Purpose

This policy details how TLG Group Limited will manage its obligations to treat customers fairly and ensure a consistency of approach within the company.

TLG Group Limited will meet its obligation to conduct itself ethically by properly managing any potential conflicts of interests of its customers.

TLG Group Limited is authorised by the Financial Conduct Authority (FCA) and, as such, will act in accordance with the Principles as defined in the FCA Handbook, which will take precedence over the requirements of this policy. 

Review of Policy

This policy will be reviewed regularly, at least once a year, and amended as considered necessary by the TLG Group Limited’s Management Body in the event of changing circumstances or regulations.

Responsibilities

Management Body Responsibilities

The Management Body of TLG Group Limited are responsible for ensuring that the culture of treating customers fairly is embedded within the company and is central to its practices.  

Culture

TLG Group Limited takes its responsibilities towards its customers seriously and as such has ensured that a culture of treating customers fairly starts with the Management Body and is cascaded down through the company.

Fair treatment of customers is central to the behaviour and values of TLG Group Limited and senior management can articulate what the fair treatment of customers means for their company and communicate this to all employees.

Strategy

When determining a strategy, the Management Body has aligned its vision and values with the fair treatment of customers at the forefront of the process.

TLG Group Limited sets out their objectives and risk appetite to reflect a consistent approach to treating customers fairly and appropriate resources are allocated to ensure that actions that ensure fair treatment of customers agreed at the planning stage are delivered.

Employee Responsibilities

All employees are expected to read, understand, and accept any policies and procedures that relate to how TLG Group Limited expects customers to be treated to ensure fair outcomes. Employees are tested on this to ensure a clear understanding.

Treating Customers Fairly

TLG Group Limited has reviewed each outcome and has documented how such an outcome may apply to the business and how it will evidence fair outcomes for its customers.

Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.  

• The Management Body have approved this policy and made it available to employees to ensure that they are aware of their obligations
• Remuneration structures have been designed to discourage behaviour that could result in poor outcomes
• Training has been made available to all employees on understanding TCF obligations
• Complaints will be closely examined to identify any TCF failings and actions taken where appropriate
• Information provided to customers for onward transmission to their customers will be designed to meet the information needs of that customer group                                                                                                                                                     

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.

• TLG Group Limited will take into account the information needs of the underlying customer when developing marketing and distribution strategies for our products and services

Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale. 

• Our “terms of business” does not use ‘jargon’ and takes the information needs of our customers into account

Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.

• TLG Group Limited does not have permission to give advice on insurance products and will not be in a position where advice may be inadvertently provided to a consumer
• TLG Group Limited has permission to give advice on credit broking, debt counselling and debt adjustment where it relates to vehicle finance and has a robust suitability process in place which is subject to rigorous monitoring

Outcome 5: 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. 

• The information provided to our customers regarding our product and service will be sufficiently detailed to ensure that the underlying customer is able to understand how their products/services are performing

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. 

• Complaint’s procedures have been put in place by the Management Body
• There are no onerous post-sale or exit penalties applied where the customer wishes to withdraw or change provider

Management Information

TLG Group Limited must be able to measure the effectiveness of its policies and obligations to treat customers fairly through Management Information (MI).  Where deficiencies are noted, the Management Body must demonstrate that they take positive steps to address them and ensure that no customers were disadvantaged.

Conflicts of Interest

TLG Group Limited has implemented a separate Conflicts of Interest policy that sets out how they intend to identify and manage the risks arising from conflicts of interest.  Where a conflict is identified as likely to cause a poor outcome for customers, the relevant actions will be taken by TLG Group Limited. 

Vulnerable Persons

TLG Group Limited has implemented a separate Vulnerable Persons policy that sets out how it intends to identify vulnerable persons, as well as how to deal with them in a fair and sensitive manner. Where an individual is identified as being vulnerable, the employee dealing with this individual will ensure that they follow the requirements set out in the Vulnerable Persons policy and manage the customer relationship accordingly.

Anti-Money Laundering

TLG Group Limited has implemented a separate Anti Money Laundering policy that sets out how it intends to take necessary preventative action and promptly investigate any suspicion of money laundering.

At present, TLG Group Limited does not enter into any financial agreements with customers. They are handed over to the client (manufacturer, dealer, funder) at this point so they can perform their own required due diligence prior to completing a sale. TLG Group Limited does however recognise that early detection can minimise risk in this area and so employees receive training on Anti-Money Laundering – what it is, what to look out for and how to handle any suspected cases.

Recruitment

TLG Group Limited recruitment strategy considers the previous conduct and behaviour of potential employees.  Where there are indications that a potential employee may have participated in poor outcomes, further references will be obtained, and the outcome will be considered in any decision to offer a contract of employment.

Potential employees will be questioned on their experiences of ensuring good outcomes where it is relevant to the role.

Remuneration

In line with its Remuneration Policy, TLG Group Limited operates a remuneration structure that is transparent and recognises the fair treatment of customers.

Training and Competence

Management makes positive behaviours and attitudes towards the fair treatment of customers as central to how it conducts its business, and this is encouraged through effective training and maintenance of staff knowledge.

TLG Group Limited has developed its own ‘Customer Journey’ which is central to the way it engages with and deals with customers and ensures that all its customers are treated fairly. 

Any training must embed the concept of “Treating Customers Fairly” within the corporate culture and competence assessments should ensure that the concept is fully understood and implemented.  Management will have effective controls in place allowing them to identify and act on poor customer outcomes and ensure that good outcomes are encouraged.

Customer Communications

In its communications with customers, TLG Group Limited does not promise to or imply that they are able to provide services that they are not able or equipped to deliver.

Our communications consider a customer’s information needs and is set out in such a way as to ensure that customers can clearly understand the nature of the service that is provided to them by TLG Group Limited and the markets in which the relevant regulated entity dealing with that customer operates in.

Customers must be able to fully understand TLG Group Limited terms, conditions, and charges, therefore the tone and content of the communications will consider the likely level of understanding displayed by its customers.  Similarly, TLG Group Limited will apply the necessary procedures to ensure that its customers fully understand all costs and charges that they may incur.

TLG Group Limited will communicate with its customers in an open, transparent, and easily understandable manner.

Financial Promotions

All non-real time financial promotions are reviewed and signed off before hand by the compliance manager to ensure balance and conformity with the Financial Promotion rules, i.e. fair, clear and not misleading.

Complaints

Customer complaints will be handled in accordance with TLG Group Limited complaints policy. The opportunity to refer the customers concerns to the Financial Ombudsman Service must be clearly stated where the customer is an eligible complainant.

TLG Group Limited will ensure that the service offered to a customer is not negatively influenced by a customer’s complaint and customers can be assured that their complaint will be investigated fairly and objectively.

All complaints are recorded, and the outcomes monitored with management information analysed by the Management Body to identify any endemic issues within TLG Group Limited.

Breaches of Treating Customers Fairly Policy

Any breaches of the Treating Customers Fairly rules will be recorded on TLG Group Limited’s breach log in conjunction with its Regulatory Breach procedure.