Treating Customers Fairly policy - pre- Consumer Duty
The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) initiative was primarily based on the obligation set out in Principle 6 requiring an advisory Financial Services firm to pay due regard to the interests of its clients and treat them fairly. This principle has now been superseded by the Consumer Duty although we feel that TCF is still relevant and closely related to its successor. You will see reference to the Consumer Duty elsewhere on this website.
Pioneer is fully committed to TCF and the Consumer Duty and these firm policies have been designed to demonstrate the application of TCF and the Consumer Duty during the course of our day to day activities. TCF is embedded throughout the FCA’s Handbook - the FCA also identified six core consumer outcomes which explained what it wanted TCF to achieve for consumers.
These principles were:
Consumers can be confident they are dealing with firms where TCF is central to the corporate culture.
Products and services marketed and sold in the retail market 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.
Our TCF mission statement - echoed by the Consumer Duty
We will act with integrity and ethically in everything that we do and aim to be in partnership with our clients.
Our TCF Principles:
- Customers will be provided with clear information and kept appropriately informed before, during and after the point of sale - client understanding and client support -
- If we give advice to our customers, the advice will be suitable and take account of their circumstances - product governance and target market
- Our level of service and product performance will meet the expectations of our customers as far as reasonably possible - good client outcomes
- We will ensure that there is no barrier for customers to express their requests, concerns or complaints, and will always be responsive to them - client support
- Products and services will be designed to meet the needs of clients - target market
- We will assess, develop and implement our TCF principles within which we will also question and assess any personal or financial vulnerabilities that may arise for any client.
Marketing all Pioneer’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. Pioneer’s advisers obtain a detailed understanding of the clients’ investment objectives, their level of expertise and their attitude to risk so that their recommendations are suitable. We ensure that our clients understand the risks involved with any service or product offered and are aware of all applicable charges.
We classify all our clients correctly (segmentation) to ensure they are offered the appropriate level of protection. Investment and asset allocation decisions are regularly reviewed by the relevant decision-makers.
Post-sale information and support
Pioneer strives to keep its clients informed at all times. Appropriate records are provided as required and on an ongoing basis. We have appropriate capacity and processing arrangements in place to ensure continuous support and no post-sale barriers. Policies and Procedures Pioneer has a number of policies and procedures that are relevant to the fair treatment of clients and also achieve adherence to FCA requirements.
Management information
Pioneer produces Management Information (MI) in order to assess its performance against TCF (and Consumer Duty) 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. Pioneer produces MI reports which are reviewed regularly.
Awareness/training
Pioneer ensures that all employees 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 our advisers 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 so that we can be certain of their competence.
Compliance
Pioneer has a compliance officer who regularly monitors all key areas of regulatory compliance including TCF.
Remuneration
Pioneer 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.
Complaints
Pioneer aims to provide excellent customer service and complaint handling is a major component of its TCF and Consumer Duty 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 our compliance team and reported and analysed in company MI reports.
Conclusion - be it TCF or the Consumer Duty
Pioneer’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, so that we can improve our service. The information we collate from our clients can be reflected in company MI and reviewed to help shape any strategic decisions.
The FCA's key focus is on ensuring good outcomes for all consumer clients, which both TCF and the Consumer Duty are relatedly based on.
