Treating Customers Fairly
This policy outlines The Start Up Loans Company’s (SULCo) approach to ensuring that the Financial Conduct Authority’s (FCA) principles for Treating Customers Fairly (TCF) are applied in all areas of SULCo’s day-to-day business activities. This Policy is designed to provide customers and SULCo employees with a clear and transparent overview of how TCF principles are demonstrated and applied at SULCo.
SULCo is a corporate subsidiary of the British Business Bank, but this Policy only applies to SULCo and its employees.
Purpose and Objective
SULCo is exempt from FCA regulation, however it will adhere to the industry and regulatory requirements in respect of how customers should be treated, and strives to deliver a fair and positive experience for all individuals engaging with the scheme. As part of this endeavour, SULCo is committed to continually reviewing and improving both its offering and the way this offering is delivered.
This approach has been developed in accordance with the principles and requirements outlined by the FCA, which specifies that ‘All firms must be able to show consistently that fair treatment of customers is at the heart of their business model.’ The FCA does not set down a standard approach for how TCF should be assessed and implemented; that said, demonstrating TCF is not difficult or onerous and SULCo does this in a number of ways. These are detailed in this policy and incorporated in other policies such as the Complaints Handling Policy, Privacy and Data Sharing Policy and Collections Policy.
The FCA has developed six TCF consumer outcomes that firms should strive to achieve, to ensure fair treatment of consumers. The six TCF outcomes are outlined below:
- 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 objective of this Policy is to provide a broad overview of how SULCo seeks to apply these outcomes in every day practice.
FCA principles focus on a conduct culture – a culture of fairness, where a demonstrable commitment from senior management is evident, and extends well beyond the first point of contact with customers.
The fair treatment of customers is as much about employee behaviour and the overall approach of a firm, as it is about its systems and controls. How employees are engaged, appraised, trained and motivated plays a key part in the culture of fairness.
In embedding TCF, SULCo endeavours to:
- Provide appropriate guidance that is suitable to each customer;
- Take into account customer circumstances and, where appropriate and with their consent, obtain further information about our customers to better understand individual circumstances;
- Treat customers with dignity and respect;
- Provide customers with appropriate information, such as adding our policies to our website and referencing where customers may obtain further information from the FCA;
- Never mislead customers;
- Ensure staff are trained appropriately to demonstrate TCF outcomes; and
- Perform risk assessments of TCF non-compliance.
What TCF does not mean
TCF does not mean delivering identical levels of service to every customer. Each customer should be treated as an individual, taking into consideration their own personal circumstances, rather than adopting a “one-size-fits-all” approach.
“Dissatisfied” customers may have been treated fairly. For example, if a Loan application is declined due to low personal affordability, poor credit worthiness or the customer’s inability to satisfactorily demonstrate the viability of their business.
“Satisfied” customers may not always have been treated fairly. For example, if a Loan is approved where there are concerns of affordability, then the customer may have been unnecessarily burdened with debt.
Delivering the TCF Outcomes
TCF forms part of the company culture of SULCo and is embedded throughout our processes. SULCo’s management recognises its responsibility towards treating customers fairly and ensures this is a focus for all SULCo employees. As a result, several monitoring initiatives are embedded into SULCo’s ways of working.
Marketing and Promotions
Appropriate measures are taken by SULCo to ensure that all promotional and marketing materials, including, but not limited to websites, email communications and advertisements, are not misleading and do not target individuals that are clearly ineligible or not suitable for a Start Up Loan.
SULCo’s marketing and promotions contain appropriate statutory disclosures set out by the FCA and ensure all applicants understand that loan applications are subject to assessments of creditworthiness, affordability and business viability.
SULCo provides appropriate and relevant information to customers at each stage of the process, to ensure customers are well informed about what is expected of them and why certain decisions have been made. This includes following key stages of a customer’s journey: when customers are considering applying for a loan, during the customer registration process, during the application process, once a loan outcome has been decided, once the customer has drawn down their loan, and during the loan repayment period.
SULCo’s Credit Policy sets out best practices for ensuring the fair treatment of customers at all stages of the application process, including rules and guidance set out in the FCA Handbook. For more information on the FCA Handbook please visit www.handbook.fca.org.uk.
SULCo will provide a level of service, which is in line with the service customers are told to expect. It will adhere to the industry and regulatory requirements in respect of how customers should be treated, although they are not governed by them directly. For example, this will include the provision of accurate information, and a fair and consistent approach to the assessment of loan applications and fair treatment of our lending criteria. SULCo ensures that customers are given a reasonable opportunity to satisfy the requirements for a loan.
Before approving Loans, SULCo’s Delivery Partners (DPs) will be reasonably assured that an applicant’s business plan is viable and suitable for individual circumstances, and that the loan will not overburden the individual, ensuring repayments are affordable.
Individuals, partnerships, companies or other organisations (remunerated or otherwise) tasked with delivering pre or post application business guidance, support and mentoring (Mentors) will have access to this Policy so they are fully aware of the high standards SULCo has set and expects when interacting with customers.
Any direct guidance provided to customers by SULCo, or signposting to sources of advice, will be provided based on individual circumstances.
The Collections Policy adheres to FCA rules and guidelines to ensure fair treatment of customers.
Whilst this Policy, is not for external use, it complies specifically with Conc 7 within the FCA Handbook which is available at: https://www.handbook.fca.org.uk/handbook/CONC/7/
Complaints Handling Policy
In the event that a customer feels they have not been treated fairly, SULCo will offer a clear and easy process for capturing customer complaints, in accordance with the Complaints Handling Policy. This process will give customers the opportunity to raise their concerns via a method that suits them, i.e. by telephone, website, email, and social media or in writing. All complaints will be reviewed and responded to in accordance with this Complaints Handling Policy and adequate responses will be issued within reasonable timeframes.
Monitoring TCF through Management Information (MI)
SULCo has MI systems and other measures in place (including but not limited to processes, controls and standards) to monitor and test how effectively SULCo is delivering TCF consumer outcomes.
SULCo’s Customer Experience Team and Quality Control functions will incorporate TCF outcomes when completing periodic reviews, including regular risk assessments, of SULCo’s products and services.
MI is reviewed on a regular basis to ensure SULCo is monitoring its TCF responsibilities. This includes, but is not limited to:
- Product/customer research reviews
- Loan volumes
- Successful Loan Applications not taken up
- Internal audit/Compliance reports
- Case File Reviews
- Complaints and customer feedback, provided through SULCo’s Voice of the Customer Programme.
Results from these reviews are provided to the senior management team and feeds into SULCo’s business strategy and processes.
TCF is a regular agenda item at senior management meetings. TCF is under constant review and the results and findings from regular progress reports inform the senior management team and influence strategic decision making. This is then logged, tracked and closely monitored on an on-going basis.
All SULCo employees are reminded that personal information is classed as “personal data” or (as the case may be) “sensitive personal data” under data protection legislation, including but not limited to the Data Protection Act 1998 and the European Union’s General Data Protection Regulation (Regulation *(EU) 2016/679). Please refer to SULCo’s Privacy and Data Sharing Policy for further details.
If you would like further information about SULCo’s approach to Treating Customers Fairly, or this Policy, please contact us via any of the following channels:
Customer Service team:
Phone: 0344 264 2600*
Webchat* on the SULCo website
User Online form:www.startuploans.co.uk/contact/
*Services available weekdays 9.00am – 6.00pm, excluding bank holidays and during staff training.
**Individuals should expect a reply from a SULCo representative within two working days.