Introducing 2be Development Consultancy




2be Development Consultancy was formed in 2009.  We describe ourselves as a people management and development consultancy.


We specialise in helping firms within the UK financial services sector deal with people aspects of regulation and people development.  People aspects of regulation relate to any aspects that relate to the competence/behaviour. 

We enjoy working with firms to ensure that they feel in control of their business and still comply with the needs of the regulators.  We do this by utilising the aspects of their business that are important to them which they do well and build on these to craft solutions that they are happy to use.  We create ownership by working with firms, listening to them, involving them and responding to their feedback.


Customer Focus
We will ensure that our support is in response to your needs. We will shape our solution to reflect your culture, values and ethics. We will respond to your feedback and ensure that you are completely satisfied with the service or product provided. We are committed to quality.

We believe that all costs should be clear and set out from the outset. We do not believe in “smallprint.”

We will work with you to confirm whether we are able to help you. We will communicate clearly with you at all times. We will keep you informed.



We have decades of experience in working with the regulations that affect UK financial services firms.  This experience has been gained both as practitioners and consultants. Many of our consultants have held senior management positions within financial services companies and have an in depth understanding of the challenges firms face and how they can be addressed.


We are happy to support you with any project that falls within our area of expertise no matter what the size.  We enjoy working with clients where we can support the development of people at the same time.  If we can improve the capability of your people and create a sustainable solution that you can manage yourself we feel we have done a good job.



The Senior Managers & Certification Regime (SM&CR) along with the Code of Conduct affect nearly every financial services firm in the UK. Ensuring that you understand the intent and purpose of the regulations requires more than following the letter of the regulation.  This is where we come in and can help ensure that the approach you develop creates a true culture of accountability that focuses on the consumer.


Working with you we can design processes and procedures to develop appropriate solutions. A key part of the SM&CR regulations require Senior Management Functions (SMF) to take reasonable steps in discharging their duty of responsibility. Such steps are defined within the Decision Procedures and Penalties (DEPP) sourcebook and provide clear evidence that processes and procedures are needed to address the regulatory expectations.


We can develop a range of training solutions and where required deliver them on your behalf. Such training could relate to briefing people on the regulations, how to conduct a FIT and Proper check, Ensuring supervisors of certification functions are competent to perform this task or developing the understanding and help embed the code of conduct into your business.


Within the FIT and Proper assessments that are required a person’s competence and capability must be confirmed.  In order to do this you must have measurable standards, appropriate and consistent evidence gathering approaches and reliable judgements.  We can help you develop and implement all these key aspects.


If you are classified as a SMF and carry the prescribed responsibility for either the Certification Regime or the Code of Conduct you may wish to ensure that the steps that have been implemented by your firm represent reasonable steps taken by you to discharge your Duty of Responsibility.

We will be happy to take a look at any of the elements of your approach to ensure that you can have the peace of mind that you have covered what the regulator is seeking

If you would like peace of mind then why not ask for a Certification or Code of Conduct Review?  We will look at all the following aspects for you and grade your approach Green, Amber or Red.

 Certification Regime

  • Cultural fit
  • Governance
  • Reporting & Controls
  • Certification Issue
  • Scope
  • Competence Approaches
  • Remuneration & Reward
  • Recruitment & Referencing

 Code of Conduct

  • Training
  • Understanding
  • Sustainability
  • Cultural Fit
  • Breach Reporting



We have decades of experience in working with the regulations that affect UK financial services firms.  This experience has been gained both as practitioners and consultants. Many of our consultants have held senior management positions within financial services companies and have an in depth understanding of the challenges firms face and how they can be addressed.


We find the best way to design a T&C scheme is to work closely with you and develop an approach that ties into:

  • Your culture and values
  • Your business goals and objectives
  • Your customer proposition
  • Your appetite for risk
  • Your business capability

We help build a scheme that recognises and uses the best practices you have built up in your business or those you wish to add into your business.

We use your processes, policies, procedures, systems, forms and business language wherever we can and involve and engage your staff in the design process to help ensure you recognise and take ownership of something that looks and feels familiar.

We use our expertise to ensure that your scheme complies with the TC sourcebook and associated regulations but the scheme remains an enabler for your business.

Firms are happy to adapt our approach for areas within their business that are not directly affected by the TC sourcebook but like the way we approach and address the challenges of competence.

Working with you we help ensure you end up with a scheme that works for you, is sustainable by you and will keep the regulator happy and deliver the consumer outcomes you seek.

We have been engaged in T&C Scheme design for over 20 years and are happy to share this experience and support with you.


We can develop a range of training solutions and where required deliver them on your behalf. Such training could relate to briefing people on the T&C regulations or how your scheme works, how to define and measure competence or ensuring supervisors are equipped with the necessary assessment, coaching and feedback skills.


