Post content (reconstructed from run)
Short video-led post. Core message: “2026 in UK financial services is about evidence, not intent.” Boards, regulators and customers don’t want promises — they want to see frameworks that actually work. That means real outcomes, clear accountability and data that proves it — across Consumer Duty, Operational Resilience, AI, cyber and third-party risk. The firms that will do best are the ones that treat their control environments as living systems: tested, measured, and improving. Whistleblowing and vulnerable-customer handling sit at the sharp end of that test. (Captured from feed; verbatim capture on next run.)
Today
Open items below. Mark progress as you comment on LinkedIn.
Queue
0/ 0
Streak
—
Not tracked in-app
This week
—
Not tracked in-app
Last 30 days
—
Not tracked in-app
Author
Topic
Audience
Engagement
Status
2026-04-26 — Supplemental run
1. Charlotte Johnson
Royal Mail hiring Employee Relations Absence Management Specialists (12-month FTC) · Path 1 ER champion role being created · Tier 2 contact-centre / large-frontline employer
CHRO
TODO
Draft comment
Naming the role “Employee Relations Absence Management Specialist” rather than “Absence Co-ordinator” is a meaningful signal — it puts the casework muscle ahead of the admin. What we’re seeing across large frontline employers is that the long-term absence conversations are where managers freeze hardest, and the ER team ends up carrying cases the line should have held earlier. Hope you hire someone willing to push capability upstream into the manager population, not just absorb it downstream.
2. Browne Jacobson Financial Services & Insurance
FCA NFM rules from Sept 2026 · Investigations, documentation, manager accountability · Employment Rights Act 2025 raises stakes of poorly handled investigation
Influencer
TODO
Draft comment
The investigations bit is where the ERA 2025 + NFM stack really bites — you can’t evidence “reasonable steps” if the people running the conversations haven’t actually rehearsed handling a disclosure under pressure. What we’re seeing with FS clients is that the policy and the training will be in place by September; the investigator and manager capability under examination is the gap that’s harder to close. The personal SMF risk makes this very different from a normal HR investigation.
3. Stephen Shedletzky
Hard conversations framework · Speak-up culture · Vulnerable / worthwhile conversations at work
Influencer
TODO
Draft comment
The framework is the easy part — the harder shift is moving from “I know what to say” to actually saying it when the room goes quiet. What we’re seeing with clients is the gap rarely sits in the model; it sits in whether the manager has rehearsed enough variations to stay regulated when the conversation doesn’t follow the script. The “can opener” lands when the muscle is already there.
4. HR Magazine
New NDA rules under ERA 2025 · Misuse in harassment / discrimination / bullying cases · Employer policy reset
Influencer
TODO
Draft comment
The NDA reset matters less for the legal teams than for the HR investigators — once you can’t silence an outcome, you have to be able to defend the conversation that led to it. What we’re seeing with clients is a renewed appetite for evidence of how the original disclosure and investigation were handled, not just the settlement. That’s a capability shift, not a policy one.
5. Women in Safety
Compliance vs culture · Behaviour under pressure · Conversations replace checklists
Influencer
TODO
Draft comment
“Safety doesn’t live in documents — it lives in what people do when pressure is on” reads exactly the same in conduct, ER and customer-outcomes work as it does in H&S. What we’re seeing across regulated firms is that the biggest gap isn’t the policy or the audit trail; it’s whether anyone has rehearsed the conversation that decides whether the system actually holds. The systems-vs-behaviour question lands the same way everywhere.
6. 15Five
Growth Studio launch · PIPs, IDPs, succession planning · HR-tech vendor with HRBP / People Ops audience
Influencer
TODO
Draft comment
The PIP module is the interesting one — the workflow tooling is rarely the bottleneck; it’s the manager’s ability to actually run the first PIP conversation without it landing as a surprise or a threat. What we’re seeing with clients is that the IDPs and succession plans get attention precisely because the harder, more emotionally loaded PIP conversation is the one most managers avoid. Curious whether Growth Studio includes any rehearsal layer or just the workflow.
