Treating Customers Fairly Policy

 

Introduction

'Treating Customers Fairly’ (TCF) is a key principle that the Financial Conduct Authority (FCA) expects all regulated firms to pay attention to and achieve certain standards. Achieving fair and positive customer outcomes is central to our company culture and approach. We hope that by publishing this policy our customers and partners can clearly see what is important to us as a company. 

This policy aims to document our approach to TCF regardless of whether the customer has purchased from us or not. 

As a company, we aim to ensure that we: 

  • Set the best possible culture that is built around TCF 

  • Provide a framework that all staff can apply when making decisions that affect customers 

  • Meet the TCF guidelines and standards set by the FCA, our industry trade body, the British Vehicle Rental and Leasing Association (BVRLA), and our partners 

What is TCF

Six consumer outcomes to ensure customers are treated fairly 

The FCA requires regulated and authorised firms like ourselves to achieve the below six consumer outcomes to ensure the fair treatment of customers: 

  • 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 company culture 

It is extremely important to us that we have a company culture that promotes staff helping customers make the right decisions for them and achieving good customer outcomes at all times. 

We seek to create and maintain a TCF focussed culture and therefore we: 

  • Lead by example and promote an ethical approach to decision making 

  • Seek to avoid, as far as possible, any conflicts of interest between the interest of our company and the interests of our customers

  • Recruit staff that we believe will have the customer at the heart of what they do 

  • Empower & train our staff to understand how their role affects the fair treatment of customers and how they too can empower customers to make the right decisions 

  • Support staff with the right tools to provide customer service that responds to the needs of our customers and embed a continuous improvement approach where we seek feedback and opportunities to improve our services

  • Ensure that our company ethos is understood so that all staff are on the same page 

  • Promote that staff should feel confident to flag and raise issues to senior management 

  • Build a strong and customer focussed management team 

  • Design our products, services and communications with our customers in mind

  • Consider the customer when we set internal targets 

  • Achieve a positive balance between resource in sales and customer service roles 

  • Ensure staff have access to this policy and other relevant policies (e.g. vulnerable customers, ethics, conflicts of interest, whistleblowing) via our internal CRM 

Ensuring good outcomes for all customers

We are committed to ensuring the fair treatment of all customers and recognise that some customers may be in vulnerable circumstances which affect how they engage with us and how our services impact them. 

To ensure that we achieve good outcomes for all vulnerable customers, we: 

  • Understand the needs of our customers and the impact vulnerabilities can have on their customer experience

  • Have an Affordability Policy on our website and encourage customers to consider the affordability of the scheme

  • Ensure that we discuss affordability with our customers (and flag to their scheme coordinator) if a customer wishes to order a car whose list price is more than their annual salary

  • Make sure our staff have the right skills and capability to recognise and respond to our customers and their particular needs

  • Train staff on vulnerable customers and ensure they understand how to provide good outcomes for different customers

  • Respond to our customer needs via our service delivery, ensuring that the customer experience and communications work for all customers

  • Monitor and assess whether we are meeting the needs of our customers and continue to make improvements to ensure that we are providing good outcomes for all customers 

How we ensure our customers are treated fairly

Customer experience 

We have a dedicated customer operations who focus on customer feedback and complaints. From a customer feedback perspective, we aim to collect as much feedback as possible from our customers. 

To achieve this, we: 

  • Invite customers to provide feedback at any stage of the process

  • Provide formal feedback opportunities at different stages of the process (i.e. over email)

  • Seek to respond to customers within 4 hours of a customer service query, so as to ensure that questions, issues and feedback are processed in a timely manner

  • Analyse feedback received and join it with complaints data so that we can continually improve our processes  

Staff understanding and incentives 

We work hard to make sure our staff are making the right choices for our customers. To do this, we link staff incentives to great customer outcomes and we: 

  • Ensure staff have access to this policy via our internal CRM 

  • Encourage staff to ask questions in relation to our policy and discuss any uncertainties with their line manager or senior management 

  • Require all staff to receive annual training in relation to compliance with FCA and industry best practice for the treatment of customers

  • Ensure sales staff are rewarded for successful orders (rather than at the point of order, which may subsequently be cancelled)

  • Ensure sales staff must hit certain standards linked to TCF in order to pass probation and achieve an incentive 

  • Require staff to conduct regular quality checks on their interactions with customers to ensure that we are meeting our internal standards and continually learning 

Internal systems 

We have developed bespoke systems (that continually get updated) in order to streamline the journey for our customers and make our communications as clear and straightforward as possible. 

Leadership & management 

We are conscious that leadership is critical to ensuring that we deliver this policy well. 

To achieve this, we:

  • Have an experienced and customer-focused senior management team that believe in our company ethos and treating all customers fairly

  • Have a dedicated customer experience manager who is focused on turning bad outcomes into positive ones 

  • Invest in our organisational structure and process to ensure that we have the resources to observe, provide feedback and coach within the day-to-day role

  • Record telephone calls for the training and monitoring purposes so that we can maintain our high TCF standards 

  • Appointed our CEO as Consumer Champion to champion consumer interests across the business

Quality control & governance 

We have developed internal systems to support quality control. It is our belief that this function has a direct impact on customer outcomes. We have strong governance structures that aim to ensure senior managers regularly meet and discuss all of the standards required, including those linked to TCF and vulnerable customers.

Customer complaints 

Our customer experience manager is focussed on turning bad outcomes into positive ones. We believe in making it easy for customers to make a complaint as this is an opportunity to learn and put things right. 

To achieve this, we: 

  • Ensure that our complaints process is clearly sign-posted on the footer of each page on our website 

  • Make it easy for complaints to be submitted such as by email, phone or in writing 

  • Encourage all staff to log every complaint received so that we can deal with the issue professionally and to analyse the themes 

  • Invest in our complaints training, systems and processes 

  • Encourage staff to flag issues raised in customer complaints or queries so that we can quickly respond and improve our services

External audit 

We are regularly audited by independent third parties, and this helps us keep our policies up to date and in line with industry standards. As a member of the BVRLA, we regularly undergo a formal external audit of our business, which includes a review of our policies around TCF. We also directly partner with the leading finance companies in the UK and we have to evidence TCF as part of these relationships.