Mrs Cheung complains in writing that her account executive, Mr Ng, placed trades without her instructions. Mr Ng's team head offers to investigate personally because he supervises Mr Ng. Under the Internal Control Guidelines, how should the firm handle the complaint?
Part V (Compliance) of the Internal Control Guidelines requires policies and procedures for the proper handling of client complaints, with prompt remedial action. The complaints procedures should be in writing and, where possible, complaints should be investigated by staff performing the compliance function who are not directly involved in the subject matter. The team head supervises Mr Ng and is directly involved. Firms are expected to investigate complaints themselves, not simply pass them to the SFC. Leaving the account executive to settle it privately defeats the control. Source: SFC Internal Control Guidelines (April 2003), Part V para 5 (as at October 2026).
Letting the line supervisor investigate. Independence from the subject matter is the point of the control.
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