The Institute and Faculty of Actuaries (IFoA) has introduced new Diversity, Equity and Inclusion (DEI) requirements to the Actuaries’ Code and associated Guidance following a lengthy and wide-ranging consultation process with members, employers and other stakeholders.
These revisions reflect a broader regulatory trend, mirroring developments at bodies such as the SRA and ICAEW, towards strengthening professional ethics and workplace culture, particularly in relation to the fair treatment of others.
Key Changes
1. Clarification of the Respect Requirement (Principle 1: Integrity)
The Actuaries’ Code has always required members to act with integrity and to show respect, however Amplification 1.1 has been amended to read:
“1.1 Members must show respect for everyone” (emphasis added).
This change essentially simplifies the requirement and emphasises that members must show respect to everyone. The accompanying Guidance clarifies that this duty applies to all interactions, not only with clients and users of actuarial advice, but also with colleagues and the wider public. Respect extends beyond words to tone, non-verbal conduct and behaviour such as not taking credit for others’ work or spreading false information.
2. New Prohibition on Bullying, Victimisation and Harassment (Principle 1: Integrity)
A new amplification has been added to the Integrity principle of the Code, which reads:
“1.2 Members must not subject others to bullying, victimisation or harassment.”
The Guidance provides detailed explanations and examples:
- Bullying is defined as a behaviour that is offensive, intimidating or malicious, including persistent derogatory remarks, overbearing supervision, or inappropriate online communications.
- Victimisation is subjecting someone to detriment because they have, or are perceived to have, raised concerns or supported another person in doing so.
- Harassment involves unwanted conduct (verbal, physical or non-verbal) that violates dignity or creates a hostile environment, such as racist or sexist jokes or mocking someone’s disability.
Members are expected to consider both the nature of their conduct and its effect on others, applying an objective standard of reasonableness.
3. Speaking Up about Unfair Treatment (Principle 5: Speaking Up)
Another new amplification has been added to the Speaking Up principle of the Code, which reads:
“5.2 Members should speak up if they believe that others are being treated unfairly or excluded unreasonably.”
This addition emphasises that the Speaking Up principle extends beyond technical or professional issues to include fairness, inclusion and workplace culture. The Guidance recognises that speaking up can be difficult and requires judgement. While members are expected to act proportionately, there is no requirement to break the law or put personal safety at risk.
4. Changes to the Actuaries’ Code Guidance
While some subtle changes have been made to the Actuaries’ Code itself, more extensive changes have been made to the Guidance which supports the Code. The changes to the Guidance are intended to explain and provide context for the obligations in the Actuaries’ Code so that IFoA members can better understand how to apply the Code. Although the Guidance is not mandatory, it can be considered by a disciplinary panel as evidence of what the IFoA expects of its members, therefore IFoA members should ensure that they have read and understood both the Actuaries’ Code and Guidance.
What does this mean for IFoA members?
Although the changes to the Actuaries’ Code are less extensive than those initially consulted upon and haven’t gone as far as to require IFoA members to encourage DEI, they do introduce some additional obligations on members. While the changes to the Integrity principle could be seen as a clarification of IFoA members’ existing obligations, the requirement to speak up about unfair treatment and unreasonable exclusion does expand IFoA members’ speaking up obligations. Speaking up can be a challenging area to navigate and IFoA members may wish to seek advice to avoid breaching this new requirement.
IFoA members will also be aware that their obligations under the Code are not limited to their actuarial work; but can also apply to their personal life if their conduct could reasonably be considered to reflect upon the profession. IFoA members should therefore take particular care in circumstances where they are easily identifiable as a member of the IFoA.
Next Steps for Members and Firms
- IFoA members should read the updated Actuaries’ Code and Guidance carefully.
- Firms may wish to review internal training, workplace policies, and reporting mechanisms to ensure consistency with the revised professional standards.
- Both individuals and organisations should reflect on how these changes interact with existing initiatives on ethics, inclusion, and professional behaviour.
If you have questions regarding this article, or your professional obligations under the Actuaries’ Code, please contact a member of the Regulatory team.
about the auhtors
Jenny is a Legal Director in the Regulatory team. She specialises in actuarial, accountancy and financial services regulation, and is experienced in advising regulated individuals and firms as well as acting on behalf of professional regulatory bodies.
Zoe is an Associate in the Regulatory team. Zoe works with the Zacchaeus 200 Trust charity, acting for clients to appeal disability benefit decisions. She also volunteers for Amicus, Queen Mary Legal Advice Clinic and the Schools Consent Project.
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