Introduction

The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) initiative is primarily based on the obligation set out in Principle 6 requiring a firm to pay due regard to the interests of its clients and treat them fairly. CIRCA5000 is fully committed to TCF and this Policy has been designed to demonstrate the application of TCF during the course of our day to day activities.

TCF is embedded throughout the FCA’s Handbook and we support the TCF initiative and satisfy the FCA’s six core consumer outcomes which explain what it wants TCF to achieve for consumers. These are:

• 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 acomplaint.

Our TCF Mission Statement

We will act with integrity 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.
• We will not give advice to our customers. Where they seek advice from us we will recommend that they seek independent financial advice from a regulated and qualified advisor.
• Our level of service and product performance will meet the expectations of our customers as far as reasonably possible.
• We will ensure that there is no barrier for customers to express their requests, concerns or complaints, and will always be responsive to them.
• Products and services will be designed to meet the needs of clients albeit we do not give advice as to suitability.

Assessing and implementing our TCF Principles

Marketing

All CIRCA5000’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.

Sales, Advice, Management

We ensure that our clients have ready access to Key Investor Documents both before during and after any transaction.

We classify all our clients correctly to ensure they are offered the appropriate level of protection. Investment and asset allocation decisions are regularly reviewed by the relevant committee.

Post-Sale Information and Support

CIRCA5000 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

CIRCA5000 has a number of policies and procedures that are relevant to the fair treatment of clients and also achieve adherence to FCA requirements, these are (this not an exhaustive list):

• Data Protection Policy

• Training and Competence Policy

• Complaint Handling Procedures

• Financial Promotions Procedures

Management Information

CIRCA5000 produces MI in order to assess its performance against TCF 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. CIRCA5000 produces MI reports which are reviewed regularly by senior managers, directors and board members in various committee meetings.

Awareness/Training

CIRCA5000 ensures that all advisers and staff 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 all of our advisers and staff 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 and staff so that we can be certain of their competence.

Compliance

CIRCA5000 has a compliance team who is independent and regularly monitors all key areas of regulatory compliance including TCF.

Remuneration

CIRCA5000 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

CIRCA5000 aims to provide excellent customer service and complaint handling is a major component of its TCF measures. We deal with customer complaints fairly and objectively and attempt to put things right as quickly as possible, 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 and committee meetings.

Conclusion

CIRCA5000’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, sometimes formally through customer surveys, so that we can improve our service. The information we collate from our clients can be reflected in company MI and reviewed by senior managers, directors and board members to help shape any strategic decisions.

March 2021