Our Policy Towards Treating Customers Fairly (TCF)
It is our policy to treat customers fairly in every area of our business and in every way we can. We fully support the FCA’s Principles for Businesses number 6: “Customers’ interests – a firm must pay due regard to the interests of its customers and treat them fairly”. We believe that treating customers fairly and paying due regard to their interests has the following benefits:
Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture.
Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
In summary, we believe that conforming to the principle of treating customers fairly benefits not only our customers but also our staff and our firm itself.
We will therefore ensure that the needs and requirements of our clients will be taken into account in everything we do, not just in our customer facing areas. Some examples are:
Management information (MI) and management meetings – we will consider on a regular basis reports on:
This data will be used to guide future business decisions to improve TCF performance.
Advertising and promotions – we have a robust procedure in force to ensure that financial promotions and all other advertisements are FCA and Advertising Standards Authority (ASA) compliant. We also monitor the application of such procedures. We ensure that all advertising material is clear, fair and not misleading and provides a balanced picture of the product or our service. We will endeavour to identify and understand our target audience to ensure we treat them fairly.
Remuneration strategy – we have a remuneration policy in place to ensure that the risk of any inducements which are potentially unfair to our clients are removed or the risks recognised and minimised.
Disclosure information – we treat customers fairly by ensuring that all disclosures are made in sufficient time for clients to make informed decisions about a purchase.
Sales – we will ensure that all staff advising customers are competent to do so in a fair way and that their competence is checked regularly.
This policy and the procedures arising from it are reviewed at least annually. Ian Walker is responsible for this policy.