FCA Conduct Rules and Principles: The Complete UK Guide

Conduct Regulation Support: Find Senior Compliance Specialists Who Have Embedded the Rules

UK financial services conduct regulation sits in two layered frameworks. At the top, the FCA’s twelve Principles for Businesses set the high-level behavioural standards that every regulated firm must meet. Beneath the firm-level Principles, the Conduct Rules in the FCA Handbook’s Code of Conduct sourcebook (COCON) set individual-level behavioural standards that apply to almost every employee of an FCA-regulated firm. Together, the Principles and the Conduct Rules are the behavioural backbone of UK retail and wholesale financial services regulation.

Understanding conduct regulation is not merely a compliance exercise. The FCA uses Principle breaches and Conduct Rule breaches as primary enforcement hooks — it is much easier for the regulator to prove a Principle or Conduct Rule breach than to prove a specific rulebook breach, and enforcement action against firms and senior individuals is increasingly framed around the Principles and the Conduct Rules. Every serious compliance function, every board, and every senior manager at an FCA-regulated firm needs a working understanding of what these rules actually require.

This guide sets out the full conduct framework. The twelve FCA Principles for Businesses, including the new Principle 12 introduced by Consumer Duty. The six Individual Conduct Rules that apply to essentially all staff. The four Senior Conduct Rules that apply additionally to Senior Managers. The relationship between the Principles, the Conduct Rules and the broader FCA Handbook. The evolution from Treating Customers Fairly to Consumer Duty. The training, investigation and notification obligations that sit around conduct regulation. And the common failings that supervisory reviews and enforcement cases have identified. It is written for compliance, risk, HR and senior leadership at FCA-regulated firms.

The Conduct Rules sit within the wider Senior Managers and Certification Regime, and interact closely with the Consumer Duty and with the MLRO regime. This guide focuses on the Principles and Conduct Rules specifically; those related guides provide the broader context.

The Twelve FCA Principles for Businesses

The FCA Principles for Businesses are the highest-level behavioural standards in UK financial services regulation. They apply to the firm as a legal entity, not to individuals. Every rule in the FCA Handbook can ultimately be traced back to one or more of the Principles — and where no specific rule applies, the Principles themselves are binding standards the firm must meet.

The Principles in full

The FCA Handbook (PRIN 2.1.1R) sets out twelve Principles for Businesses. Paraphrased:

• Principle 1 — Integrity: A firm must conduct its business with integrity.
• Principle 2 — Skill, care and diligence: A firm must conduct its business with due skill, care and diligence.
• Principle 3 — Management and control: A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
• Principle 4 — Financial prudence: A firm must maintain adequate financial resources.
• Principle 5 — Market conduct: A firm must observe proper standards of market conduct.
• Principle 6 — Customers’ interests: A firm must pay due regard to the interests of its customers and treat them fairly. This is the statutory expression of Treating Customers Fairly.
• Principle 7 — Communications with clients: A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.
• Principle 8 — Conflicts of interest: A firm must manage conflicts of interest fairly, both between itself and its customers and between different customers.
• Principle 9 — Customers: relationships of trust: A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for customers entitled to rely on its judgment.
• Principle 10 — Clients’ assets: A firm must arrange adequate protection for clients’ assets when it is responsible for them.
• Principle 11 — Relations with regulators: A firm must deal with its regulators in an open and cooperative way, and must disclose to the FCA appropriately anything relating to the firm of which the FCA would reasonably expect notice.
• Principle 12 — Consumer Duty: A firm must act to deliver good outcomes for retail customers. Added by the Consumer Duty with effect from 2023.

How the Principles operate

The Principles are binding rules, not guidelines. A firm that breaches a Principle can face enforcement action in the same way as a firm that breaches a specific Handbook rule — and often the Principle-based enforcement is easier for the FCA to pursue because the standards are deliberately high-level rather than tightly defined.

