1
Responsible for the governance of compliance risks.
2
Formulate and implement compliance and other policies such as prevention of front running, outside business activity, commercial bribes and kickbacks, Whistle Blower policy, record retention policy, outsourcing arrangements etc. in accordance with SEBI risk management framework and approved by the Board of AMC and Trustee
3
Review and suggest changes in the policies and obtain approval from Board of AMC and Trustee
4
Ensure identification and communication of regulatory updates to the respective functions and CXOs and monitor implementation
5
Provide inputs to CRO to define risk threshold and risk appetite of Compliance
6
Define and delegate roles to the key personnel within the compliance function for identifying and reporting risks
7
Provide relevant information to CRO regarding monthly / quarterly risk reporting to the Committees
8
For the relevant functional risks, identify, analyze and report and escalate to the CRO and CEO along with recommended action plan for Early warning signals, Emerging risks, Major findings, Near miss and loss events and fraud incidents.
9
Ensure timely and accurate filing of the regulatory returns / filings
10
Review the risk level for the functional risk is in accordance with the control framework and defined threshold
11
Ensure adherence with the DoP framework
12
Formulate and review the RCSA for key risks and controls and periodically provide inputs to update the RCSA for compliance function.
13
Perform and report outcomes of periodic testing of the RCSA to CRO
14
Identify and implement corrective actions / recommend action plans for deviations in the controls and present to CRO/ CEO
15
Ensure adherence to the guidelines pertinent to SEBI in respect of RMF and relevant principles thereunder including risk identification, risk management, risk reporting (both periodic and escalation of material incident) and corrective actions taken.
16
Ensure timely submission of regulatory reports to the Regulator and Board of AMC and Trustee as prescribed by the SEBI Mutual Funds Regulations
17
Monitor the following scheme related disclosures –
- Disclosure of credit (quality of investments made mainly debt based on the credit rating), counterparty, investment and other risks associated with the scheme to the investors
- Scheme's risk profile is stated in all communications with investors including in the SID and marketing materials
- Incorporate any other elements of risk appetite as may be stipulated by AMCs and Trustees in SID
18
Implement process for prevention or detection of possible insider trading at the personnel or portfolio levels
19
Implement process for performing compliance check of AMC’s marketing materials (collateral, brochures etc.), website uploads, digital advertising, and performance advertising etc. before its usage
20
Ensure that roles and responsibilities as per the RMF is disclosed on the AMC website
21
Responsible for the governance (incl. reputation and conduct risk associated for the respective function)
22
Maintaining risk level as per the risk metric
23
Define specific responsibilities regarding risk management of key personnel reporting to Chief Compliance Officer
24
Undertake immediate corrective action for non-compliance or major finding post approval from CEO as per DoP and shall report to CRO regarding the risk reports.
25
Perform adequate due diligence of outsourced vendors prior to onboarding
26
Ensure periodic assessment of outsourced vendors considering following elements:
- Review of vendors' people, systems and processes
- Documentation and communication of error tolerance and code of conduct and monitoring breaches
- Monitor fraud vulnerabilities in the outsourced process.
- Report SLA breaches