Treating customers fairly

We are committed to treating all of our customers fairly and in line with the Treating Customers Fairly (TCF) initiative. We recognise and share the key desired outcomes articulated by the Financial Conduct Authority (FCA) as an intended result of TCF:

Outcome 1: Consumers can be confident 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 identified consumer groups and are targeted accordingly.
Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the 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 have 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.

The Consumer Duty Principle

The Consumer Duty, which is effective from 31st July 2023, introduces a new Principle which sets a higher and more exacting standard of consumer protection across financial services and requires firms to act to deliver good outcomes for retail customers.

Principle 12: a firm must act to deliver good outcomes for retail customers.

The Consumer Duty also introduces the Cross-Cutting Rules, which articulate the standards of conduct that the FCA expect of firms under Principle 12 to help ensure that good outcomes are delivered.

Cross-cutting Rules

Firms must:

Act in good faith toward retail customers.
Avoid foreseeable harm to retail customers.
Enable and support retail customers to pursue their financial objectives.

In addition to the Treating Customers Fairly outcomes, the FCA have identified four Consumer Duty outcomes that the Bank must act to deliver.

The four Consumer Duty outcomes relate to:

Products and services
Price and value
Consumer understanding
Consumer support

The Bank’s obligations under TCF and the Consumer Duty are continually monitored to ensure that the Bank’s systems and controls continue to reflect regulatory requirements and industry best practices.