Chapter 8 - Financial Services Regulation and Professional Integrity

FS Regulation, Fin Crime, Market Abuse, Data Protection, Complaints and Compensation, Integrity and Ethics in Professional Practice

Why is financial regulation important?

Effective financial markets are an essential part of developed and developing economies. They fuel economic development and aid wealth creation. As a result, confidence and trust in these markets is vital; loss of confidence and trust can result in an adverse impact on customers and the economy.

Why does financial regulation exist?

The risk of monetary loss that can arise from dealing in all types of financial transactions has meant that financial markets have always been subject to the need for rules and codes of conduct to protect investors and the public.

Why were regulations implemented as markets developed?

• There grew a need for market participants to be able to set rules so that there were agreed standards of behaviour, and to provide a mechanism so that disputes could be settled readily. This need developed into what is known as self-regulation, when, for example, a stock exchange, as well as providing a secondary market for shares, would also set rules for its members and police their implementation.

• As markets, financial institutions and financial services developed, and the potential impact that they could have on both the economy and society grew, self-regulation became increasingly untenable, and most countries moved to a statutory approach and established their own regulatory bodies.

• This required governments to become involved in the regulation of financial markets. The role of the government is to establish the legal framework within which financial markets operate and how supervision of markets and participants will take place.

How were regulatory bodies established?

• By governments or other bodies sanctioned by governments to oversee the functioning and fairness of financial markets and the firms that engage in financial activity.

• The government delegates the responsibility for setting rules and supervising financial market activity to these regulatory bodies and then oversees their effectiveness.

What is the key characteristic of regulating financial markets?

Setting standards, rules and codes of conduct to define standards of acceptable conduct by firms and individuals.

What are the main purposes and aims of regulation in all markets globally?

• Maintain and promote the fairness, efficiency, competitiveness, transparency and orderliness of markets

• Promote understanding by the public of the operation and functioning of the financial services sector

• Provide protection for members of the public investing in or holding financial products

• Minimise crime and misconduct in the sector

• Reduce systemic risks

• Assist in maintaining the market’s financial stability by taking appropriate steps

What is regulation?

• A combination of rules and standards generally covering matters such as observing proper standards of market conduct, managing conflicts of interest, fair treatment of customers, and ensuring the suitability of customer advice.

• Objectives of regulation are typically achieved through a combination of law, regulation, enforcement and compensation

What are the objectives and benefits of regulation?

• Increasing the confidence and trust in financial markets, systems and products.

• Establishing an environment to encourage economic development and wealth creation.

• Reducing the risk of market and system failures, including their economic consequences.

• Enhancing consumer protection by giving them the reassurance they need to save and invest.

• Reducing financial crime by ensuring that financial systems cannot easily be exploited.

What makes up UK financial regulation?

From 1st Dec 2001, Financial Services and Markets Act 2000 (FSMA) came into force. Key parties involved are the Financial Policy Committee (FPC), the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA).

What is the Financial Policy Committee (FPC)?

• Established by BoE, with responsibility for ‘macro-prudential’ regulation, or regulation of the stability and resilience of the financial system as a whole.

• The FPC has the power to make recommendations on a comply-or-explain basis to the PRA and the FCA; that is, to comply with the recommendation as soon as practicable, or explain to the FPC, in writing and in public, why they have not done so.

What is the Prudential Regulation Authority (PRA)?

• Part of BoE and is responsible for prudential regulation of financial firms that manage significant risks on their balance sheets – in other words, it is responsible for the regulation and supervision of ‘significant’ individual firms including all deposit-taking institutions, insurers and other prudentially significant investment firms. The latter include the supervision of central counterparties and securities settlement systems, and this responsibility sits alongside the BoE’s existing responsibilities for overseeing recognised payment systems.

• The PRA has a primary objective of enhancing financial stability by promoting the safety and soundness of PRA-authorised firms in a way which minimises the disruption caused by any firms which do fail. In fulfilling its objective, it will take an ‘intrusive’ approach to regulation and supervision.

• The PRA is responsible for prudential supervision of those firms, but their day-to-day conduct is supervised by the FCA. As a result, they are referred to as dual-regulated firms.

