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Why Wealth Management Firms Must Prioritise PEPs and Sanctions Screening

By employing PEPs and sanctions screening tools, wealth management firms can identify and avoid high-risk individuals and entities. Integrating AML practices ensures a transparent operating environment, fostering client confidence and preserving the firm’s integrity.

Achieving and Maintaining Regulatory Compliance

Regulatory expectations in wealth management are stringent, with a strong emphasis on preventing money laundering and financial crime. The FCA has highlighted its intrusive supervisory approach, with unannounced visits and increased scrutiny of firms’ compliance measures. Non-compliance could lead to severe penalties and legal ramifications.

PEPs and sanctions screening solutions enable firms to meet these regulatory requirements by flagging politically exposed and sanctioned individuals. Robust AML screening, ensures adherence to regulatory frameworks, helping firms avoid costly penalties and demonstrating their commitment to ethical operations.

Mitigating Risk

Due diligence is a cornerstone of wealth management, where the stakes are high, and risks must be meticulously managed. PEPs and sanctions screening solutions empower firms to conduct thorough background checks, uncovering potential risks associated with politically exposed clients or blacklisted entities. By proactively addressing risks, wealth management businesses can protect their clients, assets, and reputation.

Driving Operational Efficiency

Manual AML compliance processes can hinder the efficiency of operations, causing frustrating delays when onboarding high-value clients and increasing operational costs. Automated PEPs and sanctions screening, powered by advanced AI, accelerates onboarding, ensuring real-time due diligence with accurate results.

Screening tools that incorporate AI reduce the burden on compliance teams by catching sophisticated AI-fraud and reducing instances of inaccurate false-positive results. When AML compliance with regulatory standards is automated and accurate, this frees wealth managers and advisors to focus on client engagement and strategic growth.

Strengthening Global Collaboration and Information Sharing

The fight against financial crime transcends borders, requiring cooperation across industries and jurisdictions. For wealth management firms operating internationally or with diverse client bases, access to up-to-date information on PEPs and sanctioned entities is critical.

Leveraging shared databases and collaborative networks enhances the accuracy of screening processes, aligning firms with global efforts to combat financial crime. This proactive approach reinforces the firm’s standing as a responsible participant in the financial ecosystem and supports long-term sector resilience.

Conclusion: A Call to Action for Wealth Management Firms

Wealth management companies operate in a high-risk, high-trust environment where client relationships and compliance are paramount. Ignoring the risks posed by money laundering, terrorist financing, and other financial crimes is not an option. By prioritising PEPs and sanctions screening alongside AML compliance and electronic identity verification, wealth management firms can safeguard their reputation, mitigate risks, and improve operational efficiency.

Adopting these measures is not only a regulatory requirement but also a step towards building a more transparent, secure, and ethical financial future. Firms that embrace these practices will be better positioned to navigate the complexities of the financial landscape, delivering exceptional outcomes for their clients and stakeholders.

Key Takeaways

  • Robust Screening is Essential: Wealth management firms must implement effective PEPs and sanctions screening to protect against money laundering, terrorist financing, and other financial crimes.
  • Reputation is at Stake: Failing to screen clients properly can result in reputational damage, loss of client trust, and diminished market standing.
  • Regulatory Compliance is Non-Negotiable: Adhering to stringent AML regulations is critical to avoid penalties and maintain operational integrity.
  • Proactive Risk Mitigation Pays Off: Enhanced due diligence processes reduce exposure to high-risk individuals and entities while safeguarding firm operations.
  • Efficiency and Collaboration Drive Success: Leveraging technology for automated screening and engaging in global information-sharing strengthens financial crime prevention efforts.

If you would like to discuss how digital identity verification and AML screening can benefit your wealth management practice, please feel free to email me: alex@id-pal.com or connect with me on LinkedIn here.

