Most firms learn about a bullying manager far too late. The people who worked for that manager knew, and so did those who worked alongside them, but the knowledge went no further. Since 1 September the FCA has treated bullying and harassment between colleagues as a conduct issue, and from 30 October employers in the UK must take all reasonable steps to prevent sexual harassment. For both, the key test is what the firm knew and what it could reasonably have found out. That makes the way information about managers’ behaviour reaches the top of the firm a governance question as well as an HR one.
A quiet complaints log proves little
Boards tend to read a low number of complaints as good news. The FCA takes a different view. Reporting on its survey of more than 1,000 investment banks, brokers and wholesale insurers, it said that a high number of reported incidents may reflect a healthy speak-up culture, while a low number may suggest the opposite. It also found that 38% of those firms’ boards received no management information on non-financial misconduct at all (FCA).
Complaints depend on someone choosing to speak, and the evidence suggests many people don’t. In the CIPD’s 2026 Good Work Index, half of the employees who had experienced conflict at work simply let it go (CIPD), and Mental Health First Aid England found this year that 45% of UK workers feel unable to speak up when they spot mistakes or risks (MHFA England). A 360-degree feedback survey asks colleagues, direct reports and managers to describe one person’s behaviour, without anyone having to raise a grievance. More than that, it gives the firm a channel to understand and address behaviour before it becomes a problem.
Financial services is no exception. In the Banking Standards Board’s 2018 survey of 72,000 bank staff, 37% of those who had a concern did not raise it, most often because they expected it to be held against them (BSB).
Silence costs most around high performers. Quade, Greenbaum and Petrenko found that colleagues shunned unethical employees less when those employees performed well (Personnel Psychology, 2017). Housman and Minor’s Harvard Business School study of nearly 60,000 workers put a figure on the trade-off: avoiding one toxic worker saved about $12,500, while a top-1% performer added about $5,300 (HBS). Those figures are a decade old, and the problem has grown since. Acas’s 2025 survey recorded the highest level of workplace conflict it has ever measured, with line managers involved in almost a third of cases (Acas, 2025). Its earlier estimate put the annual cost of conflict to UK employers at £28.5bn, about £1,000 per employee (Acas, 2021). The performer’s contribution shows in the revenue line, but the cost of their behaviour is spread across other people’s attrition, absence and claims, which is why firms underestimate it.
What the regulators already point towards
Two existing sources of guidance point towards structured feedback from colleagues. The Equality and Human Rights Commission’s technical guidance on sexual harassment says an employer is unlikely to meet its duty without a risk assessment, and lists power imbalances among the risk factors. It notes that complaint numbers do not accurately reflect the level of harassment, and recommends anonymous staff surveys, read alongside complaint data, to test whether preventive steps are working (EHRC technical guidance; EHRC eight-step guide). A 360 is the version of that survey that asks specifically about people who hold power over others.
The FCA, for its part, criticises fitness and propriety assessments that act as a “rubber stamp”, and competence checks that lack objectivity (FCA). A line manager’s view is a single source. A 360 adds the views of peers and direct reports, moving the assessment from one person’s opinion to a broader base of evidence. When the Banking Standards Board consulted on fitness and propriety in 2016, it listed 360-degree feedback among the internal evidence a firm could draw on (BSB consultation).
Why the fashion turned, and why it is turning back
The 360 has a long history. Multi-rater feedback has been in use since the middle of the last century and became mainstream in the 1990s; Bracken, Rose and Church have traced both its rise and its partial decline (Industrial and Organizational Psychology, 2016). Between 2012 and 2015 Adobe, Microsoft and Deloitte all abandoned annual ratings, and Deloitte estimated that its own process consumed about 2 million hours a year. The 360 went out with the annual rating, even though it is a different instrument.
Yet Deloitte’s own evidence supports the 360. It cited a study of 4,492 managers which found that 62% of the variance in a rating reflects the person giving it (Scullen, Mount and Goff, 2000; HBR, 2015). That is a weakness of any single-rater judgement. Averaging the views of eight or ten colleagues reduces the influence of any one of them, which is the statistical reason multi-rater feedback is more robust.
Ratings are now returning. Cornell’s Center for Advanced Human Resource Studies found that firms that dropped them are reintroducing them in some form (CAHRS, 2025), and last year Amazon began scoring staff against its Leadership Principles alongside their results (Fortune). The emphasis has moved towards how people work. A line manager sees only part of that picture; together, the colleagues who work alongside someone see far more of it.
What makes a 360 worth running
The critics had a fair point. Kluger and DeNisi’s landmark review of feedback interventions found that more than a third of them reduced performance (Psychological Bulletin, 1996). Smither, London and Reilly’s meta-analysis of 24 studies found that performance improves after multi-rater feedback, but only slightly on average (Personnel Psychology, 2005).
However, the research also shows where the improvement comes from. Walker and Smither tracked 252 managers over five years and found that those who discussed their results with their teams improved more. Not only that, they improved more in the years they held those discussions than in the years they did not (Personnel Psychology, 1999). The report starts the process, but it is the conversations that change behaviour. Held early and regularly, those conversations can stop a behaviour turning into an issue.
The case for the board
Senior managers are personally accountable for conduct they will rarely see. Policies and training records show intent, but they say little about how managers actually behave. From 1 January 2027 employees gain unfair dismissal protection after six months’ service, and the cap on compensation is removed, so problems found late will cost even more. Boards are also asking about culture: only 47% of chief HR officers told Gartner that their culture currently drives performance (Gartner).
A well-run 360 programme gives the board regular, anonymous evidence about how its leaders treat people, gathered before anyone has to complain. In our experience, few controls produce as much relevant evidence for the money.
The 360 has fallen out of fashion before, but that was when firms ran it as a form and expected the form to change behaviour. Run as a structured programme, with a conversation after the report and a second survey to follow up, it takes what the team already knows to the people who can act on it.