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Conduct Rules (Individual Conduct Rules under SM&CR)

The Conduct Rules are the minimum standards of individual behaviour that apply to nearly everyone working in an FCA or PRA regulated firm under SM&CR. Set out in the Code of Conduct (COCON) sourcebook of the FCA Handbook, they comprise Tier 1 rules applying to almost all staff and Tier 2 rules applying additionally to senior managers.

The Conduct Rules are the baseline standards of personal behaviour that the Senior Managers and Certification Regime (SM&CR) imposes on individuals in FCA and PRA regulated firms. They are contained in the Code of Conduct sourcebook, COCON, within the High Level Standards block of the FCA Handbook. The rules are split into two tiers: Tier 1 rules that apply to almost all staff, and Tier 2 rules that apply only to senior managers.

The Tier 1 Individual Conduct Rules

COCON 2.1 sets out the five core rules applying to nearly everyone: act with integrity; act with due skill, care and diligence; be open and cooperative with the regulators; pay due regard to customers’ interests and treat them fairly; and observe proper standards of market conduct. Following the introduction of the Consumer Duty, a sixth Individual Conduct Rule requires staff in scope to act to deliver good outcomes for retail customers.

The Tier 2 Senior Manager Conduct Rules

COCON 2.2 adds four rules for senior managers: take reasonable steps to ensure their area of the business is controlled effectively; take reasonable steps to ensure it complies with relevant regulatory requirements; take reasonable steps to ensure any delegation is appropriate and overseen; and disclose appropriately anything the regulators would reasonably expect to know. These rules reinforce the senior manager’s personal accountability under the Senior Managers Regime.

Application, training and reporting

The Conduct Rules apply to nearly all employees, with only narrow exceptions for purely ancillary functions (COCON 1). Firms must train staff on how the rules apply to their roles and must report breaches that result in disciplinary action: within seven business days for senior managers, and through the annual REP008 return for other Conduct Rules staff. A breach can lead to FCA enforcement action against the individual personally.

SM&CR, Senior Managers Regime and conduct risk.

Frequently asked questions

What are the Individual Conduct Rules?
The Tier 1 Individual Conduct Rules in COCON 2.1 are: (1) act with integrity; (2) act with due skill, care and diligence; (3) be open and cooperative with the FCA, the PRA and other regulators; (4) pay due regard to the interests of customers and treat them fairly; and (5) observe proper standards of market conduct. A sixth rule was added under the Consumer Duty requiring staff to act to deliver good outcomes for retail customers.
What are the Senior Manager Conduct Rules?
The Tier 2 Senior Manager Conduct Rules in COCON 2.2 apply in addition to the Tier 1 rules: (SC1) take reasonable steps to ensure the business of the firm for which you are responsible is controlled effectively; (SC2) take reasonable steps to ensure that business complies with relevant requirements and standards; (SC3) take reasonable steps to ensure any delegation of responsibilities is to an appropriate person and overseen effectively; and (SC4) disclose appropriately any information of which the FCA or PRA would reasonably expect notice.
Who do the Conduct Rules apply to and must breaches be reported?
Under SM&CR the Conduct Rules apply to nearly all staff in a regulated firm, with narrow exceptions for ancillary roles such as catering and security (COCON 1). Firms must notify the FCA of disciplinary action taken for a Conduct Rules breach: within seven business days for senior managers (using Form D / Form C as applicable), and in the annual REP008 return (Form H) for other Conduct Rules staff.

Reviewed by Margaret Hassett

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