We set out how firms should continue to identify and monitor key workers (also known as critical workers) in financial services.
Through the coronavirus (Covid-19) pandemic, the identification of key workers has been essential in enabling the UK Government and devolved authorities to prioritise aspects of their response. Such aspects have included access to transport, education provision for children and young people, and testing to ensure the uninterrupted provision of essential services.
It remains important for financial services firms to continue to identify and monitor key workers to ensure that firms respond effectively in the event of further local or national lockdowns. A key financial worker at a dual-regulated, FCA solo-regulated firm or PSR-regulated firm, or operators of financial market infrastructure, fulfils a role which is necessary for the firm to continue to provide essential daily financial services to consumers, or to ensure the continued functioning of markets.
Firms are best placed to decide which staff are essential for the provision of financial services. To help firms identify their key workers, firms should first identify the activities, services or operations which, if interrupted, are likely to lead to the disruption of essential services to the real economy or financial stability. Firms should then identify the individuals that are essential to support these functions. Firms should also identify any critical outsource partners who are essential to continued provision of services, even where these are not financial services firms.
We recommend that the Chief Executive Officer Senior Management Function (SMF1) is accountable for ensuring an adequate process so that only roles meeting the definition are designated. For firms that do not have an SMF1 Chief Executive Officer this will be the most relevant member of the senior management team.
The types of roles that may be considered as providing essential services could be:
- Individuals essential in the overall management of the firm.
- Individuals essential in the running of online services and processing.
- Individuals essential in the running of branches and providing essential customer services, such as those dealing with consumer queries (including via call centres), client money and client assets and those maintaining access to cash and other payment services.
- Individuals essential to the functioning of payments processing and of cash distribution services.
- Individuals essential in facilitating corporate and retail lending and administrating the repayment of debt.
- Individuals essential in the processing of claims and renewal of insurance.
- Individuals essential in the operation of trading venues and other critical elements of market infrastructure.
- Risk management, compliance, audit and other functions necessary to ensure the firm meets its customers’ needs and its obligations under the regulatory system.
- Any individual that provides essential support to allow the functioning of the above roles, such as finance and IT staff.
Firms should consider, if they have not already done so, whether they should issue a letter to all individuals they identify as key workers, including any new joiners, should it be necessary for these individuals to provide evidence of this in the future. We recommend that the letter includes the sentence 'the individual has been designated as a key worker in relation to their employment by [firm name]' and is signed by someone with appropriate authority.
Firms should continue to follow the Government’s guidance closely and take the recommended steps.
24/04/2020: Information added Following government & Devolved Administrations' recently expanded coronavirus testing