Purpose
Provide one integrated client-protection process covering safeguarding, communications, promotions, complaints, market conduct and privacy throughout service delivery.
Policies Implemented
- POL-SAFU-001 Client Asset Protection and Safeguarding Manual
- POL-COMM-001 Client Communication and Promotion Compliance Manual
- POL-COMP-001 Client Complaints Handling Manual
- POL-MCT-001 Market Conduct and Trading Compliance Manual
- POL-PRIV-001 Data Protection and Privacy Manual
Trigger
The process starts when a client interaction, communication, promotion, order, trade, asset movement, complaint, data event or service exception requires protection, decision or remediation.
High-Level Flow
Identify client and service context -> provide fair and approved information -> execute controlled service activity -> safeguard assets and data -> monitor conduct and outcomes -> handle complaints and incidents -> remediate and report -> retain evidence and improve.
Inputs
- Client profile, instructions, communications and consent.
- Product, pricing, trading, settlement and safeguarding information.
- Complaint, incident, conduct, privacy and service-quality information.
- Legal, regulatory and contractual protection requirements.
Outputs
- Fair, clear and documented client communications and service decisions.
- Controlled orders, trades, asset movements and safeguarding records.
- Resolved complaints, privacy events, conduct exceptions and remediation.
- Client, management and regulatory reporting evidence.
Roles
- Compliance defines conduct, safeguarding, communications, complaints and privacy requirements.
- Operations and client-facing personnel execute approved service and evidence steps.
- Finance and Treasury support settlement, safeguarding and reconciliation controls.
- Technology protects client information and service systems.
- Management oversees client outcomes and remediation.
- Independent assurance tests fair treatment and control effectiveness.
Operating Model
This is a primary BCMS process. It links directly to policies, requirements, procedures, controls and systems. It does not contain or depend on subordinate PRC objects. Detailed operating steps remain in the linked PROC objects.
Relationships
- Architecture decision: ADR-003 Flatten Compliance Process Architecture
- Safeguarding policy: POL-SAFU-001 Client Asset Protection and Safeguarding Manual
- Communications policy: POL-COMM-001 Client Communication and Promotion Compliance Manual
- Complaints policy: POL-COMP-001 Client Complaints Handling Manual
- Market-conduct policy: POL-MCT-001 Market Conduct and Trading Compliance Manual
- Privacy policy: POL-PRIV-001 Data Protection and Privacy Manual
Assurance
- Design status: implemented through approved client-protection policies.
- Operating status: inherited from the linked procedures and controls.
- Evidence status: defined in the linked controls and systems.
- Overall status: implemented primary process; operating effectiveness remains subject to linked issues and assurance.
History
- 2026-07-26: Created as one of the five active processes in the flattened BCMS process architecture.