RAMP was the first packaging association to reveal a code of conduct in August 2004, three months before the start of mortgage regulation. It placed a duty of care on its members to uphold the highest standards in dealing with lenders and intermediaries as well as specific compliance areas such as senior management controls and organisation, designated compliance function, training, succession planning, disaster recovery and complaint-handling.
Nick Battersby, compliance director at RAMP, explained that when the original code of conduct was put together it was before the full effects of regulation could be measured and, while it covered most of the issues, it felt it was important to revisit the Code in the light of experience gained since its inception.
The changes to the Code reflect the strengthening of areas covering senior management controls and organisation, plus Training and Competence. He said: “It is a testament to the quality of the original document that there have been no ‘root and branch’ changes.”
John Rice, managing director of RAMP, commented: “Our members have all signed-up to the new Code. We can approach the anniversary of ‘Mortgage Day’ with a robust and workable system which demonstrates that RAMP members are among the best served in terms of compliance support and supervision, and in the way they deal with their intermediaries and lenders.
“ My view remains that the total elimination of business risk is not realistic for any compliance function but effective monitoring will assist in reducing and managing risk.”
Wayne Smethurst, senior partner at The Finance Centre, a member of RAMP, commented: “We welcome the revision. Regulation is an ongoing process so all professional institutions should make a point of reviewing the structure of their codes.”
