Written by Jasthi Alom’s case raises a sharp public-interest question: can a public regulator demand rigorous compliance from the firms it supervises while failing to maintain a visible, structured human-rights framework for its own workforce?
Publication snapshot
- The article examines allegations concerning Jasthi Alom’s treatment by the Financial Conduct Authority.
- It distinguishes the case from a conventional PIDA whistleblowing dispute and focuses on alleged victimisation, appraisal unfairness, discrimination and human-rights compliance.
- It treats Article 6, Article 8 and Equality Act points as legal arguments requiring determination, not as established findings.
- It argues for a formal human-rights policy, independent complaints mechanisms and stronger oversight of public regulators.
Overview
British public authorities, including regulators such as the Financial Conduct Authority, are required to act compatibly with human-rights obligations. The case of Jasthi Alom, as presented in the source material for this article, raises serious questions about whether the FCA’s internal treatment of staff reflects the standards of fairness, procedural integrity and accountability that the regulator expects from the firms it supervises.
This article does not treat Alom’s case as a conventional whistleblowing dispute under the Public Interest Disclosure Act 1998. The argument advanced is different: that his treatment should be examined through the lens of alleged victimisation for protected acts, internal discrimination, appraisal unfairness, disciplinary process failures and potential breaches of rights protected by the Human Rights Act 1998.
The central public-interest concern is whether the FCA has a coherent internal human-rights framework capable of identifying, investigating and remedying complaints by employees or others affected by its actions.
A broken system?
The source material argues that Jasthi Alom was penalised after challenging what he regarded as a toxic HR culture, unfair appraisal arrangements and discriminatory internal practices. Those claims require evidential testing, but they are significant because they concern the FCA’s own employment culture and its approach to internal accountability.
The draft material characterises Alom’s position as involving protected acts under the Equality Act 2010 rather than protected disclosures under PIDA. On that framing, the key legal issue is not simply whether he made public-interest disclosures, but whether he was subjected to detrimental treatment because he raised equality-related complaints or challenged discriminatory practices.
Alleged employment concerns
- Retaliatory treatment following complaints about internal unfairness.
- Disciplinary action said to have followed protected acts.
- Decision-making alleged to have been predetermined or affected by bias.
- Damage said to have been caused to reputation, career and financial security.
Alleged due-process concerns
- Failure to provide key material relied upon in the disciplinary process.
- Insufficient opportunity to answer the case against him.
- Concerns about natural justice and internal procedural fairness.
- Potential impact on psychological integrity, private life and family life.
The Article 8 argument is that the alleged treatment affected Alom’s reputation, career, financial security, psychological integrity and family life. The Article 6 argument is that the disciplinary process allegedly denied him a fair opportunity to meet the case against him, including by withholding the accuser’s witness statement. Those arguments should be presented as contested legal analysis unless and until determined by a court or tribunal.
The FCA and human-rights governance
The draft material states that the FCA does not have one specific human-rights policy and refers to a letter to MP Diane Abbott from Siobhán Sheridan, Chief People Officer of the FCA. The quoted position is that the FCA does not have one specific policy, but says it incorporates human-rights legislation and considerations into the organisation.
Quoted FCA position
“We do not have one specific human rights policy, but we incorporate human rights legislation and considerations into our organisation.”
That response, if accurately quoted and current, raises a serious governance question. For a regulator that expects documented systems, controls and compliance frameworks from regulated firms, reliance on dispersed or implicit human-rights consideration may appear inadequate when compared with the standards it applies externally.
The analogy is straightforward. A regulated firm would not ordinarily expect to satisfy the FCA by saying that it incorporates anti-money laundering considerations somewhere within the organisation, while declining to identify a clear policy framework, responsible function, escalation route and audit trail. The same logic applies to human-rights governance in a public authority.
Internal mechanism
Policy architecture matters because employees and affected parties need to know how human-rights complaints are identified, escalated, investigated and remedied.
Public accountability
Regulatory credibility depends on the FCA being able to demonstrate that its internal governance matches the compliance discipline it expects from others.
Limited immunity and accountability
The FCA benefits from significant statutory protections against civil liability. The draft material argues that human-rights claims and bad-faith conduct may provide rare openings for accountability where ordinary civil claims would face immunity barriers.
That point should be verified against the relevant statutory framework before publication. However, the underlying accountability concern is clear: where a public authority is shielded from many forms of litigation, the routes that remain available become especially important.
On the article’s analysis, Alom’s case is significant because it is said to sit within one of those remaining routes. If human-rights breaches can be properly pleaded and evidenced, the FCA may face a form of scrutiny that cannot be dismissed merely by relying on its ordinary regulatory immunity.
The need for independent oversight
The wider policy question is whether UK financial regulators are subject to sufficient independent scrutiny when internal complaints raise human-rights concerns. The draft material argues that existing mechanisms are inadequate and that an independent oversight body is needed to provide enforcement, consistency and public confidence.
The Office of the Whistleblower Bill is presented in the source material as one possible route for broader reform. Its precise status, text and proposed enforcement powers should be verified before publication, particularly any reference to penalties, scope, investigatory powers or application to public and private bodies.
Reform themes raised by the draft
- Creation of a genuinely independent reporting and enforcement body.
- Centralised routes that bypass ineffective internal complaint systems.
- Greater investigatory power before disputes escalate into litigation.
- Clearer human-rights standards across regulators and regulated entities.
The case for reform is not limited to whistleblowing. If employees of regulators allege discrimination, victimisation, procedural unfairness or human-rights breaches, there must be a process that is independent enough to command confidence and practical enough to provide remedy.
Recommendations
The draft calls for urgent reform of the FCA’s internal governance and the broader accountability structure surrounding financial regulators. Those recommendations can be framed as practical steps rather than rhetorical demands.
1. Publish a human-rights policy
The FCA should adopt and publish a clear human-rights policy explaining how human-rights risks are identified, assessed, escalated and remedied.
2. Create an independent complaints route
Human-rights complaints involving regulators should be capable of external review, particularly where internal HR or disciplinary processes are themselves part of the complaint.
3. Clarify legal remedies
Employees and affected parties should have clear, accessible routes to challenge conduct by regulators where human-rights obligations are engaged.
4. Build human-rights scrutiny into reform
Any whistleblower or regulator-accountability reform should expressly address human-rights compliance, procedural fairness and protection against victimisation.
Conclusion: the FCA’s human-rights test
The FCA’s alleged failure to maintain a dedicated human-rights policy is not a technical footnote. If the source material is accurate, it raises a serious question about whether the regulator’s internal governance is sufficiently robust for a public authority with significant power over firms, markets and individuals.
Jasthi Alom’s case is therefore not only about one employment dispute. It is about the standard to which a public regulator should be held when its own conduct is challenged. If the FCA demands structured compliance, documented controls and accountability from others, it must be prepared to demonstrate the same discipline internally.
The message is simple: human-rights compliance should not be aspirational. For a public authority, it is a legal obligation and a governance test.
Disclaimer
This article is general public-interest commentary and does not constitute legal advice. It is based on the materials available at the time of writing and should be checked against source documents, correspondence, tribunal records, court records, statutory provisions and regulator publications before publication. Allegations and legal arguments referred to in the article should not be treated as findings of fact unless determined by a court, tribunal, regulator or other competent authority. Human-rights, employment, regulatory-immunity and defamation issues are fact-sensitive, and affected parties should seek advice from a suitably qualified solicitor.