We help financial institutions (“FIs”) satisfy the outcomes (the “Outcomes”) set out in the Monetary Authority of Singapore’s (the “MAS”) Guidelines on Individual Accountability and Conduct (the “IAC Guidelines”) and the Information Paper on Culture and Conduct Practices of Financial Institutions (the “Information Paper”).

As part of achieving the Outcomes, a FI is expected to:

Assess whether it has achieved the Outcomes

We conduct independent assessments or assist a FI with its own assessments with respect to the IAC Guidelines and the Information Paper, including preparing a scorecard rating the FI’s success in achieving the Outcomes.

Adopt appropriate measures to achieve the Outcomes

We advise FIs on how to achieve the Outcomes in a way that adds value to their business, including adapting the MAS’ specific guidance to each FI’s unique business model, service offering and complexity. We also help FIs prepare their whistleblowing processes and offer Outsourced Ombudsman Services.

Review the effectiveness and adequacy of measures taken to achieve the Outcomes

We audit the effectiveness of the FI’s internal processes, including identifying gaps between observed behaviours and the FI’s desired standards of conduct.


While the process described above can be done by an FI in-house, we believe we offer a compelling solution for the following reasons:
  • Our senior team includes personnel who have been employed as senior managers of MAS-regulated FIs, including roles as General Counsel, COO and CEO. We believe this experience gives us insight and perspective that many other consulting firms do not have.  In particular, we emphasize the need to have processes that a FI can understand and follow.
  • The Outcomes include an expectation for FIs to have clear and transparent management structures and reporting relationships. We understand the potential sensitivities around reporting lines and the allocation of responsibilities among senior management.  We believe independent parties such as Holland & Marie are likely to be more objective in their views of governance structures and other issues relating to culture and conduct compared to in-house personnel.
  • As an independent consultant, we will assist on these projects for multiple clients which will assist in our understanding of best practices and solutions to governance issues across the financial services industry.



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