NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES REGULATION - WHERE DO WE STAND? - DECEMBER 2020
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NON-FINANCIAL
MISCONDUCT IN
FINANCIAL SERVICES
REGULATION – WHERE
DO WE STAND?
DECEMBER 2020
NON-FINANCIAL MISCONDUCT IN
FINANCIAL SERVICES REGULATION –
WHERE DO WE STAND?
Three new decisions from the Financial Conduct Authority (FCA)
show renewed focus on “non-financial misconduct,” a term
covering issues such as sexual misconduct and bullying, but a
recent High Court finding against another regulator, the
Solicitors Regulation Authority (SRA), potentially undermines the
FCA approach. This briefing explores, amongst other issues:
when non-financial misconduct may amount to a breach of the
Conduct Rules; how non-financial misconduct should be
assessed; what the regulatory expectations on firms are to
conduct investigations and notify the regulator; how the FCA
views culture and psychological safety and links these with its
objectives; and will there be a shift in stance as the High Court
has recently cautioned regulators against being “dogmatic.”
What is the FCA’s stance? More recently, in November 2020,
Jonathan Davidson, Executive Director of
In September 2018, the Women and
Supervision (Retail and Authorisations)
The FCA expects high Equalities Committee published its report
reiterated that the FCA has increased its
standards of character, on sexual harassment in the workplace.
focus on non-financial misconduct,
In response, Megan Butler, then the FCA’s
probity and fitness and drawing attention to the prohibition of
Executive Director of Supervision
properness from those who (Investment, Wholesale and Specialists
three individuals following convictions for
sexual offences. In announcing those
operate in the financial Division) wrote a well-publicised letter
prohibitions Mark Steward, Executive
services industry, and will explaining the three main bases on which
Director of Enforcement and Market
the FCA sees sexual misconduct as
take action to ensure these Oversight, said:
falling within the scope of the financial
standards are maintained. services regulatory framework: through
“The FCA expects high standards of
supervision of workplace culture; through
character, probity and fitness and
fitness and propriety assessments; and,
properness from those who operate in
potentially, through enforcement of the
the financial services industry, and will
Conduct Rules themselves. The letter
take action to ensure these standards
suggested how the FCA draws a link
—MARK STEWARD, are maintained.”
between non-financial misconduct,
Executive Director,
culture, psychological safety and the
Enforcement and Market Oversight At the same time, however, in SRA v
FCA’s statutory objectives.
Beckwith [2020] EWHC 3231 (Admin) the
High Court has sounded a note of
In a speech shortly afterwards, in
caution to all professional services
December 2018, Christopher Woolard,
regulators against being “dogmatic” and
then Executive Director of Strategy and
treating popular outcry as “proof that a
Competition, reiterated that message to
particular set of events gives rise to any
firms with the aphorism “non-financial
matter falling within a regulator’s remit.”
misconduct is misconduct, plain
and simple”.
2 CLIFFORD CHANCE
NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES
REGULATION – WHERE DO WE STAND?
Conduct Rules examples of dishonest or
misleading conduct in the course
Firms investigating allegations of non-
of providing financial services,
financial misconduct will typically
including misleading clients,
need to consider whether the
misleading the regulators and
allegations may give rise to a breach
misleading others in the firm. But
of the Individual Conduct Rules. This
there are no examples of non-
may be to determine whether there is
financial misconduct.
a requirement to notify the regulator
immediately or following a disciplinary
• Given these parameters, the
investigation for the purposes of the
circumstances in which non-
annual report to the FCA pursuant to
financial misconduct will be within
section 64C FSMA.
scope of the Conduct Rules may
be limited. Even for banks, where
The Conduct Rules include the
the Conduct Rules apply to any of
obligation to act with integrity (Rule
the firm’s activities whether
1). As Megan Butler indicated in her
regulated or not, the rules apply
2018 letter to the Women and
only in relation to the performance
Equalities Committee, non-financial
of functions relating to the
misconduct could, in principle, give
firm’s activities.
rise to a breach of this Rule.
