Entire section
Competencies
Guidance for Fund Management Activity and Funds in the AIFC

Training and Competence Document and Programme

7.1.   An Authorised Person is expected to ensure that the firm’s policies, procedures, systems and controls appropriately and adequately address the training requirements.


7.2.   An Authorised Person is expected to be able to provide documentary evidence of its compliance with the requirements relating to the training and competence of individuals who perform a Controlled or Designated Function. This includes training and competence document and training and competence programme.


7.3.   Training and competence document should include:

  1. a) brief description of training and competence programme;
  2. b) the requirements, characteristics and role of each of the Controlled and Designated Function;
  3. c) how the firm is to satisfy itself that each individual who performs a Controlled or Designated Function has, and continues to have, the competencies required to perform the function;
  4. d) how the firm is to ensure that it complies, and can demonstrate its compliance, with its training and competence programme;
  5. e) how, and in what circumstances, the firm will review the programme and the document, including who is to carry out the review and evaluation and when; and
  6. f) how, and in what circumstances, the firm will revise the programme and the document, including who is to approve any revision (revision includes amendment and replacement).


7.4.   Training and competence programme should:

  1. a) be aligned with the training and competence documents;
  2. b) be relevant, updated and appropriately structured;
  3. c) include reference to policies, procedures, systems and controls on competence assessment;
  4. d) describe continuing professional development plan;
  5. e) include review and evaluation of training needs;
  6. f) include measures that ensure that individuals who perform a Controlled or Designated Function:
  7. i. maintain their competencies;
  8. ii. are kept up to date with developments relating to their functions; and
  9. iii. are trained on any changes to the firm’s policies, procedures, systems and controls.


7.5.   In designing its training and competence programme, the firm should consider all relevant factors, including but not limited to:

  1. a) the individuals’ differing needs, experience, skills and abilities;
  2. b) their differing roles and levels in the firm;
  3. c) the degree of supervision over, or independence exercised by, them;
  4. d) the availability of information needed for them to perform their roles;
  5. e) the nature, scale and complexity of the firm’s business, including the products and services it offers or provides, and proposes to offer or provide;
  6. f) the firm’s customers;
  7. g) the outcome of reviews of the individuals’ training and competence;
  8. h) any analysis showing areas where training needs to be enhanced; and
  9. i) the regulatory system, including any recent, or reasonably expected changes to it.


7.6.   An Authorised Person is expected, at regular and appropriate intervals (at least once in 12 months) to review and evaluate its training and competence programme and training and competence document for quality and effectiveness and to ensure that the training needs of individuals performing Controlled or Designated Functions are appropriately met.


7.7.   For the purposes of this Guidance, the examples of training shall include but are not limited to:        

  1. a) academic studies;
  2. b) obtaining professional qualifications;
  3. c) technical training for roles that are highly technical or that involve constant changes in legislation or regulatory practice;
  4. d) in-house training;
  5. e) industry literature review.