Firms must inform staff that they are subject to the Conduct Rules and take “all reasonable steps” to ensure that staff understand how the Conduct Rules apply to them.[1] The firm should provide “suitable training” in order to ensure that staff understand how the Conduct Rules apply to them[2] generally, but also the way in which specific Conduct Rules are relevant to the work individual members of staff perform.[3] In other words, Conduct Rules training must be tailored to an individual’s role.
For example, individuals who trade in markets should receive training on the specific application of Conduct Rule 5 (“You must observe proper standards of market conduct”). Similarly, individuals who deal with clients should understand how Conduct Rule 4 (“You must pay due regard to the interests of customers and treat them fairly”) applies to their role.[4]
[1] FSMA 2000, section 64B and COCON 2.3.1G
[2] COCON 2.3.2G(1)
[3] COCON 2.3.2G(2)
[4] COCON 3.2.2G(3)
As part of its Pro package, Corterum provides a range of training materials on the Conduct Rules, including specific scenarios of potential breaches drawn from real-world examples. These resources will help you meet the role-specific requirement for Conduct Rules training.