Alexander Blayney, Head of Strategic Partnerships and Enterprise Sales, id-pal

PIMFA response to Modernising the redress system

O-IM Three Years Of Solid Performance

O-IM’s Investment Team will reflect on their three-year track record, discuss the key drivers behind the performance, and share their outlook for the months ahead.

For more information contact john.muir@o-im.co.uk, 07821 535587 or click here.

Scotsman Investment Business Breakfast

 

The Scotsman Investment Business Breakfast will show investors how to best position themselves in the financial year to come. This year’s conference will cover a wide range of themes, such as impacts of global shifts on investment, trends for 2025, the importance of sustainability and alternative investments.

The 2025 event will be a breakfast event providing the opportunity to discuss and debate a broad spectrum of investment-related issues in the current economic climate, with a focus on the future.

For more details, please get in touch with the event manager, Cameron Henderson- cameron.henderson@nationalworld.com

Morningstar Investment Conference UK

Don’t miss the 19th edition of the Morningstar Investment Conference UK on May 7, 2025, at Sancroft, St. Paul’s, London!

This engaging one-day event offers valuable insights into market trends, strategies, and research tailored for financial advisers and fund selectors. With customised content tracks, attendees can choose the topics that matter most to them. Leading experts and influential speakers will address the key issues shaping the investment landscape.

Expect dynamic presentations, interactive panel discussions, and excellent networking opportunities covering market outlooks, portfolio management, investment strategies, and regulatory updates. Stay ahead in today’s fast-paced market—register now.

Any question please contact: Sarah Rouse or email: investment.conferenceuk@morningstar.com

PIMFA response to Quarterly Consultation CP24/26 – Corrections and clarificatory amendments to the Sustainability Disclosure Requirements (SDR)

Wealth Management: Finding the Industry’s iPod Moment

Wealth Management: Finding the Industry’s iPod Moment

When I left my first city job back in 2006, my colleagues gifted me an iPod. At the time, I didn’t fully grasp its value and left it boxed for over a year. Eventually, I gave it a go, and it completely transformed the way I experienced music. My CD collection, once a source of pride, was relegated to memorabilia, later encased in a friend’s clear flooring—a quirky reminder of the shift in how music was consumed.

This experience feels oddly parallel to where we stand in WealthTech today. The industry is brimming with innovative technology, but its value remains underappreciated or misused. Much like my pre-iPod music world, wealth management is struggling with outdated systems and the challenge of integrating new tools into a legacy infrastructure. Without a unifying leap forward—a “Bluetooth moment”—we risk limiting the full potential of emerging advancements.

The Industry’s Tipping Point

Nearly half of IFAs (Independent Financial Advisers) are expected to retire in the next five years. This inevitable shift is fuelling a wave of consolidation and represents a golden opportunity for the next generation of business leaders to reshape the status quo. Digital transformation is no longer optional; it’s essential. However, transformation doesn’t have to mean adopting fully automated robo-advisors. Instead, it’s about harnessing technology to improve efficiency and refocus on what truly matters: building relationships and delivering value.

A significant roadblock is integration—or the lack thereof. Across the supply chain, too much time is spent transferring data manually between systems. In few other sectors do key personnel waste so much time wrestling with outdated processes. My iPod moment came when a colleague helped me load my entire music library. Suddenly, I had access to a vast collection, streamlined for every context: jogging, reminiscing, or hosting a party. It revolutionised my relationship with music, much like better integration could redefine wealth management workflows.

Streaming, But Not Yet Streaming-Ready

In a previous blog, I touched on the need for streaming-style services in wealth management: low-cost, high-accessibility, and client-centric solutions. But the reality is that many businesses aren’t ready for this kind of disruption. Without tackling the challenge of integrating legacy systems, the industry risks skipping a crucial evolutionary step.

Wealth management has yet to experience its iPod moment, let alone its Spotify revolution. To unlock the benefits of cutting-edge technology, we must first embrace solutions that bring cohesion between the old and the new. The tools for automation and AI are already accessible; what’s missing is a willingness to take that leap, often requiring a champion within the organisation to show the way.

