Treating Customers Fairly Policy
Allenbridge Group Ltd as a part of Close Brothers Group are fully committed to the FSA's principles of Treating Customers Fairly; we will seek to achieve the TCF outcomes (listed below) in the following principal ways:
We will only offer well designed products and services which are easy to understand and have been created with customers? needs in mind;
All Terms and Conditions and marketing materials will be balanced, clear, realistic, fair and not misleading. We will be clear on how the product or service operates and any costs that the customer may incur;
We will not make customers feel any undue pressure by any sales or advice process under any circumstances;
We will aim to communicate on an ongoing basis in a way that clients understand, including regular reporting and ad hoc information where necessary;
We will aim to deliver to clients the service that has been promised to them, i.e. we will do what we have said we would do with our products/services, and monitor the performance and communicate with clients as necessary;
We will ensure that complaints are handled promptly and fairly and that wider implications are addressed;
We will ensure there are no unjustified barriers to investors wishing to transfer or leave the product or service;
Sales processes should ensure that CAM only offers appropriate products or services based on the identified needs of the customer;
Where relevant, any mandatory right of cancellation should be made clear at the point of sale;
Where advice is given, it should always be suitable, based on the identified needs of the customer; and
All verbal information provided to customers before, during, or after the point of sale should be clear fair and not misleading.
- What is TCF?
- What the FSA is trying to achieve (the six outcomes)
- What the FSA expects
- Who is the customer?
- The TCF assessment
- A Culture of Treating Customers Fairly
What is TCF?
The Financial Services Authority (FSA) is an independent non-governmental body that regulates the financial services industry in the UK. The FSA is accountable to Treasury Ministers, and through them, to Parliament.
One of the FSA's 11 Principles for business requires that:
"A firm must pay due regard to the interests of its customers and treat them fairly."
In 2001 the FSA launched their Treating Customers Fairly initiative to help restore customer confidence in the financial services industry and to create a fairer and more effective financial services industry.
This continued in 2006, with the publication of a set of six "outcomes" to help firms understand what TCF means in practice - "Treating Customers Fairly - Building on Progress".
The FSA wants firms to decide how they will treat their customers fairly and expect TCF to be built into firms' strategy, culture and operations.
What the FSA is trying to achieve (the six outcomes):
The objective is to create a fairer and more effective financial services industry. If the outcomes are being achieved then, from the perspective of the FSA, customers are being treated fairly.
Outcome 1
Consumers can be confident that 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 both 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
What the FSA expects:
Most firms in the financial services industry already aim to treat their customers fairly. However, the FSA wants to take this further and challenge firms and their ways of doing business against TCF principles. The FSA expects all distributor and provider firms to “embed" TCF effectively into their values, and the way they conduct business.
This includes:
- Understanding how TCF applies to the firm's business and its target customers
- Embedding TCF into the firm's strategy and culture
- Ensuring that TCF has been delivered at every level of the firm
- Reviewing the firm's performance against its TCF obligations, and addressing any shortfalls.
- In specific terms, firms are expected to take account of the following aspects:
- The design and governance of the product
- Identifying the right target market for the product
- The marketing and promotion of the product
- The sales and advice processes
- The provision of post-sale information to the customer and the complaints process
Who is the customer?
TCF defines the customer as the end consumer - the person who buys or uses a product from a distributor or provider. As such, every distributor and provider company is responsible for making sure that their customer is being treated fairly throughout the lifetime of the product.
The TCF assessment
The FSA is expected to carry out assessments of distributor or provider firms to establish whether they are complying with the principles of TCF.
A Culture of Treating Customers Fairly
Allenbridge Group is fully committed to the principles of TCF and making sure that they are an intrinsic part of the way we perform business.
Our products and services are approved and reviewed internally for their initial and continued fitness for purpose;
Employees are encouraged to discuss the effect of their actions on the 6 FSA TCF Outcomes and to suggest improvements in the fair treatment of our clients;
Compliance reviews all key communications prior to issue;
We seek client feedback periodically to assist in determining the success of the TCF outcomes;
Compliance track a number of indicators to ensure TCF principles are being followed;
We monitor complaints to ensure that responses are consistent with the TCF principle and within the framework of FSA Rules;
And we seek to ensure that job descriptions and objectives are aligned with TCF outcomes and Employees are appraised against these accordingly.
In this way, we are seeking to ensure that TCF is embedded into all aspects of our business and that the whole product and advice process is fair and clear at all times to our customers throughout the lifetime of their investments.
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