
Written by Joanne Hughes, Policy & Compliance Specialist at Policy Pros
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Financial Policies and Processes - Policy Writing Services
Policy Pros provides financial policy writing services to a wide range of UK organisations, from SMEs and charities to FCA-regulated firms and public sector bodies. Sound financial policies and procedures are not just a mark of good governance — they are a regulatory requirement for many businesses and a critical component of audit readiness, risk management, and stakeholder confidence.
These policies and procedures assist with compliance with the UK Companies Act 2006 and provide a solid framework of controls and processes for clients to adhere to throughout their departments.
The Regulatory Landscape for Financial Policies
The UK's regulatory framework for financial governance is extensive and applies differently depending on the type of organisation, the sector it operates in, and whether it is subject to oversight by a specific regulatory body. Understanding which regulations apply to your business is the first step towards building an effective policy framework.
Companies Act 2006
The Companies Act 2006 is the primary statute governing UK companies. It sets out directors' duties (Sections 170 to 177), including the duty to promote the success of the company, to exercise reasonable care and skill, and to avoid conflicts of interest. The Act also imposes requirements around the preparation, approval, and filing of annual accounts, the appointment of auditors, and the maintenance of adequate accounting records (Section 386). Financial policies should directly support directors in meeting these statutory obligations.
Financial Services and Markets Act 2000
For firms authorised and regulated by the Financial Conduct Authority (FCA), the Financial Services and Markets Act 2000 (FSMA) provides the overarching legislative framework. The FCA Handbook — and in particular the Senior Management Arrangements, Systems and Controls sourcebook (SYSC) — requires regulated firms to establish and maintain adequate policies, procedures, systems, and controls to manage the risks to which they are exposed. SYSC 6.1.1R, for example, requires firms to establish effective policies and procedures for countering the risk of financial crime. Failure to maintain adequate systems and controls can result in enforcement action, fines, and in serious cases, the withdrawal of a firm's authorisation.
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
The Money Laundering Regulations 2017 (MLR 2017) impose specific obligations on firms within the regulated sector, including requirements for customer due diligence, ongoing monitoring, record-keeping, and the appointment of a nominated officer responsible for receiving and reporting suspicious activity. These regulations apply to a wide range of businesses, including banks, building societies, investment firms, accountancy service providers, estate agents, and legal professionals. A robust Anti-Money Laundering (AML) policy is a mandatory requirement under the MLR 2017 (Regulation 19), and the policy must be proportionate to the nature, size, and complexity of the firm's activities.
Other Relevant Legislation
Depending on your organisation's activities, additional legislation may also be relevant to your financial policy framework:
- Bribery Act 2010 — requires organisations to have adequate procedures in place to prevent bribery
- Criminal Finances Act 2017 — creates a corporate criminal offence for failing to prevent the facilitation of tax evasion
- Charities Act 2011 — imposes specific financial governance obligations on charitable organisations
- Proceeds of Crime Act 2002 — relevant to reporting obligations for suspected money laundering
- UK GDPR and Data Protection Act 2018 — applicable to the handling of financial data containing personal information
Types of Financial Policies
The specific financial policies an organisation needs will depend on its size, sector, and regulatory obligations. Below are the core policy types that form the backbone of a comprehensive financial governance framework.
Audit Compliance Policy
This is essential for ensuring that a company meets legal and regulatory requirements. This policy outlines the procedures and practices a business follows to comply with auditing standards. It establishes trust among stakeholders by demonstrating the company's commitment to transparency and accountability.
Budgeting and Forecasting Policy
This is crucial for the financial planning process of a company. It provides a structured approach to creating financial plans, predicting future financial performance, and allocating resources effectively. It ensures that the company's financial activities are aligned with its strategic goals, leading to sustainable growth.
Corporate Governance Policy
This policy defines the roles and responsibilities within a company. It sets the framework for controlling and managing the company, ensuring a balance of power among the board of directors, management, and shareholders. It aims to foster a culture of integrity and accountability.
Director's Responsibilities Document
Documenting the legal and ethical obligations of company directors is crucial for steering the company towards its objectives while ensuring compliance with corporate laws and protecting the interests of shareholders.
Financial Analysis and Reporting Policy
This policy dictates the methods and standards for evaluating and presenting the company's financial health. It is pivotal in providing accurate and timely information to stakeholders, aiding in informed decision-making and strategic planning.
Financial Reporting Policy
Closely related to the above, the Financial Reporting Policy focuses specifically on the standards and procedures for compiling financial statements and reports. This policy ensures that financial disclosures are transparent, consistent, and compliant with regulatory requirements.
Internal Control Systems Policy
This document is designed to manage risks and safeguard the company's assets. It encompasses the processes and procedures that ensure the effectiveness and efficiency of operations, the reliability of financial reporting, and compliance with applicable laws and regulations.
Record Keeping Policy
Fundamental for maintaining accurate and comprehensive records of all business transactions. This policy underpins the company's financial integrity, supporting effective management and compliance with statutory requirements.
Expenses Policy
Outlines the protocols for incurring and reimbursing business expenses. It ensures that expense claims are legitimate, reasonable, and consistent with the company's financial objectives and ethical standards.
Treasury Management Policy
Addresses the strategies for managing a company's liquidity, investments, and financial risks. This policy is fundamental in safeguarding the company's capital and ensuring financial health through effective cash flow management and investment practices.
