Escalation to our senior officers
We encourage open dialogue. Your feedback is welcome at any stage during our compliance activity. We give you access to our senior officers when issues need to be escalated. Feedback you provide or concerns you raise will not influence our view of your compliance or your future interactions with us.
If you believe our officers have not conducted themselves according to the principles and practices in these guidelines, a senior officer will be available to hear your concerns. We take any claim of abuse of our formal powers seriously. We consider the facts and circumstances of each case. Our investigations could result in counselling or disciplinary proceedings against the officers involved.
There are consequences for not complying with our formal notice. If you receive a notice from us that you disagree with, you should contact us before the due date. If there is a delay in giving us your information, we expect you to discuss this with our compliance team – early discussions help to identify and resolve issues causing the delay. This can give you clarity about our information request, resolve the reasons for the delay and canvass future action should a resolution not be reached. Some matters will require escalation within your own organisation or within ours to a senior officer.
Our escalation process is intended to help resolve information-gathering issues without us needing to use our formal powers. The role of our senior officer in these circumstances is not to assume control of the compliance activity, as that responsibility will usually remain with our compliance team. Instead, the senior officer will work with you and the compliance team to try to resolve the issues. At the end of this escalation process, if the matter is not resolved, each party should clearly understand the other’s position, the issues and the next course of action.
It is helpful if we agree on an escalation plan at the beginning of the compliance activity. This would generally include the contact details of your senior representatives and the name of our senior officer who can be contacted for unresolved matters.
Figure 7 Escalation to our senior officers