Platform 3.0:

Consider the emergence of Platform 3.0, the new generation of investment platforms. These promise richer functionality, tighter integration, and even innovative business models, such as Adviser-as-a-Platform. However, integration challenges remain. Asset allocation processes, for example, are still disconnected. Similarly, portfolio products rely on a supply chain push model with minimal coupling due to a lack of straight-through processing. Advisors influence where assets are directed, but the upstream inefficiencies often go unnoticed.

In an integrated ecosystem, the industry could achieve far more. Advisors could offer bespoke products tailored to specific investor groups, while discretionary portfolio managers could keep allocations aligned with greater precision. Platforms would better manage liquidity and inventory, and fund managers at the top of the chain could expedite the release of funds and special share classes. The result? More choice, lower costs, enhanced risk management, and improved outcomes for end investors.

Andrew Spence, of Aspen Advisers, has often presented the game changing effect that multi-platform integration could have on the model portfolio (MPS) landscape.

Commenting on his vision, he stated that “The Aspen business was initially going to be fully customisable portfolios – the optimal mix of assets for a client’s circumstances and needs – in a move away from traditional “cookie cutter” models. But it was a non-starter across multiple platforms. So, we needed to scale that back and offer advisers a complete CIP experience using model portfolio building blocks. Still, multi-platform integration of this scale takes time and resource. Better integration is badly needed”.

Tikker are working with Aspen to automate Portfolio Operations cross-platform, bringing this evolution within reach.

Overcoming the CD Era

Right now, the wealth management industry feels stuck in its pre-iPod phase—juggling stacks of CDs, painstakingly organising them, and dealing with inefficiencies that make progress feel like an uphill climb. Worse still, these inefficiencies ripple through the supply chain, consuming valuable time and increasing the risk of errors.

What’s needed is an iPod moment: a unifying system that bridges legacy technology and modern tools, streamlining processes to unlock new possibilities. With integration and automation, the industry can shed its clunky inefficiencies, empowering advisors to focus on delivering genuine value to clients.

The Next Generation’s Opportunity

The next wave of wealth management leaders holds the key to this transformation. They must embrace technology not as a threat but as an enabler of better client experiences and operational efficiencies. This might mean prioritising solutions that balance creditworthiness with operational risk, acknowledging the role of custodians in securing holdings.

By bridging the gaps between legacy and modern systems, the industry can evolve into something far greater. The question is whether today’s leaders will seize the opportunity—or let it pass, leaving the wealth management sector to languish in an outdated era. For those ready to embrace change, the tools are already within reach. What’s needed now is the courage to press play.

 

Tom Whittle, Founder, Tikker

tom.whittle@tikker.co.uk

PIMFA response: Financial Services Growth & Competitiveness Strategy

PIMFA Response Papers

PIMFA responds on behalf of our membership to numerous key issues within our industry.

PIMFA Response Papers

PIMFA responds on behalf of our membership to numerous key issues within our industry. We do this via vital feedback and discussion with member firms via our committees, working parties and industry forums.

From this member feedback PIMFA create responses to consultation documents and discussion papers issued by bodies such as the UK’s regulator, the Financial Conduct Authority (FCA), Government departments and many European and International bodies.

Found 234 Results
Paper Type: PIMFA Response Papers
Recipients: Home Office UK
Month Published: May 18, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: May 12, 2026
Paper Type: PIMFA Response Papers
Recipients: Cabinet Office
Month Published: May 7, 2026
Paper Type: PIMFA Response Papers
Recipients: HM Treasury
Month Published: April 9, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: March 31, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: March 6, 2026
Paper Type: PIMFA Discussion Papers
Recipients: UK Listing Authority (managed by the FCA)
Month Published: March 6, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: February 20, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: February 19, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: February 2, 2026
Paper Type: PIMFA Response Papers
Recipients: The Financial Ombudsman Service (FOS)
Month Published: January 27, 2026
Paper Type: PIMFA Response Papers
Recipients: Financial Conduct Authority (FCA)
Month Published: January 27, 2026

The scope of regulation is increasing all the time and one of PIMFA’s key objectives is to ensure this regulation is proportionate and fair, bringing real benefits to the investment management and financial advice community and their clients.