What is the Financial Conduct Authority (FCA)?

• Is responsible for the conduct of all firms and the prudential regulation of firms not supervised by the PRA.

• The FCA focuses on the day-to-day regulation of all firms in retail and wholesale financial markets, as well as the infrastructure that supports these markets.

• It has responsibility for the prudential supervision of firms that do not fall under the PRA’s scope.

• HM Treasury is responsible for oversight of how the FCA conducts it’s operations.

What is the FCA responsible for?

• Regulating standards of conduct in retail and wholesale markets

• Supervising trading infrastructures that support those markets

• The prudential supervision of firms that are not PRA-regulated

• Acting as the competent authority for listing and maintaining the Official List (of listed companies) under its primary markets function

What are the FCA’s 3 statutory objectives?

• Protect consumers

• Enhance the integrity of the UK financial system

• Help maintain competitive markets and promote effective competition in the interests of consumers

What is authorisation?

• FSMA makes it an offence for a firm to provide financial services in the UK without being authorised to do so. There are certain exemptions from this requirement, for example for the BoE.

• Authorisation is granted by the relevant regulator. Following the establishment of the FCA and the PRA on 1 April 2013, solo-regulated firms need to be authorised by the FCA.

• However, other firms, known as dual-regulated firms, are regulated by the FCA for the way they conduct their business and by the PRA for prudential requirements and, therefore, require authorisation from both.

How do the regulators authorise a firm?

• The regulator(s) looks at each applicant to assess whether the firm is fit and proper and meets certain threshold conditions.

• Before granting authorisation, the regulator considers the company’s management, its financial strength and the calibre of its staff.

• The latter is particularly important in certain key roles, which the regulator refers to as senior management functions.

Why are only fit and proper firms authorised?

By only allowing fit and proper firms to be involved in the financial services sector, the regulator begins to satisfy the statutory objectives of enhancing financial stability, enhancing the integrity of the financial system and protecting consumers.

What are the PRA’s 8 Fundamental Rules and the FCA’s 12 Principles for Business?

Apply to all firms, setting out fundamental obligations of financial services firms and it is vital that boards and senior management understand these and the more detailed rules, and establish within their firms a culture that supports adherence to the spirit and the letter of the requirements.

What are the key themes of the 8 Fundamental Rules and 12 Principles for Business?

• General overriding theme of ‘fair play’.

• Coupled with a recognition that there is often an information imbalance between the firm and its customers (since the firm is usually more expert in its products and services than its customers are).

  • This theme is reinforced through the FCA’s fair treatment of customers (FTOC) initiative and the Consumer Duty (below) that sets higher and clearer standards of consumer protection.

What are the 6 consumer outcomes the FCA believes FTOC should do for consumers?

1. Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture

2. Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly

3. Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale

4. Where consumers receive advice, the advice is suitable and takes account of their circumstances

5. Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and as they have been led to expect

6. Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint

What is Consumer Duty?

• Finalised in 2022, frequently described as TCF.

• Designed designed to set a higher standard than Principle 6 of the Principles for Businesses. The concept is about focusing on consumer outcomes rather than processes.

• New principle added, 12: ‘a firm must act to deliver good outcomes for retail clients’.

What does the new principles of business introduced by Consumer Duty detail?

• You must act in good faith towards retail customers. (Acting in good faith is a standard of conduct characterised by honesty, fair and open dealing and acting consistently with the reasonable expectations of retail customers).

• You must avoid causing foreseeable harm to retail customers.

• You must enable and support retail customers to pursue their financial objectives.

What is money laundering?

The process of turning money that is derived from criminal activities – dirty money – into money which appears to have been legitimately acquired and which can, therefore, be more easily invested and spent.

What forms can money laundering take?

• Turning money acquired through criminal activity into clean money

• Handling the proceeds of crimes such as theft, fraud and tax evasion

• Handling stolen goods

• Being directly involved with, or facilitating, the laundering of any criminal or terrorist property, and

• Criminals investing the proceeds of their crimes in the whole range of financial products.

What is placement in money laundering?