Principles operate in three overlapping ways:

• As background standards: every specific rule in the Handbook is informed by and consistent with the Principles, so complying with the specific rule typically also complies with the relevant Principle.
• As gap-fillers: where the Handbook has no specific rule addressing a situation, the Principles still apply. A firm cannot exploit a rulebook gap to behave in a way that breaches a Principle.
• As enforcement hooks: enforcement decisions frequently cite Principle breaches alongside specific rule breaches, and sometimes rely on Principle breaches alone where the facts do not fit any specific rule.

Principle 11 — the one most often relied on in enforcement

Principle 11 (relations with regulators) is probably the Principle most frequently cited in enforcement actions. It requires firms to be open and cooperative with the FCA and to disclose matters of which the FCA would reasonably expect to be notified. Firms have been fined for delayed notifications, incomplete notifications, failing to disclose matters they should have disclosed, and attempting to manage supervisory engagement in ways the FCA considered adversarial rather than cooperative. A firm that wants to minimise regulatory risk must get Principle 11 compliance right — proactive, timely, substantive engagement with the FCA on matters the regulator would expect to know about.

Principle 12 — the Consumer Duty

Principle 12, added with the Consumer Duty, goes further than Principle 6 (treating customers fairly). Principle 6 sets a standard of fair dealing; Principle 12 requires the firm to positively act to deliver good outcomes. The distinction is between not causing harm (Principle 6) and actively producing benefit (Principle 12). See our Consumer Duty guide for the full detail on how Principle 12 operates through the four outcomes, three cross-cutting rules and governance framework.

The Individual Conduct Rules — Who They Apply To

While the Principles apply to the firm, the Conduct Rules apply to individuals. The regime sits within COCON (the Code of Conduct sourcebook) in the FCA Handbook, and operates under the Senior Managers and Certification Regime.

The scope of the Individual Conduct Rules

The Individual Conduct Rules apply to essentially all employees of an FCA-regulated firm (and to some other connected parties in specific circumstances). The exclusions are narrow — broadly, staff whose role has no connection to regulated activities (receptionists, catering, cleaning, facilities, postal/courier, security, general maintenance and some others). In practice at most firms, the Conduct Rules apply to the vast majority of staff.

This is the single biggest change from the pre-SMCR world. The old Approved Persons Regime applied only to approved persons — typically a few dozen individuals per firm. The Individual Conduct Rules apply to thousands (sometimes tens of thousands) of individuals at larger firms. The operational, training, monitoring and notification implications are correspondingly large.

The six Individual Conduct Rules

COCON 2.1 sets out six Individual Conduct Rules:

• Rule 1 — Integrity: You must act with integrity.
• Rule 2 — Skill, care and diligence: You must act with due skill, care and diligence.
• Rule 3 — Open and cooperative with regulators: You must be open and cooperative with the FCA, the PRA and other regulators.
• Rule 4 — Customer interests: You must pay due regard to the interests of customers and treat them fairly.
• Rule 5 — Market conduct: You must observe proper standards of market conduct.
• Rule 6 — Consumer Duty: You must act to deliver good outcomes for retail customers. Added by the Consumer Duty with effect from 2023 (applies where the individual’s role has retail customer impact).

How the Individual Conduct Rules work in practice

The rules are deliberately high-level. They do not specify particular behaviours to avoid in specific situations — they set standards that apply across situations. FCA guidance in COCON provides illustrative examples of behaviours that would breach each rule, but the rules themselves are not exhaustive.

Rule 1 (integrity) examples of breach include misleading customers or the firm, misappropriating assets, falsifying documents, concealing information with intent to deceive. Rule 2 (skill, care and diligence) examples include failing to understand transactions properly before committing to them, failing to escalate matters that warranted escalation, or performing functions outside the individual’s competence. Rule 3 (open and cooperative with regulators) examples include failing to respond fully to regulatory enquiries, concealing relevant information from the FCA, misleading the regulator about the firm’s position. Rule 4 (customer interests) examples include recommending products known to be unsuitable, failing to disclose material conflicts, creating barriers to customers exercising legitimate rights. Rule 5 (market conduct) examples include insider dealing, market manipulation, front-running, disorderly trading. Rule 6 (good outcomes) examples include actively undermining customer outcomes, failing to flag systemic customer harm, or participating in processes designed to game outcome metrics.