Past consultation responses from WMA and APFA can be accessed via their respective archives.

PIMFA Journal Edition #29

PIMFA delighted to welcome two new members to its Board of Directors

21st November 2024

PIMFA delighted to welcome two new members to its Board of Directors

PIMFA, the trade association for wealth management, investment services and the financial advice and planning industry is delighted to welcome Andy McGlone, Chief Executive of Quilter Cheviot and Charley Davies, General Counsel at Evelyn Partners who joined its Board of Directors this month (November 2024) and bring with them a fantastic array of skills and experience.

Andy was appointed Chief Executive of Quilter Cheviot in January 2019, and of Quilter Cheviot Financial Planning in January 2022. Previously, he was Head of Quilter Cheviot’s London office with overall responsibility for the front office functions based out of its Head Office, including the private client investment teams, and the research and dealing teams and was Managing Director of London Investment Management from 2015 to 2018.

Charley joined Evelyn Partners in 2022 as Group General Counsel from Provident Financial Group PLC, the London Stock Exchange listed specialist bank, where she was Group General Counsel and Company Secretary. Prior to this she served as General Counsel and Company Secretary at Cabot Credit Management. During her time at Cabot, she also served on the Board of their industry body, the Credit Services Association as a Non-Executive Director. She has also held senior positions at Lockton, the insurance brokerage, and insurer RSA group.

Liz Field, Chief Executive of PIMFA, commented: “I am delighted to welcome Andy and Charley to our Board. Their skills, experiences and expertise will be an invaluable resource and a fantastic addition to PIMFA. I look forward to working with them all as we continue to deliver member value on a myriad of critical issues across our industry. Their strategic insights and direction on how we rise to meet the challenges, opportunities and priorities for the years ahead will be vital”.

Andy McGlone, Chief Executive, Quilter Cheviot, said: “PIMFA plays an important role in our industry, and I am looking forward to working with Liz, the PIMFA team and my colleagues on the Board to champion financial health across the UK. Through this work we will continue to support members and their clients and push for positive change as the face of our industry continues to evolve”.

Charley Davies, General Counsel, Evelyn Partners, commented: “As the voice of the industry, PIMFA represents the sector to government and the regulators alike. I look forward to being part of the Board to help direct our priorities as the regulatory, political and economic landscape continues to evolve and we address the various complexities and challenges this brings to ensure we support our member firms and their clients at every turn”.

 

NOTES TO EDITORS

About PIMFA – the Personal Investment Management & Financial Advice Association

  • PIMFA is the trade association for firms that provide wealth management, investment services and the investment and financial advice to everyone from individuals and families to charities, pension funds, trusts and companies.
  • The sector currently looks after £1.65 trillion in private savings and investments and employs over 63,000 people.
  • PIMFA represents both full and associate member firms. Full members provide a range of financial solutions including financial advice, portfolio management, as well as investment and execution services. They assist everyone from individuals and families to charities and pension funds, all the way to trusts and companies.  Associate members provide professional services to the PIMFA community.
  • PIMFA leads the debate on policy and regulatory recommendations to ensure that the UK remains a global centre of excellence in the wealth management, investment advice and financial planning arena. Our mission is to create an optimal operating environment so that its member firms can focus on delivering the best service to clients, providing responsible stewardship for their long-term savings and investments.
  • PIMFA was created in 2017 as the outcome of a merger between the Association of Professional Financial Advisers (APFA) and the Wealth Management Association (WMA) with a history as a trade association since 1991 – read more.
  • Further information can be found at pimfa.co.uk

Contact

For further information on this release or other press matters please contact:

Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk,
+44 (0)20 7011 9869 / +44 (0)7979 493225.

