Confidence for customers

Our policies and procedures set the standards for how we run our business. They help us manage risk, stay compliant and keep our promises to customers and investors. These policies are mandatory and it’s our responsibility to follow them.

Our Conduct Risk Oversight committee monitors regulatory and conduct risks across the Group and tracks any issues or actions. Our compliance policies explain how we expect our business to run. They include:

• Customer Conduct Risk Policy – it covers the full product life cycle, from development  to closure. It sets out how we work with third-party distributors, communicate with customers, and handle claims and complaints. We commit to:
  • act in the best interests of our customers
  • act as an honest market participant
  • comply with all regulatory and legal requirements
  • adapt our approach when dealing with vulnerable customers
• Employee Conduct Risk Policy – it helps us identify and manage conflicts of interest, including any benefits offered to or by third parties.

Our internal audit team reviews these policies and reports on how well they work in practice.

We follow clear standards when designing, launching and managing products, propositions and funds. This includes:

• stress and scenario testing customer research
• understanding who benefits most from our products

We also review products after launch to make sure they remain suitable and relevant. Each business is responsible for its products once they’re on the market.

Clear, fair and accurate communication is at the heart of what we do. Our Advertising Standards team ensures we meet regulatory rules and UK advertising codes.

All our employees complete training to ensure they understand and deliver our governance framework. It includes compulsory courses on:

• complaints awareness
• GDPR
• environmental responsibilities
• financial crime
• security awareness
• health and safety
• treating employees fairly
• personal responsibility
• supporting vulnerable customers

We measure our success by the relationships we build with customers. We look at:

• Culture – are we customer focused in everything we do?
• Product performance – does the product do its job?
• Experience – do we deliver a good experience?
• Complaints – do we put things right when things go wrong?
• Conduct – do we meet the expectations of auditors and regulators?

Twice a year, the Financial Conduct Authority publishes complaints data for firms with 500 or more complaints in  six-months, or 1,000 or more in a year. This includes the number of complaints , redress paid, product type and  reason for the complaint.

The Financial Ombudsman Services also publishes a bi-annual report showing how many customers asked for an independent review of our decisions. We publish our own complaints data for each legal entity in the Group every six months.

Customer needs can change over time. We work with charities and social enterprises to understand how we can improve our products and services for customers with characteristics of vulnerability.

We make reasonable adjustments for customers with disabilities under the Equality Act’s anticipation duty. This means offering support such as Braille, large print or audio formats.

We train our people to support customers effectively and sensitively. We also partner with charities to deliver training and guidance. More than 100 of our employees are trained mental health first aiders, helping us support customers and colleagues when it matters most.

We’ve  increased the number of charity sector professionals, known as critical friends, who review our products and services. Their feedback helps us improve and innovate.