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Non-Financial Misconduct: From Culture to Conduct

Human Resources Operational Regulatory & Compliance

Online

22nd April 2026 • 13.00 - 14.00

About this session

This session explores how the UK regulator expects firms to identify, assess and manage non-financial misconduct following the FCA’s clarification in Policy Statement PS25/23. It focuses on why behaviours such as bullying, harassment, discrimination and intimidation are no longer viewed as purely HR issues, but as matters of conduct, governance and accountability under SM&CR.

Using practical examples drawn from supervisory expectations and industry experience, the session explains how firms should assess whether behaviour is in scope of the Conduct Rules, when it may impact fitness and propriety, and how to apply judgement and proportionality including the treatment of behaviour outside the workplace. The session also highlights the responsibilities of senior managers and boards, common pitfalls observed by regulators, and what “reasonable steps” look like in practice.

Learning Objectives

Describe how the FCA defines and approaches non-financial misconduct under the Conduct Rules and Fitness and Propriety framework
Explain when non-financial misconduct may fall within the scope of SM&CR, including the relevance of behaviour outside the workplace or on social media
Explain when non-financial misconduct may fall within the scope of SM&CR, including the relevance of behaviour outside the workplace or on social media
List the key practical steps firms should take to manage non-financial misconduct risk in a consistent, proportionate and defensible way

Suneeta Padda

CEO • Padda Consulting Limited

Suneeta Padda is the founder of Padda Consulting and has spent over two decades working in financial services regulation, conduct and culture. She advises boards, senior managers and firms across the London Market and wider financial services sector on how to deal with difficult conduct issues in a way that is practical, fair and defensible.

Suneeta has extensive experience supporting firms on non-financial misconduct, including bullying, harassment and inappropriate behaviour, and how these issues intersect with SM&CR, the Conduct Rules and fitness and propriety. She regularly works with HR, Compliance and senior leadership teams to help them apply regulatory expectations in real situations, rather than relying on theory or tick-box policies.

She has collaborated with industry trade bodies on market-wide presentations and guidance, and is known for translating FCA policy into clear, workable steps that firms and managers can follow. Her approach is grounded, proportionate and focused on good judgement.