TCF Code

Treating Customers Fairly (TCF)

What is Treating Customers Fairly?

Officially, a UK firm “must pay due regard to the interests of its customers and must treat them fairly.” For us, this is not a regulatory, tick-the-box exercise – it is at the heart of who we are.

We recognise that we must continue to ensure TCF is integral to our products, our service and our operations and that, to treat our customers fairly, we need to:

  • Provide a professional service
  • Sell customers products that fit their needs
  • Ensure no claims are unreasonably rejected

In order for this to be fully understood throughout the UK business, we provide TCF and customer conduct training for all our staff on an annual basis using our regulatory e- learning programme. Additionally, in October 2008 we appointed a TCF Committee to provide governance of our TCF policy and to actively support our front line managers in ensuring TCF is embedded throughout the business.

Other key milestones in our TCF journey have included:

  • Ensuring Management Functions, Roles & Responsibilities reflect customer focus
  • Requiring all relevant staff to have customer focus objectives as part of our annual performance review processes
  • Ensuring the production of detailed TCF and customer conduct management information is a business as usual practice

The UK TCF Committee reviews this management information on a regular basis to identify and drive through any remedial actions, best practice and policy.

Taking our three core TCF values in turn, our response can be summarised as follows:

Professional Service:

  • TCF is embedded in our policies and processes and is central to our culture
  • Customer Focus accountabilities are included in role profiles of relevant staff
  • All relevant staff are given specific customer focus goals/objectives
  • All relevant staff receive TCF and customer conduct training

Suitable products:
Product development forums have been established to review all new and certain updated products prior to launch to ensure, amongst other things, they are consistent with TCF and customer conduct principles. Our financial promotions policy also ensures our marketing and sales materials:

  • Are clear fair and not misleading;
  • Support our TCF policy; and
  • Comply with corporate standards and relevant product and distribution policies

The Procedures cover:

  • Approval and sign-off of financial promotions
  • Timely review of existing promotions
  • Management of the withdrawal of expired financial promotions