2017年-FCA英国金融行为监管局_whistleblowing_in_deposit_takers_pra_designated_investment_firms_and_insurers_3页_171kb

报告摘要

Regulator Assessment Summary: Whistleblowing in Deposit-Takers, PRA-Designated Investment Firms and Insurers (FCA PS15/24)

Core Content

This assessment outlines the regulatory provisions introduced by the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) to enhance whistleblowing mechanisms within financial institutions in the UK. The provisions aim to foster a culture where employees feel safe and encouraged to report wrongdoing, while also ensuring that firms have appropriate internal procedures in place.

The rules were finalized in October 2015 and came into effect on 7 September 2016. They apply to:

UK deposit-takers with assets of £250m or more
PRA-designated investment firms
Insurance and reinsurance firms under Solvency II
The Society of Lloyd's and managing agents

These rules affect approximately 1,500 firms across the UK.

Main Requirements

The key requirements for affected firms include:

Establishing internal whistleblowing arrangements capable of handling all types of disclosures
Informing UK-based employees about the FCA and PRA whistleblowing services
Requiring appointed representatives and tied agents to communicate the FCA whistleblowing service to their employees
Reporting to the FCA if an employment tribunal case involving a whistleblower is lost
Presenting an annual report on whistleblowing to the Board

Impact on Business

The assessment provides an estimate of the annual costs and benefits associated with the new provisions.

Annual Costs

Cost Category	Estimated Annual Cost (EANDCB)
Running whistleblowing arrangements	£8.5m
Training staff on whistleblowing	£7.9m
Overseeing effectiveness of arrangements	£2.2m
Total Estimated Annual Cost	£18.6m

One-off Set-up Costs

These include updating employment contracts, settlement agreements, and training materials. The costs vary by firm size:

Firm Size	One-off Set-up Cost (EANDCB)
Large firm (e.g., 10,000 staff)	£70,000
Medium firm (e.g., 500 staff)	£6,000
Small firm (e.g., 50 staff)	Negligible

Cost Breakdown by Firm Size

Firm Size	Whistleblowing Reports	Annual Cost of Running Arrangements	Annual Cost of Training	Annual Cost of Oversight	Total Annual Cost	One-off Set-up Cost
Large firm	Over one hundred	£140,000 (2 FTE)	£125,000 (450 man days)	£15,000 (0.2 FTE)	£280,000	£70,000 (1 FTE)
Medium firm	Over a dozen	£9,000 (30 man days)	£6,000 (20 man days)	£6,000 (20 man days)	£21,000	£6,000 (20 man days)
Small firm	One or two	£900 (3 man days)	£1,000 (25 man hours)	£600 (2 man days)	£2,200	Negligible

Benefits

Encourages a culture of transparency and accountability
Provides legal protection and confidentiality to whistleblowers
Enhances regulatory compliance and reduces reputational risk

Key Information

The rules do not include implementation of the Cutting Red Tape review.
The assessment is based on data from the British Bankers' Association, Building Societies Association, and Association of British Insurers.
The BIT score for the policy is 89.0, indicating a high benefit-to-cost ratio.
The estimated Net Present Value of the policy is -160.1, suggesting a long-term cost to the industry.
The requirement to report lost employment tribunal cases involving whistleblowers is expected to have negligible ongoing costs.