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Code comfort

The history of conformity to codes of conduct is gener-ally not a good one. I well remember the struggles that the OFT had with codes for a variety of industries. The conclusion reached a few years ago was that, to a large extent, the work was wasted because, once the code was approved, there was insufficient application within the industries or firms concerned.

The fact is that a good many people are turned off by the whole idea of applying moral-ity or codes of ethics and conduct in a business context.

I remember the attempts of the FSA in the context of a number of consultation papers to attach ethics to the train-ing and competence regime. The presen-tations given by FSA officials on ethical questions were quite often well attended but most attendees discarded the ideas on the way out.

I do not think this was entirely down to the FSA, perhaps more to a reluctance to see the regulator as an authority in establishing general standards of behaviour.

The preferred approach of many people has tradit-ionally been to ask the regulator to be specific about what it wants either in rules or enforce-ment so that compliance can be carried out with certainty.

Voluntary move-ments to establish professional standing consist of putting in place a set of guidelines which will only work if the practi-tioners who sign up to the professional standards have self-discipline in the direction indicated by the standards. The PFS/CII code of ethics and conduct is no different.

What is the hook that would cause members to look at whether they are behaving with responsibility, integrity, profess-ional competence, skill, care, diligence and objectivity? Why would they give fair and proper consideration and appropriate priority to the interests and requirements of all customers? Why would they avoid conflict between personal interests and their duties to customers? Why would they be open, fair and respectful at all times and, very specifically, why would they provide suitable and objective recommendations to customers?

I suggest that the purpose of doing these things is not to engage in an activity of self-promotion. It is about the standards of the individual and the good that they do in relation to customers, coll-eagues, employers and the community at large. The atten-tion is on the individual having self-discipline and assessing their stan-dards. A by-product may well be good repute and goodwill but the essential feature is the self-discipline.

Why does this not always work? The fact is that, when people come into a work context, quite often, very different agenda are running. We need to ask ourselves what is going on in these situations. Is our activity about power and control or self-assertion or acquisition or is it about making our daily activity conform to standards which we believe are in themselves right with the intention that our relation-ships in work will be improved for the good of others.

I would be inter-ested to hear the views of readers.


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