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The FCA’s 5 conduct questions: Translating theory to practice

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Dewar Sally
Sally Dewar

CEO, A&O Consulting

London

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Sarah Henchoz

Partner

London

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Hitchins Sarah
Sarah Hitchins

Partner

London

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19 October 2020

The FCA has published its “Five Conduct Questions” report for 2020, highlighting key observations and issues with respect to firms’ conduct and culture programmes.
In this year’s report, the FCA focused on certain key themes that it has identified within firms’ conduct and culture programmes, including the identification of conduct risk, remuneration and performance assessments, leadership and speaking up. Across these themes, the FCA set out examples of emerging best practice, as well as certain areas for improvement. 

However, the FCA does not prescribe what a firm's conduct and culture programme should look like and firms still face the considerable task of taking the FCA’s latest feedback and translating that into practical and tangible actions. In this briefing, we set out some practical considerations for firms to support the review and development of their conduct and culture programmes based on the FCA’s latest feedback.