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Non-Financial Misconduct Training: Key Considerations for Financial Services Firms
July 13th, 2026
Why non-financial misconduct is now a priority for financial services firms
From September 2026, new FCA regulations will place greater emphasis on firms being proactive in preventing bullying and harassment where there is a work-related link. That means this is no longer just an HR issue; it is also a culture, governance and regulatory issue.
As expectations around non-financial misconduct increase, financial services firms are reviewing how they train managers to respond. But effective non-financial misconduct training requires more than policy awareness. It must build the confidence and practical skills managers need to intervene, support colleagues and escalate concerns appropriately.
Why traditional knowledge-based training is not enough
For many organisations, the instinctive response will be to rely on existing training packages, with updated content. However, this is unlikely to have the impact needed. There is a big difference between knowing something and being able to do it. Assuming that completion of training is a sign of readiness may prove a costly mistake.
Our research found that 86% of people did nothing when they witnessed behaviour that they knew was inappropriate. Why? Because several barriers get in the way. People may be unsure whether the behaviour was inappropriate, feel a diminished sense of responsibility when others are present, fear the consequences, assume challenging it will not help, or simply not know what to say.
This is where many training programmes fall short. Too often, anti-harassment or conduct training follows a familiar pattern: explain the policy, say what is unacceptable, test recall, and assume the job is done. But if a programme does not build capability and confidence to intervene constructively, it is unlikely to deliver the results firms need.
Key ingredients for effective non-financial misconduct training
For managers to tackle inappropriate behaviour, such as harassment, any training needs to achieve four outcomes. By the end of the training, managers should:
- Recognise problematic behaviours and understand their impact.
- Feel personally responsible for responding.
- Have practical strategies to support team members, challenge inappropriate behaviour and escalate concerns, all in line with your updated policies.
- Feel confident in their ability to intervene confidently and effectively – what psychologists call ‘bystander efficacy’. That confidence does not come from information alone; it develops through discussion, rehearsal and feedback.
Each of these has a social component. If we bring managers together, we create new social norms. We build consensus over what is inappropriate, what is expected of us, and the most appropriate ways of intervening. And this builds confidence.
How do we ensure that people use the training?
Even well-designed training will fall short if the learning does not transfer into day-to-day management practice. If you are commissioning training, it’s important that the training has been designed with the end in mind – i.e. people using it in their day-to-day. It’s also important that the training has a lasting impact and continues to be used months later. Very few training programmes are evaluated, and when they are, the results are often disappointing: knowledge is quickly forgotten, and little of what is learned is applied back in the workplace.
How to improve training transfer after non-financial misconduct training
If you want your non-financial misconduct training to have a lasting impact, here are some key considerations:
- Communication of the training – learner’s motivation before the training is one of the strongest predictors of whether they will do something with it later. It affects how much people engage with the content, how much they learn and how much they use later. Be clear on the WIIFM (‘what’s in it for me?’), ensure that their managers are supportive, and that there is a clear expectation that what is covered in the training will be used later.
- Opportunity to practise – challenging inappropriate behaviour is a skill and not something that can be developed passively. Managers need to practise the behaviours that you need from them with relevant scenarios.
- Experience of the trainer – the trainer has a key role to play. They influence the learning environment and the impact of the training content.
- Peers and line managers – a trainee’s immediate work environment has a big impact on whether training is used. Are peers and line managers supportive? For a culture shift, we need to help people adapt their behaviour together, not in isolation.
The bottom line is simple: passive training will not be enough. To prevent NFM effectively, organisations need training that moves managers from awareness to action — and an environment that reinforces those behaviours long after the session ends.
If you would like to request more information on our Non-Financial Misconduct training and begin your path to FCA compliance, get in touch.