Pay strategies to counter non-financial misconduct

A keen regulatory focus on how firms approach problem behaviours is driving careful attention to payment and accountability structures. Kate Pumfrey and Sarah Ward explore how the latest developments in NFM are impacting remuneration design and committee practices.

Kate Pumfrey (kate.pumfrey@aoshearman.com) is a partner with A&O Shearman who advises on the employment and remuneration aspects of international transactions, as well as on standalone employment advisory and contentious employment matters. Sarah Ward (sarah.ward@aoshearman.com) is an associate who practices all aspects of employment law.

"Non-financial misconduct is misconduct, plain and simple." Since Christopher Woolard, then executive director of Strategy and Competition at the Financial Conduct Authority, reiterated this point in 2018, non-financial misconduct (NFM) has remained in the regulatory spotlight.