Treating Customers Fairly Policy

AFL (Fleet Management) Ltd (“AFL”) is authorised and regulated by the Financial Conduct Authority and is fully committed to complying with the FCA’s Consumer Duty (PRIN 2A), which came into force on 31 July 2023 for open products and 31 July 2024 for closed products.

Consumer Duty sets a higher standard of consumer protection and requires firms to act to deliver good outcomes for retail customers.

While Treating Customers Fairly (TCF) principles remain embedded within FCA rules, Consumer Duty is the primary framework governing AFL’s conduct.

2. The Consumer Principle

In accordance with Principle 12 of the FCA Handbook:

“A firm must act to deliver good outcomes for retail customers.”

AFL embeds this principle within its culture, governance framework, operational procedures, remuneration model and customer journey.

3. Cross-Cutting Rules

AFL applies the three cross-cutting rules across all areas of its business:

3.1 Acting in Good Faith

We act honestly, fairly and professionally in all customer interactions. Customers are not exploited through pricing structures, complexity, behavioural bias, or information asymmetry.

3.2 Avoiding Foreseeable Harm

We proactively identify potential risks of harm throughout the customer journey, including:

• Product suitability risks
• Affordability risks
• Communication misunderstandings
• Vulnerability indicators
• Post-sale servicing barriers

Where risks are identified, mitigating actions are implemented.

3.3 Enabling and Supporting Customers

We provide clear, timely and appropriate information to enable customers to pursue their financial objectives. Customers are supported throughout the lifecycle of their agreement.

4. The Four Consumer Duty Outcomes

4.1 Products and Services

AFL operates as a credit broker working with a panel of UK finance providers.

We ensure:

• Products are designed for defined target markets
• Customers fall within the intended target market before introduction
• Finance products are suitable based on customer needs and circumstances
• Regular review of lender product governance information
• Monitoring of product performance and complaints trends

We do not manufacture financial products but conduct due diligence on the products we distribute.

4.2 Price and Value (Fair Value)

AFL is committed to ensuring customers receive fair value.

This includes:

• Transparent disclosure of our status as a credit broker
• Clear explanation of commission structures where applicable
• No discretionary commission arrangements
• Monitoring total cost of credit outcomes
• Regular assessment of broker fees and remuneration structures
• Review of complaint themes relating to pricing

We conduct periodic Fair Value Assessments to ensure remuneration structures do not create consumer harm or bias.

4.3 Consumer Understanding

All financial promotions and marketing materials are reviewed to ensure they are:

• Clear, fair and not misleading
• Appropriate for the intended audience
• Compliant with FCA financial promotion rules

During the sales process:

• Customers are provided with pre-contract explanations
• Key terms are explained in plain language
• Customers are given adequate time to consider decisions
• Important information is not obscured or presented in a misleading way

We test communications through monitoring and feedback to ensure understanding.

4.4 Consumer Support

AFL ensures customers receive appropriate support throughout the lifecycle of their agreement, including:

• Pre-sale assistance
• Support during order processing
• Assistance post-delivery
• Clear signposting to lenders for regulated account servicing
• Transparent complaints process

We do not impose unreasonable post-sale barriers.

Customer contact channels remain accessible throughout the customer journey.

5. Customers in Vulnerable Circumstances

AFL recognises that vulnerability may arise due to health, life events, resilience or capability.

We:

• Train staff to identify vulnerability indicators
• Record vulnerability appropriately
• Adapt communication where necessary
• Provide additional support where required
• Monitor outcomes to ensure vulnerable customers receive fair treatment

Vulnerable customers are expected to achieve outcomes comparable to other customers.

6. Governance, Oversight & MI

Consumer Duty is overseen at Board level.

AFL:

• Produces Management Information (MI) to monitor customer outcomes
• Reviews complaints data, cancellation rates, declines and arrears themes
• Conducts root cause analysis where issues are identified
• Maintains documented evidence of outcome monitoring
• Produces an annual Consumer Duty Board Report

Senior Management retains accountability for Consumer Duty compliance.

7. Training & Competence

All advisers and relevant staff:

• Receive Consumer Duty training
• Are assessed under our Training & Competence framework
• Are monitored through call reviews and file audits
• Maintain the required competence to perform their roles

Refresher training is delivered regularly.

8. Remuneration

AFL operates a remuneration model designed to:

• Mitigate sales bias
• Avoid incentivising unsuitable recommendations
• Reward quality and compliance standards

Remuneration structures are reviewed periodically to ensure alignment with Consumer Duty.

9. Complaints Handling

AFL operates a formal complaint handling procedure in accordance with FCA DISP rules.

We:

• Record all complaints
• Investigate objectively and fairly
• Provide clear responses within required timeframes
• Monitor complaint themes through MI
• Report findings to senior management

Complaint analysis forms part of our outcome monitoring framework.

10. Compliance Monitoring

AFL engages an independent external compliance consultancy to conduct periodic reviews of regulatory adherence, including Consumer Duty requirements.

However, ultimate accountability for compliance remains with AFL’s senior management and Board.

11. Continuous Improvement

AFL regularly reviews its:

• Policies and procedures
• Customer journey
• MI outputs
• Staff training
• Remuneration models
• Lender relationships

Customer feedback is actively sought and used to improve outcomes.

Conclusion

Consumer Duty is embedded within AFL’s culture, governance and operational processes.

We are committed to acting to deliver good outcomes for retail customers and will continue to enhance our systems, controls and monitoring to meet evolving regulatory expectations.