The Senior Conduct Rules — Additional Obligations for Senior Managers

Senior Managers (individuals holding Senior Management Functions under SMCR) are subject to four additional Conduct Rules beyond the Individual Conduct Rules that apply to all in-scope staff.

The four Senior Conduct Rules

• SC1 — Effective control: You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively.
• SC2 — Compliance with regulatory requirements: You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system.
• SC3 — Delegation: You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively.
• SC4 — Disclosure to regulators: You must disclose appropriately any information of which the FCA or PRA would reasonably expect notice.

The “reasonable steps” standard

All four Senior Conduct Rules use the formulation “reasonable steps.” Senior Managers are not strictly liable for every failing in their area. But they must be able to demonstrate that they took reasonable steps — proactive steps, documented steps, steps that a reasonable Senior Manager would have taken in the circumstances.

The “reasonable steps” test connects to the Duty of Responsibility under SMCR. Where the firm breaches a regulatory requirement in the Senior Manager’s area of responsibility, the FCA can take enforcement action against the Senior Manager personally unless the Senior Manager can show they took reasonable steps to prevent the breach. The Senior Conduct Rules and the Duty of Responsibility operate together as the accountability mechanism for Senior Managers. See our SMCR guide for more on the Duty of Responsibility framework.

What “reasonable steps” typically means

FCA guidance and enforcement outcomes indicate that reasonable steps typically involve:

• Understanding the risks and regulatory obligations in the area of responsibility
• Establishing appropriate policies, procedures and controls
• Ensuring adequate resources are deployed
• Putting in place effective management information
• Reviewing information received and acting on concerns
• Escalating to the board or to the regulator where appropriate
• Documenting decisions and the basis for them
• Responding appropriately when issues are identified

Where Senior Managers have been subject to enforcement action under the Senior Conduct Rules, the common failing has been an inability to demonstrate these steps were taken — either because they were not taken, or because they were taken but not documented.

The FCA Handbook COCON Sourcebook

The Code of Conduct sourcebook (COCON) is the part of the FCA Handbook that contains the Conduct Rules and the related rules and guidance. It is relatively short compared to other Handbook sections but is central to day-to-day conduct regulation.

COCON structure

• COCON 1: Application and general provisions — who the Conduct Rules apply to, exceptions and scope clarifications.
• COCON 2: The individual and senior Conduct Rules themselves.
• COCON 3: The scope of the rules, including scope limitations and the location of the conduct in question.
• COCON 4: Guidance on the specific Conduct Rules, including examples of behaviours consistent with or contrary to each rule.
• COCON 5: Enforcement and notifications — how breaches are treated, notification obligations, and the interaction with the FCA’s enforcement framework.

Using COCON in practice

Compliance teams use COCON as the reference point when designing Conduct Rules training, investigating potential breaches, handling disciplinary processes, and preparing notifications to the FCA. The guidance in COCON 4 is particularly important — it sets out the FCA’s view of what specific behaviours would breach each rule, which is the starting point for any breach assessment.

Treating Customers Fairly — the Legacy Framework

Before the Consumer Duty, the FCA’s principal customer-outcome framework was Treating Customers Fairly (TCF). TCF remains relevant because it is embedded in Principle 6, in Individual Conduct Rule 4, and in several Handbook requirements — and because the Consumer Duty explicitly builds on and extends TCF rather than replacing it.

The six TCF outcomes

The original TCF framework set out six customer outcomes:

1. Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
2. Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
3. Consumers are provided with clear information and kept appropriately informed before, during and after the point of sale.
4. Where consumers receive advice, the advice is suitable and takes account of their circumstances.
5. Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
6. Consumers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint.

From TCF to Consumer Duty

The Consumer Duty takes the TCF outcomes further in several ways:

• Raises the standard from “fair treatment” to “good outcomes.” Fair treatment means the firm has dealt appropriately with the customer; good outcomes means the customer has actually achieved a positive result.
• Requires firms to positively evidence outcomes, not merely to have processes that should produce good outcomes.
• Adds specific outcome categories (products and services, price and value, consumer understanding, consumer support) with detailed requirements under each.
• Introduces cross-cutting rules (act in good faith, avoid foreseeable harm, enable customers to pursue their objectives).
• Adds Principle 12 and Individual Conduct Rule 6 to lock the outcomes expectation into the conduct framework.