Increasing pay transparency and pay equity: a global issue

Pay transparency, both as a value in itself and as an element of pay equity, is rapidly becoming a pivotal issue across the globe. Driven by legislation, regulatory activity, and cultural expectations, the rapid pace of change makes it essential for organisations to stay informed and prepared.

In this session our panel of lawyers from the U.S., UK, Ireland and Belgium will review the trends in pay equity and transparency across the globe, providing insights into possible future directions of pay transparency and equity measures.

We will also more specifically explore the current status of pay transparency/equity requirements in the U.S., UK and in the EU, including in relation to the EU Pay Transparency Directive, and will then consider how in practice organisations are addressing compliance requirements on an international scale.

Key topics will include:

– The history and evolution of pay transparency and its relationship with pay equity
– Where we are now in key jurisdictions and a comparative analysis of practices in the U.S., the EU, the UK amongst others
– Practical steps and strategies for organisations
– Future trends and what organisations need to be doing to plan for the future

Who should attend this session?

This webinar will be of interest to HR directors/managers, in-house counsel, and compliance professionals from global organisations particularly those with responsibility for operations in the U.S., UK and Europe.

Increasing pay transparency and pay equity: a global issue

Pay transparency, both as a value in itself and as an element of pay equity, is rapidly becoming a pivotal issue across the globe. Driven by legislation, regulatory activity, and cultural expectations, the rapid pace of change makes it essential for organisations to stay informed and prepared.

In this session our panel of lawyers from the U.S., UK, Ireland and Belgium will review the trends in pay equity and transparency across the globe, providing insights into possible future directions of pay transparency and equity measures.

We will also more specifically explore the current status of pay transparency/equity requirements in the U.S., UK and in the EU, including in relation to the EU Pay Transparency Directive, and will then consider how in practice organisations are addressing compliance requirements on an international scale.

Key topics will include:

– The history and evolution of pay transparency and its relationship with pay equity
– Where we are now in key jurisdictions and a comparative analysis of practices in the U.S., the EU, the UK amongst others
– Practical steps and strategies for organisations
– Future trends and what organisations need to be doing to plan for the future

Who should attend this session?

This webinar will be of interest to HR directors/managers, in-house counsel, and compliance professionals from global organisations particularly those with responsibility for operations in the U.S., UK and Europe.

How employers can manage the increasing mental health issues amongst younger workers

Contact details: Stephanie Pollard (stephanie.pollard@clydeco.com) | +44 7843 833 106

Mental ill health is one of the leading causes of sickness absence in the UK but look beyond the headline statistics and we see that younger workers are disproportionately impacted by mental health issues.

Join us for a special webinar where Counselling Psychologist Mr Simon Brittz from HCA Healthcare will join Employment Partner Chris Holme to look at how employers can manage the rising mental health issues amongst younger workers 💼

Our speakers will give their expert insights on what is driving the rise in mental health issues among younger workers, spotting the warning signs that an employee is experiencing difficulties and key practical steps employers can take to support their employees, manage legal risks and prepare managers to deal with mental health issues.

📆 28 November, 12:30-1:30PM GMT

Unlocking the Potential of Private Markets in Wealth Management

Join Mercer for an insightful event designed specifically for wealth managers looking to enhance their understanding and implementation of private market investments. This gathering will provide a unique opportunity to explore the evolving landscape of private markets and their integration into wealth management strategies.

Joined by guest speakers, Mercer will explore:

• Insights from a real-world example of how to implement private market solutions for clients
• CIO perspectives on private markets and challenges of portfolio integration
• How to incorporate both illiquid and liquid asset classes into a Strategic Asset Allocation framework
• Key considerations and due diligence practices when allocating to General Partners in private markets

This event is tailored for select wealth managers who are eager to unlock the potential of private markets and enhance their investment strategies. Whether you are looking to deepen your knowledge, network with peers, or gain practical insights, this event promises to deliver valuable content and connections.

