It’s just so beautifully simple and based on common sense.

It demands that sustainability references for a financial product:-

#1 Are correct and capable of being substantiated

#2 Are clear and presented in a way that can be understood

#3 Are complete – not omitting important information or isolating claims to just one area of the company or product’s operations

#4 Only make comparisons to other products or services that are ‘fair and meaningful’

The simplicity is beautiful because it will wash out the box-tickers and the people who think they are clever to find ‘work-arounds’.

This is unfortunately what often happens when detailed rules are published. Corporate nitwits (and unscrupulous advisers) think they’re smart to try and find ways of bucking the system, arguing the detail. Just think what happens in the world of tax!

However, by basing the guidance on points of principle, the FCA has blown these people out of the water. To comply with notions such as ‘fair’ or ’complete’ or ‘substantiated’ automatically drives organisations towards gold-plating their compliance, rather than ticking the box.

Organisations will be driven to imagine being under examination – by the regulator or by a court – and having to demonstrate their adherence to these broad notions.

No chance to hide behind details or legalisms.

So if you haven’t read it yet, I strongly recommend a glance!