The first stage and typically involves placing the criminally derived cash into some form of bank or building society account.

What is layering in money laundering?

The second stage and involves moving the money around in order to make it difficult for the authorities to link the placed funds with the ultimate beneficiary of the money. Disguising the original source of the funds might involve buying and selling foreign currencies, shares or bonds.

What is integration in money laundering?

The third and final stage, the layering has been successful and the ultimate beneficiary appears to be holding legitimate funds (‘clean’ money rather than ‘dirty’ money). The money is integrated back into the financial system and dealt with as if it were legitimate.

What is terrorist financing?

• There can be considerable similarities between the movement of terrorist funds and the laundering of criminal property.

• Because terrorist groups can have links with other criminal activities, there is inevitably some overlap between anti-money laundering (AML) provisions and the rules designed to prevent the financing of terrorist acts.

• Terrorist organisations require significant funding, and will employ modern techniques to manage the funds and transfer them between jurisdictions.

What are the differences between ML and TF?

• Often, only quite small sums of money are required to commit terrorist acts, making identification and tracking more difficult.

• If legitimate funds are used to fund terrorist activities, it is difficult to identify when the funds become terrorist funds.

What is identity fraud?

The use of a misappropriated identity in criminal activity, to obtain goods or services by deception. This usually involves the use of stolen or forged identity documents such as a passport or driving licence.

What is identity theft?

Also known as impersonation fraud. Is the misappropriation of the identity (such as the name, date of birth, current address or previous addresses) of another person, without their knowledge or consent. These identity details are then used to obtain goods and services in that person’s name.

Why are individual’s identity so important?

• A person’s identity (and their ability to prove it) is central to almost all commercial activity.

• Organisations need to verify that the person applying for credit or investment services is who they say they are and lives where they claim to live.

• The procedures used by organisations to check the information supplied by customers help to detect and prevent most identity fraud.

• However, some fraudulent applications are accepted due to the sophisticated techniques used by the fraudsters.

How do fraudsters use bank accounts to commit identity fraud or theft?

When opening accounts in banks and other financial organisations, criminals will use data from legitimate persons to provide information for applications and other purposes which, when checked against normal credit reference, postal and other databases, will seem to confirm the genuine nature of the application.

What are breeder documents?

• They allow those who possess them to apply for or obtain other documentation and thus build up a profile or ‘history’ that can satisfy basic customer due diligence (CDD) processes (processes to verify the identity of a client and verify that they are indeed who they claim to be).

• The information may either be used quickly before the source of the data is alerted or used, for example, as a facilitator for other identities so as not to alert the source.

What is advanced cybercrime/high-tech crime?

Sophisticated attacks against computer hardware and software.

What is cyber-enabled crime?

Many ‘traditional’ crimes have taken a new turn with the advent of the Internet, such as crimes against children, financial crimes and even terrorism.

How is cybercrime committed?

• In the past, cybercrime was committed mainly by individuals or small groups.

• Today, the authorities are seeing highly complex cybercriminal networks bringing together individuals from across the globe in real time to commit crimes on an unprecedented scale.

• New trends in cybercrime are emerging all the time, with estimated costs to the global economy running to billions of dollars.

What are examples of cybercrime?

Among the various forms of cybercrime are malware attacks, encompassing viruses, worms, ransomware and spyware, designed to disrupt, damage, or gain unauthorised access to computer systems. Cybersecurity, therefore, becomes important to consider.

What is phishing?

Phishing involves the deceptive use of emails, messages or websites to trick individuals into disclosing sensitive information. Identity theft sees cybercriminals stealing personal data to impersonate individuals for financial fraud or other criminal purposes.

What are Distributed Denial of Service (DDoS)?

Distributed Denial of Service (DDoS) attacks overload targets with traffic, rendering networks or websites temporarily or permanently unavailable.

What is cyber espionage?

Cyber espionage involves state-sponsored or corporate-driven efforts to steal sensitive information, intellectual property or trade secrets for political, economic or competitive advantage

What is cyber security?

• A proactive approach aimed at safeguarding digital systems, networks and data from cyber threats.

