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The FCA has published the results of a survey covering investment banks, brokers, and insurance firms which found an increase in misconduct allegations between 2021 and 2023. The most prevalent concerns were bullying and harassment (26%) and discrimination (23%). ‘Other’ concerns accounted for 41% of complaints, showing that there is still work to do in categorisation of these issues. The FCA has indicated that it expects all firms to review the results of the survey and take appropriate action.
How concerns were identified varied between firms, from internal systems used to monitor potential issues and more formal processes such as whistleblowing. This demonstrates that in the identification of misconduct, good practice requires a varied approach. The FCA has shared these findings to allow firms to benchmark their own reporting against their peers.
Following the survey, you should consider, at senior management level, whether the following areas of your business need improvements:
- your firm culture
- how you identify and manage risks
- the way in which you address non-financial misconduct on an ongoing basis.
To do this, you should set up and maintain processes that enable employees to speak up about non-financial misconduct and confirm how concerns or issues can be raised.
The FCA also reminded firms that:
- non-financial misconduct allegations must be taken seriously
- they must have effective systems in place to investigate any allegations
- allegations have to be reported to the FCA as required by the handbook
- individual fitness and corporate culture play significant contributory roles in the risk a firm and its staff pose to the FCA’s objectives
- a corporate culture that tolerates non-financial misconduct is unlikely to be one in which people feel able to speak up and challenge decisions, therefore raising questions about a firm’s decision making and risk management.
How can Bovill Newgate help you prevent and address non-financial misconduct?
Our specialist team can help implement policies to identify and respond to non-financial misconduct concerns.
We can assist in the creation, dissemination, and analysis of staff culture surveys and other tools to help your senior management respond to the FCA’s growing focus on non-financial misconduct.