Non-Financial Misconduct: Ongoing Risk & Governance Scrutiny

In this episode of DC Talks, Employment Partner Emma O'Connor and Regulatory Partner Benedicte Perowne explore the FCA's renewed focus on non-financial misconduct (NFM) and what it means for regulated firms.

The discussion examines the FCA's new rules, effective from 1 September 2026, which reinforce the regulator's view that behaviours such as bullying, harassment, discrimination, sexual misconduct and intimidation can be relevant when assessing an individual's integrity, fitness and propriety. Crucially, the FCA sees workplace culture as closely linked to regulatory outcomes, making NFM a governance and risk management issue rather than simply an HR concern. 

The episode highlights the practical steps firms should be taking now, including reviewing policies and procedures, strengthening governance frameworks, ensuring robust record-keeping, providing targeted training, and creating clear collaboration between HR, compliance and legal teams. The speakers also discuss the FCA's likely focus on supervisory scrutiny as firms embed the new requirements into day-to-day operations.

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