6th September 2021

Conundrum training in Olympic Park

In September 2020, the FCA published it’s ‘Ethnicity Action Plan’ noting “We’ll be refreshing our Unconscious Bias mandatory training, exploring more impactful alternatives and rolling out three workshops across the organisation to support the changes we want to see. These workshops will focus on exploring privilege “

Fast forward to 15^th December 2020, in a written Ministerial Statement on Unconscious Bias Training (UBT) the Government stated that “Unconscious bias training typically aims to raise awareness of the potential biases and cognitive shortcuts that may negatively affect decision-making and behaviour in the workplace” was to be scrapped for all Civil Servants.

Their statement noted that “there is no recognised way of assuring the quality of unconscious bias training”. Additionally, there was “no conclusive proof that it changes behaviour or improves workplace equality in the long term”.

Government speak for it’s a complete waste of time and money.

The Government’s view is that UBT has serious implications for organisations, who risk putting funding into poor quality and ineffective training and that other parts of the public sector should review their approaches.

An FCA whistle-blower has told us the FCA does not seem to have heard the message and has been conducting workshops on White privilege and Micro-aggression since January 2021, just a couple of weeks after the Ministerial statement that “there is no conclusive proof that it changes behaviour or improves workplace equality in the long term”.

With this in mind, we sent an FOI to the FCA.

And yes, the reply we got confirms it’s true. 

At 22 June 2021 some 333 had been through this course with more to follow. Soon it will be some 10% of the workforce. At this stage ‘all’ senior leaders and managers have been invited to attend. 

We have no idea about who devised or designed the courses. We know they aren’t written externally or developed by an actual “specialist” in this area, so if internally curated, how are the individuals writing these courses qualified to do so?

Not a month goes by without hearing of some serious financial services failings that regulation was intended to prevent consumer detriment. There is the usual handwringing regulatory  ‘coulda, woulda, shoulda’ responses. 

Hindsight is the foundation what regulation is built on. So, some more FOI questions to the FCA. 

1. With the benefit of hindsight, would you please confirm what regulatory failings could have been prevented by Unconscious Bias Training courses (UBT) since April 1^st 2013?
2. With the benefit of hindsight, what consumer detriment could have been prevented by Unconscious Bias Training (UBT) courses since April 1^st 2013?
3. How has the integrity of the UK financial system been enhanced by Unconscious Bias Training (UBT) courses? 
4. How much more effective has competition in the interests of the consumer been enhanced by Unconscious Bias Training (UBT) courses?
5. Why are these courses still being run given the government directive that such courses were to be scrapped? 
6. How did you assure the quality of unconscious bias training as there is no recognised way of assuring such quality according to the Government? 

At the time of publication, these questions remain unanswered.

The UK financial services sector should be very wary of what is happening at the FCA . Programmes such as this will be compulsorily extended to the firms they regulate adding more cost, more complications.

We are seeing a Woke drive with gender, ethnicity, pronoun zealotry, rainbow logos all creating minefields for any firm who does not ‘comply’ to navigate safely.

Gone are the days of principle or rules-based regulation, they are being replaced by virtue signal and bias based regulation. 

I would urge consideration is given to an updated version of the Niemoller verse.

First, they came for the Asset Managers
And I did not speak out
Because my business was not an Asset Manager

Then they came for the Platforms
And I did not speak out
Because my business was not a Platform
Then they came for the Life companies
And I did not speak out
Because my business was not a Life company
Then they came for me
And there was no one left
To speak out for me

I’ll keep you posted if I get answers to those six questions.

Panacea Comment