Amy Bird#11949

Amy Bird

Amy is a Partner in the London office of the global employment team of Clifford Chance. She has almost two decades' experience of providing employment advice across sectors and geographies. She divides her time equally among transactional, advisory, and contentious work. She has particular experience in financial services employment regulatory matters/ SMCR (including culture and conduct investigations). Prior to Clifford Chance she worked in-house as a sole-employment counsel at a European bank and at CMS (including secondments to FTSE 100 companies). She is a member of the Employment Lawyers Association.

Practice Area

Panel

  • Contributing Author

Qualified Year

  • 2007

Experience

  • Clifford Chance (2019 - Present)
  • Credit Agricole Corporate and Investment Bank (2016 - 2019)
  • CMS (2005 - 2015)

Membership

  • Employment Lawyers Association

Qualifications

  • Law degree (First Class Honours) (2004)
  • LPC (Distinction) (2005)
  • MA, Creative Writing (Merit) (2013)

Education

  • BPP Law School (2004-2005)
  • King's College London (2001-2004)
  • Birkbeck, University of London (2011-2013)

1 Contributions by Amy Bird

FCA non-financial misconduct: rules, guidance and enforcement under SM&CR and COCON (effective 1 September 2026) — implications for fitness and propriety, culture, systems and controls in UK financial services
PRACTICE NOTES
FCA non-financial misconduct: rules, guidance and enforcement under SM&CR and COCON (effective 1 September 2026) — implications for fitness and propriety, culture, systems and controls in UK financial services
The FCA has, in recent years, acknowledged that weak culture — notably any acceptance of non-financial misconduct — frequently underpins serious conduct breaches across financial services. Consequently, the regulator has sharpened its oversight of non-financial misconduct when supervising firms and individuals. September 2023 saw consultation CP23/20, outlining measures to advance diversity and inclusion and proposing clarifications on how its rules apply to non-financial misconduct. In July 2025, the FCA issued the resulting policy statement alongside CP25/18, detailing its stance on non-financial misconduct. As part of that package, the Code of Conduct (COCON) sourcebook was revised to introduce new non-financial misconduct rules for the sector. The scope of COCON was broadened to bring banks and non-banks into alignment on non-financial misconduct, confirming that for non-banks the rules capture serious bullying, harassment, violence and comparable behaviour directed at a colleague — defined to include fellow employees, staff of group companies and contractors. The rules take effect on 1 September 2026...
Financial Services
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