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Senior conduct rules staff members should take reasonable steps to satisfy themselves, on reasonable grounds, that each area of the business for which they are SC1: You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively. SC2: 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 Acting with due skill, etc as a manager (rule 2) · (1). Failing to take reasonable steps to ensure that the business of the firm for which the manager has handbook.fca.org.uk. COCON 4/9. 4.2. Specific guidance on senior manager conduct rules. SC1: You must take reasonable steps to ensure that the. take reasonable steps to ensure that other persons acting on its behalf comply with CONC. Guidance on appointed representatives. CONC 1.2.3G Action against individuals under section 66 of the Act In some cases it may not be appropriate to take disciplinary measures against a firm for the actions of The FCA5 expects an approved person performing an accountable higher management function5 to take reasonable steps both to ensure their5 firm's compliance withActing with due skill, etc as a manager (rule 2) · (1). Failing to take reasonable steps to ensure that the business of the firm for which the manager has