1. Introduction
This policy outlines the criteria and processes for assessing whether an individual is a fit and proper person to hold a position of responsibility within our organization. This policy ensures that individuals in key roles possess the integrity, competence, and experience required to perform their duties effectively and uphold the organization\\\’s standards and reputation.
2. Scope
This policy applies to all individuals seeking or holding positions of responsibility within the organization, including but not limited to:
- Board members
- Senior management
- Key personnel involved in decision-making processes
3. Policy Objectives
- To ensure that individuals in key roles have the necessary qualifications, experience, and integrity.
- To protect the organization’s reputation and maintain stakeholder confidence.
- To comply with relevant laws, regulations, and industry standards.
4. Criteria for Assessment
Integrity and Honesty
- No history of criminal convictions or civil penalties related to dishonesty, fraud, or financial impropriety.
- No involvement in unethical behavior or activities that could harm the organization’s reputation.
- Demonstrated commitment to ethical principles and the organization’s values.
Competence and Capability
- Appropriate educational qualifications and professional certifications.
- Relevant experience and proven track record in the industry or role.
- Demonstrated ability to perform the responsibilities of the position effectively.
Financial Soundness
- No history of personal or business bankruptcies.
- No adverse findings or actions taken by regulatory or professional bodies.
- Sound financial standing that does not compromise the individual’s ability to perform their duties impartially.
Conflict of Interest
- Full disclosure of any potential conflicts of interest.
- Commitment to managing and mitigating conflicts of interest in accordance with the organization’s policies.
5. Assessment Process
Initial Assessment
- Candidates must complete a comprehensive application form and provide all necessary documentation.
- Background checks, including criminal record, credit history, and reference checks, will be conducted.
- Interviews and competency assessments will be carried out by a designated committee.
Ongoing Assessment
- Annual reviews of fit and proper status for existing individuals in key roles.
- Continuous monitoring of any changes in circumstances that may affect an individual’s fit and proper status.
- Mandatory disclosure of any new conflicts of interest, legal issues, or changes in personal circumstances.
6. Decision-Making Process
- A Fit and Proper Person Committee, comprising senior management and board members, will be responsible for making final decisions.
- Decisions will be based on a comprehensive review of all gathered information and assessments.
- Individuals will be informed of the decision in writing, with reasons provided if the decision is negative.
7. Appeals Process
- Individuals have the right to appeal a negative decision.
- Appeals must be submitted in writing within 30 days of the decision.
- An independent review panel will consider appeals and make a final determination.
8. Record Keeping
- Detailed records of all assessments, decisions, and appeals will be maintained securely.
- Records will be kept in compliance with data protection regulations and organizational policies.
9. Policy Review
- This policy will be reviewed annually to ensure it remains current and effective.
- Updates and amendments will be made as necessary to comply with changes in laws, regulations, and best practices.
10. Compliance and Enforcement
- Compliance with this policy is mandatory for all individuals within its scope.
- Breaches of this policy will result in disciplinary action, up to and including termination of employment or removal from position.
11. Communication of Policy
- This policy will be communicated to all relevant stakeholders.
- Training will be provided to ensure understanding and compliance.