The Anti-Greenwashing Rule: Understanding and Managing the Risk

Anti-Greenwashing Training Introductions

• Welcome, agenda/objectives

What is Sustainability?

• Understanding sustainability
• Evolving client priorities

Greenwashing

• Definitions
• How can it 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 should be correct and capable of being substantiated
• Claims should be clear and presented in a way that can be understood
• Claims should be complete – they shouldn't omit or hide important information
• Comparisons should be fair and meaningful
• Links to the existing Financial Promotions rules
• Anti-greenwashing training provides useful examples of good and poor practice

Greenwashing in Practice

• Seven Deadly Sins of Greenwashing
• Plus four more
• Case studies – where firms got it wrong (and how to avoid it)

Summary

• Anti-greenwashing course wrap-up
• Questions and answers
• Open forum

With over 20 years of experience in financial services training, Redcliffe’s anti-greenwashing course trainer brings deep expertise in compliance. 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.

A former member of the Investment Management Association’s Training & Education Committee, he won the Thomson Reuters award for "Most Effective Compliance Training" in 2010. With this extensive background, he is uniquely positioned to deliver expert anti-greenwashing training.

Anti-greenwashing training covers:

• Why greenwashing is a significant regulatory issue for the Financial Conduct Authority (FCA).
• The risks to consumer protection posed by the misrepresentation of sustainability claims.
• What exactly greenwashing is and provides relevant examples to illustrate its harmful effects.
• Evaluating 'risky terminology' and recognising language that can be confidently used in sustainability contexts.
• The importance of referring to the relevant international regulations that guide 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
• Identifying common greenwashing typologies that must be avoided within your firm is also explored in this anti-greenwashing course.

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.

Following the introduction of the EU regulation, the FCA published its own Sustainability Disclosure Regulation, which includes an anti-greenwashing rule that took effect on May 31st, 2024. Additional guidance was issued in April of the same year.

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. This 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 and undermine the integrity of the marketplace.

This greenwashing course explores the requirements, the risks, and the practical steps that can be taken. It provides participants with a solid rationale for building their own internal anti-greenwashing control frameworks.

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