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Treating Customers Fairly

Introduction

The Financial Conduct Authority’s (“FCA”) Treating Customers Fairly (“TCF”) initiative is primarily based on the obligation set out in Principle 6 requiring a firm to pay due regard to the interests of its clients and treat them fairly. Central (UK) Vehicle Leasing Limited is fully committed to TCF and this Policy has been designed to demonstrate the application of TCF during the course of its day to day activities.

The FCA has outlined six core consumer outcomes that it wishes to see as a result of the TCF initiative, these are:

Outcome 1: Customers 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 any identified consumer groups and are targeted accordingly.

Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after 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 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.

How do we ensure customers are treated fairly?

What is TCF?

  1. CUSTOMER SATISFACTION: Creating a high level of customer satisfaction is a key business objective. However, we could have a satisfied customer who has not been treated fairly just like we can have an unsatisfied customer who has been treated fairly. Customer satisfaction is important, but it does not, in itself, measure TCF.

  2. CUSTOMER OUTCOMES: In order to achieve TCF we need to think in terms of outcomes, both for the business but more importantly the outcome for the consumer. Consumers are entitled to expect good outcomes; those that are fair. TCF is a mind-set – a way of thinking about what you do, how you do it and what you actually deliver. It is about looking at things through the lens of the consumer and intelligently considering the impact of policies, processes and business decisions on our customers.

  3. SAME SERVICE LEVEL: In order to achieve TCF we may have to treat some customers differently (e.g. vulnerable customers) in order to accommodate and cater for their individual needs and requirements. It is natural for a business to want to achieve a consistent level of service for all of its customers but TCF may require that we act differently depending on the circumstances and the customer.

  4. CUSTOMER RESPONSIBILITY: TCF is not about customers no longer being expected to make decisions or take responsibility for the products and services that they decide to buy. Customers are still expected to shop around, compare prices, read written documentation provided and take responsibility for their purchasing decisions. However, they should be able to count on a firm being transparent with its prices, providing written documentation that is clear, fair and not misleading. The sales process should be simple and transparent with an emphasis on good, easy to understand jargon - free communication.

  5. A FAIR TREATMENT CULTURE: TCF is about culture - doing business in a way that will help ensure customers get fair treatment. A positive customer orientated culture is an essential TCF ingredient.

  6. COMPLAINTS: Whilst Central (UK) Vehicle Leasing Limited does not want to receive a high volume of complaints, it is inevitable in any business that complaints will arise. It is not the existence of the complaint that matters or necessarily the numbers. It’s the way a business responds to a complaint that indicates whether it is delivering TCF and its commitment to root cause analysis to ensure that any problems are eradicated at source. High complaints levels per se do not necessarily mean that you are not delivering TCF. If complaints are being hidden and suppressed this would be an indication of poor TCF although the numbers, you would initially see would be low.

  7. FIRM/BRAND REPUTATION: All businesses want to protect their brand and their business name from reputational damage. However, a company with a poor reputation from the past could be currently delivering a high level of TCF just like a company with a good reputation may in fact be delivering poor TCF. Reputation is important to the business but is not necessarily a reliable indicator of good TCF.

How do we treat our customers at Central (UK) Vehicle Leasing Limited?

Customer Service

Putting our customers above all else

We value our customers above all else and seek to provide outstanding customer service through happy, conscientious and well-motivated teams. Our business is founded on customer service. For over a decade we have consistently put our customers first and this single-minded emphasis will continue. We recognise, of course, that outstanding customer service can never be taken for granted, so we continually measure and constantly seek to improve. In living this value, through our behaviour, we will:

  • Be polite and respectful at all times
  • Meet our customers’ expectations
  • Respond promptly to our customers’ complaints and enquiries
    • Refer all regulated complaints to Compliance immediately upon receipt
    • Ensure that our customers have a great experience every time
  • Make informed decisions with our customers in mind
    • Take pride in delivering on time, within budget and fit for purpose
    • Seek feedback from our customers
    • Know who our external and internal customers are Listen to our customers and anticipate their needs
    • Act in the spirit of partnership

Integrity and Fairness

Upholding the highest standard of integrity and fairness

We strive to exhibit the highest standards of integrity and fairness in everything we do. There must be no gap between what we say and what we do. We put integrity and fairness among the fundamental principles of our business and abide by these core values. They are ingrained in the way we do things at Central (UK) Vehicle Leasing Limited.

As our business has expanded we have never lost sight of the essential need to reinforce our reputation for integrity and fair play. In living this value, through our behaviour, we will:

  • Take responsibility for our actions
  • Adopt an unbiased approach to all colleagues
    • Put safety and regulatory requirements at the forefront of what we do
    • Do the right thing and deliver what we promise
    • Be open and honest and act with integrity in all that we do
    • Be considerate of individual differences and cultures

Assessing and implementing TCF

The FCA does not specify any particular way in which TCF should be assessed and implemented, but it has highlighted key areas within the product lifecycle where it is appropriate to have extra checks in place. These include:

  • Product design
  • Financial promotion/marketing practices
  • The sales process
  • Information and customer support after the point of sale
  • Complaint handling

In practice this means identifying potential gaps in TCF practice and developing procedures and checks to plug these in the following areas:

  • Staff training / awareness of TFC
  • Sales and marketing material
  • Product understanding
  • Advice and sales process
  • Fact find and flow of information to the client (including after-sales)
  • Complaints handling
  • Remuneration / incentives
  • Record keeping and management information

Awareness / Training

Central (UK) Vehicle Leasing Limited ensures that all colleagues are familiar with the fundamental principles of TCF. In addition, where applicable, staff are trained in order to professionally explain and provide our products and services. We make sure that all our staff achieve the necessary qualifications and training in order to carry out their job functions with the required competence level. We undertake regular monitoring and assessment of our colleagues so that we can be confident of their competence.

Regulated Complaints

Central (UK) Vehicle Leasing Limited aims to provide excellent customer service and regulated complaint handling is a major component of its TCF measures. We deal with customer complaints fairly, objectively and independently and attempt to put things right as quickly as possible, in accordance with the rules laid down by the FCA. All complaints are recorded and monitored by our compliance team and reported and analysed in company committee meetings. Please visit our complaints policy for further information.

Conclusion

Central (UK) Vehicle Leasing Limited’s culture is and has been throughout the years in line with the outcomes stipulated by the FCA’s TCF initiative. However, we frequently review our policies, procedures and practices to ensure that TCF remains a crucial part of our business. We ask our customers to provide us feedback, sometimes formally through customer surveys, so that we can improve our service. The information we collate from our customers can be reflected in company MI and reviewed by senior managers, directors and board members to help shape any strategic decisions.