Treating Customers Fairly


'Treating Customers Fairly’ (TCF) is a key principle that the Financial Conduct Authority (FCA) expects all regulated firms to pay attention to and achieve certain standards. Achieving fair and positive customer outcomes is central to our company culture and approach. We hope that by publishing this policy our customers and partners can clearly see what is important to us as a company. 

This policy aims to document our approach to TCF regardless of whether the customer has purchased from us or not. 

As a company we aim to ensure that we: 

  • Set the best possible culture that is built around TCF 
  • Provide a framework that all staff can apply when making decisions that affect customers 
  • Meet the TCF guidelines and standards set by the FCA, our industry trade body, the British Vehicle Rental and Leasing Association (BVRLA), and our partners 

What is TCF

Six consumer outcomes to ensure customers are treated fairly 

The FCA requires regulated and authorised firms like ourselves to achieve the below six consumer outcomes to ensure the fair treatment of customers: 

  • Outcome 1: Consumers can be confident 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

Our company culture 

It is extremely important to us that we have a company culture that promotes staff helping customers make the right decisions for them and achieving good customer outcomes at all times. 

We seek to create and maintain a TCF focused culture and therefore we: 

  • Lead by example and promote an ethical approach to decision making 
  • Seek to avoid, as far as possible, any conflicts of interest between the interest of our company and the interests of our customers
  • Recruit staff that we believe will have the customer at the heart of what they do 
  • Empower & train our staff to understand how their role affects the fair treatment of customers and how they too can empower customers to make the right decisions 
  • Support staff with the right tools to provide customer service that responds to the needs of our customers and embed a continuous improvement approach where we seek feedback and opportunities to improve our services
  • Ensure that our company ethos is understood so that all staff are on the same page 
  • Promote that staff should feel confident to flag and raise issues to senior management 
  • Build a strong and customer focussed management team 
  • Design our products, services and communications with our customers in mind
  • Consider the customer when we set internal targets 
  • Ensure staff have access to this policy and other relevant policies

Ensuring good outcomes for all customers

We are committed to ensuring the fair treatment of all customers and recognise that some customers may be in vulnerable circumstances which affect how they engage with us and how our services impact them. 

To ensure that we achieve good outcomes for all vulnerable customers, we: 

  • Understand the needs of our customers and the impact vulnerabilities can have on their customer experience
  • Have an Affordability Policy on our website and encourage customers to consider the affordability of the scheme
  • Make sure our staff have the right skills and capability to recognise and respond to our customers and their particular needs
  • Train staff on vulnerable customers and ensure they understand how to provide good outcomes for different customers
  • Respond to our customer needs via our service delivery, ensuring that the customer experience and communications work for all customers
  • Monitor and assess whether we are meeting the needs of our customers and continue to make improvements to ensure that we are providing good outcomes for all customers 

How we ensure our customers are treated fairly

Customer experience 

We have a dedicated customer operations who focus on customer feedback and complaints. From a customer feedback perspective, we aim to collect as much feedback as possible from our customers. 

To achieve this, we: 

  • Invite customers to provide feedback at any stage of the process
  • Provide formal feedback opportunities at different stages of the process (i.e. over email)
  • Analyse feedback received and join it with complaints data so that we can continually improve our processes  

Staff understanding and incentives 

We work hard to make sure our staff are making the right choices for our customers. To do this, we:

  • Ensure staff have access to this policy 
  • Encourage staff to ask questions in relation to our policy and discuss any uncertainties with their line manager or senior management 
  • Ensure sales staff maintain standards linked to TCF in order to achieve an incentive 
  • Do not incentivise staff to sell one product over another 


Leadership & management 

We are conscious that leadership is critical to ensuring that we deliver this policy well. 

To achieve this, we:

  • Have an experienced and customer-focussed team that believe in our company ethos and treating all customers fairly
  • Have dedicated customer facing staff focussed on turning bad outcomes into positive ones 

Customer complaints 

We are focussed on turning bad outcomes into positive ones. We believe in making it easy for customers to make a complaint as this is an opportunity to learn and put things right. 

To achieve this, we: 

  • Ensure that our complaints process is clearly sign posted on the footer of our website 
  • Make it easy for complaints to be submitted such as by email, phone or in writing 
  • Encourage all staff to log every complaint received so that we can deal with the issue professionally 
  • Encourage staff to flag issues raised in customer complaints or queries so that we can quickly respond and improve our services