Topic hub
Governance and Decision Defensibility
Boards and executive teams are increasingly expected to show their working, not just their conclusions. When a decision is challenged after the fact, what matters is whether the reasoning, evidence and dissent were properly recorded and tested at the time, not simply whether the outcome was reasonable.
Polar Insight's view
Polar Insight helps leadership teams build decisions that can withstand scrutiny before it happens, by testing evidence quality, capturing genuine challenge, and creating a rationale that holds up under review.
Featured insights
Odey upheld: the Upper Tribunal's integrity finding and what it signals for founder-led firms
The Upper Tribunal has upheld the FCA's ban of Crispin Odey and imposed a £1.53 million fine, finding that he lacked integrity and dismantled his firm's governance to avoid accountability. The ruling reframes non-financial misconduct as a governance failure that boards, not just HR functions, are expected to prevent.
RTGS delay: why the CHAPS standards slip is a governance problem, not a technical one
The Bank of England has deferred the November 2026 RTGS standards release in its entirety after Swift postponed its own CBPR+ release, citing industry concerns about readiness for the removal of unstructured postal addresses. For boards that had budgeted, staffed and sequenced ISO 20022 migration around a fixed November date, the reset is a live test of change governance and vendor accountability.
Dolfin visa scheme: what the £35.5m ban says about SMCR integrity tests
The FCA has fined and banned former Dolfin executives over a scheme that helped at least 99 clients bypass investor visa rules, generating £35.5m in fees. The case resets expectations on shadow control, concealment, and senior manager integrity for boards across wealth and private banking.
SVS ban: FCA sends pension custody warning to fund manager boards
The FCA has fined and banned Demetrios Hadjigeorgiou, former CEO of SVS Securities, for failing to manage the firm and protect customers whose pension savings were placed in high-risk products. For senior leaders in asset and wealth management, the case sharpens personal accountability where retail money, product incentives, and pricing decisions intersect.
Debt management ban shows FCA tightening the honesty net
The FCA has banned Howard Roland Duckett, a former senior manager at debt management firm Beauforce Corporation, citing a serious lack of honesty and integrity following a High Court director disqualification he failed to disclose. Combined with the recent Blue Horizon prohibitions, the action signals a sharper regulatory posture on individual accountability that senior leaders and boards must factor into governance and disclosure practices.
Blue Horizon bans: the FCA draws a hard line on integrity at the top
The FCA has fined and banned two former Blue Horizon Asset Management executives for falsifying documents during attempted acquisitions of a UK bank and Reading Football Club. The case sets a clear marker on senior manager conduct and the evidentiary weight regulators place on acquisition submissions.
Relevant guides
How to Design a Board-Level Risk Appetite Statement Regulators Will Accept
This guide sets out how to build a risk appetite statement that functions as a genuine governance tool, not a compliance artefact. After reading, you will know how to structure, calibrate, and operationalise a statement that boards can use and supervisors will credit.
How to Brief a Board Ahead of a Section 166 Skilled Person Review
This guide explains how to prepare your board for a Section 166 review so directors understand the scope, their obligations, and what credible engagement looks like. After reading, you will know how to structure the briefing, what to put in front of the board, and which judgement calls to surface early.
How to Structure an SMR Handover When a Key Function Holder Departs
A practical guide to managing the departure of a Senior Manager under the SMCR, covering sequencing, documentation, regulatory notifications, and successor readiness. After reading, you will know how to run a handover that stands up to supervisory review and protects continuity of accountability.
How to Structure a Board Paper Seeking Approval for a New Market Entry
A practical guide to building a board paper that wins approval for entering a new market, covering structure, evidence, and the judgement calls that matter most. After reading, you will know how to frame the opportunity, pre-empt scrutiny, and give the board a decision they can defend.
How to Prepare a Credible Wind-Down Plan That Satisfies Board and Regulator
This guide sets out how to build a wind-down plan that holds up to board challenge and regulatory scrutiny, covering trigger design, resource adequacy, and operational realism. After reading, you will know where most plans fail and what to prioritise to produce one that is genuinely executable.
How to Pressure-Test a Board Decision Before Committing
A practical guide for chairs, CEOs, and senior directors on how to stress a board decision before it becomes irreversible. After reading, you will know how to structure challenge, expose weak assumptions, and identify the stakeholder reactions that most often derail execution.