Keeping focused on our customers
We know our customers want to know that the products and services they have bought from us will do their job when needed. They want to be treated fairly during the sales process and be able to trust us to do our job when they call upon us.
We have teams of people in every level of our business whose job is to make sure that we are constantly refining what we do for our customers and that we operate in a fair way. We want our customers to feel confident that we are factoring the best outcomes for them into the way we do business.
how We govern
Our Group policies and procedures underpin the commitments we have made to our customers and investors, setting out the minimum standards and procedures to ensure effective governance and control of our UK and overseas businesses. The policies are mandatory and it’s the responsibility of our Managing directors and Senior executives to make sure that they are followed.
Our range of Compliance policies is part of the framework of how we expect our business to be conducted. Our current policies that set out the regulatory principles, rules and guidance include:
- Inducements – this sets out how we should act when any benefits are offered to us as individuals or as a company
- Conflicts of interest – this includes our framework to make sure we identify and manage conflicts to prevent any adverse impact on our customers
- Complaints – our policy clarifies our requirements and the standards we expect employees to follow to deliver good outcomes to customers. Complaint trends are monitored, reviewed and acted on in each business area and also at a quarterly Complaints committee attended by senior business management
- Provider/distributor – this covers how responsibilities for relationships should be established and maintained with the aim of delivering consistently fair outcomes for customers.
how We design
Our Product lifecycle management (PLM) is a framework that sets out the standards we require, and the approach we follow, when designing, launching and managing products, propositions and funds. The comprehensive framework covers areas such as how we expect stress and scenario testing, customer research and understanding target markets. It also includes guidance on running Customer operational and Regulatory risk assessments. Our ongoing management guidance focuses on how we review the risks on our products once they have been launched to make sure they are still right for customers.
During 2012 we applied our PLM framework and principles to over 140 products impacted by the Retail Distribution Review.
Each business channel has a Product committee which approves product launches and has oversight of our products once they’re launched.
Communicating with customers in a way that is ‘Clear, fair and not misleading’ is central to our business. Our Advertising Standards function ensures we communicate with customers in this way, and that we comply with FSA rules and guidance, UK advertising codes and our own brand values.
We have a Fund panel in place to monitor funds. Its role is to ensure they are performing in a way that is continues to be right for customers.
how We train
We engage our employees in understanding and helping to deliver our internal governance framework through training. This includes computer based training for everyone in the company on:
- bribery and corruption
- data protection
- financial crime.
how We measure and monitor
Our Treating customers fairly management information is used to help our senior executives and non-executive directors understand how we are delivering against our customer commitments and to drive improvements. During 2012 we refreshed how we collect and present this information.
An example of the areas that our businesses measure on a monthly basis that we think are important to our customers includes:
- the culture of our people – are they customer focused and on your side? Do they quickly put things right when things don’t go to plan?
- the quality of the advice and product when it was sold to you
- ongoing product performance – has the product done its job?
- service performance – when you contact us or we contact you do we deliver good service?
- conduct – can our businesses justify their performance to our auditors or our regulator?
Our checks and balances
We have a number of organisations and regulators that we work with to ensure our performance in delivering to our customers is comparable to other financial services companies. Some of the key ones include:
- our Internal Audit team looks at how we apply our policies and standards and reports back on the effectiveness of their implementation
- the Financial Ombudsman Service (FOS) publishes data on how many of our clients ask for an independent review of a complaint decision made by us compared to our peers. See the latest of the Financial Ombudsman Service. In 2012 the FOS overturned a lower proportion of our decisions on complaints compared to the industry average in each sector. We use this data to make sure that we are handling complaints fairly.
- We have increased disclosure on complaints for our overseas businesses. For example in . We expect the same to follow from our US and Dutch operations in 2013:
We think it's important that we stand up and be accountable for our business performance and whether our customers think we do business the right way for them.