Run notes — 2026-04-26 (supplemental)
- Second Sunday run — volume genuinely thin. Today already had a morning run (5 cards). This supplemental sweep added 6 more after a fresh ~14-search pass across Audience A Paths 1–4, Audience B Track 1, and Audience C modifiers + watchlist. Final shortlist 6 cards (1 CHRO, 0 ICP, 5 Influencer).
- Strongest pick: Women in Safety carousel (110 reactions). Adjacent vertical (H&S not regulated FS), but the “safety doesn’t live in documents” framing is a carbon-copy of Toby’s positioning — biggest stage of the run with a transferable comment.
- CHRO buying signal: Charlotte Johnson’s Royal Mail ER Absence Specialist hire is a clean Path 1 champion role at one of the UK’s largest frontline employers (130k+ employees). Long-term absence conversations are exactly the manager-capability gap Real Talk targets.
- No direct ICP Compliance practitioner picks today (again). Tried 7+ Track 1 searches (NFM/COCON, three lines of defence, SMCR conduct, compliance culture, Dear CEO FCA, Consumer Duty vulnerable/outcomes, Worker Protection Act). Browne Jacobson FS (NFM Sept 2026 employer-prep article, 26 reactions) was the strongest piece — included as Audience C with note that the firm was also covered Apr 23 (different angle this time: investigations + ERA stack vs. previous manager accountability piece).
- Near-threshold borderlines (notable, not included): Linda Neville (mental fitness coach, ~1h post on early-stage manager intervention) — on-message but engagement not yet visible; Graham Brimage (FlowSignal founder, SMCR/SS1/23 accountability gap, 8 reactions) — sharp framing but well below 25-reaction Audience C bar; Leaman Crellin (SMCR Phase 1 reforms, 3 reposts) — same topic as Saima Sabir already covered Apr 23, skipped to avoid over-coverage.
- Skipped on dedupe: David Green/Insight222 (BCG Four Power Moves, 151 reactions) — already covered in this morning’s run; Steven Claes (calibration room, 228 reactions) — same; Carlos Larracilla / Anthony Calleo (Wowledge HR priorities) — same; Sicsic Advisory (FCA work programme webinar) — covered Apr 24.
- Search bias confirmed (Sunday cut): “manager as coach,” “sheep dip,” “deliberate practice,” and “Consumer Duty + outcomes” all returned mostly off-target results today (Uganda microfinance, literal sheep dipping, generic motivational, hiring-pages). The narrower practitioner-language searches (“return to work” conversation, NFM/COCON, Worker Protection Act + reasonable steps) were higher signal even on a dead Sunday.
- Watchlist hits: HR Magazine (NDA rules ERA, 27 reactions, 6 reposts) was the only on-topic watchlist piece — Lewis Silkin company page redirected to /unavailable/ today (404-style). CIPD watchlist returned only their CEO announcement (Neil Carberry, 16 reactions) — not on-topic. Tagged Browne Jacobson FS as a watchlist hit too.
- Real Talk meta: Interhuman AI co-marketing post about Real Talk Studio (17 reactions, 3 comments) showed up under “AI roleplay” search. Not added to tracker (commenting on a post featuring his own company is off-meta) — flagging here so Toby can react organically if he wants.
2026-04-26
1. Kendal Morris
ScottishPower hiring Head of Employee Engagement & Capability · Path 2 buying signal · Tier 2 utilities, 500+ employees, UK
CHRO
TODO
Draft comment
Naming the role “Engagement & Capability” rather than “L&D” is a meaningful signal — it puts the outcome ahead of the activity. What we’re seeing across utilities and other frontline-heavy industries is that the firms pulling ahead are the ones measuring whether a manager can actually hold the conversation, not just whether they sat through the module. Hope they hire someone willing to challenge what “capability built” really means in evidence terms.
