The Anti-Greenwashing Rule: Understanding and Managing the Risk

Introductions

• Welcome to the session, agenda and objectives of anti-greenwashing rules training

What is Sustainability?

• Understanding sustainability
• Evolving client priorities

Greenwashing

• Definitions
• How greenwashing can occur

Current Regulatory Position

• Sustainability Disclosure Requirements
• The EU equivalent – Sustainable Finance Disclosure Regulation (SFDR)
• The four sustainability labels
• Product descriptors and associated rules
• FCA commentary on greenwashing
• The Advertising Standards Authority – additional detail

The Anti-Greenwashing Rule: Effective May 31st, 2024

• Claims need to be correct and capable of being substantiated
• Claims are required to be clear and presented in a way that can be understood
• Claims should be complete and not omit or hide important information
• Comparisons should be fair and meaningful
• Links to the existing Financial Promotions rules
• Anti-greenwashing training illustrates both good and poor practices through practical, real-world examples

Greenwashing in Practice

• Seven deadly sins of greenwashing
• Plus four more
• Case studies – where firms got it wrong and how to avoid it

Summary

• Course wrap-up
• Q&A
• Open forum

With over 20 years of experience in financial services training and a solid compliance background, participants are in the safe and knowledgeable hands of our expert in anti-greenwashing rules.

Formerly the Head of Education at HSBC UK and Europe, he led regulatory and financial crime compliance training during a period of intense oversight, including the bank's Deferred Prosecution Agreement.

His career includes leading the Monitoring and Testing program for a UK wealth manager and serving as Senior Vice President of Global Risk & Compliance training at a US-based bank. He also worked at the Financial Conduct Authority (FCA) as the divisional expert on the Training & Competence handbook.

Having held key roles at HSBC and Barclays, including five years in Barclays' Private Clients and Wealth functions, he has extensive experience in retail, commercial, and private banking. Since leaving HSBC, he has worked with compliance, HR, and operations teams, delivering training to private equity firms, investment houses, and wealth managers. He also leads core programs for TISA and the Investment Association.

Thoroughly versed in greenwashing risk, our trainer, a former member of the Investment Management Association’s Training & Education Committee, won the Thomson Reuters award for "Most Effective Compliance Training" in 2010.

At Redcliffe Training, our anti-greenwashing course provides you with a clear understanding of the FCA’s expectations on sustainability claims and how to ensure communications remain fair, clear, and not misleading. Through practical analysis and regulatory insight, the programme helps firms identify, manage, and prevent greenwashing risks across their operations:

• Training includes the discussion and determination of why greenwashing is a significant regulatory issue for the Financial Conduct Authority (FCA).
• Sessions cover the risks to consumer protection posed by the misrepresentation of sustainability claims.
• Participants learn specifically what greenwashing is, providing relevant examples to illustrate its harmful effects.
• Evaluating 'risky terminology' and recognising language that can be confidently used in sustainability contexts is covered during anti-greenwashing training.
• The importance of referring to the relevant international regulations guiding sustainability claims and greenwashing prevention when required.
• Explanation of the anti-greenwashing rule effective May 31st, 2024 and its implications for firms in terms of compliance and best practices.
• Connecting these requirements to existing COBS and Financial Promotions rules.
• Sessions identify and explore common greenwashing typologies that must be avoided within firms.

Redcliffe Training’s anti-greenwashing course is suitable for all staff involved in the design, approval, operation, monitoring and auditing of financial products that make any reference to the sustainability characteristics of those products.

Sessions are designed for professionals involved in the design, approval, oversight, or promotion of financial products referencing sustainability characteristics. It is particularly relevant to compliance, risk, audit and the legal teams responsible for ensuring claims meet FCA expectations.

Attendees gain the practical understanding needed to identify and mitigate greenwashing risk, align internal controls with the FCA’s Anti-Greenwashing Rule, and ensure all sustainability communications remain fair, clear, and not misleading.

Following the introduction of the EU regulation, the FCA published its own Sustainability Disclosure Regulation, which includes an anti-greenwashing rule, taking effect as of May 31st, 2024. Additional guidance was issued in April of the same year, and Redcliffe’s anti-greenwashing course covers this.

As consumer demand for sustainable products grows, firms are under increasing pressure to be perceived as ‘green.’ However, failing to meet these expectations can lead to significant reputational damage and financial losses. Such pressure may tempt some firms to engage in greenwashing—repackaging an existing product as sustainable, misleading consumers into believing it meets their environmental or sustainability goals. Such practices not only pose a risk to consumers but also harm the industry’s reputation whilst undermining the integrity of the marketplace.

Anti-greenwashing sessions provide the requirements, risks, and practical steps required. Training gives participants a solid rationale for developing their own internal anti-greenwashing control frameworks.

We consider operational management of sustainable products as well as environmental claims within marketing activity.