PRESS RELEASE
12 September 2025

Lewis Silkin Responds To FCA’s Consultation On Tackling Non-financial Misconduct In Financial Services

LS
Lewis Silkin

Contributor

We have two things at our core: people – both ours and yours - and a focus on creativity, technology and innovation. Whether you are a fast growth start up or a large multinational business, we help you realise the potential in your people and navigate your strategic HR and legal issues, both nationally and internationally. Our award-winning employment team is one of the largest in the UK, with dedicated specialists in all areas of employment law and a track record of leading precedent setting cases on issues of the day. The team’s breadth of expertise is unrivalled and includes HR consultants as well as experts across specialisms including employment, immigration, data, tax and reward, health and safety, reputation management, dispute resolution, corporate and workplace environment.
Overall, we consider that additional guidance in COCON and FIT is necessary to support the new rule as well as regulator expectations in relation to non-financial misconduct.
United Kingdom

We have submitted a written response to the FCA’s consultation CP25/18 on potential new Handbook guidance in COCON and FIT, which the FCA revised following feedback it received on the previous draft guidance it consulted on in CP23/20.

Overall, we consider that additional guidance in COCON and FIT is necessary to support the new rule as well as regulator expectations in relation to non-financial misconduct. However, we believe that a number of provisions expect a disproportionately high standard of behaviour in an individual’s private or personal life wholly unconnected to work that is not necessary for the FCA to satisfy its statutory objectives and would result in an unjustified regulatory burden for both individuals and firms. You can read our full response here and our article for more detailed information on the proposed changes.

Contributor

We have two things at our core: people – both ours and yours - and a focus on creativity, technology and innovation. Whether you are a fast growth start up or a large multinational business, we help you realise the potential in your people and navigate your strategic HR and legal issues, both nationally and internationally. Our award-winning employment team is one of the largest in the UK, with dedicated specialists in all areas of employment law and a track record of leading precedent setting cases on issues of the day. The team’s breadth of expertise is unrivalled and includes HR consultants as well as experts across specialisms including employment, immigration, data, tax and reward, health and safety, reputation management, dispute resolution, corporate and workplace environment.

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