• This comprehensive strategy involves diverse measures, technologies, and best practices to prevent unauthorised access, mitigate risks, and respond efficiently to incidents.

• For example, network security employs tools such as firewalls, intrusion detection/prevention systems, and secure protocols to defend against unauthorised access and cyber attacks.

• Endpoint security focuses on securing individual devices through measures like anti-virus software, encryption and secure configurations.

• Also, access control and authentication enforce strict controls and identity management to ensure only authorised individuals access systems and data.

• Other forms of cybersecurity include encryption technologies used to protect sensitive data during transit and at rest, rendering it unreadable to unauthorised users.

What is bribery?

The Bribery Act 2010 came into force in July 2011 as part of a complete reform of corruption law to provide a modern and comprehensive scheme of bribery offences that enable courts and prosecutors to respond more effectively to bribery at home or abroad.

Bribery is a criminal offence and penalties include a maximum of ten years’ imprisonment, unlimited fines, confiscation of proceeds, debarment from public sector contracts and director disqualification.

What are the key provisions of The Bribery Act?

• Two general offences are created covering the offering, promising or giving of an advantage, and the requesting, agreeing to receive or accepting of an advantage.

• There is a discrete offence of bribery of a foreign public official to obtain or retain business or an advantage in the conduct of business.

• A new offence is created, of failure by a commercial organisation to prevent a bribe being paid for or on its behalf.

What is failing to prevent bribery?

• Does not require corrupt intent.

• This will make it easier for the Serious Fraud Office (SFO) to prosecute companies when bribery has occurred.

• The only defence available to a commercial organisation charged with the corporate offence will be for the organisation to show that it had adequate procedures in place to prevent an act of bribery being committed in connection with its business.

• Employees need to be aware that although bribery may be seen as ‘normal’ in certain foreign countries, it is still an offence under UK law.

What is insider dealing?

When directors or employees of a listed company buy or sell shares in that company, there is a possibility that they may be committing a criminal act.

What is an example of insider dealing?

For example, a director may be buying shares in the knowledge that the company’s last six months of trade was better than the market expected. The director has the benefit of this information because they are ‘inside’ the company. Under the Criminal Justice Act 1993, this would be a criminal offence punishable by a fine and/or a jail term.

Are securities part of insider dealing?

The instruments covered by the insider dealing legislation in the Criminal Justice Act are described as ‘securities’. For the purposes of this piece of law, securities are:

• Shares

• Bonds (includes government bonds and others issued by a company or a public sector body)

• Warrants

• Depositary receipts

• Options (to acquire or dispose of securities)

• Futures (to acquire or dispose of securities), and

• Contracts for difference (based on securities, interest rates or share indices).

Does not embrace commodities or derivatives on commodities (such as options and futures on agricultural products, metals or energy products), or units/shares in open-ended collective investment schemes (such as OEICs, unit trusts and SICAVs).

How can you be found guilty of insider dealing?

The Criminal Justice Act 1993 defines who is deemed to be an insider, what is deemed to be inside information and the situations that give rise to the offence.

What is inside information?

Information that relates to particular securities or a particular issuer of securities (and not to securities or securities issuers generally) and which:

• Is specific or precise

• Has not been made public, and

• If it were made public, would be likely to have a significant effect on the price of the securities.

This is generally referred to as unpublished price-sensitive information and the securities are referred to as price-affected securities.

When does information become public?

• When it is published.

• For example, a UK-listed company publishing price-sensitive news through the LSE’s Regulatory News Service.

• Information can be treated as public even though it may be acquired only by persons exercising diligence or expertise (for example, by careful analysis of published accounts, or by scouring a library).

Who can be guilty of having price-sensitive information?

If they know that it is inside information from an inside source. The person may have:

• Gained the information through being a director, employee or shareholder of an issuer of securities

• Gained access to the information by virtue of their employment, office or profession (for example, the auditors to the company), or

• Sourced the information from (1) or (2), either directly or indirectly.

When does a person commit the offence of insider dealing?

• When an insider acquires or disposes of price-affected securities while in possession of unpublished price-sensitive information.

