The FCA's position on firm culture has shifted — it now considers workplace conduct a regulatory matter, not just an HR one. A firm that tolerates bullying or harassment isn't just exposed to Employment Tribunal claims — it's demonstrating to the FCA that its governance, systems and controls, and conduct risk management are inadequate. Under SM&CR, a Senior Manager dismissed for harassment generates a regulatory reference that follows them to every future FCA authorisation. The employment claim is expensive. The FCA referral is permanent. The FCA doesn't wait.
What's included:
Full regulatory mapping: Equality Act 2010 ss26–27, Protection from Harassment Act 1997, SYSC 3A.2.1R, SYSC 22, SM&CR Conduct Rule 1, PRIN 6 & 8, ERA 1996, and HRA 1998
Six-channel harassment taxonomy: Face-to-Face, Electronic and Digital, Telephone, Email and Written, Social Media and Online, and Technology-Facilitated — including fake profiles, cyberstalking, and unauthorised recording
Investigation timeline: 2-day initial assessment, 5-day commencement, 15-day evidence gathering, and 25-day final determination — with external investigator provision for senior management allegations
Disciplinary sanctions ladder: verbal warning through to summary dismissal — with explicit gross misconduct examples including sexual harassment and deliberate victimisation
Regulatory consequences framework: withdrawal of regulatory approval, FCA fitness and propriety referral, and regulatory reference implications — explicitly mapped to SM&CR controlled and certification function holders
Victim protection: Section 27 victimisation prohibition, immediate protective measures, working arrangement adjustments, 24/7 EAP access, and ongoing welfare monitoring
Reporting channels matrix: line manager, HR, senior management, and anonymous hotline — with explicit provision for cases where the line manager or HR is the alleged perpetrator
+ much more
Who is this for?
Compliance Officers, HR Directors, SMF16 holders, and senior management at FCA-regulated firms who need a complete, board-approved Bullying and Harassment Policy that protects the firm against both Employment Tribunal and regulatory exposure.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
The FCA's position on firm culture has shifted — it now considers workplace conduct a regulatory matter, not just an HR one. A firm that tolerates bullying or harassment isn't just exposed to Employment Tribunal claims — it's demonstrating to the FCA that its governance, systems and controls, and conduct risk management are inadequate. Under SM&CR, a Senior Manager dismissed for harassment generates a regulatory reference that follows them to every future FCA authorisation. The employment claim is expensive. The FCA referral is permanent. The FCA doesn't wait.
What's included:
Full regulatory mapping: Equality Act 2010 ss26–27, Protection from Harassment Act 1997, SYSC 3A.2.1R, SYSC 22, SM&CR Conduct Rule 1, PRIN 6 & 8, ERA 1996, and HRA 1998
Six-channel harassment taxonomy: Face-to-Face, Electronic and Digital, Telephone, Email and Written, Social Media and Online, and Technology-Facilitated — including fake profiles, cyberstalking, and unauthorised recording
Investigation timeline: 2-day initial assessment, 5-day commencement, 15-day evidence gathering, and 25-day final determination — with external investigator provision for senior management allegations
Disciplinary sanctions ladder: verbal warning through to summary dismissal — with explicit gross misconduct examples including sexual harassment and deliberate victimisation
Regulatory consequences framework: withdrawal of regulatory approval, FCA fitness and propriety referral, and regulatory reference implications — explicitly mapped to SM&CR controlled and certification function holders
Victim protection: Section 27 victimisation prohibition, immediate protective measures, working arrangement adjustments, 24/7 EAP access, and ongoing welfare monitoring
Reporting channels matrix: line manager, HR, senior management, and anonymous hotline — with explicit provision for cases where the line manager or HR is the alleged perpetrator
+ much more
Who is this for?
Compliance Officers, HR Directors, SMF16 holders, and senior management at FCA-regulated firms who need a complete, board-approved Bullying and Harassment Policy that protects the firm against both Employment Tribunal and regulatory exposure.
How it works
Step 1 — Read it. Every section exists for a reason, grounded in a specific regulatory obligation.
Step 2 — Understand it. Map the content against your current practices. Identify where you're strong and where gaps exist.
Step 3 — Make it yours. Tailor the language to reflect how your organisation actually operates. A policy that sounds like your firm is a policy your people will follow.
Step 4 — Take ownership. Assign clear accountability — Board approval, named SMF holder, designated policy owner. A policy without an owner is a liability, not an asset.
Step 5 — Operationalise it. Embed the policy into your governance calendar, training programme, and annual review cycle. This is where compliance becomes culture.
Or, get this free with RegTechPRO
Access this alongside the full compliance policy library — SM&CR, COBS, AML, Consumer Duty, GDPR, and more — for a fraction of the cost of consultancy.
View RegTechPRO pricing and packages →
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