Treating Customers Fairly

At Belmont Vehicle Leasing, customer service is a passion of ours and part of the ethos of the company since we were founded in 2016.

Linked to our service levels is the act of Treating Customers Fairly (TCF), which is one of the principles set out by the Financial Conduct Authority (FCA).

Below we cover what TCF means and how it will impact your dealings with Belmont Vehicle Leasing. There are 6 outcomes which have been identified by the FCA as the core features of TCF, these are:

Outcome 1:
Consumers can be confident that 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 both 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.

What does this mean for you?

Belmont Vehicle Leasing adopted the idea of TCF right from the outset of our formation in 2016. Therefore, you can expect the following when dealing with us:

We listen to our customers and assess their needs and requirements on an individual basis.
Any information provided by us is stated clearly and accurately to ensure there is no ambiguity or misleading of our customers.
All pricing is clear and transparent, both on the website and on any quotation or documentation you may receive from us.
We are open about any fees we may charge or receive in our Initial Disclosure Document.
We will remain in contact throughout the product life-cycle to ensure everything is okay and providing answers to any queries you may have.

How do Belmont Vehicle Leasing intend to continue Treating Customers Fairly?

TCF is a continuous process which evolves with the needs of our customers as well as with any changes within the industry. The following are ways in which we meet these requirements in the day to day running of our business:

We continually aim to understand the needs of our clients
We ensure that the marketing of our products is appropriately targeted, clear, not misleading and highlights the risks/conditions as well as the key features/benefits of a product.
We make certain our clients understand the risks associated with our services at the outset of an instruction.
We keep our clients fully informed in a clear and fair manner that is unambiguous and not misleading.
We ensure our services are delivered with clarity and transparency and do not contain hidden conditions or rely on complex technical definitions.
Any advice provided will be appropriate and take into account the customer’s individual needs and circumstances.
We take our clients’ privacy seriously and ensure that our staff are aware of and follow rules in relation to data protection to ensure that clients’ details are kept secure and confidential.
We take any complaint seriously and will deal with any complaints promptly and make improvements to our operations where required.

What to do if you feel you haven’t been treated fairly?

A key point in our adherence to the philosophy of TCF is how we treat our customers in the event of a complaint.
If you’re not happy, full details of our complaints procedure can be found on our website.

Vulnerable Customer Policy

Belmont Vehicle Leasing has established clear and effective policies and procedures for identifying and dealing with vulnerable customers. These are first identified through the underwriting process.

Generally, a person is considered to be vulnerable if it would be unreasonable to expect them to be able to deal with a problem themselves. There is no legal definition of a vulnerable person, but the National Standards for taking control of goods says this could include:

older people
disabled people
the seriously ill
the recently bereaved
single parent families
pregnant women
unemployed people
those who have obvious difficulty in understanding, speaking or reading English.
people with mental health issues.

Under TCF outcome 6, staff must ensure that vulnerable clients are not presented with barriers preventing them from obtaining advice and transacting business. Staff should take appropriate steps to assist vulnerable clients.

This may include:

Recommend that they are accompanied at interviews.
Conduct more meetings than usual to ensure understanding is fully confirmed and demonstrate appropriate care of this type of client.
Provide documentation in bigger print or change the style of correspondence to suit the understanding of the client (Braille, larger print etc).
Provide them with advice to seek further help.
Refer them to a debt agency such as Citizens Advice Bureau

Definition of ‘consumers in vulnerable circumstances’

A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.
The most significant detriment occurs when people, using consumer credit, get into unmanageable or problem debt This can often lead to spiralling problems, leading to both financial and non-financial costs.

Breaking this down further, the FCA has identified the following characteristics and circumstances that it views as ‘vulnerable’;

Personal characteristics

Communications needs – lack of English Language skills
Restricted mobility-caused by physical disability or sever or long-term illness
Resource limitations
Low basic skills
Low literacy, numeracy and financial capability skills

Personal circumstances

Mental health problems e.g. depression / anxiety, bi-polar disorder
Memory problems e.g. age, dementia
Life events e.g. bereavement, illness
Poor financial situation
Niche requirements e.g. example, health conditions, legal status, etc.
Being young (associated with less experience)
Being ‘older old’ for example over 75, although this is not absolute (may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill- health, not being comfortable with new technology)
Non-standard requirements or credit history (e.g. armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants)

Our approach

Our priority is to provide our clients with an excellent service. We aim to treat our entire client bank fairly and deliver high quality services which meet and exceed their expectations throughout their relationship with us.

We understand the need for “fair and appropriate treatment of customers, who the firm understands or reasonably suspects to be particularly vulnerable.” (CONC 7.2.1) There are a number of key expectations which the FCA require from regulated companies when dealing with vulnerable clients:

Have appropriate policies in place to identify consumers in vulnerable circumstances
Policies to approach consumers in vulnerable circumstances in a sensitive and flexible way
Be as transparent as possible in their dealings with consumers in vulnerable circumstances

To ensure expectations are met we will ensure;

All employees will be given initial training in identifying and dealing with vulnerable clients
All employees will be provided with ongoing training and regular updates to ensure employees continue to implement our policies
Support to individuals in relation to identified risk and vulnerability
To provide means of reporting any instance where they believe that a client might be in a vulnerable circumstance

Conclusion

Belmont Vehicle Leasing’s culture is in line with the outcomes stipulated by the FCA’s Treating Customers Fairly initiative. However, we will frequently review our policies, procedures and practices to ensure that Treating Customers Fairly remains a crucial part of our business.