Investment Policy
Guides the company's investment decisions, aligning them with its risk tolerance, financial goals, and regulatory requirements. It ensures that investments are managed prudently to maximise returns and support the company's growth.
Anti-Money Laundering and Counter-Terrorist Financing Policy
A mandatory policy for all firms within the regulated sector under the MLR 2017. It must set out the firm's risk assessment, customer due diligence procedures, ongoing monitoring arrangements, suspicious activity reporting procedures, and staff training requirements. For more detail on this area, see our dedicated page on OPBAS and AML compliance.
Prevention of the Facilitation of Tax Evasion Policy
Required under the Criminal Finances Act 2017 for organisations to demonstrate they have reasonable prevention procedures in place against the facilitation of tax evasion by their employees or associated persons.
What FCA-Regulated Firms Must Document
Firms authorised by the FCA face the most prescriptive policy requirements. The FCA Handbook's SYSC sourcebook requires regulated firms to maintain documented policies and procedures covering, at a minimum:
- Governance and oversight — clear allocation of responsibilities under the Senior Managers and Certification Regime (SM&CR), including Statements of Responsibilities
- Financial crime prevention — AML/CTF policies, sanctions screening, fraud prevention, and anti-bribery and corruption policies
- Conflicts of interest — identification, management, and disclosure of conflicts (SYSC 10)
- Complaints handling — a documented complaints procedure compliant with the FCA's Dispute Resolution sourcebook (DISP)
- Operational resilience — business continuity planning, IT disaster recovery, and third-party risk management
- Conduct of business — fair treatment of customers, product governance, and financial promotions
- Record keeping — retention of records for the periods specified by the FCA, including transaction records, client communications, and compliance monitoring records
The FCA takes a risk-based approach to supervision, and the absence of adequate policies is frequently cited in enforcement actions and regulatory findings. Maintaining well-drafted, up-to-date documentation is a fundamental expectation of all authorised firms.
Why Financial Policies Matter for Audit Readiness
Whether your organisation is subject to a statutory audit under the Companies Act 2006, a regulatory review by the FCA, or an internal governance review, the quality of your financial policies directly affects your audit readiness.
Auditors and regulators look for evidence that:
- Policies exist and are documented, approved, and version-controlled
- Policies are proportionate to the organisation's size, complexity, and risk profile
- Staff are aware of and trained on relevant policies
- There is evidence of implementation — that policies are being followed in practice, not simply existing on paper
- Policies are subject to regular review, with a documented review schedule and evidence of updates in response to regulatory changes
Organisations that cannot demonstrate robust financial governance through their policies and procedures are significantly more likely to receive qualified audit opinions, regulatory findings, or enforcement action.
Sectors With Specific Financial Policy Requirements
While all UK organisations benefit from sound financial governance, certain sectors face heightened or specialised requirements:
- Financial services — FCA-regulated firms including banks, insurers, investment managers, payment institutions, and consumer credit firms must comply with the FCA Handbook and applicable EU-retained legislation
- Charities and non-profits — governed by the Charities Act 2011 and Charity Commission guidance, with specific requirements around reserves policies, investment policies, fundraising governance, and Trustees' Annual Reports
- Housing associations — regulated by the Regulator of Social Housing, with a specific emphasis on financial viability, governance, and value for money
- Education — schools, academies, and universities must comply with the Academies Financial Handbook (now the Academy Trust Handbook) or the Office for Students' conditions of registration
- Healthcare — NHS bodies and care providers must follow NHS Financial Standing Instructions and relevant Department of Health and Social Care guidance
- Legal and accountancy firms — subject to AML supervision by their professional body (e.g., SRA, ICAEW) and the requirements of the Office for Professional Body Anti-Money Laundering Supervision (OPBAS)
Financial Policies by Organisation Type
Your required policies may differ slightly from the above depending on your organisation type. For example, our charity clients focus more on Reserves, Investments, and Fundraising policies.
We recommend all organisation types should have an Anti-Money Laundering and CTF policy in place as well as a Prevention of the Facilitation of Tax Evasion Policy.
Organisations should also consider Sanctions Compliance documentation where applicable.
How Policy Pros Can Help
Keeping up with the latest policy and compliance requirements is crucial. Our team writes bespoke financial policies for UK businesses and organisations of all sizes, ensuring your documentation is accurate, current, and proportionate to your regulatory obligations.
Whether you are an FCA-regulated firm preparing for a supervisory visit, a charity needing to update your reserves and investment policies, or a growing business that needs its first set of financial governance documents, we deliver tailored solutions from brief to completion.
We also provide specialist support for OPBAS and AML compliance and anti-money laundering policy development. Here is how we can help your organisation:
- Tailored Consultations: Our specialists provide bespoke consultations to understand your unique business needs, identifying the specific policies you need to stay compliant.
- Custom Policy Creation: Based on our discussions, we develop tailored policies for your business.
- Compliance Assurance: We ensure your business aligns with the latest UK regulations, keeping your policies current.
- Implementation and Training: Beyond creating policies, we support their rollout, offering training for your team and strategies for seamless integration into your operations.
- Ongoing Support: The regulatory landscape is ever-changing. We provide continued assistance to review and update your policies as necessary, ensuring long-term compliance and efficiency.
For more information on our services, please complete the form below.