Ethics, Conduct and Professional Standards
This domain tests judgement under pressure: how to investigate, share data and treat customers ethically while still controlling fraud. Examiners reward proportionality, fairness and awareness of vulnerability.
Standards framework
- CII Code of Ethics: integrity, objectivity, competence, confidentiality, fairness, compliance and professionalism.
- FCA Principles for Businesses, especially Principle 6 (customers' interests) and Principle 7 (communications), plus Consumer Duty and SM&CR.
- Equality Act 2010; FCA guidance FG21/1 on vulnerable customers.
Investigation ethics
- Proportionality, privacy, presumption of innocence and non-discrimination.
- Lawful open-source research only; no harassment, no pretexting that breaches data protection.
- Conflicts of interest: savings targets can incentivise false positives and unfair outcomes.
- Report concerns; whistleblowing is protected under PIDA 1998.
Worked example
An investigator finds a claimant skiing while reporting whiplash. Before acting: verify authenticity, consider whether the image is relevant and lawfully obtained, avoid contact or harassment, and check vulnerability. Use the evidence proportionately in the claim decision.
Traps
- "The end justifies the means" reasoning.
- Unlawful surveillance or data sharing.
- Ignoring vulnerability and the distress of a wrongly suspected customer.