SBAI Responds to FCA Discussion Paper 21/2 on Diversity and Inclusion
FCA Discussion Paper on Diversity and Inclusion (July 2021)
As part of our mission to increase collaboration between asset managers and institutional investors to improve industry outcomes, at the SBAI we have a dedicated Culture and Diversity Working Group. We are supportive of the FCA’s intentions in this discussion paper and through the work and discussions within our working group make the following observations:
- Quantitative vs Qualitative Data: On the theme of our next focus area in the C&D initiative we observe that disclosure solely based on metrics may not be appropriate as it can be difficult for smaller firms amongst other reasons. We recommend the use of qualitative questions also.
- Regional differences: We note that global firms based in the UK may not be able to provide data for non-UK based employees
- Proportionality: We recommend that should detailed metrics based reporting be decided on that a concept of standard and enhanced reporting should be introduced with thresholds based on number of employees and other similar measures.
- Standardisation: We recommend that the FCA consider reporting requirements and allocator questionnaires that are currently in circulation to avoid introducing additional frameworks and reduce some of the resource requirements on firms.
