01The regulator shapes the process
In the UK, the Senior Managers and Certification Regime asks firms to take responsibility for the people they employ. Senior managers hold documented responsibilities. Staff in certified roles must be assessed as fit and proper at least once a year. The Conduct Rules apply to almost everyone, and firms must train people on them and report breaches. None of this is a performance review, but each part relies on the same evidence: what a person did, how they did it and what their manager knew.
02Balanced scorecards replaced sales-only targets
Many retail banks moved away from sales-only incentives after the mis-selling cases of the 2000s and 2010s. A typical scorecard now weighs financial results against customer outcomes, risk and control, and people or leadership measures. Many banks also rate the “what” and the “how” separately, so that a strong commercial result cannot hide poor conduct. The design matters less than whether managers can explain a rating using specific evidence.
03Reward is adjusted for risk
Remuneration rules for larger firms require variable pay to reflect financial and non-financial performance. Awards can be reduced before they vest, or recovered afterwards, when conduct or risk failings come to light. That gives the performance record a long life. A rating agreed in January may be examined years later, by people who were not in the room. Clear notes, written near the event, are worth more than a polished year-end summary.
04Three lines, many managers
Front-line teams, risk and compliance functions, and internal audit each see a different part of a person’s work. Project and change roles often report to a delivery lead and a functional head at once. Useful reviews gather those perspectives deliberately, with each contributor clear about what they are being asked to comment on.
