Master Class: Non-financial Misconduct in Financial Services
Description
The FCA’s recent policy statement and guidance on Non-Financial Misconduct (NFM) will come into force on 1 September 2026. Is your organisation prepared to demonstrate clear, consistent, and defensible conduct capabilities?
Join us for this in person interactive 90‑minute masterclass hosted by David Berman, Partner, Covington. This session will equip attendees with the practical tools, confidence and clarity needed to navigate today’s evolving conduct landscape. Built around the IA’s Conduct in Financial Services framework in partnership with Covington, the session brings the rules to life through realistic, scenario‑based discussions drawn from everyday workplace dilemmas.
Session highlights include:
- Practical Application: Learn how to apply the user-friendly NFM Assessment Flowchart and Notifications Decision Tree to reach clear, consistent, and defensible outcomes, even in complex or ambiguous cases.
- Regulatory Clarity: We will break down the crucial distinctions and interactions between COCON, FIT, and organisational HR processes when assessing potential misconduct.
- PS25/23 NFM Deep Dive: Crucially, we explore the implications of the FCA’s recent policy statement on non-financial misconduct. Understand the final expectations for how firms must identify, assess, report, and address NFM, including what constitutes “serious” misconduct and how to demonstrate “reasonable steps.”
AGENDA
08:30 Breakfast
09:00 Practical Application: Tools for Consistent Decisions
- Applying the NFM Assessment Flowchart
- Key distinctions between COCON, FIT, and organisational HR
09:20 Working Through NFM Scenarios
- What constitutes “serious” misconduct
- Demonstrating “reasonable steps”
- Requirements for identifying, assessing, reporting, and addressing NFM
- Ensuring consistent, defensible outcomes
10:20 Q&A and Close
10:30 Networking
11:00 End
WHO SHOULD ATTEND
Who should attend?
HR, Compliance, Legal, Conduct, Culture, Risk, line managers, and senior leaders who are responsible for ensuring fair and consistent conduct assessments and fostering a healthy workplace culture.
Equip your teams now for the new regulatory era and ensure your firm is confident, consistent, and compliant before the FCA’s enhanced NFM rules take effect.
Spaces are limited, so register today.
SPEAKERS
David Berman, Partner, Covington
David Berman leads Covington’s financial services practice in EMEA. He advises a range of financial institutions on key regulatory compliance and investigations matters, and frequently counsels boards and senior management teams on significant regulatory issues. He specializes in tactical and strategic issue prevention, containment, and resolution, and has an outstanding track-record of achieving optimal outcomes for clients. David has extensive experience across a wide spectrum of litigation, investigations, compliance, and transactional issues, including market conduct, whistle blows, culture and conduct, risk management, systems and controls, internal investigations, individual accountability, governance, conflicts of interest, inducements, regulatory aspects of transactions, remediation and redress exercises, and conduct of business regulation generally, as well as acting as a “skilled person” under Section 166 FSMA 2000. His representative clients include: institutional investment managers, integrated investment banks, central banks, hedge funds, private equity houses, stockbroking firms, credit funds, consumer credit firms, clearing banks and corporates. David is recommended by Chambers UK and Legal 500 UK as a leading practitioner for financial services regulatory matters. He is often consulted as a subject-matter expert by industry bodies and regulators and is a frequent speaker at financial sector conferences and events.
Emily Lemaire, Associate. Covington
Emily Lemaire is an associate in Covington’s financial services practice in London. She advises clients, whether emerging or established, on complex regulatory issues relating to financial services provided both domestically and on a cross-border basis. Emily has experience advising a broad spectrum of clients in the industry, including retail, investment and corporate banks, asset managers, consumer finance providers, payment and e-money institutions, retail brokers and cryptoasset service providers. In 2021, Emily was seconded to Goldman Sachs International Bank to support the Consumer Digital Finance Team in the operation of the firm’s UK digital and consumer business, Marcus by Goldman Sachs.
Megan Evers, Associate, Covington
Megan Evers is an associate in the firm's Financial Services Regulation Group in London. She advises financial institutions, corporates, technology companies, and payment firms on a broad spectrum of financial services regulatory issues. Megan advises clients on, amongst others, corporate governance, individual accountability (SMCR), conduct and culture (including non-financial misconduct), market abuse, whistleblowing, FSMA perimeter, and the EU’s Digital Operational Resilience Act (DORA).
PRICING
Free to attend