Treating Customers Fairly Policy

Last Updated: 31 May 2020

Introduction
1. The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) initiative is primarily based on the obligation set out in Principle 6 requiring a firm to pay due regard to the interests of its clients and treat them fairly. PollenPay is fully committed to TCF and this Policy has been designed to demonstrate the application of TCF during the course of our day to day activities.TCF is embedded throughout the FCA’s Handbook and PollenPay supports the TCF initiative and satisfies the FCA’s six core consumer outcomes which explain what it wants TCF to achieve for consumers. These are:
  1. Consumers can be confident they are dealing with firms where TCF is central to the corporate culture.
  2. Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and targeted accordingly.
  3. Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
  4. Where consumers receive advice, the advice is suitable and takes account of their circumstances.
  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.
  6. Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
Our TCF Principles
1. 1. Customers will be provided with clear information and kept appropriately informed before, during and after the point of sale.
  2. Our level of service and product performance will meet the expectations of our customers as far as reasonably possible.
  3. We will ensure that there is no barrier for customers to express their requests, concerns or complaints, and will always be responsive to them.
  4. Products and services will be designed to meet the needs of clients.
PollenPay aims to deliver the FCA’s TCF outcomes in the following ways:
1. 1. 1. The responsibility for ensuring that TCF is implemented in the systems and culture of PollenPay lies with the Board of Directors of PollenPay.
    2. Senior managers and staff are responsible for ensuring that TCF outcomes are effectively managed within their area. This includes working to ensure that everyone in PollenPay understands how to deliver the TCF outcomes.
    3. We will ensure that there is no barrier for customers to express their requests, concerns or complaints, and will always be responsive to them.
    4. PollenPay aims to demonstrate the achievement of TCF objectives in regular reporting under the FCA’s Senior Management Systems & Controls arrangements. This reporting is also subject to monitoring by PollenPay’s compliance & legal team.
    5. PollenPay aims to describe clearly the different products it offers, including their aims, objectives and other features, to ensure customers understand the approach, risks and costs involved.
    6. The TCF requirement applies to all PollenPay staff and this is made clear by inclusion in the induction programme for all new employees, and a statement in the PollenPay Staff Handbook, supported by regular communication with all staff.
    7. Where PollenPay delegates an activity which impacts its customers or other third parties, to a regulated company or otherwise, PollenPay looks to ensure that the principles of TCF are maintained by that delegate. It also arranges to receive regular feedback on the TCF activities of its third party administrators and to ensure that they have access to appropriate technical information and literature concerning PollenPay products and services.
    8. PollenPay aims to act consistently with applicable guidance around TCF from the FCA and, where appropriate, other industry bodies.