Our Customers.

Our customers, and the outcomes we deliver for them are at the centre of our Vision, Purpose and Beliefs. To fulfil these obligations, we conduct our business through the lens of ‘Consumer Duty’ to ensure we are fulfilling the needs and objectives of our customers. We ensure customer outcomes are at the heart of our products and processes by design, reviewing the product prices and features, the appointment of distributors or the way we communicate and support customers. We operate key controls to ensure we do this on an ongoing and sustained basis. Some controls include communication testing, customer outcome testing, our product governance and oversight, and much more. The outcomes of our customers’ remain, and will always be a top priority of the Board, the Executive Team and the business’ culture.

We have a detailed product management framework which sets out how our products are governed, assessed and managed in order to ensure that products are appropriately designed, launched and distributed. We have well embedded processes in place to ensure that the products we offer meet the needs of our target customers, provide good customer outcomes, and help customers to achieve their financial objectives.

We have robust governance in place to ensure that we monitor and oversee product design and performance. We have a formal Product and Pricing Committee with the delegated responsibility from Board for oversight of product governance and product and pricing changes. This includes governance of our periodic product review calendar which ensures that we continually assess the performance and customer outcomes associated with our existing product set, and governance of changes to products or pricing and launch of new products. 

When making changes to products and launching new products, we have a defined product lifecycle from ideation to delivery and review to provide structure and governance to product changes. We have a defined materiality matrix which dictates where material product changes or launches are escalated from Product and Pricing Committee to the Executive Committee and Board for approval.

We are responsible for ensuring that all relevant audience needs are understood, and that our products and services are promoted in line with those needs and company strategy/objectives, through effective, engaging and compliant communication. We use customer-appropriate marketing techniques and all marketing is conducted in-line with required regulation for example FCA, ASA & CAP. We have a clearly defined end to end marketing procedure framework which details how the team approach the task of developing activity and a robust approvals process which identifies which stakeholders need to be consulted on marketing activity. The marketing team are also required to follow the correct data approvals processes. Quality assurance checks are completed each month to ensure marketing activity is being executed in line with our documented process, record keeping and approval processes.

Products are clearly and transparently labelled, and communicated along with detailed information on product risks, benefits and contractual terms.

We understand that sometimes things don’t go to plan and we are ready to support customers facing financial difficulty. We’ll actively contact those in difficulty, understand their circumstances and tailor forbearance outcomes to their individual needs.

We regularly review customer accounts that are behind with their payments, to make sure that the arrangements we’ve made are still appropriate and to see if any further support is needed.

If their difficulties go beyond their loan with us, we’ll tell them about other organisations that can help, to make sure they can get the support they need.

We maintain policies in relation to our arrears management and forbearance. We ensure these policies are adhered to by having well-defined procedures. All our colleagues complete learning, at least annually. For our colleagues in customer facing positions they receive additional learning to ensure our customers’ are given the support they require.

All of our customers are unique and we understand that the things that happen in their lives can affect them in different ways. We understand that that means they may become vulnerable and need different levels of support. We’re committed to ensuring that our vulnerable customers receive the support they need and receive positive outcomes, despite other difficulties they may be facing.

Our systems and processes enable us to record those needs, preventing customers from having to tell us more than once that they need support. We monitor the outcomes provided to our vulnerable customers across lots of different customer journeys, making sure that they receive outcomes as good as anyone else.

All of our colleagues are trained to recognise different types of vulnerability and provide adjustments where needed.

We strive to get things right first time, but unfortunately that doesn’t always happen. We’ve got clear and simple complaint handling processes for when things don’t go right. We’ll fully investigate our customers’ concerns, explain our findings quickly and simply, and fix any problems that we find.

We’re committed to continuous improvement and our complaints data is used to understand what is driving complaints and how we can improve our processes, preventing complaints in the first place. We monitor our complaint trends through colleague working groups and through formal governance. Our Risk Committee and Board regularly review complaints metrics. We’ll take timely action where needed to address any underlying issues.

Where applicable, our customers will be made aware of how they can refer their complaint to the Financial Ombudsman Service (FOS).

Our customer facing colleagues support our customers every day and to make sure they are able to deliver the excellent service we expect, they are provided with extensive training and ongoing support.

From an in-depth induction training process, dedicated operational trainers delivering master-classes, through to daily coaching and feedback from managers, our colleagues have all the support they need to perfect the service they deliver to our customers.

We really value insights from our customers and invite customers to provide us with feedback at key points along the customer journey. We monitor our scores and take steps to understand what is going well, so we can do more of it, and what isn’t, so we can improve it.

Every individual review is assessed by our management team and we’ll take action if needed, including contacting customers to understand more about their feedback.

We’re proud to have been accredited by CCA Global following an extensive assessment of our approach to managing and supporting our customers.