Conduct Rules BreachInvestigation Toolkit
A complete, structured framework for investigating Individual Conduct Rules breaches under SM&CR. Templates, checklists, and FCA notification guidance included.
Trusted by Compliance Officers, MLROs, and HR Professionals across UK financial services
When a Conduct Breach is Alleged, Are You Prepared?
Poorly handled investigations create regulatory risk, employment disputes, and potential FCA scrutiny. Most firms lack a structured approach.
Inconsistent Process
Without a standardised framework, investigations vary in quality and thoroughness. This creates legal risk and undermines confidence in outcomes.
Missed Notification Deadlines
FCA requires notification within 7 business days for certain breaches. Missing this triggers regulatory concern and potential enforcement interest.
Inadequate Documentation
Poor records make it impossible to defend decisions if challenged. The FCA expects comprehensive audit trails for conduct matters.
Everything You Need to Investigate With Confidence
A 20+ page comprehensive toolkit providing the structure, templates, and guidance to conduct fair, thorough, and compliant investigations.
Individual Conduct Rules Guide
Detailed breakdown of Rules 1-5 with specific breach indicators and examples to help you identify and categorise potential breaches accurately.
Senior Manager Conduct Rules Guide
Complete coverage of SC1-SC4 with breach scenarios specific to Senior Managers and their enhanced responsibilities.
5-Stage Investigation Protocol
Structured process from initial assessment through to final report, with clear timelines (Days 1-42) and milestone checkpoints.
Breach Assessment Matrix
Severity scoring framework across Intent, Impact, Pattern, Seniority, and Cooperation factors with outcome guidance.
Evidence Collection Checklist
30+ item checklist covering documentary, transactional, communications, customer, witness, and regulatory evidence.
Interview Templates
Subject notification letter and structured interview question framework ensuring fair and comprehensive investigation interviews.
Disciplinary Recommendation Guide
Outcome matrix linking severity to appropriate actions, plus aggravating and mitigating factors framework.
FCA Notification Decision Framework
Clear guidance on when regulatory notification is required under SUP 10C and SYSC 25, with decision matrix by staff category.
Investigation Record Template
Comprehensive case documentation template capturing all key information from allegation through to outcome.
Timeline Tracker
Milestone-based progress monitoring tool ensuring investigations stay on track and deadlines are met.
Covers All Nine Conduct Rules
The toolkit provides detailed guidance and breach indicators for every Individual and Senior Manager Conduct Rule.
Rule 1: Integrity
Acting honestly, straightforwardly, and trustworthy in all professional dealings.
Rule 2: Due Skill, Care & Diligence
Performing your role competently to the standard reasonably expected.
Rule 3: Open & Cooperative
Full cooperation with regulators including proactive disclosure.
Rule 4: Customer Interests
Paying due regard to customer interests and treating them fairly.
Rule 5: Market Conduct
Observing proper standards of market conduct and integrity.
Plus Senior Manager Conduct Rules
SC1: Effective Business Control
Taking reasonable steps to ensure effective control of the business.
SC2: Regulatory Compliance
Ensuring the business complies with relevant regulatory requirements.
SC3: Appropriate Delegation
Ensuring delegation is appropriate and properly overseen.
SC4: Disclosure
Disclosing information the FCA or PRA would reasonably expect notice of.
Structured 5-Stage Investigation Process
Stage 1: Initial Assessment
Receive and log allegation, assess if conduct breach is alleged, appoint investigating officer, define scope and terms of reference.
Stage 2: Evidence Gathering
Preserve documentation, interview witnesses, review system logs and communications, gather expert input where required.
Stage 3: Subject Interview
Notify subject in writing, allow preparation time, conduct structured interview with right to be accompanied.
Stage 4: Analysis & Findings
Review all evidence, apply balance of probabilities, determine which rules were breached, assess severity.
Stage 5: Report & Recommendations
Finalise investigation report, make disciplinary recommendations, assess regulatory notification requirements.
Know When to Notify the FCA
The toolkit includes a clear decision framework for regulatory notification under SUP 10C.14.18R and SYSC 25.
| Staff Category | Outcome | FCA Notification |
|---|---|---|
| Senior Manager | Any disciplinary action | YES — within 7 business days |
| Senior Manager | Finding of breach, no action taken | YES — within 7 business days |
| Certification Person | Dismissal, suspension, clawback, demotion | YES — within 7 business days |
| Certification Person | Warning only | NO — but record for references |
| Other Conduct Rules Staff | Any outcome | NO — but maintain records |
Who Is This Toolkit For?
Compliance Officers
Leading or overseeing conduct breach investigations
HR Directors
Managing disciplinary processes for regulated staff
MLROs
Investigating Rule 1 and Rule 3 breaches
Risk Managers
Assessing conduct risk and breach severity
Get the Complete Toolkit
Conduct Rules Breach Investigation Toolkit
- 20+ page comprehensive Word document
- All 9 Conduct Rules with breach indicators
- 5-stage investigation protocol with timelines
- Breach severity assessment matrix
- 30+ item evidence collection checklist
- Subject notification letter template
- Interview question framework
- Disciplinary recommendation guide
- FCA notification decision framework
- Investigation record template
- Timeline tracker with milestones
- Key regulatory references (COCON, SUP 10C, SYSC 25)
- Instant download — start using today
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Frequently Asked Questions
What format is the toolkit?
The toolkit is provided as a comprehensive Word document (.docx) that you can customise with your firm’s branding and adapt to your specific procedures.
Is this suitable for all FCA-authorised firms?
Yes. The Conduct Rules apply to all FCA-authorised firms under SM&CR, including solo-regulated firms, banks, insurers, and investment firms.
Can I use this for multiple investigations?
Absolutely. Once purchased, you can use the templates and frameworks for unlimited investigations within your firm.
Is the content up to date?
Yes. The toolkit reflects current FCA requirements under COCON, SUP 10C, and SYSC 25 as of January 2026.
Do you offer refunds?
Due to the digital nature of the product, we cannot offer refunds once the download link has been accessed.
Can I get a sample before purchasing?
The detailed contents list above shows exactly what’s included. If you have specific questions, contact us before purchasing.
Be Ready When Conduct Issues Arise
Don’t wait until you’re facing an allegation to build your investigation framework. Get the toolkit now and be prepared.
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