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Treating the Customer Fairly

Treating customers fairly policy


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. GB Car Leasing is fully committed to TCF and this Policy has been

designed to demonstrate the application of TCF during the course of our day to day activities.

TCF is embedded throughout the FCA’s Handbook and GB Vehicle Contracts supports the TCF initiative and satisfies the FCA’s six core consumer out comes which explain what it wants TCF to achieve for consumers. These are:


• Consumers can be confident they are dealing with firms where TCF is central to the corporate culture

• Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and targeted accordingly

• Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale

• Where consumers receive advice, the advice is suitable and takes account of their Circumstances

• Consumers are provided with products that perform as firms have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect

• Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint


Our TCF Mission Statement


Working together to find the best car leasing solution.


Our TCF Principles


• Clients will be provided with clear information and kept appropriately informed before, during and after the point of sale

• When advising clients on financial products, the advice will be suitable and take account of their circumstances

GB Car Leasing is a trading style of Green Bison Limited, which is authorised and regulated by the Financial Conduct Authority. Our FCA Firm Registration Number is 672334. Green Bison is a Credit Broker Not a Lender.

Green Bison Limited, Unit B1, Caerphilly Business Park, Van Road, Caerphilly, CF83 3ED (Registered Number 04596559).

• Our service will meet the expectations of our customers as far as reasonably possible

• We will ensure that there is no barrier for clients to express their concerns or complaints, and will always be responsive to them

• Products and services will meet the needs of clients


Assessing and implementing our TCF Principles


Marketing


All GB Car Leasing financial promotions and marketing literature are reviewed to ensure that they are appropriate for the target audience and are presented in a clear, fair and not misleading manner.


Sales / Customer Service


We will:


• Obtain a good understanding of clients’ needs and financial circumstances so we can find the most suitable product

• Only recommend a product that we consider to be suitable, and this will always be the most suitable from the options available

• Ensure that our clients understand the service we provide and are aware of any applicable Charges

• Strive to keep clients informed at all times, regarding possible delays, deliveries etc. • Encourage clients to ask if there's something they do not understand

• Give access to a formal complaints procedure should anyone become unhappy with our Service


Post-Sale Information and Support


Appropriate records are kept, and we have appropriate capacity and processing arrangements in place to ensure support to customers with queries regarding their contracts.


Policies and Procedures


GB Car Leasing have numerous policies and procedures that are relevant to the fair treatment of clients and adhere to FCA requirements, these are (this not an exhaustive list):

GB Car Leasing is a trading style of Green Bison Limited, which is authorised and regulated by the Financial Conduct Authority. Our FCA Firm Registration Number is 672334. Green Bison is a Credit Broker Not a Lender.

Green Bison Limited, Unit B1, Caerphilly Business Park, Van Road, Caerphilly, CF83 3ED (Registered Number 04596559).

• Conflicts of Interest Policy

• Data Protection Policy

• Training and Competence Policy

• Complaint Handling Procedures

• Financial Promotions Procedures

• Compliance Manual


Management Information


GB Car Leasing use MI to ensure that our TCF commitment is being met. Good MI should be accurate, timely, relevant and consistent.


Staff Training and Competence


GB Car Leasing regularly monitors all key areas of regulatory compliance including TCF. We ensure that all advisers are familiar with the fundamental principles of TCF. In addition, where applicable, advisers are trained to suitably advise on the products and services we offer.


Complaints


GB Car Leasing aims to provide excellent customer service and complaint handling is a major component of its TCF measures. We deal with client’s complaints fairly and objectively and attempt to put things right as quickly as possible, in accordance with the rules laid down by the FCA. All complaints are recorded, monitored and reported in company meetings.


Vulnerable Customer Policy 


GB Car leasing has established clear and effective policies and procedures for identifying and dealing with vulnerable customers. These are first identified through the underwriting process. 


Generally, a person is considered to be vulnerable if it would be unreasonable to expect them to be able to deal with a problem themselves. There is no legal definition of a vulnerable person, but the National Standards for taking control of goods says this could include: 

  • older people 
  • disabled people 
  • the seriously ill 
  • he recently bereaved 
  • single parent families 
  • pregnant women 
  • unemployed people 
  • those who have obvious difficulty in understanding, speaking or reading English. 
  • people with mental health issues. 


Under TCF outcome 6, staff must ensure that vulnerable clients are not presented with barriers preventing them from obtaining advice and transacting business. Staff should take appropriate steps to assist vulnerable clients. 


This may include: 

  • Recommend that they are accompanied at interviews. 
  • Conduct more meetings than usual to ensure understanding is fully confirmed and demonstrate appropriate care of this type of client. 
  • Provide documentation in bigger print or change the style of correspondence to suit the understanding of the client (Braille, larger print etc). 
  • Provide them with advice to seek further help. 
  • Refer them to a debt agency such as Citizens Advice Bureau


Definition of ‘consumers in vulnerable circumstances’


A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care. 

  • The most significant detriment occurs when people, using consumer credit, get into unmanageable or problem debt 
  • This can often lead to spiralling problems, leading to both financial and non-financial costs.


Breaking this down further, the FCA has identified the following characteristics and circumstances that it views as ‘vulnerable’;


Personal characteristics 

  • Communications needs – lack of English Language skills 
  • Restricted mobility-caused by physical disability or sever or long-term illness 
  • Resource limitations 
  • Low basic skills 
  • Low literacy, numeracy and financial capability skills 


Personal circumstances 

  • Mental health problems e.g. depression / anxiety, bi-polar disorder 
  • Memory problems e.g. age, dementia 
  • Life events e.g. bereavement, illness 
  • Poor financial situation 
  • Niche requirements e.g. example, health conditions, legal status, etc. 
  • Being young (associated with less experience) 
  • Being ‘older old’ for example over 75, although this is not absolute (may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill- health, not being comfortable with new technology) 
  • Non-standard requirements or credit history (e.g. armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants)


Our approach


Our priority is to provide our clients with an excellent service. We aim to treat our entire client bank fairly and deliver high quality services which meet and exceed their expectations throughout their relationship with us. 

We understand the need for “fair and appropriate treatment of customers, who the firm understands or reasonably suspects to be particularly vulnerable.” (CONC 7.2.1) There are a number of key expectations which the FCA require from regulated companies when dealing with vulnerable clients:


  • Have appropriate policies in place to identify consumers in vulnerable circumstances 
  • Policies to approach consumers in vulnerable circumstances in a sensitive and flexible way 
  • Be as transparent as possible in their dealings with consumers in vulnerable circumstances


To ensure expectations are met we will ensure; 


  • All employees will be given initial training in identifying and dealing with vulnerable clients 
  • All employees will be provided with ongoing training and regular updates to ensure employees continue to implement our policies 
  • Our systems will facilitate the identification of vulnerable clients 
  • Our systems will enable us to deal with vulnerable clients in the most appropriate manner so their needs are met 
  • The needs of vulnerable clients will be factored in to the service provision and design of the products we offer 
  • Our policies will be clear to consumers and consumer organisations 
  • Management Information will be used regularly to review and improve our policies and procedures.


Conclusion


GB Car Leasing’s culture is in line with the outcomes stipulated by the FCA’s TCF initiative. However, we will frequently review our policies, procedures and practices to ensure that TCF remains a crucial part of our business.