The FCA has published a speech by Christopher Woolard, Executive Director of Strategy and Competition at the FCA, on diversity in the financial services. In his speech, Mr Woolard highlights that diversity has moved beyond being "nice to have" to being recognised as a commercial imperative for firms. While progress has been made in relation to diversity and inclusion, more needs to be done. For example, the percentage of women at the senior management level below the Board has only increased by 1.5 per cent over the last 10 years, from 14 per cent to 15.5 per cent. However, the key to diversity is broader, incorporating different voices from people with varied life experiences.

Mr Woolard emphasises that a firm’s approach to diversity and inclusion portrays a picture of the culture of the firm and the way firms treat non-financial misconduct allegations is relevant to the FCA’s assessment of the firm. In addition, Mr Woolard states that the FCA considers diversity and inclusion may have an impact on the fitness and propriety (in particular, competence and character) of senior managers. Mr Woolard flags that over the last year or so, there has been an increase in the number of reports to the FCA which concern issues of discrimination and sexual harassment in financial services. Mr Woolard suggests that anyone involved in this debate needs to think through their response carefully. The FCA is seeing some firms take a "zero-risk approach" in response to #MeToo, which, he states, “rather than having the intended effect of making women safer in the workplace, I fear may see the re-emergence of cosy boys’ clubs and men-only networks. That misses the point.”.

Mr Woolard’s key takeaway is that "non-financial misconduct is misconduct, plain and simple".