The Equality Act 2010 Creates Legal Obligations. The FCA Creates Regulatory Ones. For Authorised Firms, They're the Same Obligation.
Most FCA-regulated firms have an Equal Opportunities Policy. Very few have one that does what the Equality Act 2010 actually requires, integrated with what the FCA actually expects. The Act prohibits six distinct forms of discriminatory conduct — direct discrimination, indirect discrimination, harassment, victimisation, discrimination by association, and discrimination by perception — across nine protected characteristics, in every employment decision from job advertisement to termination. It requires annual pay gap analysis. It demands structured investigation processes with natural justice standards. It creates personal liability for individual perpetrators alongside vicarious liability for the firm. And the FCA, through SYSC, PRIN 6, and its conduct risk framework, treats systemic equality failures as governance failures. A firm that can't demonstrate merit-based recruitment, transparent pay structures, equal training access, and robust grievance procedures isn't just exposed to Employment Tribunal claims — it's demonstrating inadequate systems and controls to its regulator. For any firm with SMF holders, a discrimination finding against a Senior Manager triggers fitness and propriety questions under SYSC 22 that follow them through every subsequent regulatory authorisation. This comprehensive Equal Opportunities Policy gives FCA-regulated firms a complete Equality Act and FCA-aligned framework covering the full employment lifecycle — from recruitment and selection through training, pay equality, discrimination prevention, grievance procedures, monitoring, and accountability — built to satisfy both statutory obligations and regulatory expectations simultaneously.
A tribunal claim costs money. An FCA fitness and propriety referral costs a career.
What's included: Full legislative mapping — Equality Act 2010 (ss4/26/27: nine protected characteristics/six prohibited conduct forms: direct discrimination/indirect discrimination/harassment/victimisation/discrimination by association/discrimination by perception), Equality Act 2010 (Specific Duties) Regulations 2011, Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (annual reporting obligations), Public Sector Equality Duty (three needs: eliminate discrimination/advance equality of opportunity/foster good relations), Human Rights Act 1998, Employment Rights Act 1996, FCA SYSC (governance/systems and controls), FCA PRIN 6 (customers' interests — extends to workforce conduct), SYSC 22 (regulatory references — fitness and propriety implications of discrimination findings) · Six-form prohibited conduct framework — Direct Discrimination (less favourable treatment because of characteristic)/Indirect Discrimination (provisions/criteria/practices that disadvantage protected groups)/Harassment (unwanted conduct violating dignity or creating hostile environment)/Victimisation (less favourable treatment for protected act: complaint/evidence/support)/Discrimination by Association (based on connection to person with characteristic)/Discrimination by Perception (based on incorrect belief someone has characteristic) · Nine protected characteristics — Age/Disability (substantial and long-term adverse effect on normal day-to-day activities)/Gender Reassignment/Marriage and Civil Partnership/Pregnancy and Maternity/Race (colour/nationality/ethnic or national origins)/Religion or Belief (including philosophical beliefs/lack of belief)/Sex/Sexual Orientation · Recruitment framework — job analysis (essential vs desirable requirements/indirect discrimination review)/inclusive advertising (diverse channels/accessible formats)/structured selection (standardised application forms/consistent competency-based interview questions/multiple assessors to reduce individual bias/objective scoring applied equally/reasonable adjustments throughout)/record keeping for monitoring and compliance defence · Pay equality framework — objective job evaluation criteria/pay bands for equivalent roles/annual market benchmarking/performance pay on documented measurable criteria consistently applied/annual pay review with protected characteristic cross-analysis/statistical significance threshold for investigation/documented corrective measures/gender pay gap reporting under 2017 Regulations · Training and development — equal access (training schedules accommodating different working patterns/accessible formats for disabled employees/objective selection criteria/fair financial support allocation)/structured career development pathways/transparent succession planning/diverse promotion panels with unconscious bias training/documented promotion rationale · Formal grievance procedure — written submission within 3 months of incident/5 working day acknowledgement/20 working day investigation/5 working day resolution post-investigation/10 working day appeal window/independent panel with equality expertise/external investigators for complex cases/natural justice standards throughout · Monitoring framework — recruitment statistics (application/shortlisting/appointment by protected characteristic)/employee demographic composition by level and department/training participation rates/promotion and progression data/pay gap analysis/employee turnover and exit interview analysis/grievance and complaint statistics — annual equality report published/Board quarterly audit findings · Four-tier accountability structure — Board (strategic direction/resource allocation/annual report review/regulatory compliance)/HR Department (policy custodian/training/records/data analysis/recruitment compliance guidance)/Line Managers (fair performance management/discrimination response/development support/24-hour Compliance notification of incidents)/All Employees (dignity obligations/reporting duty/training participation/investigation cooperation) · SYSC 22 regulatory reference implications explicitly addressed for SMF holders — discrimination finding triggers fitness and propriety assessment
Built for: Compliance Officers, HR Directors, SMF16 holders, and board members at FCA-regulated firms who need a complete Equality Act 2010 and FCA-aligned Equal Opportunities Policy covering every form of prohibited conduct, the full employment lifecycle, structured grievance procedures, pay equality monitoring, and accountability mechanisms that protect the firm against both Employment Tribunal and regulatory exposure.
