The person who signs

Where a signature is required

The Charter requires a human decision between any system and any action affecting a client, an employee, a counterparty, a position or a regulatory filing. That principle becomes operational through a schedule of sign-off points maintained by the Chief Operating Officer and approved by the Executive Committee each year.

The schedule states who signs, at what threshold, on what evidence and within what time. It covers automated and manual work alike, because the risk of an unconsidered decision does not depend on whether a machine proposed it. Sixty-one sign-off points were in force at 30 June 2026, of which nineteen sit in the Quantitative Strategies division.

• A dealer named on the desk rota releases each basket of orders, and the release is timestamped.
• Orders above US$2 million require a second authoriser recorded before release.
• Unlisted valuations above US$10 million are adopted by the Risk & Valuation Committee.
• Every screening match is read and concluded by a compliance officer, whatever the score.
• Every client-facing recommendation is approved by a person who can be asked to explain it.
• Every decision about an employee is taken by a person, with no system assistance at all.

What makes a signature real

A signature means something when four conditions hold. The approver can see the evidence. The approver has enough time to read it. The approver understands the work well enough to disagree with it. The approver has the authority to decide differently without seeking permission from the person whose proposal it is.

The third and fourth conditions are the ones that fail quietly. An approver who does not understand a recommendation will approve it, and an approver whose rejections are routinely overturned will stop rejecting. The group tests both by reading the record, not by asking people how they feel about the work they do.

Time is protected by a cap. A decision-support queue is limited to 25 recommendations for one approver in a day. Where the volume exceeds the cap, the queue waits or a second approver is rostered. A queue never clears itself by lowering what an approval requires.

Measuring whether oversight happens

Across the six decision-support uses, approvers amended or rejected 18 per cent of recommendations in the twelve months to 30 June 2026. The rate ranged from 9 per cent on a screening queue to 31 per cent on a deal-ranking tool. The Ethics & Technology Council reads the range as closely as it reads the average.

A use whose recommendations are amended in fewer than 5 per cent of cases across two consecutive quarters is re-examined. One was re-examined in the year to 30 June 2026. The examination found the tool proposing the only lawful outcome available, and its scope was narrowed so that the approver was deciding something.

The platform records the time between a recommendation being opened and a decision being entered. Decisions taken faster than the evidence can be read are flagged for the accountable executive. Forty-one were flagged in the year: thirty-four had a sound explanation and seven led to retraining on the desk concerned.

Disagreement is part of the design

An approver who rejects a recommendation records the reason, and the reason enters the monitoring record for the system. Rejections are evidence about the model rather than friction in a process. A pattern of rejections for the same cause is a finding for the validation unit and is graded like any other.

A rejection may be reversed only by the accountable executive, in writing, with reasons that go to the Ethics & Technology Council. Two reversals were recorded in the twelve months to 30 June 2026. Neither concerned a client-facing decision, and both were reported at the following quarterly sitting.

No approver is measured on the rate at which they agree with a system, and no remuneration in the group depends on the throughput of a queue. The Remuneration Committee tests this when it reviews the conduct objectives of the divisions that run decision-support systems.

When a person is not enough

Some work cannot be overseen at the volume proposed. The group then declines to automate it rather than accept a signature that means nothing. The test is stated plainly in the review template: if no approver could read the evidence in the time the process allows, the process is not approved.

One of the two proposals declined by the Ethics office in the twelve months to 30 June 2026 was an automated limit-setting tool for Commercial Finance. The volume implied 300 approvals in a day for one credit officer. The division returned with a higher referral threshold and a narrower scope, and that proposal was cleared with conditions.