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Treating Customers Fairly Policy

Version: 1 –

  1. Purpose

    This policy details how Complete Finance Management Ltd (the Firm) will manage its obligations to treat customers fairly and ensure a consistency of approach within the Firm.

    The Firm will meet its obligation to conduct itself ethically by properly managing any potential conflicts of interests of its customers.

    The Firm is authorised by the Financial Conduct Authority (FCA) and, as such, will act in accordance to the Principles as defined in the FCA Handbook, which will take precedence over the requirements of this policy.

  2. Review of Policy

    This policy will be reviewed regularly, at least once a year, and amended as considered necessary by the Firm’s Management Body in the event of changing circumstances or regulations.

  3. Responsibilities

    1. Management Body Responsibilities

      The Management Body of the Firm are responsible for ensuring that the culture of treating customers fairly is embedded within the Firm and is central to the Firm’s practices.

      1. Culture

        The Firm takes its responsibilities towards its customers seriously and as such has ensured that a culture of treating customers fairly starts with the Management Body and is cascaded down through the Firm.

        Fair treatment of customers is central to the behaviour and values of the Firm and senior management are able to articulate what the fair treatment of customers means for their Firm and communicate this to all employees.

      2. Strategy

        When determining a strategy the Management Body has aligned its vision and values with the fair treatment of customers at the forefront of the process.

        The Firm sets out their objectives and risk appetite to reflect a consistent approach to treating customers fairly and appropriate resources are allocated to ensure that actions that ensure fair treatment of customers agreed at the planning stage are delivered.

    2. Employee Responsibilities

      All employees are expected to read and understand and accept any policies and procedures that relate to how the Firm expects customers to be treated in order to ensure fair outcomes.

      All employees are expected to adhere to the Conduct Rules applicable to their roles, including the rule that states You must pay due regard to the interests of customers and treat them fairly.

  4. Treating Customers Fairly

    The Firm has reviewed each outcome and has documented how such an outcome may apply to the business and how it will evidence fair outcomes for its customers.

    Outcome 1: Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture
    The Management Body have approved this policy and made it available to employees to ensure that they are aware of their obligations
    Remuneration structures have been designed to discourage behaviour that could result in poor outcomes
    Training has been made available to all employees on understanding TCF obligations
    Complaints will be closely examined to identify any TCF failings and actions taken where appropriate
    Information provided to customers for onward transmission to their customers will be designed to meet the information needs of that customer group
    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
    The firm will take into account the information needs of the underlying customer when developing marketing and distribution strategies for our products and services
    Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale
    Our terms of business does not use ‘jargon’ and takes the information needs of our customers into account
    Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances
    The firm has a robust suitability process in place which is subject to rigorous monitoring
    Outcome 5: 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
    The information provided to our customers regarding our product and service will be sufficiently detailed to ensure that the underlying customer is able to understand how their products / services are performing
    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.
    Complaints procedures have been put in place by the Management Body
    There are no onerous post-sale or exit penalties applied where the customer wishes to withdraw or change provider
    1. Management Information

      The Firm must be able to measure the effectiveness of its policies and obligations to treat customers fairly through Management Information (MI). Where deficiencies are noted, the Management Body must demonstrate that they take positive steps to address them and ensure that no customers were disadvantaged.

    2. Conflicts of Interests

      The Firm has implemented a separate Conflicts of Interest policy that sets out how the Firm intends to identify and manage the risks arising from conflicts of interest. Where a conflict is identified as likely to cause a poor outcome for customers, the relevant actions will be taken by the Firm.

  5. Recruitment

    The Firm’s recruitment strategy takes into account the previous conduct and behaviour of potential employees. Where there are indications that a potential employee may have participated in poor outcomes, further references will be obtained and the outcome will be considered in any decision to offer a contract of employment.

    Potential employees will be questioned on their experiences of ensuring good outcomes where it is relevant to the role.

    1. Remuneration

      In line with its Remuneration Policy, the Firm operates a remuneration structure that is transparent and recognises the fair treatment of customers.

    2. Training and Competence

      Management make positive behaviours and attitudes towards the fair treatment of customers as central to how it conducts its business and this is encouraged through effective training and maintenance of staff knowledge.

      Any training must embed the concept of Treating Customers Fairly within the corporate culture and competence assessments should ensure that the concept is fully understood and implemented. Management will have effective controls in place allowing them to identify and act on poor customer outcomes and ensure that good outcomes are encouraged.

  6. Customer Communications

    In its communications with customers, the Firm does not promise to or imply that they are able to provide services that they are not able or equipped to deliver.

    Our communications take into account a customer’s information needs and is set out in such a way as to ensure that customers are able to clearly understand the nature of the service that is provided to them by the Firm and the markets in which the relevant regulated entity dealing with that customer operates in.

    Customers must be able to fully understand the Firm’s terms, conditions and charges therefore the tone and content of the communications will take into account the likely level of understanding displayed by its customers. Similarly, the Firm will apply the necessary procedures to ensure that its customers fully understand all costs and charges that they may incur.

    The Firm will communicate with its customers in an open, transparent and easily understandable manner.

    1. Financial Promotions

      All non-real time financial promotions are reviewed and must be signed off before hand by the director to ensure balance and conformity with the Financial Promotion rules, i.e. fair, clear and not misleading.

    2. Complaints

      Customers must be able to understand the Firm’s complaints procedure, which must be clear, unambiguous and impartial. The opportunity to refer their concerns to the Financial Ombudsman Service must be clearly stated where the customer is an eligible complainant.

      The Firm will ensure that the service offered to a customer is not negatively influenced by a customer’s complaint and customers ca be assured that their complaint will be investigated fairly and objectively.

      All complaints are recorded and the outcomes monitored with management information analysed by the Management Body to identify any endemic issues within the Firm.

  7. Breaches of Treating Customers Fairly Policy

    Any breaches of the Treating Customers Fairly rules will be recorded on the Firm’s breach log in conjunction with its Regulatory Breach procedure.