2. David Green
BCG / WFPMA “Four Power Moves for the CHRO” report · Build leadership capabilities · Linking people strategy to outcomes
Influencer
TODO
Draft comment
The third power move is the one most CHROs will struggle to evidence — building capability connected to outcomes is the easy headline, hard delivery. What we’re seeing with clients is that the skills-based strategies that actually move the dial measure whether managers can do the conversation under pressure, not whether they completed the framework. Compliance and ER becoming baseline is the right call; the next move is making capability evidence-based in the same way.
3. Steven Claes
Calibration room judgments · CHRO voice · How managers narrate talent under pressure
Influencer
TODO
Draft comment
The calibration room is one of the most under-rehearsed leadership conversations in the org — and it’s also the one with the longest shadow. What we’re seeing with clients is that the gap rarely sits in the data; it sits in whether the manager can hold and defend a nuanced judgment under peer pressure in the room. Most rooms reward decisive labels; very few reward the manager who pauses to reframe what they’re actually seeing.
4. Dr David Bozward
Capability vs content · Real work, applied skills, experience under pressure · Activity-vs-outcomes framing
Influencer
TODO
Draft comment
“Capability not content” lands the same way in corporate L&D as it does in HE — most leadership programmes still measure delivery against a curriculum and call it a result. What we’re seeing across clients is the shift from “covered the topic” to “can they do it under pressure,” and the firms making that shift are the ones putting rehearsal at the centre, not the periphery. Discussion never produced a competent manager.
5. Carlos Larracilla
HR priorities by company stage · Manager capability at 500–2,000 employees · Activity vs business impact
Influencer
TODO
Draft comment
The 500-2,000 band is exactly where the “manager capability” problem becomes a measurable business risk — small enough that one bad conversation gets noticed, big enough that you can’t coach every manager personally. What we’re seeing with clients in that band is that the priorities listed work only if “capability” is defined behaviourally rather than by completion. Otherwise the framework just industrialises the same gap.
Run notes — 2026-04-26
- Sunday quiet day — quality over quantity. Sunday is genuinely the slowest day on LinkedIn for ICP practitioners. ~14 keyword searches across Paths 1–4, Audience B Track 1, and Audience C modifiers; final shortlist 5 cards (1 CHRO, 0 ICP, 4 Influencer).
- Strongest pick: David Green / Insight222 (151 reactions). BCG “Four Power Moves for the CHRO” report — the third move (build capabilities connected to outcomes) is the cleanest opening Toby’s had in weeks for the activity-vs-outcomes argument.
- CHRO buying signal: Kendal Morris’ ScottishPower hire (Head of Employee Engagement & Capability) is the only direct Path 2 champion role posted this week — rare to catch the role being created out loud. Tier 2 industry (UK utilities), capability-language framing in the JD.
- No direct ICP Compliance practitioner picks today. Tried 6+ Track 1 searches (NFM/COCON, three lines of defence, SMCR, thematic review/Dear CEO, Consumer Duty year 2/3, compliance culture). Strongest candidate (TCC Group, year-3 Consumer Duty board reports) had on-message content but only 3 reactions. Browne Jacobson FS posted again on culture/conduct (17 reactions) but the firm was already covered Apr 23 — skipped to avoid over-indexing.
- Near-threshold borderlines (notable, not included): Nick Hobden (employment law, 6 reactions, 2 reposts) — coherent WPA + ERA stacked post, the most articulate compliance-buyer-relevant content of the day but well below the 25-reaction Audience C bar; Colossyan (10 reactions) — AI compliance training video vendor, exact category territory; Mursion (7 reactions) — direct AI simulation peer, posted manager change-conversation simulation but vendor-on-vendor commenting felt off-stage.
- Skipped on dedupe: Julie Darmudas (NFM SMF accountability, 19 reactions, on-message) — already covered Apr 21; Jo Morgan announcement of Paul Sims (101 reactions) — celebratory, not on-topic; Browne Jacobson FS roundtable — firm covered Apr 23.
