The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) Principle 6
requires a firm to pay due regard to the interests of its 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 firm. 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 account of their
• 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

Our TCF Principles
• Customers will be provided with clear information and 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
• Our level of service and product performance will meet the expectations of our
customers as far as 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.

Assessing and implementing our TCF Principles

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

Sales, Advice, Management
When providing advice, our advisers 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 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.

We ensure that all advisers and staff are familiar with the TCF Principle and its outcomes.
In addition, where applicable, advisers and staff are trained to advise on and adequately
explain our products and services. We make sure that all advisers and staff achieve the
necessary qualifications and training to carry out their role to the required competence
level. We undertake regular monitoring and assessment of our advisers and staff so that
we can ensure their competence.

We maintain a Compliance Monitoring Programme which clearly lists areas of
responsibilities and the frequency of checks required.
We have a compliance team who is independent and regularly monitors all key areas of
regulatory compliance including TCF.
Every year we carry out a TCF Self-Assessment to measure our performance and which
highlights areas of improvement

We operate a remuneration model that does not reward on sales performance only, to
mitigate sales bias. We reward non-sales staff in a which does not negatively impact on
the treatment of our customers. All staff contribute to the firm’s overall target. The sale of
finance is not incentivised.

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 & Resolution Handbook. All complaints are recorded and monitored, and a root
cause analysis performed. All are reported as MI and analysed in senior management

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 firm. 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 and our
We frequently review our policies, procedures and practices to ensure that TCF remains
central to our firm.
We ask our clients to provide us feedback, sometimes formally through customer surveys,
so which enables us to improve our service. The information we gather from our
customers is reported in our MI and reviewed by senior managers, directors and board
members to help shape any strategic decisions.