The Equality Act 2010 Creates Legal Obligations. The FCA Creates Regulatory Ones. For Authorised Firms, They're the Same Obligation.
Most FCA-regulated firms have an Equal Opportunities Policy. Very few have one that does what the Equality Act 2010 actually requires, integrated with what the FCA actually expects. The Act prohibits six distinct forms of discriminatory conduct — direct discrimination, indirect discrimination, harassment, victimisation, discrimination by association, and discrimination by perception — across nine protected characteristics, in every employment decision from job advertisement to termination. It requires annual pay gap analysis. It demands structured investigation processes with natural justice standards. It creates personal liability for individual perpetrators alongside vicarious liability for the firm. And the FCA, through SYSC, PRIN 6, and its conduct risk framework, treats systemic equality failures as governance failures. A firm that can't demonstrate merit-based recruitment, transparent pay structures, equal training access, and robust grievance procedures isn't just exposed to Employment Tribunal claims — it's demonstrating inadequate systems and controls to its regulator. For any firm with SMF holders, a discrimination finding against a Senior Manager triggers fitness and propriety questions under SYSC 22 that follow them through every subsequent regulatory authorisation. This comprehensive Equal Opportunities Policy gives FCA-regulated firms a complete Equality Act and FCA-aligned framework covering the full employment lifecycle — from recruitment and selection through training, pay equality, discrimination prevention, grievance procedures, monitoring, and accountability — built to satisfy both statutory obligations and regulatory expectations simultaneously.
A tribunal claim costs money. An FCA fitness and propriety referral costs a career.
What's included: Full legislative mapping — Equality Act 2010 (ss4/26/27: nine protected characteristics/six prohibited conduct forms: direct discrimination/indirect discrimination/harassment/victimisation/discrimination by association/discrimination by perception), Equality Act 2010 (Specific Duties) Regulations 2011, Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (annual reporting obligations), Public Sector Equality Duty (three needs: eliminate discrimination/advance equality of opportunity/foster good relations), Human Rights Act 1998, Employment Rights Act 1996, FCA SYSC (governance/systems and controls), FCA PRIN 6 (customers' interests — extends to workforce conduct), SYSC 22 (regulatory references — fitness and propriety implications of discrimination findings) · Six-form prohibited conduct framework — Direct Discrimination (less favourable treatment because of characteristic)/Indirect Discrimination (provisions/criteria/practices that disadvantage protected groups)/Harassment (unwanted conduct violating dignity or creating hostile environment)/Victimisation (less favourable treatment for protected act: complaint/evidence/support)/Discrimination by Association (based on connection to person with characteristic)/Discrimination by Perception (based on incorrect belief someone has characteristic) · Nine protected characteristics — Age/Disability (substantial and long-term adverse effect on normal day-to-day activities)/Gender Reassignment/Marriage and Civil Partnership/Pregnancy and Maternity/Race (colour/nationality/ethnic or national origins)/Religion or Belief (including philosophical beliefs/lack of belief)/Sex/Sexual Orientation · Recruitment framework — job analysis (essential vs desirable requirements/indirect discrimination review)/inclusive advertising (diverse channels/accessible formats)/structured selection (standardised application forms/consistent competency-based interview questions/multiple assessors to reduce individual bias/objective scoring applied equally/reasonable adjustments throughout)/record keeping for monitoring and compliance defence · Pay equality framework — objective job evaluation criteria/pay bands for equivalent roles/annual market benchmarking/performance pay on documented measurable criteria consistently applied/annual pay review with protected characteristic cross-analysis/statistical significance threshold for investigation/documented corrective measures/gender pay gap reporting under 2017 Regulations · Training and development — equal access (training schedules accommodating different working patterns/accessible formats for disabled employees/objective selection criteria/fair financial support allocation)/structured career development pathways/transparent succession planning/diverse promotion panels with unconscious bias training/documented promotion rationale · Formal grievance procedure — written submission within 3 months of incident/5 working day acknowledgement/20 working day investigation/5 working day resolution post-investigation/10 working day appeal window/independent panel with equality expertise/external investigators for complex cases/natural justice standards throughout · Monitoring framework — recruitment statistics (application/shortlisting/appointment by protected characteristic)/employee demographic composition by level and department/training participation rates/promotion and progression data/pay gap analysis/employee turnover and exit interview analysis/grievance and complaint statistics — annual equality report published/Board quarterly audit findings · Four-tier accountability structure — Board (strategic direction/resource allocation/annual report review/regulatory compliance)/HR Department (policy custodian/training/records/data analysis/recruitment compliance guidance)/Line Managers (fair performance management/discrimination response/development support/24-hour Compliance notification of incidents)/All Employees (dignity obligations/reporting duty/training participation/investigation cooperation) · SYSC 22 regulatory reference implications explicitly addressed for SMF holders — discrimination finding triggers fitness and propriety assessment
Built for: Compliance Officers, HR Directors, SMF16 holders, and board members at FCA-regulated firms who need a complete Equality Act 2010 and FCA-aligned Equal Opportunities Policy covering every form of prohibited conduct, the full employment lifecycle, structured grievance procedures, pay equality monitoring, and accountability mechanisms that protect the firm against both Employment Tribunal and regulatory exposure.
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