Terms of Business


All of us involved in insurance broking and related businesses understand that much of what we do is governed by 11 fundamental principles that in turn translate into a very large FCA rule book. In the last 2 or 3 years we have revised many of our documents and procedures to comply with these rules, for example in the way we conduct sales and the way we handle and keep client money. You help us maintain compliance by adhering to our procedures.

You may have heard recently that the FCA now wants to reduce the detailed rule book. Instead it wants regulated firms to individually interpret the governing principles in the context of their business operation and create their own way of dealing with them.

It will, of course, take some time to achieve this transition, but the process has already started with Treating Customers Fairly. This is actually FCA Principle 6, fully defined as:

A Firm must pay due regard to the interest of its customers and treat them fairly

There is a lot more to this than meets the eye. The FCA is saying that Firms must put customers at the heart of their business and as a result help build consumer confidence in the industry. Of course, it means that we must continue to provide good customer service and respond positively to any complaints, etc. and by following our procedures in these respects you will be helping us to ensure continuing compliance.

However, it is also important that you understand the deeper responsibilities that this Principle places on us and the actions being taken by our directors / managers in these respects. We have carried out a gap analysis of where we think we are against a comprehensive listing of ‘fairness’ standards. (As a result we have made further changes to our policies and procedures, and these have been communicated to you separately). We must now continuously monitor our performance against the following:

1. We believe that fairness is central to our business.

To help substantiate this we have developed a TCF statement: We define fairness as:

Providing excellent customer services to our paying customers. Maintaining high service levels and a platinum service to all our customers! OnClaims prides itself on reputation and efficiencies within our company.

2. Our products are only sold to people who need them.

3. Our customers are provided with relevant, accurate, timely information, and kept properly informed throughout the whole relationship process, including after the sale.

4. When we give advice it is suitable and takes the clients circumstances into account. When we do not give advice the customer knows this.

5. Our service delivery, and that of insurers, is as expected by the customer.

6. Customers can easily claim, complain, make changes, cancel and move at renewal.

Whilst directors and managers are charged with ongoing monitoring in these respects, staff views and feedback will be critically important. TCF will, therefore, form a standard agenda item in our team meetings but staff should make any concerns known to Amanda Turner at any time.

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