Firms that had mature TCF frameworks before 2022 found Consumer Duty implementation easier — because they already had the mindset of customer outcomes rather than process compliance. Firms that had treated TCF as a tick-box found Consumer Duty implementation harder because the underlying capability to monitor customer outcomes was not in place.

Training on the Conduct Rules — a Specific Obligation

Firms must train all in-scope staff on the Conduct Rules. This is not optional and the quality of training is a specific supervisory focus area.

Training obligations

Firms must ensure that all Senior Managers, certified persons and other staff subject to the Conduct Rules:

• Understand how the Conduct Rules apply to them
• Receive training on the Conduct Rules appropriate to their role
• Receive refresher training at appropriate intervals
• Receive additional training where their role changes in a way that affects Conduct Rules application

Good practice in Conduct Rules training

Strong Conduct Rules training programmes typically include:

• Role-tailored content: Senior Manager training that covers the Senior Conduct Rules in depth with scenario exercises; certified person training that addresses the specific conduct risks of their certified function; general staff training pitched at appropriate generality.
• Firm-specific scenarios: Examples drawn from the firm’s own business context rather than generic industry examples. Scenarios that reflect the actual conduct risks the firm faces.
• Integrated outcome focus: Training that addresses Conduct Rule 4 (customer interests) and Rule 6 (good outcomes) as connected requirements, not separate boxes.
• Annual refreshers: Baseline refresher training annually, with additional targeted training when major events warrant it (new products, regulatory changes, specific incidents).
• Assessment: Some form of testing or assessment that verifies the content has been absorbed, not just received.
• Manager engagement: Manager briefings that equip managers to reinforce Conduct Rule expectations in day-to-day management and to recognise potential breaches.

Common training failings

Supervisory reviews have repeatedly criticised Conduct Rules training that:

• Is generic e-learning completed as a tick-box exercise without evidence of understanding
• Uses industry-generic content that bears no relationship to the specific firm context
• Is delivered once at onboarding and not refreshed
• Fails to differentiate between Senior Manager, certified person and general staff requirements
• Does not connect to the firm’s actual disciplinary framework for breaches
• Is not assessed or reinforced in any ongoing way

Conduct Rule Breaches — Investigation, Discipline and Notification

When a potential Conduct Rule breach occurs, firms must investigate, decide on any disciplinary action, and where disciplinary action is taken, notify the FCA. This process has specific regulatory requirements and getting it wrong is itself a source of regulatory risk.

Investigation principles

Conduct Rule breach investigations should be:

• Prompt: Initiated without unreasonable delay when a potential breach comes to light.
• Proportionate: Resourced and structured in line with the seriousness of the alleged breach.
• Independent: Conducted by people who are not compromised by involvement in the matter. For senior matters, often led by compliance with HR support; for serious matters, sometimes conducted by external investigators.
• Documented: Every step recorded, every decision reasoned, every piece of evidence retained.
• Fair to the individual: Compliant with the firm’s disciplinary procedures and with employment law requirements, including the right to respond.
• Consistent: Similar alleged breaches handled similarly across the firm, to avoid inconsistency claims in employment disputes and in regulatory reviews.

Disciplinary outcomes

Where investigation concludes that a Conduct Rule breach occurred, the firm decides on disciplinary action. Outcomes range from informal feedback (for minor breaches not warranting formal action), through formal warnings, written warnings, final written warnings, to dismissal for the most serious cases. The disciplinary outcome affects the notification obligation and may affect the individual’s ongoing fit and proper status.

The notification regime

Firms must notify the FCA of Conduct Rule breaches that result in disciplinary action. The specific requirements:

• Senior Manager Conduct Rule breaches resulting in disciplinary action: Notified to the FCA within 7 business days of the disciplinary action being taken. This is the most urgent notification category.
• Individual Conduct Rule breaches resulting in disciplinary action: Notified annually via the REP008 return, covering the preceding year.
• Disciplinary action includes: Formal warning, reduction or recovery of remuneration, dismissal, and related outcomes. Informal management feedback not resulting in formal action is not notifiable.

