The NAPF welcomed the opportunity to respond to this discussion paper. Continued efforts to enhance transparency and increase trust in UK business is welcome and should help create a positive environment for investment.

We have strong reservations about the proposal which emanates from the Parliamentary Commission on Banking Standards (PCBS) report to amend directors’ duties in the Companies Act for directors of banks. The proposal to create a primary duty to promote financial stability over and above other interests, including shareholders, is mis-directed, sets a worrying precedent and could impact upon the investibility of UK banks.

We do however, believe there is merit in considering including this matter more explicitly as one which a director, in all sectors, should have regard to.

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