Lloyd’s plans to update its framework for for dealing with poor conduct & behaviors, addressing both financial and nonfinancial issues in the market.
The revised system aims to better align with partner firms’ HR and disciplinary procedures while maintaining support for their independent investigations and actions.
A market bulletin outlines these changes. Lloyd’s also intends to clarify unacceptable behaviors and define when it will intervene, increasing focus on oversight and intervention.
The market seeks to streamline its decision-making processes, as detailed in a consultation report linked to the bulletin.
The new framework for managing such issues is designed to:
- Ensure better alignment with firms’ own internal HR and disciplinary processes, supporting firms’ ability to investigate their own employees and to address issues themselves;
- Expressly recognise our trust in the ability of those managing agents and syndicates that meet the expected levels of maturity under the Culture Principle to investigate and resolve issues before intervention is required from Lloyd’s;
- Provide greater clarity as to the types of conduct or behaviours that Lloyd’s considers unacceptable, including for non-financial misconduct, and to set out when and how Lloyd’s will intervene;
- Align Lloyd’s Enforcement and Oversight functions so that Lloyd’s can adopt a more holistic approach when dealing with cases, with Oversight intervention being at the heart of this process, but with Enforcement being available as needed; and
- Improve Lloyd’s internal decision-making processes, so that decisions can be made in a more timely and consistent manner, whilst also preserving necessary procedural safeguards.
Lloyd’s proposes changes to its enforcement bylaws, introducing new categories such as “improper” conduct, repeat offenders, and mistreatment of whistleblowers. Existing categories like “discreditable” and “detrimental” conduct will stay in place, with the additions offering clearer definitions of misconduct.
The proposals also clarify that misconduct can occur outside a professional setting, and action doesn’t require institutional harm. Behaviors like drug use, harassment, or bullying are unacceptable and should be addressed, even if no direct harm to Lloyd’s or the market occurs.
by Yana Keller
