Code of Conduct (COCON) for senior managers, certificated staff and staff generally

INTRODUCTION TO COCON

A one-half day workshop or two half days

 

INTRODUCTION

Training objectives

Background to COCON and its role in the Senior Management Regime

Origins of COCON in APER and FSA/FCA enforcement experience

Sanctions for breach of COCON

 

THE SCOPE OF COCON

To whom does COCON apply?

What applies to whom?

To what conduct does COCON apply?

Where does COCON apply?

 

IMPLEMENTING COCON

Training

Assessing COCON Compliance

FCA factors for considering whether COCON has been broken and when to take enforcement action

 

INDIVIDUAL CONDUCT RULES AND EXAMPLES OF THEIR BREACHES

1. Integrity
2. Due skill, care & diligence

For individuals

For managers

For directors

1. Open & co-operative with all regulators
2. Due regard to customers’ interests and treat them fairly
3. Proper standards of market conduct

 

SENIOR MANAGER CONDUCT RULES AND EXAMPLES OF THEIR BREACHES

Reasonable steps to ensure

• Business for which you’re responsible

1 is controlled effectively

2 complies

• Generally

3 Any delegation to appropriate person & you oversee discharge of responsibilities effectively

4 Disclosure appropriately of information which regulators would expect to receive