When more than 1,300 lending bosses, regulators and MPs descended on Grosvenor House hotel on Park Lane in London for a black-tie dinner in late February, they arrived informed.
Invitees to the Financing & Leasing Association event had been handed an “annual dinner code of conduct” telling guests about a new policy on discrimination and sexual harassment. The trade body would “not tolerate any such behaviour and will, along with our event agency, take immediate action to stop it”.
Ahead of a dinner featuring speeches from broadcasters Andrew Neil and Clare Balding, nestled either side of a three-course meal featuring smoked trout, guinea fowl and glasses of Argentinian Malbec, it was the first time the industry group – whose members include Santander, Lloyds Banking Group and the lending arms of Harley-Davidson and Ferrari – had published such a declaration.
But the FLA is just one of a growing number of organisations trying to address a lax attitude to behaviour at conferences, after-work drinks and business trips in the City of London that has the potential to put their staff, guests and reputations at risk.
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FLA code of conduct
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Code of conduct sent to attenders before the Financing & Leasing Association’s annual dinner on 20 February 2024:
FLA endeavours to ensure all participants, regardless of their gender, ethnic origin, religion, belief, disability, age or sexual identity, experience an event that is free of any discrimination or harassment.
FLA will not tolerate any such behaviour and will, along with our event agency, take immediate action to stop it.
Unacceptable behaviour includes words or images of an offensive, discriminatory, disruptive or sexual nature during the event and/or in any social media (such as Twitter or Facebook) connected with or referring to it.
Participants who encounter or witness any such behaviour are asked to please contact the organising team.
FLA takes reports of any such behaviour extremely seriously and will respond to them with appropriate action
While the introduction of the UK’s Equality Act in 2010 undoubtedly kickstarted businesses’ diversity and inclusion efforts, their progress, or lack thereof, has faced mounting scrutiny since 2017 with the #MeToo movement and scandals in the City.
Prompted by rape and sexual harassment allegations against the Hollywood producer Harvey Weinstein, women across the world started sharing personal stories of sexual harassment, including in the workplace. Months later, the UK was rocked by revelations surrounding the men-only Presidents Club dinner, where hired hostesses were allegedly groped and sexually harassed by invited businessmen and bankers.
The corporate response triggered a renewed focus on the representation of women, and more stringent rules for workplace behaviour. But few firms focused attention on gatherings taking place outside working hours.
Some experts suggest it created a behavioural waterbed effect: while in-office misconduct might fall, it continued to rear its head elsewhere.
Earlier this year the influential commons Treasury committee published evidence with more than 40 women across financial services as part of its Sexism in the City inquiry.
The personal experiences shared with MPs – which ranged from bullying to rape – left the powerful panel with an impression that work-related harassment had merely shifted out of office. Instead, post-work drinks, conferences and business trips were now becoming a “danger zone” for women, the committee’s Conservative chair, Harriett Baldwin, said.
But firms, it said, had started to respond. “As awareness grows, some industry bodies are taking steps to counteract this, such as by developing an “event code of conduct”, or outlining a list of unacceptable behaviours at events.”
It highlighted evidence from the International Securities Lending Association, a finance industry trade body, which publicised a zero-tolerance policy for “unwelcome sexual advances” and “sexist, racist, homophobic or other discriminatory jokes” in its events code.
Likewise, the Association of Mortgage Intermediaries told guests that “any boisterous, lewd or offensive behaviour, including sexually explicit or offensive language, materials or conduct” could lead to perpetrators being expelled from events and banned in future.
Experts say business leaders undoubtedly want to deter harassment, but the codes are also there to protect corporate reputations if things go wrong.
“There’s a real awareness that, if you have a reputation, it could ruin the business,” said Joanna Chatterton, a partner and employment lawyer at the law firm Fox Williams. “They have to be seen to be taking steps so that they can say: ‘If somebody behaves badly, we took all reasonable steps to try to prevent this happening.’”
Chatterton was hired by the Confederation of British Industry lobby group for an internal investigation last year amid a string of sexual harassment allegations exposed by the Guardian.
Those included one woman’s claim that she was raped by a CBI manager during a summer boat party hosted by the lobby group on the Thames in 2019. Another reported an attempted sexual assault by a manager that day, and others claimed there was widespread use of cocaine at official CBI events.
The CBI is now trying to repair its reputation. Rehabilitation efforts include revamping its “events code of conduct”, a link to which is now displayed on the homepage of its website. The code asserts that the CBI will not tolerate behaviour including “inappropriate physical contact, sexual attention or innuendo, deliberate intimidation, stalking, and photography or recording of an individual without consent”.
The scandal has served as a wake-up call for corporate hosts of events. “A lot of organisations had caught on to this a while ago,” Chatterton said. “I suppose when we see things play out very publicly, the CBI being a good example, it sort of heightens the focus.”
Lawyers say the use of codes of conduct for events may accelerate further once amendments to the 2010 Equality Act come into force. Philippa O’Malley, a partner and employment lawyer at the law firm Slaughter and May, said the changes would mean that, from October 2024, employers would need to take “reasonable steps” to prevent sexual harassment of staff in the course of their employment. That could extend to harassment by third parties, including customers or clients, she added.
Randall Peterson, a professor of organisational behaviour at the London Business School, said the proliferation of codes of conduct felt like the “next logical step” for companies concerned about their responsibilities.
“Now, how effective it is going to be, given that it doesn’t have things like the employment relationship attached to it, is, I think, a really interesting question,” he said. “I think it’s probably worth the trial and experiment.”
It means the true test for employers will be showing that codes of conduct hold real weight, and that they have the appetite to pursue wrongdoers both inside and outside of their direct employment.
“I don’t think it’s reasonable, or realistic, to expect that employers can prevent absolutely every instance of bad behaviour, because they can’t control what everybody is doing,” O’Malley said. “But they need to show that there are real teeth behind those codes and policies.
“It’s important, not just in terms of hopefully preventing people from behaving that way, but I also think it’s a very important point in terms of employee’s psychological safety, and employee trust in their employer.”
