Conduct Risk in Wholesale Insurance

Date: On a date of your choice
Location: Delivered as an interactive briefing
Event Code: CRWI

Course Details

Conduct risk remains in a bright and unforgiving spotlight. In the intentional absence of anything prescriptive from the FCA, firms are defining what conduct risk means in and for their business. Connected directly to a firm’s business model, strategy, product development and distribution, fairness has been put at the heart of delivering against the three FCA operational objectives. “Fairness” will be judged proactively against possible real outcomes, not as a “tick box” regulatory exercise. It is a very different landscape. One thing is guaranteed - the commitment of the Board and senior management is essential for success.

In wholesale markets, with a commercial client base it remains a challenge – especially at board level -to balance “good outcomes” for customers in a complex supply chain without process for processes’ sake. Determining robust proportionality is also wider than “mere” product governance.

This workshop style briefing uncovers the key elements of regulatory expectations, how they apply to different parties across the wholesale insurance distribution chain and where the lines are drawn internationally. Ideal for Board members of wholesale insurance firms, or senior risk and control function holders responsible for managing Conduct risk. 


1.    Conduct risk: a new risk class?

  • Not “TCF MkII”: the scope and focus of conduct risk
  • The implications for the business model, strategy and culture

2.    Scope of Conduct risk in the wholesale insurance markets

  • The “TCF” dilemma” : the FCA wants to focus on wholesale insurance
  • Controlling the complex distribution chain and crossing international boundaries
  • The breadth of wholesale conduct: not solely product governance

3.     Models of  proportionate responses

  • Risk based variable intensity
  • Conduct risk “minimum standards”  a life cycle approach to product governance

4.    The accountability of the Board

  • Conduct risk, the ORSA and risk management
  • Creating/demonstrating a culture of fairness

5.    Getting it wrong – the consequences

  • Evidencing compliance and what good MI looks like
  • Avoiding the consequences of assuming this is not relevant
  • A commercial upside?

Key Benefits

  • Understand what the regulators really mean by Conduct Risk and their expectations of firms
  • Explore the key Conduct Risks in the wholesale insurance market and how risk management strategies can be applied
  • Appreciate the importance of culture, how it levers behaviour and how to align culture with your control environment
  • Produce Conduct Risk strategies that are robust but also proportionate: gap analysis to prevent over engineered solutions
  • Clarify Board obligations and equip individual member to articulate the firm’s Conduct Risk strategy
  • Understand the consequences of getting it wrong
  • Recognise how customer centricity can bring very real potential commercial benefits as well as a source of competitive advantage

John Constable has worked for many years consulting on regulatory topics and management development. A great communicator, he provides interactive regulatory, risk and financial briefings, bringing to them commercial awareness, credibility and pure energy.

He sees the best of business and the greatest areas of challenge within firms on a regular basis. His versatility allows him to use appropriate skills to lead groups of senior management providing current and relevant examples to illustrate points and draw parallels to clarify complex points.

John’s published articles have encompassed financial crime, learning and development strategies, operational risk management and Solvency II.

John has a BA (Hons.) History from Kings College London, he holds a Diploma in Management from Henley and is a Member of Chartered Institute of Personnel and Development.




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