- Search bias confirmed: “Difficult conversations manager OR leader” (Path 2) and “knowing-doing gap” both pulled mostly off-target results today (eyecare, military, hypnotherapy, Italian motivation coaches). The narrower practitioner-language searches (manager effectiveness, performance improvement plan, Worker Protection Act + all reasonable steps) were higher signal even on a quiet day.
- Watchlist hits: Lewis Silkin and CIPD watchlist scans returned nothing on-topic this week. David Green surfaced via the “manager effectiveness research/data” search rather than direct watchlist.
2026-04-25
1. Maxine Blake
Vento bands April 2026 · Injury to feelings awards · Sharma v Portsmouth · Tribunal cost of getting it wrong
CHRO
TODO
Draft comment
The line that lands hardest is the one about being comfortable explaining your decisions under real scrutiny — that’s the actual test, not whether the policy was up to date. What we’re seeing with clients is that the cases that go badly aren’t the ones with bad people, they’re the ones where managers had no rehearsal for the moment that mattered. The new Vento bands turn that gap into a balance-sheet number.
2. Network Plus — Aspire Leadership Programme
First-line manager development launch · Raise the Bar partnership · Performance, feedback, difficult conversations, leading change
CHRO
TODO
Draft comment
Naming a programme is the easy bit — what usually decides whether it sticks is whether new managers get to rehearse the conversations they’re going to lose sleep over before they meet them on the floor. Most firms I work with measure attendance and feedback; the programmes that actually shift behaviour measure whether the next difficult conversation went better than the last one. Curious how Network Plus is planning to track that.
3. Caroline Reid
AI roleplay with Bodyswaps · Custom angry-customer scenario · Stage Immersive Learning · Path 3 solution-aware
CHRO
TODO
Draft comment
Pressure-tested practice with a real customer scenario is where the learning actually transfers — a polished classroom answer doesn’t survive contact with an angry passenger missing their luggage. What we’re seeing across L&D is the shift from “covered the topic” to “can they handle the moment,” and AI roleplay is the only thing that scales rehearsal cheaply enough to make that real. Sounds like a strong day.
4. Frank Brown ChMC
FS NEDs whistleblowing investigation training · NFM rules Sept 2026 · Travers Smith session · Whistleblowing as canary
ICP
TODO
Draft comment
The whistleblowing-as-canary frame is the right one — the more revealing question is usually why the formal route felt unsafe, not what the disclosure said. What we’re seeing in FS boards right now is that the NFM regime is exposing the same culture gap from a different angle: the policies pass review, but few firms can show their managers have actually rehearsed handling these conversations. Hard to evidence reasonable steps without that.
5. Dr Dieter Veldsman
HR’s mandate · Performance accountability · Manager capability vs HR replacing the manager’s voice
Influencer
TODO
Draft comment
This is exactly right and it’s the trade-off most HR teams haven’t named. What we’re seeing with clients is that every time HR steps in to “just run the conversation,” the manager loses a rep — and ten conversations later the gap is real. Coaching managers through difficult moments scales; running the moment for them doesn’t. The shift you’re describing is from process owner to capability builder.
6. Jess Sandham
Sexual harassment prevention · Culture vs policy · Worker Protection Act · Everyday moments, not rules
Influencer
TODO
Draft comment
The “how leaders respond when something feels off” line is the actual test — and it’s the one most policies don’t equip managers for. What we’re seeing across organisations is that the WPA and ERA changes are exposing the same gap: the rules were already there, what’s missing is whether front-line managers have ever practised the moment. Culture lives in the first thirty seconds of those conversations.
7. Julie Ampadu
APCC Spring Conference · Sheree Howard FCA speech · Compliance consultants as coaches · Regulatory mindset
Influencer
TODO
Draft comment
The “standing on your own two feet” framing is the part that usually gets lost — firms can buy a polished policy pack tomorrow, but evidencing a regulatory mindset only comes from rehearsing real decisions. Most firms I see treat readiness as a documentation exercise; the FCA increasingly treats it as a behaviour test. The coaching role you’re describing is what closes that gap.
