AFL is fully committed to TCF and this policy has been designed to demonstrate the application of TCF during the course of AFL’s day to day activities. TCF is embedded throughout the FCA’s Handbook, however, the FCA has also identified six core consumer outcomes which explain what it wants TCF to achieve for consumers: as follows
- Consumers can be confident they are dealing with firms where TCF is central to the corporate culture.
- Products and services marketed and sold are designed to meet the needs of identified consumer groups and targeted accordingly.
- Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
- Where consumers receive advice, the advice is suitable and takes account of their circumstances.
- 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.
- Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
Assessing and implementing our TCF principles
All AFL’s financial promotions and marketing literature are reviewed to ensure that they are appropriate for the target audience and are presented in a clear, fair and not misleading manner. Sales personnel qualify our customers so that they get a clear understanding of the clients’ needs and requirements. We ensure that our clients understand everything involved with our service and are aware in advance of all applicable charges. Initial service agreements are signed by our clients in advance of us starting any work on their behalf outlining our services and any charges.
Post-sale information and support
AFL strives to keep its clients informed at all times. Our clients are communicated to at appropriate stages both before and after the contract commences via our customer care team. Electronic updates are sent regularly to our clients as various key stages of our service is fulfilled. We have appropriate headcount capacity and processing arrangements in place to ensure continuous support and no post-sale barriers. We have a number of policies and procedures that are relevant to the fair treatment of clients and also achieve adherence to FCA requirements, these are (this not an exhaustive list):
- Conflicts of Interest Policy
- Data Protection Policy
- Training and Competence Policy
- Complaint Handling Procedure
- Financial Promotions Procedure
AFL produces MI in order to assess its performance against TCF principles. We ensure that MI is accurate, timely, consistent and relevant in order to assist the business in making informed decisions in the best interests of our clients. AFL produces MI reports which are reviewed regularly by senior managers and directors.
AFL ensures that all advisers and staff are familiar with the fundamental principles of TCF. In addition, where applicable, advisers and staff are trained in order to suitably advise on and efficiently explain and provide our products and services. We make sure that all of our advisers and staff achieve the necessary qualifications and training in order to carry out their job functions with the required competence level. We undertake regular monitoring and assessment of our advisers and staff so that we can be certain of their competence.
AFL has an external compliance agency Compliancy Services Limited who is independent and regularly monitors all key areas of regulatory compliance including TCF.
AFL operates a remuneration model that mitigates sales bias and rewards non-sales staff in a way that would not negatively impact the treatment of its clients.
AFL aims to provide excellent customer service and complaint handling is a major component of its TCF measures. We deal with customer complaints fairly, objectively and in accordance with the rules laid down by the FCA. All complaints are recorded and monitored by a Board Director on a weekly basis and reported and analysed in company MI at our Board meetings.
AFL’s culture is and has been throughout the years in line with the outcomes stipulated by the FCA’s TCF initiative. However, we frequently review our policies, procedures and practices to ensure that TCF remains a crucial part of our business. We ask our clients to provide us feedback sometimes formally through an independent company called Trust pilot so that we can continually monitor and improve our service. The information we collate from our clients can be reflected in company MI and reviewed by senior managers, directors and board members to help shape any strategic decisions.