• Whilst there is some uncertainty
When might non-financial
about the nature of the connection
misconduct be a breach?
required by the words “in relation
• The Conduct Rules are capable of
to” in this context, it is clear that
applying to both regulated and
there would need to be a
unregulated activities.
sufficiently close connection
between the non-financial
• For Conduct Rule staff in banks
misconduct, the functions of the
the Conduct Rules apply to the
individual concerned and the
performance of any functions
activities of the firm for the
relating to the carrying on of
Conduct Rules to be engaged.
activities by the firm (whether
regulated or not). For Conduct
• Firms need to consider whether
Rule staff in firms other than
such a sufficiently close
banks, the Conduct Rules are,
connection exists on a case-by-
broadly speaking, limited to
case basis, and it will be sensible
regulated activities.
to seek external advice, but
conduct involving a colleague
• The COCON section of the FCA
occurring in a social context
Handbook includes includes a
outside work hours, even if at a
non-exhaustive list of examples of
work-related event, might not have
conduct that would be in breach
sufficient connection to fall
of the requirement to act with
within scope.
integrity. The list includes various
CLIFFORD CHANCE 3
NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES
REGULATION – WHERE DO WE STAND?
Fit and Proper criminal offence, the firm should
consider the seriousness of and
Assessment
circumstances surrounding the
Firms will also need to consider offence, the explanation offered by
whether allegations of non-financial that person, the relevance of the
misconduct have implications for the offence to the proposed role, the
relevant employee’s fit and proper passage of time since the offence
assessment, both for the purposes of was committed, and evidence of
annual certification and for the the individual’s rehabilitation.1
purposes of being satisfied on an
ongoing basis that the person is fit to • FIT contains a list of factors to
continue to perform their role. which the FCA and firms should
have regard in assessing integrity.
When might non-financial These focus on financial
misconduct be relevant? misconduct: for example, whether
• Fit and properness is assessed by the person has been the subject of
reference to honesty, integrity and any adverse finding in civil
reputation; competence and proceedings, particularly in
capability; and financial connection with investment or
soundness. Non-financial other financial business,
misconduct is typically seen as misconduct or fraud; there is no
potentially relevant to integrity and express reference to non-financial
reputation (although cases may misconduct.
also involve dishonesty too) is
more likely than under the Conduct • With regards to individuals holding
Rules to be taken into account in senior management functions,
the fit and proper assessment fitness and properness might be
even where it does not occur in assessed by reference to the steps
relation to the firm’s activities. they have taken against, or to
prevent, non-financial misconduct
• The FCA Handbook provides by staff operating within their area
guidance as to how firms should of responsibility. As the FCA set
assess honesty, integrity and out in a “Dear CEO” letter to
reputation, as well as a non- insurance firms on 6 January
exhaustive list of factors to be 2020: “a senior manager’s failure
taken into account. The guidance to take steps to address non-
provides that an SMCR firm financial misconduct could lead us
determining the honesty, integrity to determine that they are not fit
and reputation of staff being and proper”.
assessed under FIT should
consider all relevant matters, • In principle, this would not
including those set out in FIT, necessarily require or depend on
whether arising in the UK or action in respect of specific
abroad. Firms should inform underlying misconduct, but instead
themselves of relevant matters, could be based on evidence of
including checking for convictions broader cultural failings. In other
for criminal offences (where words, the FCA may consider a
possible) and contacting previous senior manager’s failure to take
employers who have employed action to embed a healthy culture
that candidate or person. If any to be evidence itself of a lack of
staff member being assessed competence or, in certain
under FIT has a conviction for a circumstances, integrity.
1. As regards competence and capability, the guidance in the FCA Handbook provides that the FCA would
expect an SMCR firm determining individual’s competence and capability to consider convictions, dismissals
and suspensions from employment for drug or alcohol abuse, or other abusive acts only in relation to a
person’s continuing ability to perform their role.
4 CLIFFORD CHANCE
NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES
REGULATION – WHERE DO WE STAND?
Understanding “integrity” Horsey was the sole director and
shareholder of an authorised financial
and “reputation”
[advisory] firm with permission to conduct
The list of examples of conduct that designated investment business and
would be in breach of the requirement to insurance distribution. In September
act with integrity in COCON do not 2018, Horsey was convicted of
include non-financial misconduct, and the voyeurism, contrary to the Sexual
factors listed in FIT for assessing integrity Offences Act 2003. He was sentenced to
focus only on financial misconduct. These nine months’ imprisonment suspended
are not exhaustive, and so do not exclude for 18 months, required to complete 100
the possibility of non-financial misconduct hours of unpaid work and 25 days of
constituting a lack of integrity or rehabilitation activity, and required to sign
reputation, but there is no guidance in the sex offenders register.
the Handbook on when that may be
the case. Cochran was a director and shareholder
of an authorised financial advisory firm
In the well-known case of Hoodless and with permission to advise on pensions,
Blackwell v FSA, the Financial Services mortgages and investments. In April
and Markets Tribunal offered a definition 2018, Cochran was convicted of sexual
of integrity which has been cited with assault, engaging in controlling and
approval in a variety of contexts coercive behaviour, and an offence
subsequently: contrary to the Protection from
Harassment Act 1997. He was sentenced
In our view ‘integrity’ connotes moral
to seven years’ imprisonment and
soundness, rectitude and steady
required to sign the sex offenders register.
adherence to an ethical code.