2026-04-24
1. Phillip Warren
Employment Rights Act · Healthcare / CQC crossover · Chartered FCIPD perspective
CHRO
TODO
Draft comment
Healthcare is the sector where the policy-vs-behaviour gap shows up fastest — CQC well-led and the ERA preventative duty are effectively asking the same question from two angles. What we’re seeing with clients is that the evidence inspectors want is how line managers handled the last difficult moment, not the date the policy was last reviewed. The providers that hold up rehearse the moment; the ones that don’t, re-write the handbook.
2. Sandy McGregor
Conduct Rule 7 · NFM standards · 1 Sept 2026 deadline
ICP
TODO
Draft comment
1 September isn’t a training deadline, it’s a behaviour-proof deadline — and that’s the distinction most networks haven’t landed yet. What we’re seeing with clients is that the FCA conversation has moved on from “did you cover it?” to “can your people handle the moment?” — and the honest answer for most firms is they don’t know, because they’ve never rehearsed it. Closing that gap is the real work between now and September.
3. Lewis Silkin
The Working Times · Union access rights · NDA reform · Right-to-work checks
Influencer
TODO
Draft comment
The NDA change is the one that resets how this actually plays out on the floor — the “manage it quietly” route is closing, and what gets surfaced publicly will be whatever the first-line manager said in the first 48 hours. What we’re seeing with clients is that the policy work is usually fine; the gap is whether front-line managers have ever rehearsed that conversation. That’s the piece NDA reform puts a spotlight on.
4. Chartered Institute of Internal Auditors
£1bn+ FCA fines · Internal control failures · Three lines of defence
Influencer
TODO
Draft comment
The three-lines structure almost always looks fine on the deck — the question we see clients sitting with is whether the 2nd line would actually challenge the 1st line in the moment, in front of the same people they go for coffee with. That’s a behavioural problem, not a structural one, and it’s the piece the £1bn of fines keeps pointing back to. Worth stress-testing before the FCA does.
5. Sicsic Advisory
FCA Work Programme 2026/27 · Regulatory priorities · Webinar
Influencer
TODO
Draft comment
The named priorities are clear enough — the gap is almost always the translation step between “FCA work programme” and what a relationship manager actually does differently at 4pm on a Tuesday. What we’re seeing with clients is that the workplans get written, the training gets booked, and behaviour on the desk doesn’t move because no-one’s rehearsed the specific moments the FCA will sample.
6. Neil Makwana
Consumer Duty Year 2 Board Reports · Four gaps · Year 3 prep
Influencer
TODO
Draft comment
The four gaps are all behavioural problems wearing reporting clothes — “meaningful board challenge” and “consumer understanding” are evidenced by what happens in rooms, not what gets written in decks. What we’re seeing with clients is that Year 3 is where boards will be asked to show they actually pushed back on something, and the firms that can point to specific moments win; the ones with polished narratives and no rehearsal don’t.
7. Jess Rad
Depop allyship case study · CPO / CHRO / L&D audience · Behaviour over campaigns
Influencer
TODO
Draft comment
This reads exactly right — allyship is a situational-practice problem, and campaigns don’t produce practice. What we’re seeing with clients is that people don’t rise to the moment, they fall to their rehearsal, and most programmes never give them the rehearsal. That’s the gap between a thoughtful allyship narrative and something that actually holds up in the corridor conversation.
2026-04-23
1. Kelvin Irikefe
AML training · Tick-box vs capability · FCA thematic review
ICP
TODO
Draft comment
This is exactly right — the FCA’s shift is away from training hours and towards whether someone can actually handle the moment. What we’re seeing with clients is that completion rates tell you nothing about whether a relationship manager would spot a red flag at 4pm on a Friday. The firms that hold up under thematic review are the ones that have stress-tested the behaviour, not the module.
