Treating Customers Fairly Policy
Intoduction
In order to help our customers to spread the cost of their purchases, we perform credit brokerage services by introducing our customers to Deko and their panel lenders. In performing this activity, we are undertaking a regulated activity, for which the Financial Conduct Authority (“FCA”) is the supervisory body.
We have been appointed by Deko (Pay4Later Ltd) as an Introducer Appointed Representative (“IAR”) to use their credit broking permissions to introduce our customers to them. As an IAR of a regulated business, we must meet high standards of conduct and comply with the FCA’s rules, and the requirements that Deko stipulates for us.
The fair treatment of our customers is central to our business model and this policy sets out our commitment and high-level approach to meeting our customers’ needs and expectations, and our regulatory obligations
What is TCF
The FCA regulates our industry by a combination of principles based, and rules-based regulation, with the aim of achieving fair outcomes for customers. The FCA’s 11 Principles for Business underpin their approach to regulation, with Principle 6 specifically requiring authorised firms to Treat their customers fairly; “A firm must pay due regard to the interests of its customers and treat them fairly”.
As guidance to help firms interpret and implement Principle 6, the FCA expects the following 6 core outcomes (commonly referred to as “the 6 TCF Outcomes”):
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.
Our commitment – consumer duty
The FCA has now developed its regulation to strengthen the drive for firms to achieve good outcomes for customers, with its new Consumer Duty.
The Consumer Duty comprises of:
> The Consumer Principle (Principle 12): Firms must act to deliver good outcomes for customers
> 3 cross-cutting rules:
o Act in good faith towards customers
o Avoid causing foreseeable harm
o Enable and support customers to pursue their financial objectives
> 4 customer outcomes spanning:
o Products and services
o Price and value
o Customer understanding
o Customer support
We are therefore committed to the fair treatment of our customers, whether we are introducing them to finance options, or they are simply buying our goods or services. We consider the needs of our customers across all our business, from developing and buying new products, through marketing and sales practices, to the third parties we partner with and post-sale support.
Implementing TCF
As above, we consider the needs of our customers and the outcomes we want to achieve for our customers in all parts of our business. The following summarises our approach in key areas of our business.
> Marketing
In marketing our products and services, we will ensure we are clear and transparent about everything our customers need to know. We will never deliberately attempt to mislead our customers or omit key information about our products and services.
If promoting finance or credit broking services, we will always use marketing materials approved by our lender or Deko.
> Sales
We do not and will not adopt high-pressure sales techniques or seek to mislead our customers when selling our products and services to them.
Whether selling in-store, over the phone, by email or in the customer’s home, we will always provide customers with clear information and direct them to further information where necessary, such as our cancellation and returns policies.
Where we introduce our customers to finance, we will allow customers the time they need to read and understand the documents presented to them throughout the application process and will never apply pressure or rush customers through the process.
Where customers have questions about their finance application, or the finance products available, we will provide the relevant contact information to enable the customer to speak with either the lender or Deko to ensure they receive accurate information.
> Post-sale customer support
We want to ensure our customers enjoy our products and services, and that they meet the standards that customers were led to expect.
If customers need support after their purchase, we have a number of key policies, which we make available to customers. These include:
- Cancellation policy
- Faulty goods policy
- Returns/refund policy
- Complaints policy
Where customers raise issues with us about their products or service, we will do all we reasonably can to help them resolve the issue.
In cases where the customer has taken out finance to spread the cost of their purchase, we will be open and transparent with the lender about issues which may affect their relationship with the customer, to help them ensure they continue to treat the customer fairly too.
> Training
Our staff will undergo training both at commencement of employment and on an ongoing basis to give them the knowledge and understanding necessary to deliver a high standard of service to our customers and to meet the requirements of this policy.
> Complaints handling
Whilst we aim for all of our customers to be satisfied with our service, there will unfortunately be instances where a customer feels cause to complain.
We will make it easy for customers to complain, either verbally or in writing, and we will take all complaints seriously.
All complaints will be investigated and responded to promptly. Equally, if a complaint is raised with Deko or a lender and they require information from us to support their investigations, we will promptly provide the necessary information relevant to the complaint.
> Remuneration
We acknowledge that cash and non-cash incentives have the potential to give rise to irresponsible and unfair sales practices, which could cause harm to our customers and pose risks for Deko and lenders.
In developing and reviewing our remuneration frameworks, we will ensure that no member of staff is directly or indirectly incentivised to increase sales of finance.
> Customer feedback
As with complaint handling, we take customer feedback seriously and will consider all feedback provided by our customers, both positive and constructive.
We rely on customer feedback and reviews to help build our reputation and so it is in our best interests to ensure our customers have reasons to leave us excellent reviews and to tell their family, friends and colleagues about their positive experience with us.
Responsibility
All staff are responsible for treating their customers fairly and will be expected to attend/complete all training required by the company.
The Directors of the Company are responsible to ensure that this policy is implemented and adhered to by all staff and will keep this policy under review from time to time.