Introduction
The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) Principle 6 requires a firm to pay due regard to the interests of it clients and treat them fairly. We are fully committed to TCF and this Policy has been designed to demonstrate the application of TCF during our day to day activities
TCF is embedded throughout the FCA’s handbook and the FCA’s six core consumer outcomes are embedded in our Company. These are:
- Consumers can be confident they are dealing with firms where TCF is central to the corporate culture.
- Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and targeted accordingly
- Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale
- Where consumers receive advice, the advice is suitable and takes into account their circumstances
- Consumers are provided with products that perform as firms have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect
- Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
Our TCF Mission Statement:
We will act with integrity in everything we do and put our customers at the heart of our business.
Our TCF Principles:
- Customers will be provided with clear information and be kept appropriately informed before, during and after the point of sale
- If we give advice to our customers, the advice will be suitable and take account of their circumstances
- Our level of service and product performance will meet the expectations of our customers as far as is reasonably possible
- We will ensure that there is no barrier for customers to express their requests, concerns or complaints and will always be responsive to them
- Products and services will be designed to meet the needs of our customers.
Accessing and implementing our TCF principles
Marketing:
All our financial promotions and marketing materials are reviewed to ensure that they are appropriate for our target audience and are presented in a clear, fair and not misleading in manner
Sales, Advice, Management:
When providing advice, our advisors obtain a detailed understanding of the customer’s needs so that our recommendations are suitable. We ensure that our customers understand the risks involved with any service or product offered and are aware of all fees and charges.
Post Sale information and Support:
We strive to keep our customers informed pre, during and post contract. Appropriate records are held and can be provided as required on an ongoing basis. We have appropriate capacity for storing and processing information to ensure continuous support. We have no post- sale barriers in place which restrict customers access
Policies and Procedures:
We have policies and procedures that are relevant to the fair treatment of our customers and which also meet FCA requirements. These are (this is not an exhaustive list):
• Conflicts of Interest Policy
- Data Protection Policy
- Vulnerable Customers Policy
- Training and Competence Policy
- Financial Crime including Bribery & Corruption & Money Laundering
- Complaint Handling Procedures
- Financial Promotions Procedures
Management Information (MI)
We produce MI to assess our performance against the TCF principles. We ensure that MI is accurate, timely, consistent and relevant to assist the business to make informed decisions in the best interests of our customers. We produce MI reports which are reviewed regularly by senior managers, directors and board members in various meetings.
Awareness/Training
We ensure that all team members and advisors are familiar with the TCF principle and its outcomes. In addition, where applicable, advisors and team members are trained to advise on, and adequately explain our products and services. We make sure that all advisors and team members achieve the necessary qualifications and training to carry out their role to the required competence level. We undertake regular monitoring and assessment of our advisors and staff so that we can ensure their competence
Compliance
We maintain a Compliance Monitoring Programme which clearly lists areas of responsibilities and the frequency of checks required. We have a compliance officer which regularly monitors all key areas of regulatory compliance including TCF
Remuneration
We operate a remuneration model that does not reward on sales performance only to mitigate sales bias. We reward non sales staff in a way which does not negatively impact on the treatment of our customers.
All staff contribute towards the Company’s overall target. The sale of finance is not incentivised.
Complaints
Our goal is to provide excellent customer service and complaint handling plays a major part in our TCF policy. We deal with customer complaints fairly and objectively and attempt to put things right as quickly as possible, in accordance with the requirements of the FCA Dispute and Resolution Handbook. All complaints are recorded and monitored, and a root cause analysis performed. All are reported as MI and analysed in senior management meetings.
Conclusion
We encourage a culture of personal responsibility and impress upon all involved with our firm that a good culture is central to the economic health of our Company. We strive to build a strong conduct culture which builds both customer trust and inspires employees. Getting the culture and conduct right is in the interests of our economic strength
We frequently review our policies, procedures and practices to ensure that TCF remains central to our Company.
We ask our clients to provide us feedback which enables us to improve our service. The information gathered from our customers is reported in our MI and reviewed by senior managers and directors to help shape any strategic decisions