In issuing the prohibitions, the FCA made
However, that case concerned Hoodless
specific reference to comments made by
and Blackwell’s performance of their work
the sentencing judges, including that
as brokers and their lack of co-operation
Jameson had committed an “outrageous
with the regulator’s investigation.
abuse of trust”: because he had
superimposed the faces of individuals
There are few cases addressing the
known to him onto pornographic material;
meaning of integrity in relation to non-
that Horsey’s offences involved
financial misconduct.
“substantial and significant planning” in
order to commit this offence, including
On 5 November 2020, the FCA
the careful positioning of mirrors and a
announced that it had prohibited Russell
ladder; and that Cochran’s offending
Jameson, Mark Horsey and Frank
involved a “breach of trust” and an
Cochran from working in financial services
“abuse of power”.
on the basis of convictions for sexual
offences (the three cases are unrelated) in
These specific references provide further
each case on the basis of a lack of
clarity as to the behaviours that the FCA
integrity and reputation.
will consider relevant in assessing
whether cases fall within their remit (and
Jameson was a financial adviser at an
which will therefore assist firms grappling
authorised firm and was approved by the
with how to deal with borderline cases in
FCA to hold various significant influence
the workplace): trust and abuse of power
and customer-facing functions at the firm.
are critical themes for the FCA.
In July 2018, Jameson was convicted
of criminal offences involving the making,
Evidently these were cases involving
possession and distribution of indecent
criminal convictions for serious sexual
images of children. He was sentenced
offences and have been regarded by
to five years’ imprisonment, ordered to
commentators as straightforward.
sign the sex offenders register indefinitely,
and included in the list of individuals
However, it is clear that the regulator
barred from working with children or
takes the view that there will also be less
vulnerable adults.
clear-cut cases in which an individual
could lack the necessary integrity and/or
CLIFFORD CHANCE 5
NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES
REGULATION – WHERE DO WE STAND?
reputation, even without a criminal dishonesty”. Instead, the standard of
conviction, where there is other evidence conduct required by the obligation to act
of non-financial misconduct. with integrity “must be drawn from and
informed by appropriate construction of
What sort of conduct would fall within the contents of the relevant rules”, so as
scope and what sort of evidence would to facilitate a “principled approach to the
be required? There are no financial important point raised by the
services cases or guidance to address circumstances of this appeal: the extent
this question beyond the guidance given to which it is legitimate for professional
by the regulators in the speeches and regulation to reach into personal lives of
letters described above and the limited those who are regulated.”
guidance set out in FIT and the
Enforcement Guide, neither of which The Court applied the same principle in
refers expressly to sexual misconduct. relation to the obligation on solicitors to
behave in a way that maintains the trust
That leaves firms facing difficulties in how the public places in solicitors and in the
to treat a wide range of conduct, from provision of legal services. The content of
alleged non-consensual sexual behaviour the obligation had to be derived from and
towards colleagues which does not result informed by appropriate construction of
in a criminal conviction, through to the relevant rules. There was a “qualitative
allegations relating to sexual conduct distinction” between conduct that does or
outside work potentially extending to may tend to undermine public trust in the
allegations of abusive behaviour in the profession and “conduct that would be
context of divorce proceedings or even, generally regarded as wrong,
perhaps, allegations of marital infidelity. inappropriate or even for the person
concerned, disgraceful”.
