Description

Ethics Policy Template Pack for FAIS FSPs

The Ethics Policy Template Pack is an editable downloadable document designed for authorised Financial Services Providers that need a practical framework for ethical conduct, fair client treatment, responsible decision-making, reporting of unethical conduct and ethics risk monitoring.

This Ethics Policy Template helps an FSP set clear expectations for directors, key individuals, representatives, employees, managers, service providers and third parties. It supports ethical culture, client protection, conflict management, confidentiality, proper recordkeeping, fair treatment of clients and accountability across the business.

For related compliance templates, you may also view our Fraud and Corruption Policy Pack, Conflict of Interest Management Policy Template and Complaints Management Framework Template.

For official regulatory information, you can also visit the FSCA FAIS regulated entities page.

What Is Included In This Ethics Policy Template?

This template pack is designed to help FSPs move beyond a basic code of conduct. It includes a full ethics policy together with practical annexures that support implementation, staff awareness, third-party checks, breach reporting, training and ethics risk monitoring.

The policy includes sections for:

• Document control and policy ownership
• Introduction and purpose of the ethics policy
• Definitions, including ethics, business ethics, ethical culture and conflicts of interest
• Legal and regulatory framework
• Ethical values and conduct principles
• Leadership and tone from the top
• Roles and responsibilities
• Client conduct and fair treatment
• Employee conduct and workplace ethics
• Records, information integrity and confidentiality
• Conflicts of interest, gifts and inducements
• Procurement, contracts and third parties
• Ethical risks and controls
• Reporting unethical conduct and whistleblowing
• Investigation, corrective action and consequences
• Monitoring, accountability and reporting
• Training and awareness
• Recordkeeping requirements
• Policy review and approval

Ethics Policy Template Annexures Included

The Ethics Policy Template Pack includes practical annexures that can be used as evidence that ethical conduct expectations have been communicated, monitored and reviewed.

The annexures include:

• Annexure A: Staff Acknowledgement and Ethics Undertaking
• Annexure B: Ethical Decision-Making Checklist
• Annexure C: FAIS Conduct Quick Guide
• Annexure D: Ethical Breach Report Form
• Annexure E: Ethical Breach Register
• Annexure F: Third-Party Due Diligence Questionnaire
• Annexure G: Third-Party Ethics Undertaking
• Annexure H: Ethics Training Attendance Register
• Annexure I: Annual Ethics Declaration
• Annexure J: Ethics Risk and Control Register

Why FSPs Need an Ethics Policy Template

Ethical conduct is central to financial services. It affects how clients are treated, how advice is given, how conflicts are managed, how records are kept, how complaints are escalated and how staff respond when they are under pressure.

A written Ethics Policy Template helps the FSP communicate expected conduct clearly and create a documented process for identifying, reporting, investigating and correcting unethical behaviour.

This template helps address common weaknesses such as:

• No formal ethics policy in place
• No written ethical values or conduct principles
• No staff acknowledgement of ethical responsibilities
• No ethical decision-making checklist for difficult situations
• No FAIS conduct quick guide for representatives and staff
• No ethical breach report form
• No ethical breach register
• No third-party ethics due diligence process
• No annual ethics declaration
• No ethics risk and control register

Client Conduct and Fair Treatment

The policy includes practical wording on client conduct and fair treatment. It reminds employees and representatives to act honestly, fairly and with due skill, care and diligence when dealing with clients.

It also covers clear communication, proper disclosures, avoiding unauthorised advice, keeping proper records, protecting confidential information, supporting vulnerable clients and escalating complaints through the approved complaints process.

Ethical Decision-Making and Breach Reporting

The Ethics Policy Template includes an ethical decision-making checklist to guide staff when they are unsure whether a decision, instruction, transaction, communication or action is ethical.

The ethical breach report form and breach register help the FSP record concerns relating to client conduct, conflicts of interest, fraud, bribery, discrimination, harassment, recordkeeping, confidentiality or other serious irregularities.

Third-Party Ethics Controls

The template pack includes a third-party due diligence questionnaire and third-party ethics undertaking. These tools help the FSP assess whether suppliers, outsourced service providers, consultants or partners understand and support ethical business practices.

This is useful where third-party conduct may affect the FSP, its clients, confidential information, regulatory duties or reputation.

Who Should Use This Ethics Policy Template?

• Authorised Financial Services Providers
• Key Individuals responsible for conduct oversight
• FSPs with representatives or employees
• FSPs using outsourced service providers or consultants
• Compliance officers assisting FSPs
• Managers responsible for staff conduct and client outcomes
• FSPs strengthening governance, conduct risk and ethical culture

Editable and Customisable FSP Ethics Template

This Ethics Policy Template Pack is editable and must be customised before use. The FSP must insert its name, FSP number, policy owner, approver, reporting channels, storage location, responsible persons, review process and evidence storage arrangements.

The template includes placeholders that should be completed before the final policy is approved, issued and implemented.

Important Compliance Note

This Ethics Policy Template Pack is a compliance support document. It does not replace legal advice, labour advice, disciplinary advice, whistleblowing advice or a full ethics risk assessment. Each FSP remains responsible for ensuring that the final policy is accurate, implemented, monitored and aligned with its business model, conduct risks, regulatory obligations and internal governance arrangements.