Missing a 7-day notification for a Senior Manager breach is itself a Principle 11 breach and creates additional regulatory risk on top of the underlying matter. Firms need a specific process — typically involving HR, compliance and the relevant senior management — to ensure these notifications are made on time.

The annual REP008 return

The REP008 is the annual return through which firms report Conduct Rule breaches resulting in disciplinary action during the year. The return covers:

• Number of Conduct Rule breach investigations conducted
• Outcomes (upheld, not upheld, inconclusive)
• Disciplinary actions taken
• Categories of breach (which Conduct Rules were breached)
• Roles and seniority of individuals involved

The data feeds the FCA’s supervisory view of firm culture and conduct management. Firms with very low reported breach numbers alongside known conduct issues raise supervisory questions; firms with high breach numbers but evidence of robust investigation and appropriate action often fare better than those with lower headline numbers but weaker processes.

The Relationship Between Principles, Conduct Rules and Specific Handbook Rules

The three layers of FCA requirements interact in specific ways that it is worth understanding.

The hierarchy

• Principles for Businesses (top layer): Apply to the firm. Twelve high-level standards of firm behaviour.
• Specific Handbook rules (middle layer): Thousands of specific rules across the various Handbook sections (COBS, SYSC, MAR, CASS, etc.). Implement the Principles in specific business areas.
• Conduct Rules (individual layer): Apply to individuals. Ten rules (six individual + four senior) setting behavioural standards.

How they fit together

A firm that breaches a specific Handbook rule will typically also be in breach of the related Principle. The specific rule is the particular expression of the Principle; breaking one usually means breaking the other. Individuals involved in the breach may also have breached Conduct Rules if their personal behaviour fell below the required standard.

Enforcement cases often cite all three layers simultaneously. The firm is charged with Principle breaches (typically 3, 6, 7 or 11 depending on the matter), specific rule breaches (the particular COBS or SYSC rules that were contravened), and Senior Managers may be charged with Conduct Rule breaches (SC1, SC2 or SC4 depending on their role in the matter). This is why robust conduct regulation compliance must address all three layers — gaps in any of them create enforcement exposure.

Common Conduct Regulation Failings

Across the firms we work with and the FCA’s published supervisory commentary, certain conduct regulation failings recur.

Principle 11 failures

Failures to disclose matters to the FCA in a timely, complete and cooperative way. Late notifications. Notifications that omit material facts. Supervisory engagement conducted defensively rather than openly. These failings create risk even where the underlying matter was minor — because Principle 11 breaches are treated seriously and are relatively easy for the FCA to prove.

Weak conduct culture at the top

Where senior managers and the board do not visibly prioritise conduct standards, the culture cascades down through the firm. Compliance and HR functions can run technical conduct processes perfectly, but if senior management signals through their decisions and behaviours that conduct is a secondary concern, the firm’s conduct outcomes typically reflect that.

Tick-box training

As discussed above, generic e-learning completed as a formality without genuine engagement or assessment.

Inconsistent investigation standards

Similar alleged breaches handled differently depending on the seniority of the individual involved. Commercial pressure influencing investigation outcomes. Investigations that lack independence from the matter being investigated.

Conflation of employee performance and conduct

Treating Conduct Rule breaches as ordinary performance issues or, conversely, treating performance issues as Conduct Rule breaches. The distinction matters — both for how the matter is handled internally and for the regulatory implications.

Missing Senior Manager Conduct Rule coverage

Senior Managers who understand the Individual Conduct Rules but not the additional Senior Conduct Rules. Senior Managers who do not understand the “reasonable steps” test and cannot evidence how they discharged it. Senior Managers whose Statement of Responsibilities does not align with how they actually operate, creating gaps in conduct coverage.