In Beckwith, the Administrative Court
considered the meaning of integrity and Applying this approach in the context of
reputation in the context of the regulatory financial services, whether in the context
framework applicable to solicitors, of the Conduct Rules or the fit and proper
adopting reasoning that will be equally test, means interpreting “integrity” and
applicable to financial services. “reputation” in the context of the
regulators’ objectives and the provisions
As regards integrity (in the context of the of the Handbook, including the examples
obligation on solicitors to act with and factors listed in COCON and FIT.
integrity) the Court approved the definition
of integrity offered in Solicitors Regulation Each case will need to be considered on
Authority v Wingate [2018] 1 WLR 3969 its facts but what is clear is that lack of
in which the Court had, in turn, cited integrity and reputation in this context
Hoodless with approval. The Court does not mean failure to adhere to
drew from Wingate the principle that “in prevailing moral or ethical standards at
the context of the regulation of a large (to the extent that these can be
profession there is an association determined), but failure to meet the
between the notion of having integrity standards of the profession, bearing in
and adherence to the ethical standards mind that the scope of the regulatory
of the profession.” framework, as the Court said in Beckwith,
“cannot extend beyond what is necessary
The Court further held that “there is no to regulate professional conduct and
free-standing legal notion of integrity in fitness to practise and maintain discipline
the manner of the received standard of within the profession.”
6 CLIFFORD CHANCE
NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES
REGULATION – WHERE DO WE STAND?
Culture and “A culture where sexual harassment
is tolerated is not one which would
Psychological Safety
encourage people to speak up and
In assessing whether non-financial be heard, or to challenge decisions.
misconduct amounts to a breach of Tolerance of this sort of misconduct
the Conduct Rules and/or impacts would be a clear example of a driver
the fit and proper assessment, it is of poor culture.”
also important for firms to consider
the FCA’s wider perspective and to Likewise, in the “Dear CEO” letter to
understand how the FCA links insurance firms, the FCA identified
non-financial misconduct to its wider non-financial misconduct and an
statutory objectives. Consistent with unhealthy culture as a key root cause
the judgment in Beckwith, this may of harm:
impact on the interpretation of the
scope of the Conduct Rules and the “We view both lack of diversity and
FIT assessment and it may also inclusion, and non-financial
impact the firm’s wider relationship misconduct as obstacles to creating
with the regulator. an environment in which it is safe to
speak up, the best talent is retained,
Pursuant to section 1B FSMA, the the best business choices are made,
FCA’s operational objectives include and the best risk decisions
securing protection for consumers are taken.”
and protecting and enhancing the
integrity of the UK financial system. The regulators’ perspective is that if
In recent years, the FCA has placed non-financial misconduct makes staff
increasing significance on the role of feel psychologically unsafe, that may
healthy and purposeful cultures in prevent staff from working effectively
pursuing its operational objectives. more broadly, including, for example,
In its 2020/2021 Business Plan, by inhibiting staff from speaking
the FCA identified culture as one of up/offering an appropriate upward
its five key cross-sector priorities, challenge. More broadly, it considers
noting: “Firms’ culture shapes the that tolerance of non-financial
outcomes for consumers and misconduct may serve to harm
markets, which is why [the FCA’s] diversity (which, in turn, may hinder
aim is to assess and address the both innovation and firms’ ability to
drivers of culture.” meet the needs of consumers from
diverse segments of society) and
As Megan Butler explained in her damage society’s view of the financial
letter to the Women and Equalities services sector.
Commission, the FCA views non-
financial misconduct as a potential The effect of this perspective may be
symptom and/or cause of a poor to draw within the regulator’s remit
culture, which in turn may drive other conduct and behaviours that might
forms of misconduct or impact the otherwise appear to lack sufficient
FCA’s statutory objectives: nexus with the workplace to be
relevant to the regulatory regime.
CLIFFORD CHANCE 7
NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES
REGULATION – WHERE DO WE STAND?
Investigations and in connection with any business
activity, including an internal
notifications under
investigation by an authorised firm.
