A 45-minute, CPD-assessed course on raising a concern in a firm where the person named in the policy may be the person you are worried about. What counts, what protects you, which FCA rules actually reach you, and when to go straight to the regulator. Scheduled, chased and certified for you.
Most of SYSC 18 binds larger banks and Solvency II insurers. A fund manager, MIFIDPRU investment firm or advisory firm told it must appoint a whistleblowers' champion is being told something that is not true. This is what does apply.
A smaller firm may adopt these as best practice, scaled to its size.
Written for a firm of fifteen to sixty people, without an ethics hotline or an internal audit function, because that is where almost everybody sitting it works.
The working definition of a reportable concern, why it is far wider than fraud, and why it expressly includes a breach of the firm's own policies. Includes a filmed scenario.
An honest answer about scope: most of the FCA's detailed whistleblowing rules bind larger banks and insurers, not a smaller investment or advisory firm. The parts that do reach you, the rule on internal reporting channels most MiFID firms do not know applies to them, and what a whistleblowers' champion does.
The protected disclosure regime that runs alongside the FCA's rules: what makes a disclosure qualify, telling the right person, and what is not a condition of protection.
Two words people use interchangeably that are not the same, which to choose and what each costs the concern, and victimisation in the quieter forms it takes in a small firm.
The problem with small firms, where the policy often names the person you are worried about. What actually happens when you contact the FCA, and why a confidentiality clause or settlement agreement cannot stop a protected disclosure. Includes a filmed scenario.
Three things, one of them a “do not”. Why not to investigate, what to do if somebody brings a concern to you, where this meets non-financial misconduct, what to expect afterwards, and where to get advice that is not your employer.
The real reason people say nothing in a small firm is that every route runs through somebody they work with. The course names that, and gives them a way through it. By the end, a learner can:
Two short films, shot for Fundsure with the same cast across the catalogue. In one, a colleague notices differences in a reconciliation that a senior manager has already signed off. In the other, the person the whistleblowing policy says to go to is the person whose conduct is the concern. After each, the learner chooses what to do, and is told why the tempting answers are wrong: working through the differences first to prove the point, waiting until things settle, gathering the evidence before speaking, or raising it with the partners first.
The test at the end draws 10 questions from a bank of 30, with a pass mark of 80%, and a pass issues a named, CPD-marked certificate that anyone can check online.
The FCA regards detriment to a whistleblower as able to call into question the fitness and propriety of the firm and of the people responsible. A firm protects itself best by making sure staff know what counts, how to raise it, and that they can go to the FCA directly when the internal route is the problem.
In the Fundsure Portal the course is scheduled for everyone, chased before the deadline, and every sitting, score and certificate is kept and carried into the compliance officer’s report to the board.
How the portal runs trainingWhistleblowing plus Conduct Rules, Non-Financial Misconduct, AML and CTF and the rest of the catalogue of 20, with no per-course fees.
Bullying, harassment and violence under the Conduct Rules: more of what is raised is now regulatory too.
See the courseOpenness with the regulator, breach reporting and speaking up when the normal route is the problem.
See the courseWho is answerable for what, and fitness and propriety.
See the courseRunning the compliance function, including breaches and the board's view of them.
See the courseWe will send you a link to take the whole course, filmed scenarios and test included, or walk you through the portal with a demonstration firm.
