Treating Customers Fairly

Treating customers fairly is at the heart of our principles.

Treating Customers Fairly (TCF) is one of the cornerstone principles laid down by the Financial Conduct Authority (FCA). This guiding principle is sub-divided into six key elements which dictate the way in which we deal with our customers in terms of communication, expectations, level of service and the products and services we offer.

The six guiding principle elements are:

1. Consumers are confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
2. Products and services marketed and sold in the retail marketplace are designed to meet the needs of identified consumer groups and are targeted accordingly.
3. Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
4. Where consumers receive advice, the advice is suitable and takes account of their needs and circumstances.
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.
6. Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit claims or make a complaint.

In practical terms we adhere to the above principles by:

• Listening to our customers to understand their needs.
• Offering only market products which are appropriately targeted, clear, and unambiguous and highlight the risks and conditions as well as the key features and benefits.
• Ensuring customers understand any risks associated with products and services.
• Ensuring services are delivered to customers openly, with clarity and transparency, and do not contain hidden conditions or complex definitions.
• Ensuring, in the event of providing advice, that the advice given takes into account the customer's needs and circumstances.
• Taking the customer's privacy seriously and ensuring that members of staff are trained to follow the rules in relation to data protection and to keep customers' details secure and confidential.
• Taking complaints seriously and dealing with them promptly, learning from them and modifying operations and processes where necessary.

All of our people are trained and contractually bound to:

• Act with integrity.
• Act with due care, skill and diligence.
• Be open and cooperative with our regulator, the FCA.
• Pay due regard to the interests of our customers and always treat them fairly.
• Always observe proper standards of market conduct.

Our senior managers are personally responsible to:

• Take reasonable steps to ensure that the firm is controlled effectively.
• Take reasonable steps to ensure that the firm complies with the relevant requirements and standards of the regulatory system.
• Take reasonable steps to ensure that any delegation of responsibilities is to an appropriate person with effective oversight.
• Disclose appropriately to our regulator, the FCA, any information that they might expect notice.