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Treating Customers Fairly

  1. Policy Statement
  • GC Business Finance (GCBF) ensures customers are at the very heart of all that we do. We are fully committed to providing the highest standards of customer service.
  • Our customers are our most valuable asset and our aim is to ensure we deliver a consistently fair, honest and professional financial service. As part of our overall approach we are fully committed to treating our customers fairly and as such we endeavour to meet their expectations of high quality service.
  • Our Treating Customers Fairly (TCF) policy is centred on the guidance provided by the Financial Conduct Authority (FCA) to ensure we consistently deliver fair outcomes to our customers. We will operate through a culture of openness and transparency.
  • As an organisation, we take the requirements of the FCA seriously, particularly, the requirements to treat customers fairly.
  • We recognise that our employees are critical to delivering a positive customer experience and ensuring our customers are treated fairly. Our culture and values encourage and support our employees to deliver this.
  1. Responsibility
  • The Compliance Manager has overall responsibility for this policy and ensuring its implementation throughout the organisation.
  • All staff have a responsibility to treat customers fairly.
  1. Policy Detail
  • There are 6 consumer outcomes the FCA detail as being central to the TCF initiative:
    • Outcome 1 – Consumers can be confident that 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
  • GCBF is committed to sustainability and not compromising the fair treatment of customers.
  • TCF is central to the corporate culture, as demonstrated by the following activities: We continually aim to understand the needs of our customers with particular attention paid to creditworthiness, suitability and affordability.
  • We keep our customers 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.
  • We make certain our customers understand what is required of them and the level of commitment a loan agreement entails.

4 TCF Management Information

TCF Management Information (MI) Reporting, Review and Escalation.

MI is produced on a monthly basis by a dedicated MI Team in collaboration with the Compliance Manager and analysed as part of the Compliance Monitoring Programme with appropriate input from the SMT.

Business areas where issues or anomalies are identified. This ensures there is an adequate “bottom-up” review of the TCF data.

A summary of the data is then presented to the SMT on a monthly basis with a further report presented to the board annually. This enables robust “top-down” challenge and review of the Companies’ performance against TCF outcomes.

Ad-hoc reviews of TCF are carried out by Compliance to ensure TCF processes continue to be appropriate and TCF MI remains ‘fit for purpose’.

5 Product Design and Development

GCBF operates a documented process for product development with ‘check-lists’ that evidence sign off, of any new product scope and specifications by all relevant parties within the Business, including Actuarial, Legal and Compliance, Finance, Re-insurance and Risk.

Steps are taken to ensure FCA’s suitability requirements and appropriate disclosure guidelines are met at the point of sale and in any subsequent policy documentation issued to the customer to enable GCBF to provide products to consumers that are suitable.

6 Complaints - Root Cause Analysis and Outcomes Testing

GCBF have detailed complaints handling procedures and training in place that are in line with FCA rules and guidelines. This ensures all employees are able to identify complaints and complaint handlers investigate complaints, competently, fairly and consistently in line with the GCBF Complaints Policy.

The complaints handling areas of the Company also produce detailed reports annually, which contain information on volumes and outcomes.

These reports are analysed by the SMT as part of the TCF suite of MI with the results escalated to Management for review. Trends are recorded and discussed to determine if any remedial action is required, either against individuals, products, policy wordings or processes.

7 Customer Services

The Company operate a demanding but achievable service level agreements, agreed internally, which are constantly monitored to ensure customers receive the level of service they expect. Exceptional results are achieved as a result of fully trained and dedicated employees who understand the importance of providing excellent customer service and maintaining GCBF reputation. External validation regularly confirms that GCBF meets and exceeds customer service levels via customer service reviews.

8 Incentive Schemes

GCBF seeks to avoid operating incentive schemes that could breach the principle of TCF and risk consumer detriment.

9 Conflicts of Interest

In accordance with FCA Principles and the Bribery Act 2010, GCBF is committed to ensuring its business is conducted in a way which is legal, professional, fair and in accordance with the best interests of its customers. Potential conflicts of interest between the company and its customers and between a customer and another customer are constantly monitored.

GCBF operates within the Growth Company Code of Business Conduct Policy although a GCBF guideline document has been designed specific to GCBF which is regularly monitored and reviewed. The policy provides guidance and sets out various requirements for all employees including the offering and receiving gifts and hospitality as well as oversight of relationships with customers and suppliers.

10 Training and Competence

To ensure success and provision of excellent customer service, employees receive appropriate training and are aware that TCF is at the heart of GCBF culture. All members of staff attend an extensive induction course following their appointment. Annual training and testing also takes place via outsourced training modules, including TCF, which all staff are required to pass.

11 Employee Feedback

Employees are also encouraged to feedback any concerns, observations or suggestions they have regarding TCF (amongst other matters) to enable improvements to be implemented across the business. This feedback can be provided to Management & Compliance representatives or directly via a staff suggestions scheme called “Bright Ideas”. Rewards are given to employees who provide the best and most innovative suggestions.

12 Evaluation Procedure

This policy will be evaluated at least annually. The firm reserves the right to discontinue or change the policy without prior notice to its employees.

13 Review Mechanism

This policy will be reviewed following changes in legislation, company policy or working practices. This policy will be subjected to a full review annually to ensure its continued effectiveness and validity. This review will take place during at least one of the two set Management Review meetings per year.