To book and for more information click here

“I Want to Break Free” (from Operational Complexity): Building Scalable Wealth Management Operations for Growth

Imagine wealth managers humming along to Queen’s “I Want to Break Free”, but with a twist: the tune becomes an anthem not just for freedom from constraints, but from the web of operational complexity. Just as Freddie Mercury sang of breaking free from constraints, today’s wealth managers are being driven to shed operational burdens, streamline processes and rethink their operating models.

So how can they “break free”?

In an industry where client demands are increasing, wealth managers face the complex task of balancing operational efficiency with comprehensive service offerings. As financial products and channels proliferate, traditional operating models become cumbersome and costly, requiring wealth management firms to rethink their approach.

Historically, firms have relied on management frameworks to streamline processes and reduce costs, but these efforts often yield only temporary gains. To achieve sustainable efficiency, wealth managers need to move from short-term fixes to strategic programmes that refine the entire operating model. This means aligning cost reduction with long-term goals, and distinguishing between essential complexity that drives value and redundancy that dilutes it. Embracing advanced technology is essential as automation, data analytics and self-service options reshape both back- and front-office productivity. This technology-driven transformation frees up advisers to focus on value-adding tasks, ultimately improving the client experience while reducing overheads.

But successful transformation goes beyond technology. A systematic, holistic approach that prioritises projects based on tangible outcomes – targeting both internal efficiencies and client-facing improvements – has proven most effective. For example, by establishing KPIs that track real productivity improvements, firms can more accurately measure the impact of their investments and adapt in real time to evolving market needs.

Back-office transformation is emerging as a cornerstone of operational excellence, linking efficiency to revenue growth. By embracing these strategies, wealth managers are positioning themselves not just to meet today’s demands, but to lead the industry with adaptable, scalable models that are poised for future success.

Tariq Khan

Head of Sales and Business Development, Objectway

tariq.khan@objectway.com

PIMFA response to Accelerated Settlement Taskforce, Technical Group Draft Recommendations Report & Consultation

PIMFA’s submission to Call for Input (CfI): Review of requirements following the introduction of the Consumer Duty

Budget changes will be hard felt by retail investors and the Government must now prioritise stability to build investor confidence

30th October 2024

Budget changes will be hard felt by retail investors and the Government must now prioritise stability to build investor confidence

Headline changes to the rate of capital gains tax and inheritance tax announced in today’s Budget risk stymying future investment and introducing unwanted confusion for personal financial planning, PIMFA, the trade association for wealth management, investment services and the financial advice and planning industry warned.

High amongst the concerns is the decision to increase the rate of Capital Gains Tax to 18% and 24%, respectively, which could have a detrimental impact on consumer willingness to save and invest in the UK. This is particularly so given the fact that substantial increases in the headline rate have not been accompanied by a change in the threshold, which has been eroded substantially over the previous 5 years.

Whilst PIMFA supports the Government’s decision to freeze the inheritance tax threshold until 2030, it notes that substantive changes to reliefs associated with this regime risk introducing additional complexity into the financial planning process as well as the potential to diminish the value of previous estate planning, specifically related to pensions.

Accepting that difficult decisions have had to be made, PIMFA has strongly urged the Government to ensure that these substantive changes are not likely to be further changed over the course of this Parliament. Whilst the changes are unwelcome, the Government needs to ensure it now prioritises stability in the taxation framework and guard against making tweaks in the future in pursuit of making up fiscal shortfalls.

Commenting on today’s Budget, Simon Harrington, Head of Public Affairs at PIMFA said: “Savers and investors will draw little consolation from the fact that measures announced in the Budget by the Chancellor today could have been worse.”

