Purpose
Determine whether personnel understand and apply required controls and ensure identified gaps receive proportionate, documented remediation.
Preconditions
- Learning outcomes and assessment criteria are defined.
- Completion, quality, incident, control-testing and manager-observation information is available.
- Escalation and employment processes are available for material deficiencies.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Perform knowledge checks | Perform a knowledge check after every module and scenario-based assessment for higher-risk topics. Competence should be assessed using one or more of: onboarding knowledge checks; annual refresher assessments; supervisor review and observation; practical case review; quality assurance sampling; control testing outcomes; incident or error analysis; and audit or compliance findings. Assessments should test whether employees understand their escalation obligations; when a matter must be referred to Compliance; key onboarding and screening controls; documentation expectations; sanctions stop rules; the difference between internal handling and external reporting; and how to operate within their delegated authority. | Knowledge-check and scenario results |
| 2 | Assess practical performance | Assess practical performance through observation, case review, file quality, escalation timeliness, control testing, incidents and findings. Ongoing assessment may be supported by annual training completion and test results; file reviews and quality checks; review of escalation quality and timeliness; observed adherence to procedures; incident involvement or control breaches; management feedback; and internal audit, second line or compliance testing results. | Observation and quality review |
| 3 | Conduct annual competence review | Incorporate an annual competence review into HR and Compliance performance review. Upon hiring or role transfer, assess the employee’s baseline knowledge considering prior experience, qualifications, regulatory exposure, control responsibilities and system access level. Where a role involves elevated risk, client onboarding, transaction handling, approval authority, or access to compliance-sensitive systems, role readiness should be confirmed before the employee performs the function unsupervised. | Annual competence review record |
| 4 | Classify gaps | Classify gaps by risk, recurrence and impact and assign an accountable remediation owner and deadline. Where recurring misunderstandings, poor escalation quality, weak documentation or repeated control failures are identified, targeted remediation must be initiated. | Gap classification and remediation plan |
| 5 | Apply remedial measures | Apply proportionate remedial measures: refresher or supplementary training; role-specific coaching or mentoring; closer supervision; temporary restriction of authority or access; reassignment of tasks; or formal performance management where appropriate. | Restriction, coaching and remediation evidence |
| 6 | Reassess before closing | Reassess the person before closing the gap or restoring unsupervised higher-risk work or access. | Reassessment evidence |
| 7 | Escalate material deficiencies | Escalate material or repeated deficiencies to management and link systemic gaps to control remediation and programme improvement. Where competency deficiencies create material compliance, operational, safeguarding or client risk, management must escalate the matter and ensure corrective action is documented and tracked. | Closure approval or escalation record |
Exceptions and Escalation
Assessment cannot be waived for mandatory or higher-risk modules. A material competence gap affecting compliance, client protection, security or resilience requires immediate risk mitigation and management escalation.
Records Created
- Knowledge-check and scenario results
- Observation, quality and competence review
- Gap classification and remediation plan
- Restriction, coaching and reassessment evidence
- Closure approval or escalation record
Relationships
- Policy: POL-TRAIN-001 Training and Awareness Manual
- Process: PRC-RSA-001 Resilience Systems and Assurance
- Independent testing: PROC-ICA-004 Perform Second Line Control Testing
- Control: CTRL-TRAIN-005 Ensure Competence Is Assessed and Gaps Are Remediated
Assurance
Runtime effectiveness results are maintained in Odoo and assessed through the Hermes workflow tracked in ISS-HERMES-001. This note defines design, ownership, evidence expectations and testing method; it does not contain a manually maintained operation, evidence or overall effectiveness rating.
- Frequency: after every module, periodically through observation and annually through formal competence review
History
- 2026-07-26: Created from section 4 and section 6.3.3 of the approved Training & Awareness Manual.