COCON Conduct Rules Self-Assessment

Question 1 of 9

Did the individual act dishonestly, mislead others, or behave in a way that lacks integrity?

Examples: falsifying records, misleading clients or the FCA, acting against the spirit of regulations, concealing information.

Question 2 of 9

Did the individual fail to perform their role competently, or neglect their duties?

Examples: giving unsuitable advice without proper research, failing to follow established procedures, ignoring known compliance requirements.

Question 3 of 9

Did the individual withhold information from, or fail to cooperate with, the FCA, PRA, or other regulators?

Examples: not responding to an FCA information request, coaching staff on what to say during a supervisory visit, concealing a known breach.

Question 4 of 9

Did the individual fail to consider customers' interests or treat them unfairly?

Examples: recommending higher-charging products for personal benefit, failing to disclose material information, ignoring a client complaint.

Question 5 of 9

Did the individual engage in market abuse, insider dealing, or improper use of confidential information?

Examples: trading on inside information obtained through their role, sharing client portfolio details with third parties, market manipulation.

Question 6 of 9

Did the individual fail to act to deliver good outcomes for retail customers?

Examples: identifying unsuitable products held by clients and not acting on the finding, failing to consider Consumer Duty requirements.

Question 7 of 9

Did the individual engage in serious non-financial misconduct — such as bullying, harassment, discrimination, sexual misconduct, or violence — with a sufficient workplace connection?

PS25/23 (effective 1 September 2026): Serious NFM can breach Rule 1 (integrity) and/or Rule 2 (skill, care, diligence). The misconduct must have a work connection — at the office, work events, in work communications, or involving colleagues.

Question 8 of 9

Is the individual a senior manager (SMF holder) who failed to ensure effective control of the business area they are responsible for?

Senior manager conduct rule SC1. Examples: no documented investigation process for conduct breaches, failure to establish NFM handling procedures, inadequate oversight of compliance functions.

Question 9 of 9

Is the individual a senior manager who failed to ensure their area of the business complies with regulatory requirements?

Senior manager conduct rule SC2. Examples: failure to ensure the firm can handle NFM allegations by the PS25/23 deadline, not updating policies for regulatory changes.