Conduct Risk Policy (UK) by Study Academy
Conduct Risk Policy outlines a risk-based framework to prevent harmful behaviours including conflicts of interest, misrepresentation, and abuse of authority. Developed by the Study Academy's Compliance & Governance team, specialists in UK regulatory and workplace-culture training.
Conduct Risk Policy (UK, 2025 Edition)
Purpose
This Policy establishes the organisation’s framework for identifying, assessing, managing and mitigating conduct risk, being the risk that staff behaviour or business practices result in poor outcomes for customers, counterparties, employees or the market.
Scope
Applies to all business activities, product development, sales and marketing, procurement, and senior management decision-making.
Policy Statement
The organisation will conduct its business with integrity, due skill, care and diligence. Staff must act ethically and must not engage in conflicts of interest, misrepresentation, abuse of authority or any conduct that could harm customers or the organisation’s reputation.
Conduct Risk Principles
Treat customers fairly and with respect.
Communicate clearly and transparently.
Avoid, manage or disclose conflicts of interest.
Escalate conduct issues promptly.
Maintain accurate records of advice, decisions and customer interactions.
Legislative and Regulatory Framework
Companies Act 2006 (directors’ duties)
Bribery Act 2010
Equality Act 2010
Data Protection Act 2018 and UK GDPR
Health and Safety at Work etc. Act 1974
Roles and Responsibilities
The Board is accountable for setting the tone from the top on ethical conduct and culture.
Managers must ensure that performance incentives do not encourage poor conduct.
Staff must report misconduct or wrongdoing under the Whistleblowing Policy.
Monitoring and Reporting
Conduct MI (management information) shall be collected, including complaints, errors, near misses, disciplinary actions and training completion.
Serious conduct breaches shall be reported to the Board.
Training
All staff shall receive conduct and ethics training on induction and annually thereafter.
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England & Wales note
This version is drafted for England & Wales. Scotland and Northern Ireland differ on some points — for example notice periods and tribunal procedure. Tell GitLaw where you hire and it adjusts the draft.
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