Our Treating Customers Fairly (TCF) policy is designed to ensure that we consistently deliver fair outcomes to our clients’ customers and take responsibility for the company and staff at all levels. This is done by providing an enhanced service quality, based on a culture of openness and transparency. 

In adopting the TCF principle we recognise that fair treatment of our client’s customers is about adding value to the service we offer by aiming to: 

• Ensuring that marketing material is clear, compliant, jargon free and appropriately targeted
• Ensuring that sales staff have thorough training on all services they promote, understand who they are and are not suitable for, and are encouraged to challenge where they spot inconsistencies, ambiguities or potential unfairness in any literature or service features
• Operating sales remuneration systems which assure fairness to the customer as well as customer satisfaction, rather than only rewarding sales volumes
• Finding procedures to encourage non sales staff to implement TCF in their day-to-day business activities
• Keeping detailed records of instructions and profile / attitude to risk, and of the advice and options given before, during and after a sale – to help ensure we treat customers fairly and can respond to any complaints that may arise promptly and fairly
• Encouraging post sales contact where appropriate to correct or improve on the service already provided
• Ensuring that customer complaints are assessed fairly, promptly, and impartially, and in line with Financial Conduct Authority regulations
• Encouraging staff to recommend improvements to service following customer complaints, and monitoring the outcome
• Ensuring that staff are kept up to date with relevant training in relation to competence, data protection and other matters directly affecting the quality of service offered to customers
• Offering regular training in the principle of TCF at all levels of the business
• Regularly monitoring and reporting on all of the above TCF activities as part of CC33’s monthly statistics / Management Information, in order to assess TCF performance across the business and recommend changes where appropriate
• Ensuring that TCF values, which are set and communicated by senior management, are supported by all staff, and understood in the same way