From 1 September 2026, the FCA Code of Conduct will extend to cover bullying, harassment and violence at every FCA-authorised organisation, dragging nearly 38,000 UK firms into an expanded Non-Financial Misconduct (NFM) scope for the first time.
According to Wordwatch, the change marks a decisive shift: workplace conduct is no longer simply an HR concern, but a regulatory control in its own right.
Readiness, however, has two halves, and most organisations have completed only one. The visible half is the policy work, with refreshed handbooks, training programmes underway and “reasonable steps” formally documented. The far harder half is cultivating a culture in which poor behaviour is identified early and handled sensitively, while also being able to evidence exactly what happened across every communication channel when an allegation eventually lands.
Firms tackling both sides of the equation are doing more than preparing for an FCA examination. They are safeguarding their reputation, holding on to talent, and moving their engagement with staff from reactive, “in the moment” responses towards ongoing, proactive care.
A webinar session featuring Chris Reed, head of product at Wordwatch, and Andy Davies, head of global financial compliance at Verint, will draw on their daily experience inside the capture and surveillance estates of regulated organisations. Attendees will leave with a clearer picture of where their culture and evidence layers currently stand, along with the right questions to pose to their leadership teams.
Key takeaways include what “ready” actually means in 2026, spanning both proactive culture work and defensible evidence, and 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. The session will also examine the widening compliance perimeter, noting that the population most exposed to the new rule is frequently the population least monitored today.
Delegates will explore the three retrieval scenarios most organisations cannot yet answer confidently, including the legacy gap, where a behavioural pattern stretches back to a recorder that reached end-of-support two years earlier.
Also on the agenda are the awkward channels and how to ensure oversight, with the same capture work supporting both NFM investigation and MiFID II Article 16(7) recordkeeping.
The speakers will reframe reasonable steps as an evidence question rather than a policy one, with manager accountability hinging on what they could reasonably have known, and chart the shift from reactive investigation to proactive culture, where surveillance infrastructure spots toxic patterns early and reduces 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 underlying evidence layer.
Find Wordwatch’s on-demand webinar here.
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