Treating customers fairly

VIP Gateway ensure customers are at very heart of all that we do. We are fully committed to providing the highest standards of customer service and advice.

Where we have alluded to "customers" in this policy, we refer to all third parties connected with the sale.

Our customers are our most valuable asset, and our aim is to ensure we deliver a user-friendly, robust, reliable, and cost-effective service to all concerned.

As a part of our overall approach, we are fully committed to treating our customers fairly and as such we endeavour to meet their expectations of high-quality service.

Our Treating Customers Fairly (TCF) policy is centred around the guidance provided by the Financial Conduct Authority (FCA) to ensure we consistently deliver fair outcomes to our customers and take responsibility for both the Firm as an organisation, and our staff (at all levels) providing an enhanced service quality to customers, based on a culture of openness and transparency.

As a firm, we take the requirements of the FCA seriously, in particular, the requirement to treat customers fairly.

This policy should be read in light of Principle 12, the Consumer Duty, and the firm's own Consumer Duty Policy, being particularly mindful of the Consumer Understanding and Consumer Support outcomes and the cross cutting rules.

Staff are required to complete the Declaration of Understanding at the end of this policy once they have read and digested the content.

FCA's Consumer Duty

The FCA published its policy statement and final guidance on the Consumer Duty in July 2022 (links below), and guidance for credit brokers on implementing it in March 2023. The new rules and guidance came into effect in July 2023.

FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty (fca.org.uk)
PS22/9: A new Consumer Duty (fca.org.uk)
Implementing the Consumer Duty for Credit Brokers (fca.org.uk)

The Consumer Duty comprises of an overarching principle, Principle 12, three cross-cutting rules and four outcomes. The Consumer Principle (PRIN 12) requires firms to "act to deliver good outcomes for retail customers"

This is a higher standard than both Principle 6 (pay due regard to the interests of customers and treat them fairly) and Principle 7 (pay due regard to the information needs of its clients and communicate information to them in a way which is clear, fair, and not misleading).

The 3 cross-cutting rules set out how firms should act to deliver good outcomes for retail customers. They require firms to:

• Act in good faith towards retail customers

• Avoid causing foreseeable harm to retail customers

• Enable and support retail customers to pursue their financial objectives

These rules articulate the standards of conduct that the FCA expect under Principle 12. These rules also inform and are supported by the four outcomes which set out more detailed rules in key areas of the customer relationship. The four outcomes are:

• Products & services

• Price & value

• Consumer understanding

• Consumer support

The 4 Outcomes / The Cross Cutting Rules (diagram)

Quality of Products and Services
Price & Value of Products and Services
Consumer Understanding
Consumer Support

→ Act in good faith
→ Avoid causing foreseeable harm
→ Enable & support retail customers to pursue their financial objectives

Each outcome should be measured against the cross cutting rules

We aim to ensure that Principle 12 is embedded in our approach to dealing with customers, and that the cross-cutting rules and 4 outcomes are core principles in the way we conduct business.

FCA's Treating Customers Fairly Outcomes

The FCA has outlined six key themes which are central to our TCF initiative:

1. Customers should be confident that they are dealing with firms where treating customers fairly is embedded in the corporate culture.

2. Services marketed and sold are done so with the aim that they meet the needs of customers and are targeted accordingly.

3. Customers should be provided with clear information and are kept appropriately informed before, during and after the service provision.

4. Where advice is provided, it considers a client's individual circumstances.

5. The service provided is of an acceptable standard.

6. Customers do not face unreasonable barriers to make a complaint.

We have set out how we aim to ensure these principles are embedded in our approach to dealing with our customers.

Treating Customers Fairly is a core principle of our company and the way we conduct our business.

Central to our Treating Customers Fairly ethos is our commitment to providing clear and concise information, free of "jargon" and written in plain English. For further information see our Financial Promotions Policy and Consumer Duty Policy.

Our Core Principles

The core principles of our "Treating Customers Fairly" Policy are as follows:

1. We are an organisation which holds the fair treatment of our customers as central to our corporate culture.

2. Products and services are designed to meet the individual needs of our customers and are marketed in accordance with CONC 3.

3. Our customers are provided with clear information and are kept appropriately informed before, during and after the finance has been arranged.

4. We will ensure that deals suggested to customers are suitable for their needs and take account of their individual circumstances, having obtained an understanding of their requirements.

5. Customers will not face unreasonable post-lending arrangement barriers imposed if they find the product is not fit for purpose and wish to make a complaint or access any other post-sale support.

6. We will ensure that any complaints or grievances are managed in a sympathetic, positive, and professional manner and in line with the DISP rules.

7. We will ensure that members of 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.

8. We will offer its staff regular training in the principles of TCF as and when appropriate, ensuring continuing professional development by encouraging reading of the trade press, FCA website, newsletters, and dissemination of relevant information as and when it becomes available.

Our Service

• We ascertain the appropriateness of the requested service for all new customers prior to accepting a deal, ensuring it is in line with their knowledge and experience.

• We continually aim to understand the needs of our customers.

• We aim to keep our customers 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.

• We will keep an accurate and comprehensive record of all our dealings with a customer, so that in the event of any dispute or discrepancy, we will be able to provide a full breakdown of exchanges between all parties.

• We make certain our customers understand the risks associated with our services at the outset of an instruction, where appropriate.

• We work hard to ensure that service and risk information remains clear and prominent at all times.

• In the unlikely event that there is a conflict of interest, we will inform our customers as soon as possible once we become aware of it.

Our Approach

Our priority is to provide our customers with an excellent service underpinned by quality and choice.

Our service is shaped by listening to our customer's needs and understanding what is important to them. We take responsibility for meeting the needs of our customers and always look for ways to improve the quality of our service.

We aim to treat our customers fairly and deliver high quality services which meet their expectations throughout their relationship with us.

We recognise that everyone at VIP Gateway is critical to creating a positive client experience and ensuring our customers are treated fairly. Our culture and values encourage and support any staff to deliver this.

All staff will have training in dealing with our customers, and in treating them fairly.

Complaints Handling

We respond in a timely manner to our customers' and prospective customers' questions and queries and address any issues or concerns promptly. All customer complaints are dealt with and escalated as appropriate and as required by us in order to meet our obligations to our customers. How we manage these is further detailed in our Complaints Policy and Procedure.

Our policy is in line with the current guidance from the FCA and is in line with the principles of the FCA that "a firm must pay due regard to the interests of its customers and treat them fairly".

The Directors of VIP Gateway, pay attention to the outcomes of complaints, which can serve as an important source of intelligence about the health of our business and systems. We will investigate the root causes of complaints and obtain feedback from customers who have experienced our complaints process in order to improve the level of service that we provide.

We will measure the length of time taken to deal with a complaint, the outcome, and the way in which the outcome is communicated to the customer in order to ensure that we are treating our customers fairly.