We are grateful for the significant ongoing efforts of banks, building societies and credit unions and their frontline staff working alongside the Post Office to keep access to cash, call centres and other essential services for customers.
All firms should be clear that Coronavirus (Covid-19) constitutes a public health emergency. As the regulator of the UK financial services industry, we strongly support the UK Government’s efforts to protect the public by ensuring only those workers truly essential to the real economy or financial stability, and who cannot work from home, continue to travel to and from work. Following discussions with firms, it is clear many firms are interpreting our statement of 20 March 2020 far more broadly than was intended.
The UK Government has announced further restrictions on travel and provided guidance on the circumstances where people should seek to work from home. Key financial workers, if appropriately identified, are a class of workers where continued physical presence in a firm’s office or business continuity planning (BCP) site could be appropriate, if that role cannot be effectively performed from home.
Each firm’s designated Senior Manager or equivalent person is accountable for identifying their key workers. They should make sure that only workers who are essential to support functions, which are themselves essential to the real economy or financial stability, are designated as key financial workers. They must ensure that even these workers work from home if they are able to do so.
We expect the total number of workers so identified to be far smaller than the number of workers needed to ensure all of a firm’s business activities continue to function on a business as usual basis.
Where activities or services cannot be safely undertaken or provided from home, because for instance appropriate control arrangements cannot be assured, we expect firms to consider stopping that activity or service rather than continue it in their physical offices or BCP sites.
The UK Government has made clear that employers and employees should discuss their working arrangements, and employers should take every possible step to facilitate their employees working from home, including providing suitable IT and equipment to enable remote working. For example we would not expect the following to go into work or meet face to face:
- financial advisers, as they can offer their services online or by phone.
- staff who can safely and securely trade shares and financial instruments from home
- business support staff, such as those in IT where they can triage issues from home, unless they are looking after specific equipment or technology
- anyone that is not involved in essential activities, such as claims management companies and those selling non-essential goods and credit
We expect the number of exceptions to this, because a firm’s presence in a particular market is essential to the real economy or financial stability, to be low.
Firms should continue to follow the Government’s guidance closely and take the recommended steps.
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