Treating Customers Fairly (TCF) is one of the key principles set by the Financial Conduct Authority to ensure fair treatment of customers by improving standards across the financial industry.
As a part of this, Blue Chilli Car Contracts Ltd follows the relevant aspects of the Financial Conduct Authority's six guiding principles on how to engage with our customers. These are known as the 'Treating Customers Fairly' principles and govern how we communicate with customers, the level of service we provide and the fairness of our products and procedures.
The Six Principles for Treating Customers Fairly
Ways We Meet These Requirements On A Day-To-Day Basis
We continually aim to understand the needs of our clients.
We ensure that the marketing of our products is appropriately targeted, clear, not misleading and highlights the risks/conditions as well as the key features/benefits of a product.
We make certain our clients understand the risks associated with our services at the outset of an instruction.
We keep our clients fully informed in a clear and fair manner that is unambiguous and not misleading.
We ensure our services are delivered with clarity and transparency and do not contain hidden conditions or rely on complex technical definitions. Any advice provided will be appropriate and take into account the customer's individual needs and circumstances.
We take our clients' privacy seriously and ensure that our staff are aware of and follow rules in relation to data protection to ensure that clients' details are kept secure and confidential.
We take any complaint seriously and will deal with any complaints promptly and make improvements to our operations where required.
What Is The Consumer Duty?
The Consumer Duty sets the standard of care that firms should give to customers in retail financial markets.
Consumer Principle
The Consumer Principle, Principle 12, requires firms to ‘act to deliver good outcomes for retail customers’. There are three cross-cutting rules that set out how firms should act to deliver good outcomes for customers. These are:
Cross-Cutting Rules
- Act in good faith toward retail customers - This is a standard of conduct characterised by honesty, fair and open dealing, and consistency with the reasonable expectations of customers.
- Avoid foreseeable harm to retail customers - Firms must take proactive and reactive steps to avoid causing harm to customers through their conduct, products, or services where it is in a firm’s control to do so.
- Enable and support retail customers to pursue their financial objectives - Firms must proactively and reactively focus on putting customers in a better position to make decisions in line with their needs and financial objectives.
There are four outcomes that cover the key elements of the firm-customer relationship. These are:
Outcomes:
- Products and services - All products and services must be fit for purpose. That is, designed to meet the needs, characteristics and objectives of customers and targeted/distributed accordingly.
- Price and Value - Value means more than just price. It involves firms assessing products and services to ensure that there is a reasonable relationship between the price paid and the benefit a customer receives.
- Consumer understanding - Communications must give customers the necessary information to support and enable them to make informed decisions about financial products and services.
- Consumer support - This involves the design and delivery of support that meets the needs of customers, including those with characteristics of vulnerability; ensures that customers can use their products as reasonably anticipated; ensures that the customer journey allows for the mitigation of risk of harm and gives customers sufficient opportunity.
At Blue Chilli Car Contracts Ltd we are committed to ensuring that we:
- Put customers at the heart of our business and focus on delivering good outcomes.
- Provide products and services that are designed to meet customers’ needs and which provide fair value.
- Communicate and engage with customers so that they can make effective, timely and properly informed decisions.
- Do not seek to exploit customers’ behavioural biases, lack of knowledge or characteristics of vulnerability.
- Support our customers in realising the benefits of the products and services they buy from us.
- Consistently consider the needs of our customers, and how they behave, at every stage of the product/ service lifecycle.
- Monitor and regularly review the outcomes that our customers are experiencing and take action to address any risks to good customer outcomes.
- Continuously learn from our growing focus and awareness of real customer outcomes.
Delivering The Four Outcomes
Customers can only pursue their financial objectives and avoid foreseeable harm when products and services are fit for purpose.
We will:
Product And Services
- Distribute products and services to meet this aim.
- Ensure that the product or service meets the needs, characteristics, and objectives of customers in the identified target market.
- Ensure that the intended distribution strategy for the product or service is appropriate for the target market.
- Carry out regular reviews to ensure that the product or service continues to meet the needs, characteristics, and objectives of the target market.
Price And Value
Fair value is about more than just price. The Consumer Duty aims to tackle factors that can result in products and services which are unfair or offer poor value. We will ensure that the price is fair by:
- Reviewing the nature of the product or service, including the benefits that will be provided or may reasonably be expected and their qualities.
- Reviewing any limitations that are part of the product or service (e.g., limitations on the scope of cover for insurance products), and the expected total price customers will pay, including all applicable fees and charges over the lifetime of the relationship.
- Where a product or service does not provide fair value to customers, we will take appropriate action to mitigate and prevent harm, for example, by amending it to improve its value or withdrawing it from sale.
- Assess value at the design stage and before offering products or services to customers.
- Monitor and assess the value of their products and services throughout their life, conducting regular value assessment reviews.
Consumer Understanding
- Ensure communications promote understanding and help customers to avoid foreseeable harm and to pursue their financial objectives – throughout the life of products and services.
- ‘Put ourselves in the customers’ shoes’ when considering whether our communications equip consumers with the right information, at the right time, to understand the product or service in question and make effective decisions.
- Set out principles relating to communications, which will include reviewing communications to ensure they are effective, layered, engaging, relevant, simple, and well-timed.
- Ensure that communications can be understood by the average customer intended to receive the communication, and equip them to make decisions that are effective, timely and properly informed.
- Communicate information in a way which is clear, fair, and not misleading.
- Tailor communications considering the characteristics of the customers intended to receive the communication – including any characteristics of vulnerability, the complexity of products, the communication channel used, and our role.
- Ensure information provided to customers is accurate, relevant, and provided on a timely basis.
- Tailor communications to meet the information needs of individual customers and check that the customer understands the information, where appropriate, when we are interacting directly with a customer on a one-to-one basis.
- Test, monitor and adapt communications to support understanding and good outcomes for customers.
Consumer Support
We will:
- Provide support that meets our customers’ needs. The support provided should enable customers to realise the benefits of the products and services they buy, pursue their financial objectives, and ensure that they can act in their own interests.
- Ensure customers are adequately supported throughout the lifecycle of a product or service after the point of sale – in particular, if they want to make an enquiry, claim, complain or switch provider.
- Provide an appropriate level of support that ensures customers do not face unreasonable barriers when exercising any rights or options in relation to the product.
- Not expose customers to unreasonable additional costs because of how their products are serviced.
If You Have a Complaint
Please visit our Complaints Procedure page for full details on how to raise and resolve an issue.