From 1 September 2026, the FCA Code of Conduct will extend to cover bullying, harassment and violence at every FCA-authorised organisation, dragging almost 38,000 UK firms into the expanded Non-Financial Misconduct (NFM) regime for the first time.
According to Wordwatch, the change marks a decisive shift in how workplace behaviour is treated in financial services. Conduct is no longer simply a matter for HR departments to manage quietly behind the scenes. Under the new framework, it becomes a regulatory control in its own right, one that firms must be able to demonstrate, document and defend.
Yet readiness, according to those working closest to the problem, comes in two halves, and most organisations have only completed one of them. The visible half is the policy work: refreshed staff handbooks, training programmes already in flight, and “reasonable steps” carefully written down. The harder half is cultural and evidential. Firms must build environments where poor behaviour is spotted early and handled sensitively, while also being able to evidence exactly what happened, across every communication channel, when an allegation eventually lands.
Organisations tackling both sides of the equation are doing more than preparing for an FCA examination. They are safeguarding their reputations, holding on to talent, and moving their relationship with their own people away from reactive, “in the moment” responses towards ongoing, proactive care.
A webinar session featuring Wordwatch head of product Chris Reed and Verint head of global financial compliance Andy Davies will explore these challenges from inside the capture and surveillance estates of regulated firms, where both speakers operate daily. Attendees will leave with a clearer picture of where their culture and evidence layers stand, along with questions to raise with their leadership teams.
The session will unpack what “ready” genuinely means in 2026, spanning proactive culture work and defensible evidence. It will examine what the FCA expects to see when an NFM allegation is investigated, including what falls in and out of scope under PS25/23, and the evidential bar an investigation must clear. Delegates will also hear about the widening compliance perimeter, where the population most exposed to the new rule is often the least monitored today.
Other themes include the three retrieval scenarios most firms cannot yet answer confidently, among them the legacy gap, where a behavioural pattern stretches back beyond a recorder’s end-of-support by two years. The speakers will address so-called awkward channels and how to ensure oversight, noting that the same capture work supporting NFM investigations also underpins MiFID II Article 16(7) recordkeeping.
They will reframe reasonable steps as an evidence question rather than a policy one, since manager accountability turns on what they could reasonably have known, and chart the industry’s shift from reactive investigation to proactive culture, with surveillance infrastructure increasingly used to spot toxic patterns early, support staff welfare and reduce reputational risk before it becomes a regulator’s problem.
The event is aimed at heads of compliance, surveillance, conduct risk, financial crime and records management, alongside chief people officers, HR leaders accountable for workplace culture, and heads of IT infrastructure and cloud responsible for the evidence layer underneath.
Find Wordwatch’s on-demand webinar here.
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