Key takeaways:
1. Expanded Misconduct Scope: The FCA’s new non-financial misconduct (NFM) rules take effect on 1 September and extend to all SMCR firms, bringing bullying, harassment, violence, and non-discriminatory misconduct within scope under Conduct Rules and FIT, with severity assessed by duration, repetition, impact, seniority, and prior warnings.
2. Proactive Culture Accountability: With UK deregulation shifting accountability to firms, regulators expect proactive cultural risk management—HR, Compliance, Legal, and Risk must align on investigations, consequence management, and consistent judgments to avoid both cultural and systems-control failings.
3. Preventative Harassment Measures: Employers must demonstrate “all reasonable steps” to prevent harassment, including from third parties, by strengthening due diligence, contractual standards, escalation routes, and oversight—while recognising FCA focus remains on staff conduct where work-related.
4. Data-Driven Culture: Culture must be evidenced with data, not slogans: build dashboards tracking breaches (e.g., expenses, PA dealing), speak-up trends, conduct cases by grade/team, and training completion, and use this MI for targeted interventions and governance reviews.
5. Immediate Conduct Actions: Implement practical actions now: deliver scenario-based NFM training before September, establish a cross-functional conduct committee, define clear escalation and whistleblowing channels (including to NEDs and FCA), apply transparent consequence frameworks, and ensure leaders “walk the talk” to set and reinforce expected behaviours.
Who It’s For
Compliance, Risk, HR, SMF holders, senior leaders, and anyone responsible for conduct, culture, or people risk within UK‑regulated firms.
Speakers:
Katharine Leaman
Advisory Board Member - Skillcast
Katharine has worked in financial services for over thirty years in insurance claims, giving investment advice, regulation, and banking compliance. Katharine has been European Head of Regulatory Compliance at Standard Chartered Bank and spent over a decade at the UK's regulator, the FSA (now FCA in senior policy and supervision roles.Katharine’s expertise is in technical areas of the rules such as Market Abuse, CASS, SMCR, and Outsourcing. As well as issues that have a broader regulatory focus such as market conduct, non-financial misconduct, conduct risk, operational resilience, and consumer duty.
At Leaman Crellin Katharine regularly provides compliance advice to the C-suite as well as to front-office trading and salespeople around the world.
Scott Morris
Advisory Board Member - Skillcast
Scott has over 40 years' banking and Compliance leadership experience, acquired across a number of global banking organisations, as well as a regulator and professional body. He has extensive experience in creating and directing large teams across different regions. He has performed senior roles in Compliance, Anti-Financial Crime and COO at Board, Senior Advisor, Managing Director and Executive Vice President levels.