Consumer Duty

Principle 12 of the FCA Handbook states that a firm must act to deliver good outcomes for retail customers. The rules came into force on 31 July 2023, and we treat them as a core part of how the business runs rather than a compliance exercise.

Underneath the Principle sit three cross-cutting rules. We must:

• ✓ Act in good faith towards retail customers.
• ✓ Avoid causing foreseeable harm to retail customers.
• ✓ Enable and support retail customers to pursue their financial objectives.

We are a broker rather than a lender, so we do not design finance products. What we can control is whether the products we place are right for the person in front of us — and we will not recommend one that is unsuitable or unaffordable.

• ✓ We review our processes and policies, and monitor them regularly, with named directors accountable.
• ✓ We identify specific customer needs, including vulnerability — see our Vulnerable Customer Policy.
• ✓ We check the products we broker are offered to an appropriate group of customers.
• ✓ We evaluate whether our offering meets customer needs, using product performance data, customer feedback and complaints.

That review runs across the whole journey: telling you about your right to withdraw and our complaints procedure at first contact, making our initial disclosure and commission disclosure clear, checking you understand your contractual obligations and any consequences, and explaining the total amount repayable, interest, charges, monthly payments and optional fees before you commit. Where there is any doubt that something has landed, we ask questions to check.

The FCA defines value as the relationship between what a product costs you and the quality of what you get. We assess whether the pricing we broker is reasonable, fair and in line with the market, so that you can commit knowing fair value has been considered.

• ✓ We review the market regularly and consider how our offering sits against competing providers.
• ✓ We review our own revenue and margins to check the return is fair.
• ✓ We ask customers directly whether they feel the service represents value for money.

Giving you information is not the same as making sure you have understood it. We ask questions to confirm understanding rather than assuming it, and we watch for signs of confusion.

• ✓ We check you understand the total cost, the repayments required, and what happens if you do not repay.
• ✓ We check our financial promotions explain costs clearly, including the APR and representative example where required, and that nothing in them could mislead.
• ✓ We adapt communications to the person, including anyone with characteristics of vulnerability.

If we are not satisfied that a customer understands the nature of the agreement, we should not be placing it.

You should be able to act on your decisions without facing unreasonable barriers. That means answering the phone and replying to emails in reasonable time, giving you the opportunity to understand and assess your options including the risks, and monitoring the standard of that support so we can improve it.

• ✓ We recognise vulnerable customers and provide the level of support they need, so they are not disadvantaged.
• ✓ We signpost our complaints procedure.
• ✓ We signpost anyone in financial difficulty to free, independent debt advice — including where an application is declined on affordability grounds.

We review complaints and negative feedback to find root causes, and train staff accordingly.