2. Joe Simpson
TR24/1 · Centralised Retirement Propositions · Consumer Duty outcomes
ICP
TODO
Draft comment
The TR24/1 finding about identical accumulation / decumulation propositions is one of those gaps that looks fine on paper and falls apart under Consumer Duty outcomes testing. What we’re seeing with clients is that the harder bit isn’t redesigning the CRP, it’s equipping advisers to have the decumulation conversation differently — the MI starts to tell you whether the proposition actually lands in client reality.
3. Nic Elliott
Employment Rights Act 2025 · 10-point HR playbook · Manager training & audit
Influencer
TODO
Draft comment
Step 6 — train managers — is the one that usually gets underfunded and carries the most tribunal risk after October. Most firms I work with can evidence that the training happened; very few can evidence that their line managers could actually run a fair performance or flexible-working conversation under pressure. That’s the gap the Fair Work Agency will be looking at.
4. Cosegic
PS25/23 · NFM for non-bank SMCR firms · Culture & disciplinary process
Influencer
TODO
Draft comment
The non-bank SMCR piece is where this gets interesting — a lot of mid-sized investment firms are finding their existing grievance and disciplinary frameworks weren’t designed to make a COCON 1.1.7FR determination at all. What we’re seeing with clients is that the speed of the judgement call is often the weak point, not the policy itself.
5. Browne Jacobson Financial Services & Insurance
FCA NFM rules · Manager accountability · ERA 2025 investigation stakes
Influencer
TODO
Draft comment
The overlap between ERA 2025 and the NFM regime is what most firms haven’t worked through yet — a poorly run investigation is now a regulatory risk and an uplift-on-tribunal-award risk in the same case. Most Senior Managers I work with are finding the hardest bit isn’t the rules, it’s having the confidence to make the judgement call under time pressure and then evidence why.
6. Mike Patterson
McDonald’s & EHRC · Third-party harassment · October 2026 step-change
Influencer
TODO
Draft comment
The McDonald’s case is the right anchor because it shows how quickly an “all reasonable steps” defence collapses when the evidence trail comes out in public. What we’re seeing with clients is that the policy review and the training log are the easy part — the hard part is whether frontline managers could actually handle a complaint from a customer about a colleague or a colleague about a customer in the moment. That’s the capability the tribunal will test.
7. Ali Crotch-Harvey
“Evidence, not intent” · Whistleblowing · Vulnerable customers · Consumer Duty
ICP
TODO
Draft comment
Agree — and the bit firms are least ready for is evidencing what people can actually do under pressure, not just what’s in the policy and the completion log. What we’re seeing with clients is that boards get most exposed on the whistleblowing and vulnerable customer pieces specifically, because that’s where “reasonable” collapses into “can your people actually hold the conversation.” Would be good to swap notes on how you’re approaching those two.
8. James Walker
Banking board governance · Proximity to impact · SMCR architecture vs lived experience
Influencer
TODO
Post content (reconstructed from run)
Reflection from a charity board meeting vs a banking board meeting. At the charity, the most powerful question in the room was: “Who around this table has personally experienced the problem our beneficiaries face?” Half the trustees had. In banking governance you get SMCR, three lines of defence, conduct-risk frameworks — deeply sophisticated, but often empathy-light. The best boards blend both: rigour and proximity, architecture and lived experience. The weakest have neither. (Captured from feed; verbatim capture on next run.)
Draft comment
The proximity point is the one most board packs can’t answer. You can map the framework perfectly and still have a room where nobody has stood at the other end of a complaint. What we’re seeing with clients is that the hardest piece to evidence isn’t the architecture — it’s whether oversight actually changes what happens when a vulnerable customer interaction goes wrong. We should swap notes.
9. Saima Sabir
SMCR Phase 1 reforms (22 Apr 2026) · Accountability vs admin burden · Evidencing control
Influencer
TODO
Post content (reconstructed from run)
FCA and PRA finalised Phase 1 of the SMCR reforms yesterday (22 April 2026) — streamlined certification, extended application timelines, a stated goal of halving the administrative burden on firms. The direction is welcome. The question on the risk side is: “Will this genuinely free up senior management capacity — or simply shift where firms need to demonstrate control and assurance?” Less paperwork doesn’t mean less accountability; often it raises the bar on what the individual SMF has to be able to show. (Captured from feed; verbatim capture on next run.)