“We accept that the Chancellor has sought not to place a burden on working people (however this government chooses to define them), but in targeting Capital Gains Tax (CGT) in particular, this government risks stymying the very investment it seeks to stimulate economic growth. The government’s desire to utilise capital from pension funds to aid this has been much discussed, and we urge them not to needlessly erect further barriers for retail investors who can also play a crucial role in delivering growth.”

“Whilst we welcome the government’s extension of the inheritance tax threshold, the decision to change reliefs associated with it as well as the decision to bring pensions in scope will impact the effectiveness of people’s financial plans across the country and – in some cases, it may introduce doubts about the value of previous estate planning advice – specifically advice related to pensions. The value of financial advice is the certainty of outcome it can provide, and the confidence consumers can draw from that as a result. Constant tinkering with this regime diminishes the perceived value of holistic financial planning in particular.”

‘Going forward, the Government should prioritise stability over future changes. We have been very clear that the government should adopt a taxation roadmap for personal taxation similar to the approach outlined for businesses in this Budget. Doing so would be enormously helpful and reassure savers and investors who need the confidence to know how their wealth will be treated both in accumulation and decumulation.”

 

NOTES TO EDITORS

About PIMFA – the Personal Investment Management & Financial Advice Association

  • PIMFA is the trade association for firms that provide wealth management, investment services and the investment and financial advice to everyone from individuals and families to charities, pension funds, trusts and companies.
  • The sector currently looks after £1.65 trillion in private savings and investments and employs over 63,000 people.
  • PIMFA represents both full and associate member firms. Full members provide a range of financial solutions including financial advice, portfolio management, as well as investment and execution services. They assist everyone from individuals and families to charities and pension funds, all the way to trusts and companies.  Associate members provide professional services to the PIMFA community.
  • PIMFA leads the debate on policy and regulatory recommendations to ensure that the UK remains a global centre of excellence in the wealth management, investment advice and financial planning arena. Our mission is to create an optimal operating environment so that its member firms can focus on delivering the best service to clients, providing responsible stewardship for their long-term savings and investments.
  • PIMFA was created in 2017 as the outcome of a merger between the Association of Professional Financial Advisers (APFA) and the Wealth Management Association (WMA) with a history as a trade association since 1991 – read more.
  • Further information can be found at pimfa.co.uk

Contact

For further information on this release or other press matters please contact:

Sheena Gillett, PIMFA Communications & PR Director – sheenag@pimfa.co.uk,
+44 (0)20 7011 9869 / +44 (0)7979 493225.

Protecting the workforce: preparing for the new duty on employers to prevent sexual harassment

As part of a continued concerted effort to protect the rights of individuals and improve culture in the workplace, a new Worker Protection Act, effective 26 October 2024, requires employers to “take reasonable steps” to prevent sexual harassment in the workplace.

Sexual harassment, as defined by the Equality Act 2010, is when a person engages in unwanted behaviour of a sexual nature, whether verbal, non-verbal or physical, that creates an intimidating, hostile, degrading, humiliating or offensive working environment. It can encompass a range of actions, including making sexual remarks or comments, telling sexually offensive jokes, and displaying or sharing content of a sexual nature.

Under the new duty, employers (regardless of their size, sector, or circumstance) are required to take a proactive approach to tackling sexual harassment, the intention being to shift the emphasis from redress to prevention. The duty is accompanied by Equality and Human Rights Commission (EHRC) technical guidance which outlines various examples and case studies to support employers to meet the additional new requirements.

Key points to note include:

  • The duty is anticipatory – employers are required to undertake risk assessments to anticipate and identify scenarios in which their employees may be subject to sexual harassment, and to take preventative action.
  • The duty extends to sexual harassment by third parties – including visitors, clients, or customers. The legislation does not make employers liable for third-party harassment itself, however.
  • The duty applies to ‘the course of employment’ – this could mean time working offsite, in training, and external meetings. It may include work-related time, such as work social events. Accordingly, an all-encompassing and broad approach is needed to meet the requirements of the new duty.

