Mountains

Treating Customers Fairly

This policy provides a general framework for ensuring customers are treated fairly.
Margetts recognises that customers’ trust and satisfaction and its reputation are essential to building a successful and sustainable company. Margetts is committed to ensuring that customers are at the heart of our business model and that our leadership, employees, products and processes are fit for purpose.
In addition, the regulator sets out explicit and implicit guidance for the responsibility of fair treatment of customers. PRIN 6 states ‘A firm must pay due regard to the interests of its customers and treat them fairly’.

    The regulator sets out six outcomes that regulated Firms should strive to achieve to ensure fair treatment of customers and these are core to the regulators expectations

    • Outcome 1: Consumers can be confident 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 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.
    • In addition, we consider our regulatory obligations under the FCA principles which interact with TCF considerations:

      • Principle 1: A firm must conduct its business with integrity. 
      • Principle 2: A firm must conduct its business with due skill, care and diligence. 
      • Principle 3: A firm must take reasonable care to organise and conduct its affairs responsibly and effectively with adequate risk management systems . 
      • Principle 7: A firm must pay due regard to the information needs of its clients, and communicate information to them in a way that is clear, fair and not misleading.
      •  Principle 8: A firm must manage conflicts of interests fairly, both between itself and its customers and between a customer and another client.
      •  Principle 9: A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement.

The Policy will be set by the Board of Directors (BoD) and will be based on achieving the six outcomes above.

The Compliance and Internal Audit Committee (CIA) will review management information (MI) to assess the Firm’s success in meeting the outcomes on a monthly basis focussing on areas outlined in the TCF Management Information Standard. The CIA shall report its findings to the BoD.

The Investment Risk Committee (IRC) shall review MI to assess the Firm’s success in meeting the outcomes on a quarterly basis focussing on areas outlined in the TCF Management Information Standard. The IRC shall report its findings to the Risk Committee, who in turn report to the BoD.

The Executive committee (Exec) will review MI to assess the Firm’s success in meeting the outcomes on a monthly basis focussing on areas outlined in the TCF Management Information Standard. The Exec shall report findings to the BoD.

Each manager has a responsibility to create and review MI, critically challenge the data where anomalies are suspected and report the issues where they feel that either data or feedback from team members indicates that customers are not at the heart of their processes.

The Compliance manager is responsible for training and competence of employees. All employees have a responsibility to put clients’ needs ahead of their own and ensure the client is at the heart of the processes that they are involved in.

All employees have a responsibility to whistle blow if they do not believe the Firm meets its regulatory responsibilities, as detailed in the Whistle Blowing Policy.

The Exec will assess standards and appropriateness of current controls and monitoring in achieving the TCF outcomes. The assessment will provide information to the BoD annually.

Each product will be designed to ensure that it contributes towards TCF outcomes as detailed in the Product Governance and Fund Launch Process Standards.

The IRC assess each product and its compliance with the prospectus at initiation and on an ongoing basis in line with the Scheme Risk Management Policy and the TCF Management Information Standard.

The Compliance manager has responsibility for ensuring that marketing, literature and information is in line with the prospectus, that it provides sufficient information and is clear, accurate and not misleading, as detailed in the Financial Promotions Standard.
The Exec will have responsibility for ensuring that each product meets a targeted need and represents value for money.

Each department will have processes that are consistent with the TCF policy and these processes will be documented and available to Compliance.

Managers will produce and review management information that helps them to identify performance trends in their areas of the business and identify unexpected anomalies. Data that indicates issues should be challenged and acted on to remedy the situation should be reported to the compliance team and to the Exec, CIA, or Risk Committee (RiCo).

The Compliance team will audit processes to ensure that processes either contribute to or do not conflict with TCF outcomes according to the Compliance and Monitoring Plan.
Sufficient MI will be produced by independent areas of the business, such as data management or compliance to mitigate conflicts of interest in department MI.

The CIA will review MI in line with the TCF Management Information Standard and Compliance Monitoring Plan.

HR will provide initial and annual training to all staff through the use of a desk-based training course.

The Firm has a Policy of Independence that stipulates that clients’ needs must be put ahead of the Firm and individual employees.

The Firm has a Conflicts of Interest Policy that sets out a framework for avoiding and managing conflicts of interest that may compromise or give the appearance of compromising the Firm’s ability to achieve TCF outcomes.

The Firm‘s remuneration policy will not reward behaviour that may compromise TCF outcomes as set out in the Remuneration Policy.

The Firm has a robust complaints procedure to help employees understand how to recognise a complaint and who they should report it to. The procedure sets out how complaints are handled, specifies timeframes for communication and remedial action.

Finally, all our staff are encouraged to bring any example where a procedure may not have resulted in a customer being treated fairly to the attention of their line manager or the Compliance team. Any incidents are investigated thoroughly and corrective action taken. A Whistleblowing Policy exists and there is a whistleblowing champion who is an independent nonexecutive Director. Their details are provided on the poster in the staff restroom.