Culture evidence for FCA-regulated firms: what a complaint log can’t tell you.
The policy work is largely done: handbooks updated, definitions agreed, investigation routes written down. What most firms do not yet have is evidence that their culture is what their policies say it is.
On this page
Five sources of independent culture evidence, and where most firms start.
The rules are live. The question now is evidence.
Since 1 September 2026 the FCA’s rules on non-financial misconduct have applied to every firm with a Part 4A permission. The FCA has said plainly that it expects firms to make it possible for staff to speak up, to take allegations seriously, and to have systems that identify, investigate and put right non-financial misconduct promptly. Each of those is something you can measure rather than assert.
When a supervisor, an auditor or your own board asks how you know your culture is what your policies describe, a complaint log is a thin answer. The firms that will be comfortable in that conversation are the ones holding independent, dated evidence of what their people actually experience.
What counts as evidence
Whether people would speak up
A periodic, anonymous audit of whether staff have seen or experienced harassment and whether they would report it, alongside a confidential channel that sits outside the line of management. You learn what is happening that has not reached a formal complaint, and whether your speak-up arrangements are trusted. That second point is the one a tribunal or a supervisor will ask about.
What leavers say
Poor behaviour often surfaces first at exit, from people who no longer have anything to lose by saying so. Asked independently, while still working their notice, leavers describe conduct and culture with a candour an internal interview rarely gets – and patterns by team and by manager show where to look. Senior and board-level departures carry the highest regulatory stakes and deserve their own process.
Culture across the firm, measured the same way over time
Regular, comparable measures of trust, fairness, psychological safety and confidence in leadership, broken down so that differences between business units are visible rather than averaged away.
How leaders are experienced
360 feedback on senior managers from the people who work with them is useful evidence alongside conduct and fitness assessments, and a constructive route to change rather than a disciplinary one.
What new joiners notice
People in their first months see a culture before they have adapted to it. They notice what long-serving staff no longer do.
Built for the people who will rely on it
Evidence of this kind is only useful if it is written for a board and a regulator, not only for HR: trend data, breakdowns by business area, and a short account of what has changed and what needs attention, mapped to the firm’s own conduct-risk framework. Independence matters here too. The evidence has to come from outside the line of management it describes, or it is the firm marking its own homework.
What measurement does not do
It does not investigate individual cases, give legal advice or decide whether conduct breaches the rules. Those decisions stay with the firm and its advisers. What independent evidence provides is a reliable account of where to look, and, over time, whether what you have done is working.
Where firms start
Most start with one source of evidence and add others. Leaver evidence is the quickest to stand up and the hardest to argue with; a speak-up audit answers the question the regulator is most likely to ask. Either gives a compliance function something it has rarely had: a number, a trend and a dated record, rather than an assurance.
For the related duty on employers to prevent sexual harassment, and the evidence it calls for, see The duty to prevent sexual harassment: the evidence a policy can’t give you.
Sources: FCA Policy Statement PS25/23 on non-financial misconduct, in force 1 September 2026 for FSMA firms with a Part 4A permission; FCA culture and non-financial misconduct survey findings, October 2024 (paraphrased, not quoted). great{with}talent provides SafeSpace (speak-up), LastOpinion (leaver intelligence, including Executive Exit), WinningFormula (engagement and pulse), FeedForward (360) and OnBoarder (new joiners). Data is hosted in the UK and handled under UK GDPR; we are Cyber Essentials certified. This page is not legal advice.
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