Treating Customers Fairly & Consumer Duty

At Select Car Leasing we are dedicated to providing the best possible customer service and treating you in the fairest possible manner. Ever since our formation in 2004 we have always prided ourselves on delivering the highest standards of service which our customers can be truly satisfied with.

Treating Customers Fairly (TCF) is a key principle set by the national financial regulator the Financial Conduct Authority (FCA) to ensure that customers are treated fairly.

It is a document which is crucial to how we carry out every aspect of our business. The FCA have set out six 'Treating Customers Fairly' principles which outline how we communicate and engage with our customers, the quality of service we provide and the fairness of our procedures. As a fully licensed broker we are proud to follow the FCA's treating customers fairly guidelines:

Outcome One

Customers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.

Outcome Two

Products and services marketed and sold in the retail market are designed to meet the needs of any identified consumer groups and are targeted accordingly.

Outcome Three

Consumers are provided with clear information and are kept appropriately informed before, during and after point of sale.

Outcome Four

Where consumers receive advice, the advice is suitable and takes account of their circumstances.

Outcome Five

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 Six

Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

How do we ensure customers are treated fairly?

Always put the needs and requirements of our customers at the forefront of everything we do.
Continue to make certain our customers understand from the outset about any risks associated with the services we provide.
Keeping customers informed of all information at all times in a way that isn't misleading or ambiguous.
Maintaining transparency at all times with customers.
Maintaining clarity. We don't want our customers to feel like any information is being kept from them, our services are free from any hidden terms and conditions or complex technical jargon.
Offer accurate advice that is appropriate to a customer's specific circumstances and requirements.
We understand the importance of customer privacy, you can read more about our Privacy Policy and Data Protection
Regularly reviewing internal processes and systems to make sure our customers are getting the best possible service.
Dealing with and responding customer complaints. We understand that sometimes you may not feel satisfied with the service provided, if that is the case we always respond and deal with complaints in a prompt and professional manner. You can read more about what to do if you have a complaint.

Consumer Duty & Defining a ‘good customer outcome’

Introduced by the Financial Conduct Authority in 2023, the Consumer Duty sets a higher expectation for the standard of care that firms give customers. Firms are required to comply with the Duty's cross-cutting rules by acting in good faith towards customers, avoiding causing foreseeable harm to customers and enabling and supporting customers to pursue their financial objectives.

Select Car Leasing’s target market is categorised as Retail Customers with the following common traits:

As an introducing broker we are responsible for arranging and introducing the customer to the product i.e. the finance agreement. We also source vehicles from one of our approved supplying dealers. Our target market is typically financially stable, credit worthy middle to high income earners who are either in their own or rented accommodation. As such we believe are (unlikely to present a specific vulnerability. We accept all customers are susceptible to event driven vulnerabilities”)

The financial objective of the client is to find a suitable finance product that enables them to lease, or lease purchase a vehicle. Our Sales process sis such that we can guide and support a consumer towards their objects of leasing a vehicle in a way that is suitable to their needs.

In our sales process we will seek to identify any likely consumer vulnerabilities such as the inability to understand, read, communicate, or any financial or affordability issues. We seek to identify vulnerability/ affordability concerns though our customer qualification process.

A good customer outcome is one where a client/consumer proceeds with full understanding regarding the nature of the product (financial product i.e., a Personal Contract Hire Agreement) and the specifics of leasing or purchasing a vehicle. In addition to this this customer receives a vehicle that is suitable for their needs. We endeavour to validate positive customer outcomes through our customer feedback survey.

In order to achieve good customer outcomes, we adhere to the following:

Cross Cutting Rules

Select Car Leasing recognises that delivering good customer outcomes will be achieved through adhering to the three cross-cutting rules of Consumer Duty which are to:

• Act in good faith towards retail customers.
• Avoid foreseeable harm to retail customers; and
• Enable and support retail customers to pursue their financial objectives.

Consumer Outcomes

Select Car Leasing will ensure that it adheres to the four Consumer Duty Outcomes, which are:

a. Products and Services:

We will ensure that the products and services we distribute meet the needs, characteristics and objectives of our customers and perform as they are expected to.

