirement. Add Equality Act vicarious liability, UK GDPR data processing obligations, and Consumer Duty capability standards, and a recruitment policy that amounts to "we advertise, interview, and hire the best candidate" isn't a compliance framework — it's a liability. The FCA doesn't wait.
A properly structured Recruitment Policy from a consultant typically costs £3,000–£6,000. This template — built by compliance and regulatory experts with over 150 years of combined experience across some of the world's most reputable financial services firms — gives you the same rigour at a fraction of the cost, ready to implement today.
What's included:
Full regulatory mapping: SM&CR, FCA FIT requirements, SYSC 3, TC Sourcebook, Consumer Duty, Equality Act 2010, UK GDPR/DPA 2018, and AML/CTF
Three-tier approval governance: SMF roles (Board/FCA notification), Certification Functions (CEO), and Standard Roles (department head/Finance)
Fitness and propriety assessment: FCA register searches, regulatory history verification, enhanced DBS checks, and declarations of proceedings
Financial crime safeguards: identity verification, sanctions screening, adverse media searches, and financial integrity assessments at recruitment stage
Equality Act compliance: inclusive advertising, protected characteristics across all stages, and reasonable adjustments framework with 5-day response requirement
UK GDPR data retention matrix: successful candidates (employment + 6 years), unsuccessful candidates (6 months), and interview notes (6 months)
Non-compliance framework: Compliance investigation triggers, disciplinary proceedings, and FCA notification where customer outcomes are compromised
+ much more
Who is this for?
Compliance Officers, HR Directors, SMF holders, and hiring managers at FCA-regulated firms who need a complete, board-approved Recruitment Policy that makes every hire a documented, auditable, regulatorily-compliant process.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
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