Following the FCA’s recent guidance consultation, it has now published Finalised Guidance 15/10 ‘Risk to customers from performance management at firms’ that can be found here.

In this document the FCA clarify the importance of culture within a firm to ensure the customer is at the heart of how a business is run.

It looks at performance management that includes:

• formal processes – such as appraisals and underperformance procedures;
• sales targets (or their equivalent); and
• other less formal day-to-day interactions and communications between sales staff and managers about sales results that influence behaviour (both written and verbal) – much of which may not be documented.

It highlights practices that can create undue pressure and, very importantly, it gives examples of good practice.

The FCA summarises the expectations on firms as follows:

All firms with staff who deal directly with retail customers should read this report and consider:

• how their approach to performance management may increase the risk of mis-selling;
• whether their governance and controls are adequate; and
• taking action where required to ensure the risks are adequately managed.