Supervisors are expected to ‘have the necessary coaching and assessment skills as well as the technical knowledge to act as a competent supervisor and assessor.’  There are a number of ways evidence of such competence can be obtained. Without proof of supervisory competence it is difficult to verify the accuracy of their assessments.  

Our suggested approach requires delegates to undertake a series of assessments to produce a portfolio of evidence to confirm their ability to perform these key tasks. Each delegate will receive an individual report. The competency assessments are normally run on your own premises.

 Competency Assessment Possible Components

  • FCA T&C requirements—test
  • Explain to Me—Understanding of assessment & coaching.  Written assessment
  • Use of observation aid—DVD assessment
  • Errors within a regulated sale (optional) – Written exercise
  • MI review  – case study
  • File Check—generic exercise (optional)
  • Coaching and feedback—role play
  • Development plan—written exercise

The Competency Assessment will be designed to match your specific requirements.

We are happy to use materials that you provide or indeed undertake the design of specific exercises to include in the assessment centre


Ensuring your T&C scheme remains fit for purpose is a key to ensure that it continues to:

  • Support your business objectives and deliver shareholder value
  • Minimise your conduct risk
  • Retain and attract staff
  • Deliver consumer outcomes to the required standards

When was the last time you undertook a detailed review of your T&C scheme? Do you know why you have chosen to shape the scheme the way you have and have you explored alternative ways open to you? If you do not regard your T&C scheme as an ‘enabler’ to help deliver your business results it is definitely time for a review. If you are happy that your scheme does enable your business then why not regards a review as an opportunity to benchmark and fine tune your approach for possible better results.

Scheme reviews can be undertaken for your scheme as a whole or we can undertake a specific thematic review for you.  The objectives of the review are agreed up front and an outline plan including timeline and budget agreed.

The review will normally include interviewing selected staff, reviewing procedures and supporting documents and evidence. The review report will summarise key recommendations and will normally be presented at a face to face meeting.

All reviews undertaken are underpinned against the regulatory standards required, Financial & Legal Skills Partnership good practice guidance and our own best practice framework developed through over 20 years working in this field.

Thematic reviews can be on any topic you choose.  Some examples include:

Effectiveness of supervision model
Alignment with company culture
Effectiveness of Continuing Professional Development
Connectivity to consumer outcomes
Alignment with Conduct Risk
Governance Model

All reviews are undertaken on the basis that we have no vested interest in the outcome.  If invited we are happy to work with you to define actions needed to resolve our recommendations.  These may or may not require further resource from us as mutually agreed.

We are able to review progress you have made either by specifically looking at progress against recommendations or conducting a further review.

We recommend that you undertake a review of your T&C scheme every 2 years as part of your governance



We design and facilitate activity based workshops that engage delegates and involve them by tapping into different learning styles.  We normally work with groups of up to 9 people but are happy to discuss larger numbers with you.


We offer a range of workshops that cover people aspects of regulation (T&C, SM&CR, Code of Conduct, FIT and Proper Assessments as well as Coaching, Assessment and Supervisor Programmes.  These workshops are delivered on a regular basis at different UK locations.


We are happy to deliver any of our workshops to any UK location.  Please contact us for more details


We support T-CNews Premium Subscribers by running regualr online workshops through zoom.  Full details of available workshops can be seen in the events calendar at


People accessing CPD through their laptops


Get up to speed quickly on the issues that affect your people, their competence and development within regulated UK financial services.

There are over 50000 firms operating within the UK financial services sector. All firms need to be authorised and agree to meet the rules and guidance set by the regulators (PRA & FCA). Many of the rules relate to the people who work within the firms. This is where we come in. We focus on what we call people aspects of regulation and people development. We’ve being doing this since 1996 so have a wealth of information available.

People aspects of regulation include everything associated with competence- having the right knowledge, skills, behaviours such as T&C (TC), Competent Employees Rule  (CER) and  Fitness & Propriety (FIT). The Senior Managers & Certification Regime (SM&CR) and the Code of Conduct (CoCON) are very much in our ball park. We also look at people development, their CPD, coaching, supervision and other best practices.

If your role involves working with people for any of these aspects the T-CNews is an ideal product for you.  The content will be of particular help if you carry the prescribed responsibilities associated with SM&CR or the Code of Conduct or are involved with T&C within your firm. With hundreds or articles in a searchable directory as well as videos we know that we can help you:

  • Identify key topics and trends that will affect your people
  • Develop quickly your understanding of the requirements expected
  • Discover best practice to learn what works best
  • Shorten training preparation timescales
  • Access material to share with others
  • Save £s from your CPD and Training Budgets




01361 315 003



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