SMCR | COCON 1.1.7FR | FIT
Non-Financial Misconduct Toolkit
Handle bullying, harassment and violence the way the FCA now expects. Templates, checklists and model policy wording for SMCR firms, built around the rules and guidance in force since 1 September 2026.
£99 + VAT | Instant download | Word and ExcelGet the Toolkit: £99 + VAT
What changed on 1 September 2026
Wider Conduct Rules
A new rule, COCON 1.1.7FR, extends the Conduct Rules at non-banking firms to bullying, harassment and violence against colleagues where there is a sufficient link to work.
Fitness and propriety
New FCA guidance explains how non-financial misconduct, including private life, social media and unproven allegations, can bear on whether someone is fit and proper.
Managers’ reasonable steps
The guidance also covers the reasonable steps managers should take to prevent and address non-financial misconduct.
The FCA says firms should have considered whether they needed to update their staff policies, conduct breach reporting, fit and proper assessments and regulatory references. Read the FCA’s summary and PS25/23.
The questions this toolkit helps you answer
- Is this a Conduct Rules matter, a fitness and propriety matter, or both?
- Is there a sufficient link to work, and how do we record our reasoning?
- What do we do with an allegation we cannot prove?
- When is someone’s private life or social media relevant, and when is it not?
- What regulatory steps follow once HR has reached an outcome?
- What should we report to the board?
What’s inside
A 12-part Word toolkit, an Excel case log and a quick-start guide.
| Part A | What changed and how to use the toolkit |
| Part B | Concern intake record |
| Part C | Triage checklist, including the work-link question |
| Part D | Investigation plan and report template |
| Part E | Fitness and propriety decision record, including unproven allegations |
| Part F | Private life and social media: points to consider |
| Part G | Outcome and regulatory actions checklist |
| Part H | Manager reasonable steps checklist |
| Part I | Culture indicators for board reporting |
| Part J | Records, confidentiality and data protection |
| Part K | Implementation readiness checklist |
| Part L | Model policy wording for your staff handbook |
| Excel | NFM Case Log with automatic days-open tracking and an 18-metric dashboard |
| Read Me First quick-start guide |
Who it’s for
Compliance officers
Connect conduct outcomes to certification, breach reporting and references.
HR leads
Run fair processes that also meet the FCA’s expectations.
Senior Managers
See how culture risk is identified, handled and reported.
Line managers
Know the reasonable steps expected of you, and record them.
Designed for FCA-authorised firms under SMCR, including advice firms, brokers, insurance intermediaries and investment firms.
Why this toolkit
- Practitioner-built. Written by Lee Werrell, Chartered FCSI, drawing on 25+ years of FCA regulatory experience.
- Follows the FCA’s own structure. Organised around the areas the new guidance covers and the areas the FCA says firms should have reviewed.
- Joins HR and compliance. Every form leads to a regulatory question: breach reporting, fitness and propriety, references.
- Keeps personal data out of MI. The case log works on reference numbers, with a dashboard for board reporting.
- Plain English and editable. Brand it, adapt it and use it for as many matters as you need.
Non-Financial Misconduct Toolkit
£99 + VAT
- 12-part Word toolkit (9 pages)
- Intake, triage and investigation templates
- Fitness and propriety decision record, including unproven allegations
- Private life and social media considerations
- Regulatory follow-up checklist
- Manager reasonable steps checklist
- Implementation readiness checklist
- Model policy wording for your staff handbook
- Excel case log with 18-metric dashboard
- Instant download
Secure payment via E-Junkie. VAT is added at checkout.
Handling a live investigation?
Pair this toolkit with our Conduct Rules Breach Investigation Toolkit, which gives you a staged investigation protocol, interview templates and a severity matrix for any Conduct Rules breach.
Running annual fitness and propriety assessments for certified staff? See the Annual Certification Assessment Template Pack, or explore our governance, risk and SMCR services.
Frequently asked questions
Does the new rule apply to my firm?
COCON 1.1.7FR extends the Conduct Rules at non-banking firms under SMCR to bullying, harassment and violence against colleagues, where there is a sufficient link to work. It does not apply to conduct before 1 September 2026. Banks already had the wider scope, but the new guidance is relevant to them too.What format is the toolkit?
A Word document you can edit and brand, an Excel case log, and a PDF quick-start guide, supplied in one download.Does it replace our HR policies?
No. It works alongside your grievance, disciplinary and whistleblowing procedures and links their outcomes to your regulatory obligations. Part L gives model wording to add to your staff handbook.Is this legal advice?
No. It is a practical framework built on the FCA rules and guidance. Employment, equality and data protection law also apply, so take advice on individual cases and before adopting the model policy wording.I bought the Premium Annual Certification pack. Do I need this?
The Premium pack already includes the core toolkit. The Standalone Edition adds the implementation readiness checklist, model policy wording and the Excel case log.Can I use it for more than one case?
Yes. Use the templates for as many matters as your firm needs.Do you offer refunds?
Because this is a digital download, we cannot offer refunds once the download link has been accessed.
Be ready before the next concern is raised
Put a fair, consistent and documented process in place today.Get the Toolkit: £99 + VAT
Need help with a live matter? Book a discovery call: https://bit.ly/CCDiscovr | UK 0800 689 0190 | Int’l 020 8243 8620
Making Compliance Work.
Compliance Consultant is a trading style of UK Compliance Consultant Limited (Companies House 14805896). We are an independent regulatory compliance consultancy and are not authorised or regulated by the Financial Conduct Authority. This toolkit is general guidance, not regulatory or legal advice, and should not be relied upon in place of advice specific to your firm’s circumstances.
Compliance Consultant | https://complianceconsultant.org | UK 0800 689 0190 | Int’l 020 8243 8620 | Discovery call: https://bit.ly/CCDiscovr