• It is also an offence to encourage another person to deal in price-affected securities, or to disclose the information to another person (other than in the proper performance of employment).

• The acquisition or disposal must occur on a regulated market or through a professional intermediary.

What other forms of market abuse can be committed?

• Can take many forms and may arise in circumstances where financial investors have been unreasonably disadvantaged, directly or indirectly, by others who behave unlawfully.

• In addition to insider dealing, certain types of behaviour, such as those relating to public disclosure and market manipulation, can amount to market abuse.

Is market abuse a civil or criminal offence?

• Market abuse is a civil offence and can be subject to fines and sanctions by the regulator. Insider dealing and market manipulation may also be a criminal offence, and offences are prosecuted in the courts.

• The FCA enforces the UK Market Abuse Regulation (UK MAR) which sets out the rules and prohibitions on market abuse. Market abuse can include insider dealing, unlawful disclosure of inside information and market manipulation. These behaviours are specifically prohibited, subject to certain exemptions.

What is Data Protection?

Whenever personal data is processed, collected, recorded, stored or disposed of, it must be done within the terms of the data protection regulations. These and other information rights laws set out an individual’s rights regarding their personal information, how organisations should carry out direct marketing and how an individual can access information from public authorities.

What do firms need to do to comply with the Data Protection Act?

• Notifying the Information Commissioner’s Office (ICO) that they are processing information

• Processing personal information in accordance with the data protection principles, and

• Answering subject-access requests received from individuals.

How is personal data required to be stored?

• Processed lawfully, fairly and in a transparent manner in relation to individuals

• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes

• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed

• Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay

• Kept in a form which permits identification of data subjects for no longer than it is necessary for the purposes for which the personal data is processed, and

• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

How is security linked with the Data Protections Act?

The regulations require personal data to be processed in a manner that ensures its security. This includes protection against unauthorised or unlawful processing, and against accidental loss, destruction or damage. It also requires that appropriate technical or organisational measures are used.

If a firm outsources, there are data protection implications. Firms must assess that the organisation can carry out the work in a secure way, check that they are doing so and take proper security measures. The firm must also have a written contract with the organisation, which lays down how it can use and disclose the information entrusted to it.

What if a breach of personal data occurs?

The rules place a duty on all organisations to report certain types of data breach to the relevant supervisory authority. In some cases, organisations will also have to report certain types of data breach to the individuals affected where it is likely to result in a high risk to the rights and freedoms of individuals.

How must authorised firms deal with complaints?

• FCA requires authorised firms to deal with complaints from eligible complainants promptly and fairly.

• Eligible complainants are, broadly, individuals and small businesses.

• The FCA requires firms to have appropriate written procedures for handling expressions of dissatisfaction from eligible complainants.

• However, the firm is able to apply these procedures to other complainants as well, if it so chooses.

• These procedures should be followed regardless of whether the complaint is oral or written and whether the complaint is justified or not, as long as it relates to the firm’s provision of or failure to provide a financial service.

How must complaints be handled internally?

• The internal complaints-handling procedures should provide for the receiving of complaints, acknowledgement of complaints in a timely manner, responding to those complaints, appropriately investigating the complaints and notifying the complainants of their right to go to the Financial Ombudsman Service (FOS) when relevant.

• Among other requirements, the complaints-handling procedures require the firm to issue its final response to the complainant within eight weeks of the date of the original complaint and the complainant must be notified of their right to refer their complaint to the FOS if they are dissatisfied with the firm’s response.

• The internal complaints-handling procedures must make provision for the complaints to be investigated by an employee of sufficient competence who was not directly involved in the matter that is the subject of the complaint.

• The person charged with responding to the complaints must have the authority to settle the complaint, including offering redress if appropriate, or should have access to someone with the necessary authority.

How should complaints be responded to?

• The responses should adequately address the subject matter of the complaint and, when a complaint is upheld, offer appropriate redress.

• If the firm decides that redress is appropriate, the firm must provide the complainant with fair compensation for any acts or omissions for which it was responsible and comply with any offer of redress the complainant accepts.

• Any redress for financial loss should include consequential or prospective loss, in addition to actual loss.

