Morae Supporting Financial Services Firms with Their Compliance & Reporting Obligations

With the introduction of the Financial Conduct Authority’s (FCA) new framework on Non‑Financial Misconduct (NFM), financial services firms are under growing pressure to strengthen organisational culture and improve how they identify, assess, and report misconduct.

The FCA’s evolving position makes clear that:

• NFM (including bullying, harassment, discrimination, and other behavioural issues) can be relevant to fitness and propriety assessments.
• Firms must demonstrate robust internal systems, including transparent reporting mechanisms, consistent investigation processes, and comprehensive record‑keeping.
• While the rules describe principles, they do not prescribe an exhaustive list of behaviours, placing the responsibility on firms to determine what incidents fall within scope and ensure that significant issues are not overlooked.

Against this backdrop, Morae’s financial services clients engaged us to help establish a scalable, defensible workflow for reviewing historical NFM case data and mapping it to their reporting framework.

Our clients needed a structured and reliable way to:

1. Manually review a very large corpus of case files spanning grievances, internal investigations, performance issues, and disciplinary proceedings;
2. Extract and categorise relevant facts in line with their evolving NFM definitions;
3. Create a data output that could be integrated seamlessly into their new reporting platform.

1. Ensuring Data Integrity at Scale

The primary objective was to ensure that each document was accurately associated with its corresponding case, despite challenges such as missing or inconsistent metadata, incomplete document bundles, duplicate employee names, evolving case statuses, and individuals involved in multiple concurrent or historical matters.

To address this, Morae’s data team developed custom scripts to extract and standardise metadata, identify unique case markers, and group all documents under their correct parent cases. Where metadata gaps existed, additional logic and pattern-matching rules were applied to infer document relationships. A dedicated quality-assurance layer validated allocations, ensuring that no documents were misclassified or omitted, resulting in a clean, structured dataset ready for review.
 

2. Structured Review and Categorisation

Morae’s onshore and offshore review teams received detailed training based on the client’s internal guidance on misconduct classifications. Reviewers analysed each case file to:

• Identify behaviours potentially within the scope of NFM,
• Categorise relevant incidents based on defined attributes (e.g., type, severity, context, actors involved),
• Assess case progress (e.g., allegation raised, under investigation, concluded),
• Capture key facts and provide additional insights back to the client’s case team.

A three-stage quality-control process ensured the accuracy and defensibility of reviewer outputs.
 

3. Dashboard and Reporting Output

Following review and categorisation, Morae developed a custom dashboard presenting case-level categorisations, incident types, key findings, case progression status, and cross-case themes and trends.

The dashboard was designed to support internal governance, enable senior management oversight, and allow the client to test and refine NFM reporting requirements ahead of full technical implementation.
 

4. Outcome

By understanding how the client aimed to present its NFM‑related data and aligning the review output to those objectives, Morae delivered a complete, reliable, and regulator‑ready reporting dataset. The solution enabled our clients to:

• Build a scalable NFM reporting tool supported by high‑quality historical data,
• Meet emerging FCA expectations around organisational culture and misconduct oversight,
• Strengthen internal governance and risk management processes,
• Avoid gaps in reporting that could trigger regulatory, financial, or reputational consequences.

This solution showcases Morae’s ability to combine technical expertise, regulatory understanding, and operational scale to support clients navigating evolving compliance landscapes.