The Morebo group of companies (Morebo) has a strong focus on customer fairness and satisfaction. Our mission is to be a respected and well recognised financial services provider and our Treating Customers Fairly (TCF) policy is an integral part of that objective. Our TCF policy is structured according to the guidance provided by the Financial Services Conduct Authority to ensure that we consistently deliver fair outcomes to our clients. We take responsibility for ensuring that all of our representatives and staff members provide an enhanced quality of service to our clients, based on a culture of fairness and transparency.

The six fairness outcomes:

Morebo will strive to comply with and contribute to the TCF fairness outcomes, viewed from the perspective of the customer:

• Outcome 1: Customers are confident that they are dealing with providers where the fair treatment of customers is central to the provider’s culture;
• Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of an identified customer group and are targeted accordingly;
• Outcome 3: Customers are given clear information and are kept appropriately informed before, during and after the time of contracting;
• Outcome 4: Where customers receive advice, the advice is suitable and takes account of their circumstances;
• Outcome 5: Customers are provided with products that perform as their provider has led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect;
• Outcome 6: Customers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim, or make a complaint.

Achieving the outcomes:

Morebo will aim to demonstrate through our behaviours and monitoring that we are consistently treating customers fairly throughout the stages of the product life cycle. These may include:

• Product and service design: Products and services and their distribution strategies are designed and developed for specific target markets, based on a clear understanding of the likely needs and financial capability of each customer group;
• Promotion and marketing: Products are marketed to specific target groups, through clear and fair communications that are not misleading and are appropriate to the target group;
• Advice: Where advice is provided, our representatives are fully equipped to provide advice that is suitable to the needs of the customer concerned, following the objectives of TCF and avoiding conflicts of interest;
• Point-of-sale: To provide clear and fair information to enable customers to make informed decisions about transacting with Morebo, our products and services. Product risks, commitments, limitations and charges must be transparent;
• Information after point-of-sale: To provide customers with on-going relevant information to enable them to monitor whether the product or service continues to meet their needs and expectations, and provide acceptable levels of service for post-sale transactions or enquiries.
• Complaints and claims handling: To honour representations, assurances and promises that lead to legitimate customer expectations. Legitimate expectations must not be frustrated by unreasonable post-sale barriers. There is a requirement for fair and consistent handling of claims and a mechanism to deal with complaints timeously and fairly.

In order to fulfil our commitment to treating our customers fairly we will focus on the following aspects:

• We will follow the requirements of the FAIS General Code of Conduct as embedded in the FIA Code of Conduct;
• We will adhere to our Conflicts of Interest Management policy in dealing with customers;
• We will put management information mechanisms in place that are designed to monitor and measure our representatives’ and staff’s performance in delivering the relevant fairness outcomes;
• All our members of staff are trained to deal with our clients and are committed to maintaining high standards of service;
• Our staff are not remunerated or incentivised in ways which encourage them to deal with our clients in an unfair or biased manner;
• We will always tell customers what they can expect from our relationship;
• We will provide appropriate after-sales information and service to customers;
• We will monitor the continuing performance of products that we have recommended and sold to customers to assess the on-going suitability of the product for the customer;
• We will ensure open communication lines with product suppliers we deal with and ensure that we understand their products and services;
• We will review our TCF Policy on an ad-hoc basis but at least annually.

Complaints handling:

• We will handle complaints fairly, promptly and impartially;
• In dealing with complaints we will ‘treat like situations alike’ and give careful consideration to whether an error might have affected a wider class of customers; and what should be done to remedy this;
• We will 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.

Treating Customers Fairly in our business:

• We encourage and welcome feedback from staff and customers on our services and procedures;
• Staff objectives include TCF as an explicit and measurable objective, and performance against this objective will form part of staff competency ratings;
• All staff will complete refresher training and testing on an ad-hoc basis;
• Before we contract with a third party we will satisfy ourselves of their commitment to treating our customers fairly. In particular, we will consider their TCF Policy and the management information that they can provide to demonstrate the fair treatment of our customers;
• Our complaints process will be clear and easy to understand.

For any queries or feedback in relation to Treating Customers Fairly at Morebo you can contact us at the following numbers or addresses:

Morebo