Draft comment
It shifts it. Less prescriptive process means more weight on the senior manager being able to demonstrate — under real questioning — that the controls in their remit actually work. What we’re seeing with clients is that the gap isn’t the framework, it’s whether individuals can evidence oversight in a way that holds up when a regulator presses on it. The admin burden coming down doesn’t lower the accountability bar — it raises it.
10. Chris Syder
ERA2025 · Franchise HR governance · “Evidence, not intentions”
Influencer
TODO
Post content (reconstructed from run)
Harassment prevention as a franchise-governance problem. The duty splits: the franchisee is the employer on the shop floor, the franchisor is the system designer — training, policies, reporting, audit. Tribunals can uplift compensation by up to 25% where preventative steps weren’t taken. EHRC can enforce without a complaint or incident having occurred. October 2026 is the step-change: “all reasonable steps” plus third-party liability. The test the regulator, a tribunal or a claimant lawyer will put to you: “Show me the steps you took to prevent this — and why they were reasonable for this outlet / this network. Could you answer with evidence … not intentions?” (Captured from feed; verbatim capture on next run.)
Draft comment
The “evidence… not intentions” test is exactly what most firms aren’t ready for. What we’re finding with clients is that the policy, training log and reporting lines are relatively easy to produce — the bit that falls apart is showing the manager actually could have held the conversation if it had surfaced earlier. That’s the gap between reasonable steps on paper and all reasonable steps in practice, and the franchise split makes it even harder because the evidence has to travel across two governance layers.
2026-04-22
1. Chantel Dos Santos Maidwell
New harassment duty · Preventative steps · Evidencing before a complaint lands
CHRO
TODO
Draft comment
The list of reasonable steps is right but the hardest one to evidence is manager capability — most firms can produce the policy and the training log, far fewer can show that their managers can actually hold the conversation when something surfaces. That’s the bit that will decide whether a tribunal buys ‘all reasonable steps’ or not.
2. Grace Suleyman
COCON 1.1.7FR · NFM · Compliance & HR shared framework
ICP
TODO
Draft comment
The shared framework point is the one most firms are underestimating. What we see with clients is that Compliance and HR have very different muscles — HR can run the investigation, Compliance can make the regulatory call, but almost no one has rehearsed how those two judgements sit together when a real case lands. The test will be whether a Senior Manager can explain, on the spot, why this did or didn’t cross the COCON threshold.
3. Parul Anand, CFE
Three Lines of Defence · Culture · “Oversight without teeth is just paperwork”
Influencer
TODO
Draft comment
This matches what we see with clients — the diagram is fine, the culture is where it breaks. The bit that decides whether 2LoD has teeth isn’t the escalation pathway, it’s whether senior leaders can actually hold a hard conversation when 1LoD pushes back. Most firms have the structure; very few have rehearsed the conversation.
4. Rebecca Fairlamb
Mandatory compliance training · Culture vs control system · “Nothing fundamental changed”
Influencer
TODO
Draft comment
“A control system dressed up as a culture” lands hard — that’s exactly the shift coming for FS with NFM in scope from September. What we’re seeing with clients is that completion rates tell you nothing about whether people would actually behave differently in the moment, which is the only thing the regulator now cares about.
5. Tracie Sponenberg
Programme rollouts that don’t stick · Rollout vs rewiring · Training isn’t learning
Influencer
TODO
Draft comment
“We treated it like a rollout when it was actually a rewiring” is the line most L&D teams need on their wall. The knowing-doing gap sits exactly here — the workshop closes, the habits snap back, and the programme gets measured on the event rather than whether anyone actually behaves differently on the Monday. The bit that moves the needle is what happens in the weeks after, not the day itself.