Who are the Financial Ombudsman Service (FOS)?

• The UK dispute resolution scheme.

• It is designed to resolve complaints about financial services firms quickly and with minimum formality; it is funded by industry contributions through levies and case fees.

• Eligible complainants are able to refer complaints to the FOS if they are not satisfied with the response of a financial services firm.

How superior are the FOS in decision making?

• The decision of the FOS is binding on firms, although not binding on the person making the complaint.

• Under the legislation that established the FOS, financial services businesses are required to cooperate with the ombudsman service and the ombudsman decision is final and binding on the business.

• The Financial Ombudsman can require the firm to pay over money as a result of a complaint. This money award against the firm will be of such an amount that the Ombudsman considers to be fair compensation; however, the sum cannot exceed £430,000.

• Where the decision is made to make a money award, the Ombudsman can award compensation for financial loss, pain and suffering, damage to reputation and distress or inconvenience.

What is the Financial Services Compensation Scheme (FSCS)?

• Established to pay compensation or arrange continuing cover to eligible claimants in the event of a default by an authorised person or firm.

• Default is, typically, the firm suffering insolvency. It is funded by compulsory financial services sector contributions.

• Eligible claimants are, broadly speaking, the less knowledgeable clients of the firm, such as individuals and small organisations. These less knowledgeable clients are generally the firm’s ‘private customers’ and exclude the more knowledgeable ‘professional customers’.

• The scheme is similar to an insurance policy that is paid for by all authorised firms and provides protection to some clients in the event of a firm collapsing. The claims could come from money on deposit with a bank, or claims in connection with investment business, such as the collapse of a fund manager or stockbroker.

• The maximum level of compensation for claims against firms declared in default is 100% of the first £85,000 per person per firm for investments, and £85,000 for bank deposits. There are different rules for other financial products and services.

How is ethics involved in the financial services sector?

• If we accept that ethics is about both thinking and doing the right thing, then we should seek first of all to instil the type of thinking which causes us, as a matter of habit, to reflect upon what we are considering doing, or what we may be asked to do, before we carry it out.

• There will often be situations, particularly at work, when we are faced with a decision where it is not immediately obvious whether what we are being asked to do is actually right.

• A simple checklist will help to decide. Is it:

  • Open – is everyone whom your action or decision affects fully aware of it, or will they be made aware of it?

  • Honest – does it comply with applicable law or regulation?

  • Transparent – is it clear to all parties involved what is happening/will happen?

  • Fair – is the transaction or decision fair to everyone involved in it or affected by it?

• A simple and often quoted test is whether you would be happy to appear in the media in connection with, or in justification of, the transaction or decision.

What obligation do senior managers of financial service firms have?

• To prevent regulatory breaches, but a senior manager will only be guilty of misconduct if the FCA is able to demonstrate (ie, proves and it is accepted) that the senior manager failed to take reasonable steps to prevent a regulatory breach from occurring.

• Although the burden of proof rests with the FCA, senior managers are expected to be able to provide the FCA with evidence of any reasonable steps they took when made aware of the breach.

What are the FCA Conduct Rules?

A set of Conduct Rules apply to all relevant employees based in the UK, or who deal with customers in the UK. This means that the Conduct Rules cover all employees who are in a position to affect the FCA’s objectives. The Conduct Rules are, in effect, designed to raise overall conduct standards in the industry and are presented below:

• Rule 1: You must act with integrity.

• Rule 2: You must act with due skill, care and diligence.

• Rule 3: You must be open and cooperative with the FCA, the PRA and other regulators.

• Rule 4: You must pay due regard to the interests of customers and treat them fairly.

• Rule 5: You must observe proper standards of market conduct.

What additional rules must senior managers adhere to?

• You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively.

• You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system.

• You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively.

• You must disclose appropriately any information of which the FCA or PRA would reasonably expect notice.

What are the 8 Principles of CISI Code of Conduct?

• Personal Accountability

• Client Focus

• Conflict of Interest

• Respect for Market Participants

• Professional Development

• Aware of Capabilities

• Respect Others and the Environment

• Speak Up & Listen Up