Whether action is deemed ‘reasonable’ will depend on the specific circumstances of the employer. Likely factors of relevance the employer’s size, and its practices and procedures (e.g. grievance and reporting procedures) for preventing and dealing with sexual harassment.

Enforcement measures

Employees will not be able to bring claims directly for an employer’s breach of the duty. However, where there is a successful claim for sexual harassment, the Employment Tribunal will then consider applying an uplift of 25% to any compensation awarded if it also considers the employer to have breached the duty. Even without the uplift, the compensation payable to employees after suffering sexual harassment can be substantial. As such, the financial impact of the new duty could be material.

From 26 October 2024, the EHRC will also have power to take enforcement against employers where they are found to have breached the duty.

The regulatory approach to such issues is also evolving. The Financial Conduct Authority (FCA) considers bullying, harassment (including sexual harassment) and discrimination to be forms of non-financial misconduct, increasingly an area of focus in recent years. As such, the regulator is expected to keep a close eye on firms’ approach to the new duty.

Insurance considerations

As with any key changes to employment legislation, employment practices liability (EPL) insurers will have a keen interest in understanding firms’ approach.

The new act does not place additional personal duties on directors. However, the potential for regulatory scrutiny and also an increase in the potential for boards to face allegations that they didn’t have appropriate systems and controls in place to prevent sexual harassment, means that Directors’ and Officers’ liability (D&O) insurers can be expected to focus on the subject when underwriting D&O cover.

Both EPL and D&O insurers will be keen to see firms take steps to comply with the duty and mitigate risk. Specifically, these may include:

  • Reviewing existing policies and training procedures and enhancing where appropriate g. equal opportunities policy, anti-harassment policy, and disciplinary policies. Assess the training provided in relation to relevant rules (e.g. misconduct) and the methods of delivering and communicating such training.
  • Identifying potential sources of risk – this may include reviewing past claims or grievances, or (if conducted) exit interviews or employee surveys relating to workplace culture. Compare current methods of recording and resolving complaints against relevant policies to identify potential gaps. Consider scenarios in which sexual harassment is likely to take place and identify steps to minimise/ eradicate these.
  • Conducting regular training – focus on ensuring that staff understand what sexual harassment is, how to identify it, the potential consequences, and how to respond should they experience or be informed of alleged sexual harassment.
  • Establishing reporting channels – put in place clear guidelines for whistleblowing for issues around sexual harassment, bearing in mind the need to ensure that those reporting issues are protected, respecting the need for confidentiality and data protection.
  • Implementing regular reviews – to ensure that policies are kept up to date and reassessed at regular intervals, and in response to relevant incidents and/or failings.
  • Establishing repercussions for those found guilty – and maintain the capability for allegations to be effectively and independently investigated.
  • Seeking an external review – g. from an employment law firm or similar professional consultant, and implement any advice provided.

As for wider insurance considerations, it is important to consider the extent to which your cover allows for public relations (PR) costs to support through any potential reputational issue (or can be adapted to provide for such advice). As the first cases are pursued in relation to the new duty, the press coverage may be extensive. Any impacted firms will want to carefully manage their response.

For more information, please contact laura.skaanild@lockton.com

Laura Skaanild

Women in wealth – Empowering Future Leaders in Financial Services

The Chartered Institute for Securities & Investment (CISI) Bristol & Bath Committee are delighted to invite you to join them at this Women In Wealth Event at the University of Bristol whereby undergraduates and professionals in the industry will gain insight from the journeys of many esteemed women in the industry.

Join us on 6 November at Bristol University for the CISI Bristol & Bath Women in Wealth event! This inspiring gathering is designed specifically for young professionals aspiring to enter the financial services industry. Attendees will have the opportunity to hear from a diverse panel of accomplished women who will share their insights, experiences, and journeys within the sector. Discover various pathways into financial services, gain valuable perspectives, and connect with fellow young professionals and CISI members, as well as non-CISI members. Don’t miss this chance to empower your future in finance!

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