As a distributor of products and services we will:

• Understand the features, benefits and limitations of the products and services we distribute, along with who the target market is and what the distribution channels are, to enable us to sell them in an appropriate and correct manner. Therefore, we must make sure that we have obtained all the information we need to fully understand and appropriately sell them to consumers.
• Have appropriate distribution arrangements in place for each product and service that we distribute, which will be in line with guidelines set out by the manufacturer.
• Monitor and review how products and services are being sold to make sure that they are being sold to the identified target market and are distributed in the correct way.
• Share relevant information with manufacturers to support their review of products and services.

b. Pricing and Value:

We will ensure that the products and services that we distribute offer fair value for clients.

We will ensure that:

• Fees are fair and proportionate to the cost of providing or delivering the product or service and that we can justify the value of the fees we charge. We ensure that we explain clearly in our initial disclosure document our upfront fees and remuneration. This is also clearly advised in the customer order forms.
• We review whether there are other charges levied throughout the distribution chain which might mean that the overall cost of the product or service does not provide fair value to the customer.
• We consider whether vulnerable customers may suffer harm as a result of the way that our fees are structured. This is identified via our customer harm assessment which is documented and vulnerability checks – see our vulnerability policy.
• All fees and charges applicable to our products and services are clearly and fully communicated to customers at point of enquire, on the website, the IDD, key facts, quote, and order from and through discussion/ qualification with our leasing consultants.
• We share relevant information with manufacturers in relation to pricing, including feedback from customers. We have regular review meetings with our funders and share information on an ad hoc basis.
• Review any actions take in relation to pricing and value to make sure that these changes achieve the required outcomes.

c. Consumer Understanding:

We will ensure that we support our customers by helping them to make in informed decisions about products and services. Customers will be given the information they need, at the right time and presented in a way that they can understand.

We will:

• Support our customer’s understanding by making sure that our communications are likely to be understood by our “average” customer and are provided at the right time, so that they can make properly informed and timely decisions.
• Tailor communications, taking into account the characteristics of the customers who we intend to receive these communications, including customers with characteristics of vulnerability, the complexity of the product or service and the manner in which the information will be communicated.
• Monitor, test and adapt communications on a regular basis and make sure that where information is unclear, misleading or incorrect, that action is taken to amend them.
• Review any actions take in relation to customer communications to make sure that these changes achieve the required outcomes.
• Make sure that all fees and charges, including any ongoing charges or exit charges, are clear and prominent in communications with customers.
• Make sure that the protections applicable to products and services or customers, such as the Financial Services Compensation Scheme protection and right of referral to the Financial Ombudsman Service are clearly highlighted.
• Be clear about whether a product is regulated or unregulated.

d. Consumer support

We recognise that customers can only pursue their financial objectives when we provide them with the level of support, they need to use the product or service they have bought.

We will provide customers with support channels which allows them to use products and services as expected and enjoy their benefits. This includes:

• Making how and when customers can access support clear to them.
• Providing post-sale support that is as good as pre-sale support.
• Meeting customer’s needs, including accommodating customers who are dealing with complex issues, or those who are vulnerable.
• Including appropriate “friction” points in the sales process which can mitigate the risk of harm to a customer and result in good outcomes.
• If a product or service is no longer suitable for customers, make it easy for them to switch to another product or exit.
• Being clear about how they can make a complaint when things go wrong.
• Carrying out reviews of customer support levels on a regular basis and addressing any issues identified in a timely manner.
• Reviewing any actions take in relation to customer support to make sure that these changes achieve the required outcomes.

Vulnerable Customers

Select Car Leasing are committed to treating all customers fairly and in line with this we have a policy on Vulnerability. Our policy sets out guidance for our staff around vulnerability to ensure we act with appropriate levels of care for any customers who are identified as being vulnerable. Please email our compliance manager directly should you wish for further information or wish to see a copy of our policy - stevetongue@selectcarleasing.co.uk