In response to the COVID-19 outbreak, the UK Government has closed schools for all children other than those with at least one parent who is deemed a ‘Key Worker’ and whose children cannot be cared for at home. This includes staff needed for “essential financial services provision” (Key Financial Workers) and includes but is not limited to workers in banks, building societies and financial market infrastructure.
The FCA has stated that firms are best placed to decide which staff are essential for the provision of financial services. They recommend that the firm’s Chief Executive Officer Senior Management Function (SMF1) be made responsible for ensuring an adequate process is in place to ensure that only certain defined individuals and those identified as supporting ‘essential’ financial services are designated as Key Financial Workers.
Firms should, therefore, have already identified the activities, services or operations they provide “which, if interrupted, are likely to lead to the disruption of essential services to the real economy or financial stability”, and then “identify which individuals are essential to support these functions.”
The FCA’s list of defined roles that may be considered as relevant to a firm’s Key Financial Worker includes the following individuals:
- individuals captured by the Senior Managers Regime; or
- essential in the running of online services and processing, branches and providing essential customer services, client money and client assets and those maintaining access to cash and other payment services; or
- essential to the functioning of payment processing and of cash distribution services; or
- essential in the processing of claims and renewal of insurance; or
- essential in the operation of trading venues and other critical elements of market infrastructure; or
- involved in risk management, compliance, audit; or
- that provide essential support to allow the functioning of the above roles, such as finance and IT staff.
The FCA recommends that firms produce letters on behalf of any individuals designated by them as key workers and who have children who would need to continue to attend school. This letter should include the following sentence, “The individual has been designated as a key worker in relation to their employment by [firm name]” and should be signed by someone at the firm with the appropriate authority.
The FCA also recommends that firms should “identify any critical outsource partners who are essential to continued provision of services, even where these are not financial services firms .”
