FCA rules requiring integrity are an opportunity to make firms stronger. Not a boring necessity.

Matt Dean




“You should never, ever grass on a mate at work. That’s not right. That’s my number one rule.”

The City should be buzzing with the sound of conversations about conduct. The countdown is on. FCA Conduct Rules have applied for Senior Managers and staff in the Certification Regime since March 2016. They’ll apply to everyone else from March 2017 with a few limited exceptions. Firms must make sure everyone is aware they’re subject to the rules and understand how they apply to their jobs.

Rule 1 is a tough one. “You must act with integrity.” What actually is integrity? People in the firms we engage with often have strong, controversial (and conflicting) views. The quote about grassing on a mate is a real and recent one. Now, more than ever, it is imperative for firms to make sure that everyone has a clear idea of integrity. A definition that works both for them and for the firm. It is about more than complying with the law and the rules; there’s a moral element. My view of what is ‘right’ will be different to yours. At byrne•dean we’ve been talking to people in top firms about ethics and accountability for many years. We run short, engaging sessions for large groups getting them talking and thinking. In time for the March deadline, we are also hosting an open session focussing on integrity (21 February) and looking at how firms can ensure it works on the ground.

Conduct isn’t boring and we need to stop treating it as such. Integrity is both your licence to do business and a massive selling point. Moving towards it means engaging people in a proper discussion about what it means and what they have got to change to achieve it. Not just sitting people in front of an online training course. Real integrity requires individuals to think and talk about their own values; it’s about “being whole; undivided”. I need to buy it; believe it; and understand it, if the conduct rules are really going to work. If you tell me to adopt behaviours that don’t match my personal value system, it won’t work. Not for long. It will also probably affect my engagement and commitment.

Let’s start a proper conversation about integrity. Let’s accept that people will have slightly different senses of what’s right, but that if everyone is thinking about it, the firm is going to be far stronger.

This session is free to attend, please join us on 21 February 2017: 0845-1000* at our offices in Moorgate. For bookings or further information, please contact francesca.hand@byrnedean.com.

*Our session on 21 February is now full. Due to popular demand, we are re-running this session on 22 February 0845-1000.