A closer look at expanded non-financial misconduct rules

Rules for banks on serious misconduct involving bullying, harassment and violence have been extended to non-banks, and the regulator is consulting on whether more guidance is needed. Elizabeth Robertson and Paddy Ferguson outline the changes and steps firms should be taking now.

Elizabeth Robertson (er@robertsonpugh.com) is a partner with Robertson Pugh who advises on multi-jurisdictional business crime and regulatory matters. She has successfully defended clients in enforcement actions, responded to coordinated dawn raids and provided compliance advice across a number of sectors. Paddy Ferguson (pf@robertsonpugh.com) is an associate who specialises in white-collar crime investigations and high-stakes commercial litigation. His previous experience includes working as a Serious Fraud Office investigator.

On 2 July 2025, the Financial Conduct Authority published a policy statement and consultation paper (CP25/18) concerning non-financial misconduct within the financial services sector. [1] The policy statement confirmed that, from 1 September 2026, the scope of the Code of Conduct (the 'COCON') will be expanded to include a new rule, COCON 1.1.7FR, stating that non-financial misconduct including workplace bullying, harassment and violence within the financial services sector can constitute a regulatory breach. Additionally, the consultation sets out the FCA's proposed guidance in relation to non-financial misconduct which, if adopted, will come into force alongside it.