Under-reporting and over-reporting

Firms that under-report Conduct Rule breaches, either because breach definitions are applied too narrowly or because reporting processes discourage escalation. And firms that over-report, treating minor matters as formal breaches because the investigation culture has become excessively process-driven. Both distort the data and can create supervisory concern.

The Specialist Roles Firms Need for Conduct Regulation

Conduct regulation requires specific senior and specialist roles to operate effectively.

Chief Compliance Officer (SMF16)

Holds overall responsibility for the firm’s compliance with FCA rules including conduct regulation. See our Chief Compliance Officer recruitment page for more on this SMF16 role.

Head of Conduct / Head of Culture

At larger firms, a specific senior role focused on conduct risk, culture and conduct regulation compliance. Often reports to the CCO. Owns the firm’s conduct framework, conduct risk assessment, and the interface between conduct and Consumer Duty.

Conduct Rules training specialist

Dedicated role owning Conduct Rules training programme design, delivery, effectiveness measurement and records. Typically part of the compliance function, often with a learning and development background.

Conduct Rule breach investigator

Compliance or HR professional specialising in conduct breach investigations. Independent, experienced, with the judgment to handle sensitive matters involving senior individuals.

HR leadership in conduct

The HR function has substantial conduct regulation responsibilities — fit and proper assessments, disciplinary processes, regulatory references, and the interface between the employment relationship and the regulatory obligations. Senior HR leaders at FCA-regulated firms need specific SMCR and conduct regulation expertise.

Chief Risk Officer (SMF4)

The Chief Risk Officer carries specific responsibility for conduct risk within the broader risk framework. Conduct risk typically features in the firm’s risk appetite statement, risk register and risk reporting.

How FD Capital Places Conduct, Compliance and Risk Specialists

FD Capital operates a specialist FCA-regulated firms recruitment practice. Conduct regulation leadership is a core part of our practice — Chief Compliance Officers, Heads of Conduct, Heads of Culture, Conduct Rules training specialists and investigation specialists.

Candidate pool

Our candidate pool in this area includes:

• Chief Compliance Officers (SMF16) with deep conduct regulation experience across UK FCA-regulated sectors
• Heads of Conduct, Heads of Culture and Heads of Behavioural Risk at larger firms
• Conduct Rules training specialists with track records of building and running Conduct Rules programmes
• Senior compliance investigators with experience handling Conduct Rule breach matters
• HR leaders with SMCR, fit and proper, and disciplinary conduct expertise
• Chief Risk Officers with conduct risk integration experience

Engagement models

• Permanent placements for firms building out or replacing conduct leadership — CCO, Head of Conduct, senior conduct specialists.
• Interim and fractional placements for specific situations — supervisory remediation, Consumer Duty interface work, investigation specialist support, cover during recruitment.
• Specialist project placements for finite workstreams — Conduct Rules training programme rebuild, culture assessment projects, conduct risk framework redesign.

Sector coverage

Each UK FCA-regulated sector has its own conduct profile. Retail banking conduct emphasises customer interest and Consumer Duty; wholesale and markets firms emphasise market conduct and Rule 5; insurers emphasise product governance and customer outcomes. We match candidates carefully to the specific firm context and conduct regulation priorities.

Conduct Regulation is Culture-Driven — Staff and Lead It Accordingly

The firms that handle conduct regulation well understand that it is not primarily a compliance exercise — it is a culture issue expressed through specific regulatory requirements. Strong Conduct Rule training, robust investigation processes, timely Principle 11 notifications, active Senior Manager reasonable steps discipline, and consistent application across the firm are the operational markers of a mature conduct function. But the underlying driver is senior leadership that visibly prioritises conduct and behaves accordingly. Process discipline without cultural commitment is fragile; cultural commitment with process discipline is robust.

Firms that under-invest in conduct capability find out about their weakness through supervisory intervention, enforcement action or — increasingly — through Consumer Duty outcome failures that trace back to conduct-culture gaps. The cost of investment up front is materially less than the cost of remediation later.

FD Capital can help you find the right conduct, compliance or risk leader — permanent, interim or fractional — matched to your firm’s specific conduct regulation profile and priorities.

