Compliance at Stellar
At Stellar, we place a strong emphasis on effective risk management and regulatory compliance. To support this, we have established a dedicated Risk and Compliance Committee, which has been operating for several years. The committee comprises of: Jonathan Gain, CEO and Chair of Risk and Compliance, Claire Taylor, Finance Director and Glen Halley, Fund Operations Manager. This group meets regularly to review and address various compliance-related matters. Their primary focus is to ensure that the organisation remains compliant with regulatory standards, mitigates potential risks, and upholds best practices across all areas of operation.
Committee Structure and Responsibilities
The committee meetings are guided by a comprehensive Terms of Reference (TOR), which outlines the agenda, available resources, and protocols for each session. Minutes are taken diligently to ensure transparency and provide a basis for follow-up actions.
The Risk and Compliance Committee addresses a wide range of risk-related matters to ensure the organisation maintains the highest standards of compliance and operational integrity. The key focuses for these meetings are Office updates, Asset updates, Complaints and Operational issues, FCA communications, submissions to be delivered to the FCA, Compliance and monitoring and update on staffing, new joiners and training.
Operational updates are a crucial discussion point. The committee evaluates issues related to building maintenance, fire safety protocols, and evacuation procedures to ensure a safe and efficient working environment.
In terms of asset management, the status of key assets is reviewed regularly, along with any significant changes, to maintain optimal asset performance. Furthermore, the committee oversees the Senior Managers and Certification Regime (SMCR) by monitoring staffing changes, such as new hires and promotions, to ensure proper background checks are conducted and regulatory standards are met.
The committee also places significant emphasis on capital adequacy through the Internal Capital Adequacy and Risk Assessment (ICARA). This involves thorough capital planning and fund reserve management, coupled with ongoing compliance monitoring.
The committee also addresses any operational issues. Action plans are developed to prevent the recurrence of these issues, ensuring continuous improvement in our operational processes. The committee reviews updates on client redemptions to identify trends and understand the reasons behind clients exiting services, which provides valuable insights for future client retention strategies.
Finally, the committee addresses any other business (AOB), which includes reviewing actions from previous meetings and discussing additional topics as they arise. Minutes are drafted, circulated for feedback, and finalised to secure sign-off, ensuring that key decisions are documented and aligned with the committee’s objectives.
Breakfast Briefings and Training Initiatives
In addition to formal committee meetings, we conduct Breakfast Briefings for all staff, to cover a range of compliance and regulatory topics. These briefings, which began in 2021, are part of our commitment to continuous learning and professional development.
Our training sessions cover a wide range of topics, with a particular focus on critical compliance areas such as Anti-Money Laundering (AML), Anti-Bribery & Corruption, Whistleblowing, Market Abuse, Consumer Duty, and Fair Treatment of Vulnerable Customers. By addressing these key areas, we ensure that our team is well-equipped to handle the complexities of regulatory requirements and uphold best practices in their daily operations.
The format of these sessions is designed to be highly interactive. They feature a combination of presentations, audience participation, and case studies to encourage engagement and enhance practical learning. This hands-on approach allows participants to apply their knowledge in real-world scenarios, deepening their understanding of compliance matters.
While the primary focus is on regulatory compliance, these sessions also explore broader subjects that contribute to raising overall standards across the company. By expanding the scope of training beyond compliance alone, we aim to foster a culture of continuous learning and professional growth, benefiting both our employees and the organisation as a whole.
Policies and Procedures
Our policies are reviewed and updated annually to ensure they remain aligned with the latest regulatory standards. These policies are readily accessible to team members via our core systems.
New employees are introduced to our company’s standards and expectations through a comprehensive compliance welcome pack. This onboarding resource is designed to provide a thorough understanding of our regulatory requirements, internal policies, and best practices. By equipping new starters with this essential knowledge from the outset, we ensure they are well-prepared to align with our compliance culture and contribute effectively to their roles.
In addition to the onboarding process, all staff members are required to complete attestations e.g. Gifts and Entertainment and Personal Account Dealing. These attestations serve as a formal confirmation that employees understand and adhere to the company’s key policies. This exercise not only reinforces accountability but also ensures that everyone remains up-to-date with the latest compliance requirements, thereby supporting our commitment to maintaining a high standard of regulatory compliance across the organisation.
A structured approach to compliance monitoring is achieved through quarterly reporting undertaken by Waystone , which includes pre- and post-compliance reviews. Detailed reports are prepared and submitted to CEO, Jonathan Gain, for further analysis and recommendations.
Conclusion
The Risk and Compliance Committee plays a vital role in upholding the organisation’s integrity and compliance standards. Through regular meetings, structured training programs, and thorough policy management, we continuously strive to enhance our risk management processes and ensure compliance with all regulatory requirements. This ongoing commitment helps us navigate the evolving landscape of financial regulation, thereby maintaining trust and confidence among our clients and stakeholders.