Introduction
Equaliti Ltd are dedicated to upholding the FCA's principle of treating customers fairly (TCF) across every facet of our business operations. Our commitment is to embed and uphold the TCF principle throughout all aspects of our operations, forming the foundation of our business conduct.
Purpose
This policy serves to outline Equaliti Ltd's obligations towards our customers, ensuring fair treatment as per the FCA's principle.
Scope
This policy, ratified by our Compliance Committee on behalf of the Board, extends to all personnel involved in our operations, encompassing officers, beneficial owners, and employees, including permanent, contract, and temporary staff.
Additionally, this policy applies to our Appointed Representatives (ARs). Our engagement with ARs, considered "in house," undergoes regular audits, ensuring compliance.
For any concerns within this scope, the Director of Compliance should be contacted.
Background
All FCA-regulated firms must uphold the principle that 'a firm must pay due regard to the interests of its customers and treat them fairly.' The TCF principle aims to elevate standards in business operations, benefiting consumers and bolstering their confidence in the financial services sector.
TCF Outcomes:
Outcome 1: Customers confidently engage with firms where fair treatment is fundamental to the corporate culture.
Outcome 2: Retail market products and services are designed to meet consumer needs, targeted accordingly.
Outcome 3: Clear information is provided to consumers before, during, and after sales.
Outcome 4: Advice provided to consumers is suitable and considers their circumstances.
Outcome 5: Products meet customer expectations, delivering acceptable service standards.
Outcome 6: No unjustified post-sale barriers are imposed on consumers by firms.
What is TCF?
Treating customers fairly is not about uniformity; it's about customer choice, transparent information, confidence in providers, suitable products, freedom to switch, and the assurance that products and services perform as expected.
Firms must consistently demonstrate the delivery of fair outcomes to consumers, with senior management taking responsibility for establishing a culture centred around fair customer treatment.
Expected Business Practices:
Cultivate a corporate culture emphasising fair customer treatment.
Accurately measure performance against fairness issues relevant to the business and act on the results.
Show consistency in delivering fair outcomes, avoiding serious failings reported to the FCA or identified through management information (MI).
TCF and Equaliti Ltd
Equaliti Ltd’s STANCE on TCF
S – Suitability of Products (Outcome 2)
T – Transparency in Information (Outcome 3)
A – Appropriate Advice (Outcome 4)
N – No Post-sale Barriers (Outcome 6)
C – Confidence in Our Culture (Outcome 1)
E – Expectations Fulfilled (Outcome 5)
To ensure TCF is deeply ingrained in our culture and values, Equaliti Ltd will achieve this by:
Delivering Suitable Products
Conducting income, expenditure, and suitability checks to ensure financial viability.
Personally assessing customer applications to select the best funder based on credit profiles, employment, and vehicle criteria to minimise negative credit impacts.
Providing the Consumer Credit Information document before agreement to ensure clear customer comprehension.
Transparent Information
Offering a transparent, professional service for informed customer decisions.
Ensuring promotional material is clear, compliant, and jargon-free, reaching the right audience.
Providing comprehensive product training to Sales Executives and customer-facing staff for effective customer communication.
Furnishing accessible literature and product details for customer convenience.
Streamlining the customer journey for a seamless, error-free experience.
Appropriate Advice
Providing continuous feedback, coaching, and development opportunities for all staff.
Training non-sales teams to embed TCF in their daily activities, fostering a culture of customer-centricity.
Keeping employees updated on competence, data protection, and service quality matters through relevant training.
Encouraging TCF-focused feedback from staff to improve processes and enhance the customer journey.
Eliminating Post-Sale Barriers
Implementing a structured process for recording and handling dissatisfaction and complaints.
Maintaining comprehensive customer records to handle complaints promptly and fairly.
Ensuring fair, prompt, and impartial assessment of customer complaints, aligning with FCA regulations.
Cultivating a Confident Culture
Instituting robust processes to detect and counter money laundering and fraud.
Partnering customers only with suitable lenders for their needs.
Keeping TCF visible across facilities with informative posters.
Consistent monitoring and quality checks through call, case, and process monitoring.
Structuring sales incentives that prioritise TCF values and customer satisfaction over sales volumes.
Regular monthly reviews and coaching sessions with department managers to reinforce TCF culture.
Upholding strong ethical values throughout the workplace.
Fulfilling Customer Expectations
Encouraging a feedback loop for customers, dealers, and funders.
Implementing post-deal contact questionnaires for service improvement.
Monitoring and reporting TCF activities monthly to assess performance across the business.
Ensuring all staff embrace and comprehend TCF values set by Senior Management.
