Framework

Governance & Oversight

Preserving independence, integrity, and strict boundaries between administration and legal enforcement.

Objectives

Governance Mandate

This governance framework defines the operational boundaries and oversight structure under which SEPM operates. The primary objectives are to:

  • Preserve the independence of appointed legal practitioners and courts.
  • Prevent conflicts of interest in enforcement-related matters.
  • Ensure SEPM functions strictly as an administrator, not a debt collector or legal service provider.
  • Maintain transparency, accountability, and auditability in all coordination processes.
Structure

Separation of Roles

SEPM operates independently from appointed solicitors, law firms, courts, and management bodies.

Programme Administration

Managed by SEPM

Responsible for the administrative coordination of the programme. This includes:

  • Onboarding and eligibility verification.
  • Workflow coordination and data readiness checks.
  • Managing non-legal compliance engagement.
  • Record keeping and process management.

Legal Enforcement

Managed by Independent Solicitors

Responsible for all legal actions and advice. This includes:

  • Issuing legal demand letters.
  • Conducting court proceedings and litigation.
  • Providing professional legal advice.
  • Executing enforcement actions pursuant to court orders.
Boundaries

Operational Integrity

No Fee Sharing

To ensure zero conflict of interest, SEPM does not share legal fees with solicitors. There are no success fees or recovery-based remuneration models that link administrative income to legal outcomes.

Decision-Making Boundaries

SEPM does not determine legal liability, decide who should be sued, approve legal strategies, or instruct solicitors on litigation tactics. These are the sole purview of the appointed solicitors.

Data Handling

SEPM handles information strictly for programme administration. We do not conduct private investigations and rely on information provided by JMBs/MCs in accordance with data protection principles.

Regulatory Positioning

SEPM is a private enforcement administration programme. It is not a statutory body and does not exercise statutory powers.