Non-Financial Misconduct: What are the key milestones for firms
The FCA’s new rule and guidance on non-financial misconduct (NFM) take effect on 1st September. With the implementation date fast approaching, firms need to ensure that they are on track to meet the FCA’s expectations and have made the necessary changes to their policies and procedures.
Here are six steps outlining the key milestones for firms.
- Confirm senior management accountability
Ensuring clear senior management accountability for the firm’s approach to NFM is an important first step.
- Establish a collaborative approach
In all but the smallest of firms, a robust approach to NFM will require input from, and collaboration between, the Compliance and HR functions, in addition to senior management engagement and oversight.
- Understand the new expectations
Identifying and addressing NFM can be complex, since it intersects with multiple aspects of the regulatory framework. As a result, firms need to ensure they have a comprehensive understanding of the new FCA rule and guidance.
- Review policies and procedures
Firms will need to review, and update, all of the relevant internal policies and procedures, to ensure they are aligned with the new NFM rule and guidance.
- Communication and training
NFM can be a nuanced and sensitive topic. Firms will need to communicate the new regulatory expectations clearly, while avoiding any mixed messaging. Training needs to be relevant and reflect real-life scenarios.
- Reinforce a positive culture
Dealing robustly with specific misconduct is vital, but senior managers also need to consider how they can reinforce a positive working culture.
Our range of non-financial misconduct training offerings are designed to help firms embed an understanding of non-financial misconduct and include: eLearning, instructor-led training and briefings.
