Our commitment to Treating Customers Fairly

When entering into a finance agreement our customers can be confident that we will treat them in the same way as we would expect to be treated in the same situation.

To simplify this we have split our Treating Customers Fairly (TCF) obligations into a number of key areas and added some key commitments to evidence why our customers can be confident that the principles of TCF are taken seriously within our business.

Culture

• We will ensure the principles of Treating Customers Fairly are embedded within the culture of Close Invoice Finance
• We will educate our staff on the concept of Treating Customers Fairly and what this means in practical terms
• We will make the concept of Treating Customers Fairly a regular part of our annual training programme
• We will ensure that our recruitment process reflects our commitment to and respect for our customers, their needs and requirements
• We will ensure individuals have the right skills to fulfil their stated role and implement a plan to address any identified gaps

Product design

• We will genuinely monitor all the products we sell to ensure they continue to meet a genuine need for our customers and are relevant to the finance agreements they support
• We will use feedback from our customers, administrators and sales staff to identify and drive improvements in the products

Financial promotions

• We will ensure that all Financial Promotions provide clear, understandable, relevant and up to date information
• We will ensure that our Finance Promotions take into account the subject matter and intended audience
• We will ensure that all Financial Promotions are reviewed and signed off by the correct individuals before they are published

Sales process

• We will provide adequate training to sales personnel across our range of products and services
• We will have appropriate sales monitoring controls in place
• We will operate remuneration strategies that minimise the potential for customers to be treated unfairly

Post sales

• We will endeavour to provide clear, understandable relevant and accurate information in all communications with our clients
• We will endeavour to ensure that all financial transactions are completed correctly and within the required timescales
• When we issue statements of information we will do so in a comprehensive format and timely manner
• We will regularly review the content of our communications to ensure its relevance
• We will endeavour to ensure that all client records are accurately maintained and protected
• We will endeavour to feed customer experiences learned from complaints into process improvements

Complaints

• We will encourage an open complaints culture across our business, where complaints are viewed positively and provide an opportunity to review and improve working practices
• We will ensure that viewing complaints positively is something that is continually reinforced by senior management
• We will ensure that a blame culture does not arise
• We will ensure all staff can identify complaints and how they should be dealt with
• We will encourage the identification of improvements to processes that could pre-empt complaints before they arise
• We will ensure that Regulatory rules are adhered to and prescribed deadlines are met
• We will endeavour to obtain as much information as possible in order to understand, investigate and respond to complaints thoroughly
• We will deal with all complaints on an individual basis whilst demonstrating consistency in our approach and decisions
• We will endeavour to provide clear, understandable relevant and accurate responses to complaints