FCA Non-Financial Misconduct Training
FCA Regulated Firm · All Staff · 2025

Non-Financial Misconduct:
Your Obligations

The FCA now treats bullying, harassment, and other non-financial misconduct as regulatory matters — not just HR issues. This training explains what that means for you.

~30
minutes to complete this module
4
key conduct topics covered
2025
FCA rules in force
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Section 1 — The Regulatory Context

Why Is the FCA Acting Now?

The FCA and PRA concluded that poor firm culture — including how firms tolerate bullying and harassment — contributes to financial harm. Non-financial misconduct is now a fitness and propriety matter.

2018
FCA / PRA publish "Transforming Culture in Financial Services" — culture identified as systemic risk driver.
2022–2023
Industry surveys reveal widespread bullying and harassment across financial services; FCA consultation launched (CP23/20).
2024
FCA publishes final guidance on non-financial misconduct in COCON and FIT — conduct rules explicitly extended to cover workplace behaviour.
2025 onward
Firms required to assess fitness and propriety including NFM conduct. Supervisory engagement and enforcement actions underway.
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Section 1 — Definition

What Counts as Non-Financial Misconduct?

The FCA groups NFM into behaviours that are incompatible with market integrity and fitness to work in financial services:

🚫

Bullying

Repeated behaviour that humiliates, intimidates, or undermines an individual — including excluding someone, setting impossible targets, or public ridicule. Intent is not required.

⚠️

Harassment

Unwanted conduct related to a protected characteristic (sex, race, religion, disability, age, sexual orientation etc.) that violates dignity or creates a hostile environment.

🔇

Victimisation

Treating someone less favourably because they have raised a complaint, supported a colleague's complaint, or been involved in related proceedings.

📵

Other Serious Misconduct

Dishonesty, violence, discrimination, or any conduct — inside or outside work — that calls into question a person's fitness and propriety to hold their role.

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Section 2 — Regulatory Scope

Where and When Do the Rules Apply?

Important: NFM rules are not limited to the workplace. The FCA can consider conduct outside of work if it is relevant to an individual's fitness and propriety.
In the Office
Remote / WFH
Work Events
Client Entertaining
Social Media
Personal Life*
Always in scope Typically in scope May be in scope — context dependent

* Personal conduct only becomes relevant if it calls fitness and propriety into question (e.g. fraud, violence, serious dishonesty).

→
NFM applies to all FCA-authorised individuals — not just Senior Managers or Certified Persons
→
Third parties (contractors, secondees) can still be subject to NFM processes where conduct affects regulated activities
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Section 2 — The Regulatory Framework

How NFM Links to the Conduct Rules

The FCA's Individual Conduct Rules (COCON) set minimum standards of behaviour. NFM is now explicitly linked to these rules — meaning a breach can lead to regulatory action.

1
Act with integrity — dishonesty or deceptive behaviour in any context
2
Act with due skill, care and diligence — includes how you treat colleagues
4
Be open and cooperative with regulators — includes NFM disclosures
⚖️

Potential Consequences

FCA investigation Prohibition order Fine Withdrawal of approval Public censure Fitness assessment failure Internal disciplinary Dismissal

Consequences can apply to individuals directly — not just the firm.

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Section 3 — Scenario Quiz

Recognising NFM in Practice

Scenario A
"A senior trader consistently interrupts a junior female analyst in team meetings, dismisses her ideas, and refers to her as 'sweetheart' despite being asked to stop. He copies her line manager into an email questioning her competence without any factual basis. The behaviour has gone on for four months."

Which regulatory category best describes this conduct?

⚠ You must select an answer to continue.
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Section 3 — Scenario Quiz

What About This Situation?

Scenario B
"After raising a grievance about their manager's behaviour, a compliance officer finds their projects have been reassigned without explanation, they are excluded from team meetings they previously attended, and a colleague tells them their manager described them as 'trouble' in a senior leadership meeting."

What type of NFM is most likely occurring?

⚠ You must select an answer to continue.
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Section 3 — Scenario Quiz

Spot the Issue

Scenario C — Age
"A 58-year-old operations manager is passed over for a promotion in favour of a much younger, less experienced colleague. Her line manager tells her informally: 'We need someone with fresh energy for this role — you're probably thinking about winding down soon anyway.' Over the following months, she is excluded from strategy meetings she previously attended, and a younger team member begins cc'ing the line manager on her emails 'to keep things moving.' When she raises a concern with HR, she is told it is 'just a management style difference.'"

Which of the following best describes the conduct in this scenario?

⚠ You must select an answer to continue.
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Section 3 — Scenario Quiz

Would You Know What to Do?

Scenario D
"You witness a colleague being visibly distressed after a team meeting. She tells you her line manager has shouted at her, called her 'useless' and 'an embarrassment' in front of others, and has done this repeatedly over the past two months. She is afraid to report it because the manager is well-connected and she fears retaliation."

As a bystander, what is the most appropriate course of action?

⚠ You must select an answer to continue.
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Section 4 — Your Responsibilities

What Is Expected of You

The FCA expects a culture where people feel safe to speak up and where NFM is taken seriously at every level — not just by senior leaders.

1
Treat all colleagues with respect and dignity — regardless of seniority, role, or background.
2
Challenge unacceptable behaviour when you see it — you are not required to tolerate or ignore misconduct directed at others.
3
Report concerns promptly — through your line manager, HR, the Compliance team, or whistleblowing channels (all of which are protected).
4
Cooperate with investigations — including when asked to provide information as a witness.
5
Maintain confidentiality — do not discuss ongoing investigations or attempt to influence witnesses.
Senior Managers and Certified Persons carry additional obligations: you must take active steps to prevent and address NFM in your teams. Inaction may itself constitute a conduct rule breach under COCON SC4.
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Section 4 — Speaking Up

How to Report a Concern

Internal Channels

→
Your line manager (if not involved in the concern)
→
HR / People team — for grievance or disciplinary matters
→
Compliance — particularly for regulatory implications
→
Whistleblowing hotline — confidential, can be anonymous

External Channels

You have the right to report directly to the FCA if you believe internal channels are not adequate or if you fear retaliation.

FCA Whistleblowing: 020 7066 9200

The FCA cannot disclose your identity without your consent. Victimisation for raising concerns is itself a conduct breach.

You will not face retaliation for raising a genuine concern in good faith — even if the concern cannot ultimately be substantiated.

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Section 5 — Knowledge Assessment

Final Test

You'll now answer 8 questions covering everything from this module. You need 6 out of 8 to pass. Take your time — feedback is provided after each answer.

8
Questions
75%
Pass mark
∞
Attempts allowed
Final Assessment

FCA Non-Financial Misconduct — Knowledge Check

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✓
Training Complete

Well Done

You have successfully completed the FCA Non-Financial Misconduct awareness module. Enter your name below to generate your completion record.

Slide 14 / 14 · GBM Securities | FCA Regulated