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Treating Customers Fairly Policy

1. Definition

In simple terms, Treating Customers Fairly (TCF) means treating customers as we would expect to be treated ourselves. It’s about making sure our products and services perform in the way the customer has been led to expect.

The requirement to treat our customers fairly is not new: it is one of our existing regulatory obligations and is firmly rooted in the FCA’s Principles for Businesses. Principle 6 states: ‘a firm must pay due regard to the interests of its customers and treat them fairly’. Other Principles are also relevant when taking a rounded view of what fair treatment might mean and to understand the breadth of the TCF initiative, and its significance to our organisation, it’s useful to remind ourselves of those.

1. Integrity – A firm must conduct its business with integrity.

2. Skill, care and diligence – A firm must conduct its business with due skill, care and diligence.

3. Management and control – A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.

4. Financial prudence – A firm must maintain adequate financial resources.

5. Market conduct – A firm must observe proper standards of market conduct.

6. Customers’ Interests – A firm must pay due regard to the interests of its customers and treat them fairly.

7. Communications with clients – A firm must pay due regard to the information needs of its clients and communicate information to them in a way which is clear, fair and not misleading.

8. Conflicts of interest – A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.

9. Customers: relationships of trust – A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement.

10. Clients’ assets – a firm must arrange adequate protection for clients’ assets when it is responsible for them.

11. Relations with regulators – A firm must deal with its regulators in an open and co-operative way and must disclose to the FSA anything relating to the firm of which that regulator would reasonably expect notice.

2. What does the FCA expect of Hertz Accident Support?

Under the Principles, providers and distributors of products and services have various responsibilities that have an impact on customers. Principles 2, 3, 6 and 7 are particularly relevant to these responsibilities.

The FCA has made it clear that it is up to individual firms ”to make their own assessment of what is appropriate for them, taking into account the nature of their business”.

The FCA’s six consumer outcomes explain what they want the TCF policy to achieve for consumers.

• Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
• Outcome 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.
• Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
• Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
• Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
• Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

3. How does Hertz Accident Support operate TCF as a culture framework?

Indicators
Key drivers
How we achieve
Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
Leadership
Fair treatment of customers is central to the behaviour and values of all our managers and staff, they communicate messages about the fair treatment of customers effectively and apply appropriate controls through call monitoring and internal closed file audits to ensure that the fair treatment of customers is delivered by their staff.
Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
Strategy
Hertz Accident Support has a firm clear vision which supports the fair treatment of customers. This is reflected within the formulation and implementation of strategic decisions (including change management programmes, marketing strategy and website; also when assessing outsource suppliers and requirements).
Consumers are provided with clear information and are kept appropriately informed.
Decision Making
Hertz Accident Support considers decision making at all levels and ensures it reflects the fair treatment of its customers. Hertz Accident Support uses staff, customer, referrer and external feedback where appropriate, using website and customer satisfaction survey and NPS scores to monitor the assurance that the interests of customers are balanced properly against those of the shareholders.
Where consumers receive advice, the advice is suitable and takes account of their circumstances.
Controls
Hertz Accident Support has firm controls in place including call monitoring, management information, training and service levels. These controls are integral to the firm’s risk framework.
Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
Recruitment, training and competence
Hertz Accident Support incorporates TCF in the recruitment and selection process by requesting previous good customer services skills of all potential candidates and they must exhibit and illustrate these prior to successful recruitment. Effective training of TCF begins with the new starter induction process and continues by the managers using performance management to develop their staff, identifying and acting on poor performance and rewarding good performance.
Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
Reward
All Hertz Accident Support staff are trained in handling complaints with TCF always in mind and operates a transparent process. Staff are managed with a key deliverable target being providing exceptional customer service and are rewarded for compliments received from customers.

4. How does Hertz Accident Support monitor that the TCF policy is being actioned?

Senior management is responsible for embedding and monitoring that TCF is effective in the culture of the organisation, but all staff are responsible for treating customers fairly. The way in which TCF influences your day to day activities will depend on the nature of your role.

Managers use the following methods to monitor TCF from their employees:
• Call monitoring
• Training and evaluation
• Internal closed file audits
• NPS score
• Customer Satisfaction survey
• SLA targeting
• Reporting on any breaches of policy
• Complaint MI, evaluation and trends
• Builds relationships with business partners

As stated in the Hertz Accident Support Data Protection Policy, Hertz Accident Support ensures that Principle 6 of the DPA is also adhered to, to ensure that customers are treated fairly.

5. How does Principle 6 of the DPA affect TCF?

Personal data must be processed in accordance with the rights of the individuals to whom the information relates.

The Act gives an individual the right:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling

As such all our calls are recorded and internal closed file auditing is performed by the management team quarterly.

An individual can make a written request – which may be by electronic means – or verbal request over the telephone to request access either of specific information or of all the information we hold about them. This is called a Subject Access Request (SAR). A copy of the requested information will be provided free of charge though in some instances a reasonable fee may be charged which will be based on the administrative cost associated with providing the information.

We are obliged to meet all SARs but must also remember the requirement to Treat Customers Fairly, which means we should seek to identify and respond to the individual’s underlying needs.

6. What happens if a customer wishes to make a complaint?

Treating customers fairly is an essential element of all areas of the business and fair and consistent complaints handling gives Hertz Accident Support an opportunity to ensure we are meeting and managing our client and customers experiences and expectations of the services we provide.

Following FCA complaint resolution rules 1.4.1, once a complaint has been received Hertz Accident Support will investigate the complaint competently and impartially ensuring the assessment is fair, consistent and prompt, considering if there are reasonable grounds for Hertz Accident Support to be solely or jointly responsible for the matter alleged in the complaint taking into account all relevant factors.

Hertz Accident Support under the FCA rules reserves the right to decline to consider a complaint that is made more than six months after they became aware of the complaint.

For further details please see the complaints policy.

7. What is Hertz Accident Support’s Customer Commitment?

We will treat our customers fairly and consistently, as we would wish to be treated ourselves.

Fair understanding and communication
We will:
• conduct appropriate customer research to help design our products and services
• ensure that our customers understand their responsibilities and obligations
• provide information which enables customers to make informed purchase decisions
• use written and spoken language that is relevant, easy to understand and avoids unnecessary complexity
• be clear about product terms and prices
• ensure that customers understand what they pay for
• aim to ensure that our customers do not experience any surprises

Fair service and distribution
We will:
• give our customers the service they have accepted
• respond promptly, in a friendly manner
• only use customer information for the agreed purpose
• ensure appropriately trained staff are available
• inform customers of the nature of our relationships with intermediaries
• ensure that commission structures do not encourage the promotion of unsuitable products.

Fair claims
When our customers make a claim we will:
• ensure the customer is clear about the progress of the claim at every stage and the timescale of the claim
• be empathetic and understanding
• act promptly and efficiently
• ensure the customer understands the extent of acceptance of their claim and any limiting policy terms and conditions
• explain the reasons for our decisions

Fair feedback and complaints
When our customers offer feedback, or express dissatisfaction, we will:
• listen to them carefully
• Respond quickly and effectively and learn from the feedback and use it to continually improve our service.