The FCA’s new consultation paper on tackling non-financial misconduct (CP25/18) proposes that a wider scope of Code of Conduct rules will apply to non-banks for the first time.

This means that misconduct such as bullying, harassment and violence will become a matter of regulatory concern for such firms.

This paper comes just after the Upper Tribunal upheld former Barclay’s banker Jes Staley’s ban from financial services due to his links to Jeffrey Epstein.

CP25/18 once again highlights the importance of workplace culture in financial services firms. Firms must ensure that:

✔️ Their Fitness and Propriety assessments, recruitment practices, employment contracts, and attestations reflect wider scope of application of conduct rules.
✔️ They have adequate oversight on conduct issues, supported by a healthy work environment and effective whistleblowing measures.
✔️ HR and Senior Managers are aware of their notification requirements for non-financial misconduct.

At Pathlight we offer advisory and training services in governance and culture. Visit our website to see our team’s experience in this area and get in touch to ask about support: contact@pathlight.associates