FCA Advises on Work-related Travel Responsibility for Senior Managers

At the end of March, the UK Financial Conduct Authority made it clear to firms how they should prioritise who should need to travel to the office and the responsibilities of Senior Managers in doing so. This statement applies to all FCA-regulated firms across the UK, including in Scotland, Wales and Northern Ireland. FCA expressed gratitude for the significant ongoing efforts of banks, building societies and credit unions and their frontline staff working alongside the Post Office to keep access to cash, call centres and other essential services for customers.

All firms were reminded that coronavirus (Covid-19) constitutes a public health emergency. As the regulator of the UK financial services industry, FCA strongly supports the UK Government’s efforts to protect the public by ensuring only those workers who cannot work from home, continue to travel to and from work.

Each firm’s designated Senior Manager or equivalent person should be responsible for identifying which of their employees are unable to perform their jobs from home, and have to travel to the office or business continuity site. FCA expected the total number of roles requiring an ongoing physical presence in the office or business continuity site to be far smaller than the number of workers needed to ensure all of a firm’s business activities continue to function on a business as usual basis.

The UK Government made clear that employers and employees should discuss their working arrangements, and employers should take every possible step to facilitate their employees working from home, including providing suitable IT and equipment to enable remote working. For example FCA would not expect the following to go into work or meet face to face:

• financial advisers, as they can offer their services online or by phone
• staff who can safely and securely trade shares and financial instruments from home
• business support staff, such as those in IT where they can triage issues from home, unless they are looking after specific equipment or technology
• claims management companies and those selling non-essential goods and credit

FCA expected the number of exceptions to this to be low.

Firms should continue to follow the Government’s guidance closely and take the recommended steps.