What is Treating Customers Fairly (TCF) 

The concept of Treating Customers Fairly is a regulatory initiative from the Financial Conduct Authority (“FCA”) and results from the core Principles for Business, specifically Principle 6, which states, “A firm must pay due regard to the interests of its customers and treat them fairly”. There are other FCA Principles that also apply to a firm’s dealings with its customers: -

Principle 1
“A firm must conduct its business with integrity”.

Principle 7
“A firm must 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”.

Principle 8
“A firm must manage conflicts of interest 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 judgment”.

GHC Wealth Management Limited (“GHC”) is committed both to a positive Compliance Culture and to our customers. The purpose of this Policy is to outline the ways in which GHC implements, demonstrates and evidences this commitment.

The FCA has in addition formally defined six customer outcomes, which explain what they require of firms to achieve fair treatment of customers:

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 to the retail market are designed to meet the needs of identified customer 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.

Embedding TCF principles throughout GHC Wealth Management

GHC is committed to developing a positive culture of compliance within the company and expects all of our employees to incorporate TCF into their everyday activities so that the principle becomes ‘business as usual’. We have aimed to assist all of our employees in complying with their obligations by incorporating regulatory requirements into procedures manuals and integrating responsibility for compliance into Line Management’s normal supervisory duties.

GHC is committed to delivering the best possible service to our customers. In order to fulfil our commitment to treating our customers fairly we will focus on the following areas:

Adviser and Staff Training and Competence – We ensure that all advisers and staff are appropriately versed on all of the fundamental principles of TCF. In addition, where applicable, advisers and staff are comprehensively trained in order to suitably advise on and efficiently provide our services. We ensure that all TCF training is kept up to date in order to take account of market and regulatory changes.

We operate a robust Training and Competence Scheme. This is to ensure that all of our advisers and staff achieve the necessary qualifications and training in order to carry out their job functions with the required competence level. Within our Training and Competence Scheme we implement stringent monitoring and assessment of our advisers so we can be certain that they remain competent for their respective duties.

Communication – All communications with customers will be made in an open and transparent manner.

Complaints - GHC strives to provide the very best level of customer service. We deal with customer complaints in a fair and objective way including compensation where necessary. All complaints are recorded by our Compliance Department and reported and analysed in Company MI and Board meetings.

Customer Service – We have in place set service standards for our customers so they can be sure of the service level to expect from us.

Management Information (MI) – We use MI to ensure that our TCF commitment is being met. Good MI enables the management and directors of GHC to make informed business decisions in the best interests of its customers. Good MI should be accurate, timely, relevant and consistent.

Remuneration – We will not use incentives for advisers that reward behaviour which is inconsistent with the 6 desired outcomes. 

Suitability – All clients will be correctly classified to ensure they are offered the correct level of protection. All recommendations made to our customers will be suitable to their requirements and their investment objectives. In addition, all customers will be made aware and clearly understand the risks inherent with any service or product offered.

Authorised and Regulated by the Financial Conduct Authority. FCA Number 598291.
GHC Wealth Management Limited. Registered office: 22 - 30 Horsefair Street, Leicester, LE1 5BD. Registered in England number 05917020.

© Copyright 2019 GHC Wealth Management Limited. GHC Wealth Management Limited is a subsidiary of GHC Group Limited.