On 11 November 2015, the FCA’s Director of Enforcement and Market Oversight, Mark Steward, delivered a speech on culture and governance. He recommended that a company should ensure that, in addition to rules and standards, it has:

  • an effective understanding of the nature of its business, and, particularly, how the front line, middle management and senior management actually operate;
  • effective (i.e. implemented, maintained and reviewed) systems and controls to ensure that the business is operating effectively and in accordance with standards of conduct that senior management have designed and approved; and
  • a healthy dose of reality to check whether the rules and standards that exist are good or even working.