| Link(s): | FCA will email firms directly |
Context
The FCA is writing to firms to request information related to incidents of non-financial misconduct within the organisation. The FCA is doing this as part of a sector-wide information gathering exercise, which requires all regulated Lloyd’s Managing Agents & London Market Insurers (including P&I Clubs) and Lloyd’s and London Market Insurance Intermediaries (and Managing General Agents) to complete the survey.
Firms that are sent the survey should note that completing the survey in full is mandatory.
Key points to note and next actions
In September 2023, the FCA began consulting on measures to improve diversity and inclusion in financial services and to strengthen expectations on how firms should manage allegations of non-financial misconduct. The FCA’s view is that non-financial misconduct is misconduct and not an additional principle. Non-financial misconduct includes individuals’ conduct for issues such as (but not limited to) bullying, sexual harassment, and discrimination whether in or outside the workplace.
The FCA has set forth guidelines requiring firms to establish efficient systems to recognise and manage risks associated with non-financial misconduct. If any accusations or evidence of non-financial misconduct come to light, the FCA expects the regulated firm to handle them seriously, have internal processes to investigate them promptly and impartially, and take appropriate measures when the allegations are confirmed.
The survey is an information gathering exercise to collect data on the volume and type of incidents of non-financial misconduct, the methods of detection and the actions taken to address these incidents within firms. The information collected will enable the FCA to build a clearer understanding of when and where non-financial misconduct occurs, which can then provide a baseline assessment of each sector.
Some firms may not have all this data readily accessible or in a structured format, which may require a manual search through HR files. If for any reason your firm is unable to provide all/part of the information required, then contact FCA immediately. The survey deadline is 5th March 2024.