A WHO2 and Benchmarq360 view. Non financial misconduct readiness...are you ready?

THE WHO2 GLOBAL VIEW

Non financial misconduct has gone from being viewed as “an HR issue” to becoming a boardroom conversation very quickly.

With the FCA’s updated expectations coming into focus in September 2026, the question is becoming:

WHAT ARE FIRMS ACTUALLY DOING ABOUT IT?

If we’re honest, many organisations are probably still working out where ownership sits.

Is it Compliance? HR? Risk? SMCR? Conduct? Culture?

The reality is that it is likely a combination of all of them.

The bigger issue is that this is unlikely to be solved by adding another policy to the intranet and ticking a box.

The questions firms should be asking themselves are:

Do senior managers understand escalation responsibilities?

Would Fitness & Propriety processes identify the right risks?

Are reporting routes clear and understood?

Does management information identify emerging culture issues early enough?

Could the organisation evidence oversight if challenged tomorrow?

What we are seeing is a shift away from:

“Do you have a policy?”

towards:

“Show us how this works in practice.”

That feels like a very different conversation.

AT WHO2 WE HAVE BUILT A FREE NON FINANCIAL MISCONDUCT READINESS ASSESSMENT INTO BENCHMARQ360

It is not regulatory advice and it is not intended to replicate the FCA. It is simply designed to help firms sense check current readiness, identify potential gaps and create practical actions before those gaps become bigger issues.

Sometimes the most useful question is also the simplest one.

The views expressed in this article are those of WHO2 Global Ltd and do not constitute professional advice. All content is for informational purposes only.