The Pension Protection Fund (PPF) was set up in 2005 to protect employee retirement savings when employers go bust. When the worst happens the PPF takes over the running of the pension fund but for the past 11 years most assets have been managed externally. Now, the organisation has embarked on a three-year task of bringing back a large number of these assets to be managed in-house.
As this happens head of legal, compliance and ethics Dana Grey is ensuring the PPF meets its regulatory requirements.
“I had no management or leadership experience when I first joined, but as a lawyer you develop a lot of relevent skills”
As an organisation dealing with financial products the PPF has always had to comply with Financial Conduct Authority (FCA) regulations. But as the business has grown and taken on new responsibilities its compliance requirements have changed.
When she took the job, to make sure the PPF was compliant Grey embarked on a major review of its business to highlight what processes needed to be improved or introduced.
“With one of my panel firms I assessed the business and what sort of organisation we would be in the asset management space,” says Grey. “We analysed which policies and processes we’d need to put in place from the FCA perspective. We looked at what we had and what we didn’t have, and when we found something we needed we built out something new.”
One compliance issue Grey and her team tackled was the PPF’s personal account stealing policy. While the PPF has always had an account stealing policy in place this had not been reviewed for some time. The assessment led to the policy being completely overhauled as well as widening its scope across the business.
As the PPF handles a lot of non-public information Grey also created its first markets abuse policy.
While most PPF policies were already in place the business had no codified version of its procedures. The new formalised process means members of staff across the organisation are able to look up procedures needed to remain compliant at any point.
It was Berwin Leighton Paisner that Grey picked to assist the PPF in its internal review. She does not have a standalone panel for compliance work but has suggested that the firms that have assisted the PPF with compliance advice in the past may be called on more frequently.
“My tip is to find someone who does what you want to do well and watch what they do. Have coffees and catch-up meetings”
Lawyers in management
Since joining the organisation in 2009 Grey has held a number of positions which gave her the experience needed to set up and manage the compliance team.
She joined as deputy head of relationships in the business’s scheme delivery division, which is involved in many operational aspects.
“I joined as second in command of that team,” says Grey. “I had no management or leadership experience but as a lawyer you develop a lot of skills such as interviewing, negotiating and relationship-building. So I was taking what I’d learned in eight years in private practice.”
Six months after joining the team Grey was tasked with setting up a support team to help the scheme delivery department. Less than three years later she was promoted to PPF’s head of legal.
The creation of the compliance function has been another opportunity for Grey to set up an entirely new team. Although Grey has “grabbed with both hands” any opportunity to set up new departments, she admits the only management experience she had before moving in house was acting as line manager for her personal assistant.
“We’re an organisation that is full of intellectuals – lawyers, actuaries, investment professionals and accountants,” she adds. “These are people who really need support when they go into management.
“My tip for anyone in that situation would be to seek out support and guidance. It doesn’t always need to be formal. Find someone who does what you want to do well and watch what they do. Have coffees and catch-up meetings.”
Continuing the work
The PPF’s insourcing programme went live in October 2016, meaning Grey’s work is now well underway.
To focus on setting up the compliance and ethics team Grey stepped back from her role as head of legal for eight months.
The three-strong team now consists of a compliance manager and an associate, reporting to the compliance officer.
“We needed people who were technically savvy and could inspire the confidence of people who hadn’t worked with a compliance team”
“It was important I got the recruitment side right,” says Grey. “We needed people who were technically savvy and could inspire the confidence of people who hadn’t worked with a compliance team. But they also needed to be able to inspire people used to working with a compliance team and who knew what were talking about.”
Initially, the team worked closely with colleagues who would be most closely affected by the new policies, but its role has evolved to ensure policies and processes that are put in place are enforced internally.
“The compliance and ethics team is now putting together a monitoring and testing programme so we have a plan for the whole year,” she adds. “Through monitoring our compliance activities we can see where training might be required. It’s important to keep people engaged.”
As the PPF brings more investment products in-house the demands on the compliance team will no doubt increase. And as the organisation grows it will be down to the team to work with their colleagues to keep everything compliant.
In these early days it is Grey’s leadership and ability to create a functioning team that will pave the way for the PPF’s success.
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