Principle 11/
Fundamental Rule 7 These are broad obligations applying
Where allegations of non-financial to all of the firm’s activities whether
misconduct are made, firms will regulated or not, and firms will wish
usually need to investigate in order to ensure that they do not create
to form a view on whether there additional risk by failing to notify or
has been a breach of the Conduct delaying doing so. As Megan Butler
Rules or whether there is information wrote in her letter to the Women and
relevant to the fit and proper Equalities Committee: “Firms must
assessment. inform us promptly of potentially
serious misconduct involving their
Firms will also need to investigate to employees, including criminal
assess whether their own internal convictions and other sanctions,
standards and policies – which may upheld complaints, and disciplinary
go well beyond what is required by proceedings.” And we know through
the regulatory system (and breach our interactions with both regulated
of which may itself be relevant to firms and the regulator that the FCA
the fit and proper test) – have remains particularly focused on being
been breached. notified of allegations of non-financial
misconduct relating to senior
In assessing what is necessary and managers. But firms are entitled to
proportionate by way of investigation avoid taking an overly cautious
firms may take account of the further approach under the guise of “zero
guidance on the meaning of integrity tolerance” in a manner that could be
set out above. counterproductive culturally –
discouraging those who may have
As regards notifications to regulators, legitimate grievances from coming
Principle 11 and Fundamental Rule 7 forward for fear of immediate
require firms to notify the regulators notification to the regulator. A zero-
of anything relating to the firm of tolerance approach might also result
which the regulators would in excessive internal disciplinary
reasonably expect notice. action, which could increase
employment law risk (particularly in
In addition, SUP provides that if a the context of the FCA’s regulatory
firm becomes aware of information reference regime). It is also
which would reasonably be material noteworthy and relevant that Ms
to the assessment of the fitness and Butler referred to an expectation of
propriety of a senior manager, it must being notified of serious misconduct
inform the FCA within seven business involving employees.
days. This duty extends to any
circumstances that would normally Before notifying the regulator, firms
be declared when giving the are entitled to take a reasonable time
information required for section 5 of to investigate the nature of
Form A or matters considered in FIT, allegations in order to establish
with section 5 of Form A requiring whether the conduct alleged is
information on whether the individual sufficiently serious and sufficiently
has been the subject of an closely connected with the activities
investigation into allegations of of the firm or the profession to justify
misconduct or malpractice further investigation and/or
notification to the regulator.
8 CLIFFORD CHANCE
NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES
REGULATION – WHERE DO WE STAND?
Conclusion
Presently, as a result of the Covid-19 pandemic, many firms have shifted to
homeworking, and this change looks likely to persist to some degree after the
pandemic is over. This may not mean that the FCA’s focus on non-financial misconduct
will abate. The regulator will expect firms to take action to detect and prevent
non-financial misconduct which may occur remotely or outside the office.
As Julia Hoggett, FCA Director of Market Oversight said in a speech on 12 October
2020 (albeit in relation to financial misconduct), “staff should be in no doubt about the
standards expected of them. And they should be in no doubt that these standards
apply whether they are in the regular office, a disaster recovery site or at a makeshift
workstation at home. Culture matters, and it matters most when the risks are highest.”
The FCA is also focused on whether firms and individuals are complying with the
Covid-19 regulations and the government guidance. It was recently revealed that the
FCA has received 47 whistleblower complaints relating to breaches of the Covid-19
regulations, including, for example, relating to miscategorising staff as individuals who
have ‘key worker’ status and need to attend the office. Failure by individuals to comply
with the Covid-19 regulations could be treated as relevant to the fit and proper
assessment and might also impact on the FCA’s view of a firm’s culture and
psychological safety.
In the wake of Beckwith, and subject to any appeal in that case, it may that both firms
and the regulators are more cautious about treating non-financial misconduct as
amounting to a breach of the Conduct Rules or as relevant to fitness and propriety.
But the regulator also expects firms to have in place appropriate systems and controls,
including to evaluate whether or not non-financial misconduct impacts on the Conduct
Rules or fitness and propriety. In other words, there is an obligation on firms to be
considering issues relating to non-financial misconduct in the right way, where it has
the potential to fall within the regulator’s remit, regardless of whether it ultimately does.
Failures in such systems and controls were always likely to be a greater area of risk for
firms than the underlying misconduct itself, and that has not changed.
CLIFFORD CHANCE 9
NON-FINANCIAL MISCONDUCT IN FINANCIAL SERVICES
REGULATION – WHERE DO WE STAND?
AUTHORS Amy Bird Eleanor Matthews Senior Associate Senior Associate London London T: +44 75 8308 3830 T: +44 78 1142 3470 E: amy.bird@ E: eleanor.matthews@ cliffordchance.com cliffordchance.com CONTACTS Oliver Pegden Dorian Drew Carlos Conceicao Partner Partner Partner London London London T: +44 75 3541 4174 T: +44 79 4352 6743 T: +44 79 6236 1293 E: Oliver.Pegden@ E: dorian.drew@ E: carlos.conceicao@ cliffordchance.com cliffordchance.com cliffordchance.com Chinwe Odimba-Chapman Alistair Woodland Partner Partner London London T: +44 77 1769 3826 T: +44 79 0016 7093 E: chinwe.odimba-chapman@ E: alistair.woodland@ cliffordchance.com cliffordchance.com
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