In accordance with regulatory requirements, most firms I’m speaking to are currently planning to deliver a single training session on non-financial misconduct (NFM). In many cases, this is being done in good time, something the FCA would rightly expect to see.
On the surface, it ticks a box. But it does not, on its own, guarantee meaningful understanding, cultural change or improved outcomes for the firm.
The challenge is that NFM doesn’t sit in a single context. The way it presents and the way it needs to be understood varies significantly, depending on role and responsibility.
A board member is dealing with questions of oversight, governance and accountability. HR and compliance teams are often navigating the interface between regulatory expectations, internal policy and live case management. A line manager may be dealing with a developing issue within a team, often under pressure and with incomplete information. An employee may be deciding, in real time, whether to raise a concern at all.
These are fundamentally different perspectives. Yet many firms are still delivering a single, standardised training session across the entire organisation.
The result is predictable. Individuals may come away with a general awareness of the regulatory expectations and an understanding of how NFM links to HR and escalation processes. However, they are less likely to fully understand what is expected of them in practice, or how to act proactively when issues first emerge.
In my experience, this is where the gap sits, in translating those rules into behaviour, judgement and timely action.
Effective NFM training is therefore rarely “one size fits all”. It is typically more effective when delivered through tailored, role-specific sessions, particularly for senior leaders, HR and compliance functions. For other employees, this is where training workshop discussions should bring out the realities of their own experiences.
Different roles require different conversations. Those conversations need to be reflected in how training is designed and delivered.
If helpful, I am happy to discuss this further.