Update on Coronavirus (COVID-19) continuity planning
 

Following recent developments on COVID-19 (Coronavirus) and additionally following the Prime Minister’s announcements on 16 March of an increase in steps that the UK government is taking to manage the situation, I wanted to update clients and contacts on the steps that Gem Compliance is taking to manage its business continuity in the circumstances.
 
We would like to reassure you that at Gem Compliance, we are ensuring business continuity for our clients, whilst protecting our staff. As part of contingency plans, our staff are all now working at home from Monday 16^th March, primarily to minimise use of public transport or to avoid being in more crowded areas in the meantime. We anticipate these plans will remain in place at least for the next 14 days, but may be longer depending upon UK Government advice at any given time. We will update you as and when needed. 
 
We appreciate many of you may have also adopted similar arrangements. As part of those plans, if not already done so, you may also wish to consider notifying relevant investors, clients and/or third party suppliers of your own arrangements in the meantime. 
 
But I wanted to confirm that otherwise we are running our support services as business as usual with the following minor variations in the short term:

• At present, we are not undertaking physical/face to face meetings as a normal practice and would only do so on request if considered a regulatory emergency and subject to confirmation from yourselves that this is appropriate (for both the protection of our staff but also your firm and its staff).
• The team all remain contactable by individual (or group mailboxes where appropriate) and also by mobile phone. We can also arrange online conference calls/meetings via Zoom. Therefore it is recommended that these contacts are used in the meantime rather than the offices’ direct landlines of 0131 473 1004/0203 637 6407 although messages can be taken via those lines in any case.

We also wanted to take the opportunity to remind firms of FCA expectations in such circumstances and have attached a link to their most recent statement to regulated firms available on the website. 
https://www.fca.org.uk/news/statements/covid-19-coronavirus
 
We would also draw your firm’s attention to public guidance on other general areas of advice outside of compliance and regulation.  
https://www.gov.uk/government/topical-events/coronavirus-covid-19-uk-government-response
 
Firms are encouraged to check the FCA website (in addition to other more specific websites on health and safety for coronavirus) on a regular basis for any changes to FCA messages in respect of compliance in the current environment. In addition that the FCA’s SYSC rulebook at SYSC 4.1 states that firms must have robust disaster recovery plans and business continuity plans in place which should be reviewed on a regular basis including any ‘lessons learnt’ during a business continuity event. Many firms are treating the current circumstances as part of the requirement to also test that these plans are effective. 
 
If anyone wishes to discuss FCA business continuity issues in the circumstances, or any other general compliance queries in the meantime, please do not hesitate to contact us as normal.