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
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.
Dunne and Fenech: the Tribunal recalibrates FCA penalties, not principles
The Upper Tribunal upheld the FCA's bans on two individuals central to a £126m defined benefit pension transfer scandal, but cut their fines after finding only 18% of advice was unsuitable, not all of it. For senior leaders, the ruling clarifies how enforcement outcomes will be tested on evidence, and reinforces that dishonesty toward the regulator remains a career-ending line.
Prosper's collapse: when the appointed representative bill comes due
Prosper Capital LLP has entered creditors' voluntary liquidation after the Financial Ombudsman upheld complaints against property investments sold by its appointed representative, Crowd2Let Capital. The failure crystallises a pattern regulators have been signalling for two years: principals cannot outsource accountability, and boards that treat AR oversight as a compliance formality are underwriting a contingent liability.
The £4.2m data lesson: PRA signals reporting integrity is a board matter
The PRA has fined HDI Global SE £4,165,000 for three years of inaccurate FSCS Liabilities and Fee Tariff submissions, citing failures in process, accountability and oversight. For senior leaders, the case reframes regulatory reporting from a back-office chore into a governance test with direct financial and reputational consequences.
Investment trust boards: the FCA tightens the conflict perimeter
The FCA has proposed targeted changes to the UK Listing Rules for closed-ended investment funds, extending conflict-of-interest protections to manager appointments and recognising the influence of substantial shareholders on boards. For chairs, NEDs and managers in the £260bn investment trust sector, the consultation reshapes how independence is documented and tested.
CACEIS censure: the sub-custodian's register check becomes a board-level control
The FCA has censured CACEIS UK and secured a £31.7m voluntary payment to WealthTek clients for failing to act on Financial Services Register information showing the firm was not authorised to hold client assets. The case redraws supervisory expectations for asset servicers and forces boards to treat permissions monitoring as a frontline financial crime control.
Relevant guides
How to Structure a Consumer Duty Board Report That Withstands FCA Scrutiny
This guide sets out how to build a Consumer Duty board report that demonstrates genuine oversight rather than compliance theatre. After reading, you will know what evidence to include, how to structure judgements, and where FCA scrutiny is most likely to bite.
How to Design a Board Risk Appetite Statement That Actually Works
This guide sets out how to build a risk appetite statement that satisfies PRA supervisors while giving non-executive directors something they can genuinely use in the boardroom. Readers will finish with a clear method for calibrating metrics, structuring the document, and avoiding the drafting mistakes that trigger supervisory challenge.
Assumption Risk in Strategic Planning: A Practical Guide
This guide explains how to identify, test, and manage assumption risk in strategic planning, the single biggest source of avoidable failure in board-level decisions. After reading, you will be able to audit any strategic plan for hidden assumptions and put controls in place before they become losses.
Handing Over an SMR Role Mid-Remediation: A Practical Guide
This guide sets out how to structure a Senior Managers Regime handover when a key function holder departs partway through a remediation programme. After reading, you will know how to sequence the transition, protect regulatory continuity, and defend the handover if challenged.
The Limitations of Relying on Internal Consensus: A Practical Guide
This guide sets out the specific limitations of relying on internal consensus when making strategic decisions in regulated firms. After reading it, you will be able to identify where consensus is misleading you, what to substitute for it, and how to structure decisions so agreement does not masquerade as evidence.
How to Improve Decision Quality at Board Level: A Practical Guide
This guide sets out the specific mechanisms that raise the quality of board decisions in regulated firms, from paper design to challenge protocols to post-decision review. After reading, you will know what to change in your board process to produce sharper, more defensible decisions.