Confidence for customers

Our Group policies and procedures underpin the commitments we make to our customers and investors. They set out the minimum standards that ensure effective management and control of our business. The policies are mandatory and it’s our responsibility that they are followed.

The Conduct Risk Oversight committee oversees the regulatory and conduct risks across the Group and the monitoring of associated issues and actions.

Our compliance policies outline how we expect our business to be conducted. Current policies include:

• Customer Conduct Risk Policy: This policy covers the full product life cycle, from its development through to closure. It also sets out how we oversee third party distributors, communicate with our customers, and handle claims and complaints. It’s the Group’s policy that we:
• act in the best interests of our customers;
• act as an honest market participant;
• are compliant with all regulatory and legal requirements;
• flex our processes and approach when dealing with vulnerable customers
• Employee Conduct Risk Policy: This helps us make sure we identify and manage conflicts of interest, including where any benefits are offered to us, or by us, to third parties.

Our internal audit team reviews these policies and reports back on effectiveness in operation.

Our product life-cycle management sets out the standards we require, and the approach we follow when designing, launching and managing products, propositions and funds.

This complete framework covers areas including how we undertake stress and scenario testing (analysing what could happen during a financial crisis), customer research and understanding who would benefit most from our products.

This includes guidance on running customer operations and regulatory risk assessments. Our management guidance focuses on how we review product risks once they’ve been launched to make sure they are still suitable and relevant for customers.

Each business division is responsible for products once launched.

Communicating with customers in a way that is clear, fair, and not misleading is at the heart of our business. Our advertising standards teams ensure we communicate with customers correctly and accurately, complying with regulatory rules and UK advertising codes.

By having these procedures in place, we are confident that the products our customers buy are fit for purpose.

All employees are expected, through extensive training, to understand and deliver our internal governance framework. This includes compulsory computer-based training on:

• Complaints Awareness
• GDPR
• Environmental
• Financial Crime
• Security Awareness Fundamentals
• Health & Safety
• Treating Employees Fairly
• Personal Responsibility
• Vulnerable Customers

The relationships we build with customers are crucial to our success. We always look to learn as much as possible so that our service is always helpful and provides constant value.

Examples of how we measure our relationship with customers include:

• Culture - Are we customer focused in everything we do, from setting our strategy to servicing our customers?
• Product performance - Is the product doing its job?
• Experience - Do we deliver a good experience?
• Complaints - Do we put things right when things go wrong?
• Conduct - Is our business performance meeting the expectation of auditors and regulators?

Twice a year the Financial Conduct Authority publishes complaints data for firms across the financial services industry where those firms have received 500 or more complaints in a six-month period or 1000 or more complaints in a year. This information includes details of the number of complaints received, redress paid, type of product, and the reason for the complaint.

In addition, the UK’s Financial Ombudsman Services also publishes a bi-annual report showing the number of customers that asked for an independent review of a complaint decision made by us.

We’re also required to publish our complaints data for the legal entities within the Group every six months.

There are many characteristics of vulnerability which can change over time. Our insight into the needs of customers with characteristics of vulnerability helps us create products, investments and services which help people through difficult times. We liaise with charities and social enterprise experts to help guide us on how we can improve.

We can also make reasonable adjustments for customers with a disability under the Equality Act, under the term ‘Anticipation Duty.’ This is to ensure all our customers are treated fairly and feel supported in any way we can.

It is important to us that all customer facing staff have sufficient training to support customers effectively and sensitively. We ensure our communications can be adapted to our customer needs, for example whether they need it in Braille, large print or in audio format.

Our staff are offered a wide variety of training to help better understand our customers' needs. We have a number of partnerships with third party charities who help us deliver training and support our people. We have trained over 100 mental health first aiders across all our locations to help support staff spot signs of mental health concerns. This support is invaluable to employees regularly talking to customers with characteristics of vulnerability to ensure we signpost them towards professional support.

We have increased the number of charity sector professionals, known as ‘critical friends’, who help us review our existing products and services offered to customers. We will continue to consult with ‘critical friends’ to help improve our service, processes and innovate new products.