6. Sophia Rahman
FCA Regulatory Priorities reports · Replacing “Dear CEO” · Retail banking focus
Influencer
TODO
Draft comment
The move from Dear CEO letters to a consolidated Priorities report changes how firms should actually read the signal — it’s less about reacting to a single letter and more about showing ongoing alignment to supervisory focus. What we’re seeing with clients is that the firms that cope best treat these as a live operating document rather than an annual read.
2026-04-21 — Supplemental run
1. Sarah Jackman
Non-financial misconduct · COCON · Manager role in recognising & responding
Influencer
TODO
Draft comment
The bit most firms are going to struggle with isn't the policy update or the tracking — it's the middle line, the role of managers in recognising and responding in the moment. What we see with clients is that the COCON training tells them the rule, but the capability to hold the conversation when something surfaces is still a muscle most teams haven't built.
2. Jessie Jones
Consumer Duty Board reports · Year 3 priorities · Evidence of outcomes
Influencer
TODO
Draft comment
"Evidencing meaningful Board challenge" is the one that tends to unravel Year 2 reports. Most firms I work with can show the metric pack and the action plan, but can't show how leaders actually tested the evidence in the room. That's a capability gap, not a reporting gap — and the Year 3 version will be where that shows up.
3. Sue Saunders
Compliance Leadership · Implementation to Influence · Strategic CCO
Influencer
TODO
Draft comment
The "implementation to influence" shift is the right framing — and in practice it lives or dies on whether CCOs can actually hold the challenging conversation with a Senior Manager who doesn't want to hear it. Most of the firms I work with have good frameworks; the constraint is whether the compliance team has practised the hard conversations, not written the policy.
2026-04-21
1. Siâna Grygelaitiene
Employment Rights Act 2025 · Harassment · Tribunal risk
CHRO
TODO
Draft comment
One serious incident establishing liability is exactly where the "we have a policy" defence falls over. What we're seeing with clients is that the documentation of policies is the easy bit — the hard bit is being able to evidence that managers could actually handle the conversation when the incident first surfaced.
2. Julie Darmudas
Consumer Duty · Evidencing outcomes · FCA scrutiny
ICP
TODO
Draft comment
The "can you show me the evidence" test is exactly the right one. Most firms I work with have clean policies and a decent training log — what they can't show is that their people can actually deliver good outcomes when the call goes sideways. That's the gap an FCA visit exposes fast.
3. Adedoyin Adesina
Compliance emergency · FCA supervisory shift · Consumer Duty
ICP
TODO
Draft comment
The first-response point is the one most compliance teams underestimate. What we see with clients is that the quality of the first 48 hours is almost entirely a function of whether managers have practised the conversation before — not whether the playbook exists. Good update.
4. Valerie Familusi
PS25/23 · Non-financial misconduct · COCON · Culture
ICP
TODO
Draft comment
The chain you set out — weak culture to regulatory breach — is the bit most firms still treat as abstract. The practical test from September is going to be whether anyone can evidence that leaders actually intervened when they saw early signals, not just that a policy existed. That's a very different muscle to build.
5. Jo Morgan
All reasonable steps · Behavioural risk · Code of Conduct in practice
Influencer
TODO
Draft comment
The "doing something vs demonstrating it works" line is the whole game. Most firms I work with have done the training, updated the policy, run the campaign — and still can't show that managers can hold the conversation in the moment. That's where tribunals are going to separate the two.
6. Victoria Hall
All reasonable steps · Third-party harassment · Evidence before the event
Influencer
TODO
Draft comment
The shift from "did it happen" to "what did we do in advance" is exactly right — and it's a question most HR teams can't answer with evidence today. What we see with clients is that the preparation that actually holds up is the practised conversation, not the policy PDF on the intranet.
7. Tom Durkin
FCA 2026 agenda · SM&CR reform · NFM · Hiring pressure
Influencer
TODO
Draft comment
The headcount lens is useful — and it's only half the story. Most firms I work with are going to find the constraint isn't hiring, it's whether their existing managers can actually have the conversations that NFM in COCON implies. Adding people doesn't close that gap on its own.