Our vision is to be the most effective financial technology solutions provider in the UK and to maximize employee engagement and customer satisfaction. Our TCF policy is an integral part of achieving that objective. Serpable Ltd has a very committed customer focus that is essential given the volume of customers handled by its technology platforms. It is therefore imperative, that management and employees are able to make individual judgments as to what constitutes fairness to customers. This will be achieved through constant evaluation of our products, distribution processes and by embedding TCF in all business and training reviews. This policy statement has been produced to document the various values and controls that exist to enable Serpable Ltd to demonstrate that we have the interests of our customers at the centre of everything we do. Treating customers fairly is about establishing a culture of fairness and understanding the customer’s needs across the business. A cultural rather than directive approach acknowledges the business model that Serpable Ltd operates.
These values are our watchwords. They set the standards by which we conduct ourselves with our customers and each other. They provide the foundation that sits behind our TCF policy and set the tone for the way in which we manage our TCF culture.
The Board of Directors and senior management has responsibility to deliver fair outcomes for consumers with the best interests of the customer at the heart of our thinking. We require all our employees to embrace the TCF values and consider our TCF outcomes in their day-to-day work regardless of their role. We manage and monitor this on a regular basis.
Serpable Ltd has 6 desired outcomes for its customers, which are:
1. Consumers can be confident they are dealing with a firm where the fair treatment of customers is central to our culture.
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.
3. Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
4. To make it clear to consumers that we do not provide advice under any circumstances.
5. Consumers are provided with products that perform as they have been led to expect, and the associated service is both of an acceptable standard and as they have been led to expect. 6. Consumers do not face unreasonable post sale barriers to change product, switch provider, submit a claim or make a complaint.
Our commitment to achieving these outcomes to our customers is demonstrated by the following:
• Our products and services are designed to meet the needs of identified customer groups;
• We do not sell products that are inappropriate to our customers;
• We ensure we understand the core needs of our identified customer groups;
• We provide customers with clear information and keep them appropriately informed at all times;
• We inform customers that we do not provide advice but that we will provide information both online and verbally;
• We provide products that perform as we have led customers to expect, and any associated services will be of an acceptable standard;
• Internal controls are in place to manage and monitor these principles;
• We align incentive schemes to be consistent with the desired outcomes;
• We do not create unreasonable post sale barriers for customers to change product, switch provider, submit a claim or make a complaint;
• We will deal with complaints in accordance with regulatory requirements and aim to exceed these requirements in most cases.
• All customer complaints are reviewed in monthly management meetings and reported to directors and shareholders to identify systemic failures in order to undertake corrective and timely actions.
• We will provide training and refresher courses to reinforce the TCF values and outcomes in everyday actions
Ensuring our customers are treated fairly is at the heart of our corporate culture. We can demonstrate this by the following core activities:
• Actively encouraging customer feedback from both employees and customers on our products, decision making and procedures.
• All 121 meetings with employees contain a TCF review as a measurable objective.
• Incentives schemes are consistent with the 6 desired TCF outcomes.
• Induction and ongoing training provided include TCF as part of our core training and development plan.
• Management controls exist across all business areas to identify specific TCF related risk areas. The senior management team reviews these controls and identified issues resulting for these controls as a normal part of its monthly review meetings.
• Management information is in place to measure customer outcomes, which is reviewed by senior management on a regular basis.
• FCA regulated partners must have adopted TCF principles before we will work with them. This will be measured by all regulated partners confirming they have a TCF policy in place.
• All our literature is clear and easy to understand including the ability for customers to opt in or out of further marketing activity and our complaints procedures.
