How to handle non-financial misconduct without damaging organisational culture, with former Standard Chartered surveillance chief Emily Wright and conduct risk consultant Emma Parry

Feb 10, 2026

Guest

Emma Parry

Guest

Emily Wright

Emily Wright, a compliance and conduct consultant with 20+ years at major banks, and Emma Parry, founder of NovaFin and former HSBC conduct lead, discuss tackling non-financial misconduct. They cover regulator shifts, why firms struggle to apply principles, the role of remediation versus punishment, the new Conduct Compass framework, and practical steps firms can take now to protect culture and consistency.

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INSIGHT

FCA Shifted From Principle To Practical Scrutiny

The FCA's approach to non-financial misconduct evolved from early statements to an outcomes-focused policy in December 2025 that asks firms to demonstrate how they handle NFM in practice.
Emma Parry highlights the shift from principle statements to regulators now examining firm-level implementation and practical responses.

ANECDOTE

Edible Tassels Example That Shaped A Decision

Emily recalled a real disciplinary case where a new hire gave a risque secret Santa gift, apologized, lost their bonus but kept their job.
The example shows how remorse, context and firm judgment led to a remediation rather than dismissal.

ADVICE

Run Scenarios Using Your Actual Case Data

Start by mapping the types and volumes of NFM cases your firm already sees to create data-driven scenarios for policy application.
Emma Parry recommends using those scenarios to test intent, impact and thresholds against COCON guidance before deciding processes.

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Today’s episode is part of a Following the Rules series delivering practical guidance on navigating legal, regulatory, technological and cultural change.

In this episode, we turn to one of the most challenging and fast-evolving areas of regulatory focus: non-financial misconduct. With the UK’s Financial Conduct Authority set to introduce new rules this year that explicitly bring serious non-financial misconduct within scope of the conduct rules, expectations on firms to identify NFM, address it early, and evidence fair and consistent outcomes are rising fast. And this isn’t just a UK story: regulators globally are paying much closer attention to culture, behaviour and individual conduct.

So what does good look like when regulatory guidance is deliberately principles-based? Why are firms still struggling to translate expectations into defensible decisions? And how can they respond to lower-level misconduct in a way that genuinely supports culture, rather than quietly undermining it?

Joining me to explore these questions are:
- Emily Wright, a compliance and conduct consultant with over 20 years’ experience, including senior roles at Standard Chartered, JP Morgan and ICAP, and,- Emma Parry, the Founder and CEO of NovaFin Consulting and former Global Head of Product Governance and Conduct in HSBC’s Global Banking and Markets division.

Together, we unpack what the FCA’s rule changes mean in practice, where firms are getting stuck, and why remediation, not just punishment, is becoming a critical part of the conduct conversation. We also discuss the launch of the Conduct Compass, a new framework designed to help firms address non-financial misconduct earlier, more consistently, and in a way that drives real behavioural change.

If you’re grappling with how to make conduct frameworks work on the ground, and how to get ahead of regulatory expectations on culture, this episode is for you.

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Download the Conduct Compass white paper here: https://go.ewrightconsulting.com/free-conduct-compass-wp-lm