A Note from Our Founder — Adrian Lawrence FCA

The conversations I have about conduct regulation come in two forms. The first is firms recruiting into a specific conduct role — Head of Conduct, Chief Compliance Officer, a senior investigator or training specialist — where the fit between candidate and role requires careful assessment of the firm’s conduct profile. The second is firms where something has gone wrong — a Principle 11 notification gap, a Senior Manager Conduct Rule investigation, an FCA supervisory finding on conduct culture — and the hiring question carries weight beyond the immediate role.

In both contexts, the specialists who succeed are those who understand conduct regulation as a culture issue expressed through regulatory requirements. They know the FCA Handbook, they know COCON and PRIN, they know the procedural mechanics of investigation and notification — but they also know that these things only work when the underlying culture supports them, and they have the senior-level influence to help build the culture alongside running the processes.

At FD Capital we place conduct, compliance and risk specialists at UK FCA-regulated firms across all major sectors. If you are recruiting in this area, assessing your conduct framework maturity, or handling a specific conduct regulation issue, I am happy to have a direct conversation. Every mandate I take on is handled personally.

Adrian Lawrence FCA  |  Founder, FD Capital  |  ICAEW Verified Fellow  |  ICAEW-Registered Practice  |  Companies House no. 13329383  |  Placing conduct, compliance and risk specialists at FCA-regulated UK firms since 2018

Further Reading and Authoritative Sources

The primary authoritative sources on the FCA Conduct Rules and Principles are the FCA’s Handbook and published supervisory material. The FCA Handbook COCON sourcebook contains the Conduct Rules themselves, the guidance on their application, and the scope and notification provisions. The FCA Handbook PRIN sourcebook sets out the twelve Principles for Businesses and the guidance on their application.

The FCA’s Conduct Rules pages provide supervisory commentary, FAQs and additional guidance on how the rules apply in practice. FCA enforcement decision notices against firms and individuals for Conduct Rule and Principle breaches provide useful reference material on how the FCA applies the rules in practice — specific cases involving Senior Manager enforcement under the Duty of Responsibility and the Senior Conduct Rules provide particularly instructive learning.

For firms subject to dual regulation, the PRA Rulebook contains the PRA’s equivalent Conduct Standards, which must be complied with alongside the FCA’s Conduct Rules for PRA-regulated firms.

Professional body guidance is available from the ICAEW for chartered accountants in regulated roles, and from the Chartered Institute for Securities and Investment, the Chartered Insurance Institute and the International Compliance Association for sector-specific conduct training and CPD.

Related Guides: Compliance and Regulatory Guidance for UK Financial Services

Part of FD Capital’s series of practical compliance and regulatory guides for UK financial services firms. This guide sits alongside our broader Knowledge Centre resources:

Governance and conduct: FCA Conduct Rules and Principles: The Complete UK Guide (this page) | SMCR Explained: Senior Managers & Certification Regime | Consumer Duty: The Complete UK Guide

Financial crime and AML: MLRO: The Money Laundering Reporting Officer Role Explained | Customer Due Diligence: The Complete UK Guide | Suspicious Activity Reports (SARs): UK Compliance Guide (forthcoming)

Prudential and operational: Regulatory Reporting: The Complete UK Guide | Operational Resilience: UK Financial Services Guide (forthcoming) | Section 166 Skilled Person Reviews (forthcoming)

Finance for UK growth companies: EBITDA Explained: Meaning, Calculation and Exit Valuation | Management Accounts: A Complete Guide for UK Businesses | Cash Flow Forecasting: A Complete Guide for UK Businesses | Financial Ratios: The UK CFO’s Guide | Financial Metrics & KPIs: A UK CFO’s Guide

Specialist recruitment pages: SMCR Compliance Recruitment | Chief Compliance Officer Recruitment | Chief Risk Officer Recruitment | Consumer Duty Recruitment | MLRO Recruitment | Compliance Recruitment | Risk and Compliance Recruitment | Financial Crime Recruitment | AMLRO Recruitment | Head of Regulatory Reporting | Section 166 Review | Recruitment for FCA-Regulated Firms