SYNERGY AUTOMOTIVE LTD TRADING AS SYNERGY CAR LEASING 

TREATING CUSTOMERS FAIRLY & CONSUMER DUTY

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.

This remains a core part of Synergy Automotive’s culture and is now complemented by the FCA’s Consumer Duty, which sets higher standards of consumer protection.

Synergy Automotive Ltd is fully committed to TCF and this policy demonstrates its application of TCF during the course of its day to day activities. TCF is embedded throughout its policies and procedures, including although not limited to:

• Employee Training
• Financial Promotions Policy
• General Data Protection Regulation Policy
• Complaints Handling Policy
• Record Retention Policy
• Management Information for Senior Management

Consumer Outcomes

The FCA has specified six treating customers fairly outcomes that firms should seek to achieve for their customers:

  1. Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture. Our customers are at the heart of our business, and we take the time to listen to them and understand their needs.
  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. We make sure that we match the right product to our customers individual requirements. As well as making clear the benefits of the product, we highlight any risks or considerations that may need to be taken into account.
  3. Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale. We ensure that all documentation before, during and after the sale is clear, straightforward and sent to our customers in a timely manner.
  4. Where consumers receive advice, the advice is suitable and takes account of their circumstances. We make sure we understand our customers requirements as well as their individual circumstances so that we can offer suitable, clear advice.
  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. All of our customers receive written information about their leasing agreement prior to commitment. In addition, our Account Managers, Client Services Team and other members of staff are aware of and are compliant with FCA regulations.
  6. Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint. We ensure all our customers are treated fairly and with respect. Furthermore, our complaints policy is displayed on our website and in our Initial Disclosure Documents and any complaints are dealt with promptly and satisfactorily, with any future learnings taken into account.

Synergy’s Culture

The FCA believe there are six areas of management behaviour that can influence a firm’s culture of customer treatment:

  • Leadership: all managers should make clear in their practices and communication that the fair treatment of customers is fundamental to the firm’s operation. Controls and monitoring should be applied to other staff. Daily morning meetings take place with the sales account management team, Client Services, Marketing, Compliance, Data and Finance teams to incorporate a TCF culture and going the extra mile.
  • Strategy: the firm can articulate a clear vision featuring fair treatment of customers. Strategic decisions – such as change management and outsourcing – reflect the centrality of customers to the firm’s future. Risk levels should reflect customer concerns and feedback. Regular monitoring and feedback of Feefo reviews are cascaded through the team to highlight strengths as well as any learnings which are shared with the team.
  • Decision-making: at all levels, decisions should reflect on the fair treatment of customers. Feedback from staff, customers and other external sources should be used, where appropriate. This Management Information (MI) should feed into properly balancing customers’ interests against shareholders and other stakeholders. Monthly management meetings take place where MI is discussed including complaints data, sales performance data, customer reviews, business KPIs and other feedback.
  • Recruitment, training and competence: Staff selection should reflect the importance of customer treatment to the firm. Management should then train and maintain staff knowledge, behaviour and values to accord with fair customer treatment. Managers should also reward good staff performance in this regard and act on poor performance. A thorough recruitment process takes place for new employees, which includes multiple interviews. A full comprehensive induction plan is implemented as part of our on-boarding process and ongoing training programmes embed both TCF and Consumer Duty principles.
  • Reward: The firm’s reward framework (such as incentives and bonuses) should be transparent, recognise good quality and support the fair treatment of customers. In other words, firms should not concentrate on sales, volumes and profit without considering quality and controls to mitigate this risky framework. A full time Compliance Manager is employed by the business to monitor a selection of calls marked against a Compliance balanced scorecard, which is fed back to the management team. This ensures that key information has been communicated to the customer and all processes followed. In addition, Sales Account Managers are required to undertake a completion call after delivery to ensure the customer is satisfied with their vehicle and the service from Synergy. This must be logged on our internal system in order for the transaction to be counted against their targets.
  • Controls: The firm should have controls that reflect the fair treatment of customers. These should be integral to the firm’s risk framework. These controls are seen in Compliance monitoring, MI and Feefo reviews.

Assessing and Implementing our TCF Principles

  • Synergy’s marketing and financial promotions are developed to ensure that they are appropriate for the target audience and are presented in a clear, fair and not misleading manner. They are also reviewed and signed off as approved by the Compliance Manager.
  • Communication of the application process, key details of the product and disclosure of the customer’s rights are provided in a number of formal documents before and after the customer enters into an agreement. There are no hidden terms, conditions or fees and they are written in easy to understand language. Quotations and order forms are presented in a format which are easily legible and understood.
  • All calls are recorded for quality and training purposes so customers can be confident that any conversations can be relied upon at a later stage if required.
  • Our customers view of their leasing experience with Synergy Automotive is important to us so we work with independent feedback company - Feefo to gain feedback. We also monitor our Net Promoter Score (NPS) within Feefo. Feefo is reviewed regularly in Sales Meetings, responded to and any learnings taken into account in future decision making.
  • We take our customers’ data seriously, and ensure all staff are trained to keep our customers’ details secure and confidential.

Vulnerable Customers

Synergy’s practises are developed to ensure vulnerable customers are identified in a timely manner and the service provided is appropriate for their circumstances. All customer-facing employees are aware to gain explicit consent to record information if possible and pass through to the relevant department or finance provider.

Staff Awareness and Training

TCF is already instilled in the culture of Synergy. Synergy ensures its teams are trained and competent in order to provide our service to the level of satisfaction the client expects. In addition, all teams are provided with internal training on the fundamental principles of TCF, including BVRLA e-learning modules.

Complaints

Synergy Automotive’s Complaints Policy is clearly displayed on our website and is also detailed in our Initial Disclosure Document.  We aim to deal with complaints swiftly in accordance with FCA rules, and as a member of the BVRLA, we have access to a conciliation service if required.  All complaints and queries are logged and the outcome noted in the Complaints Log, which is reviewed and analysed in Management Meetings.

Management Information

Management Information (MI) is vital for firms in analysing trends and assisting in identifying and solving any problems which are identified. Firms should use it to monitor customer treatment, expectations and outcomes.

This information – whether anecdotal or quantified – should be active rather than merely reactive. It should identify future risks rather than just dealing with known problems and should be acted on as required.

MI has no purpose if it is not used, and firms can improve their service and business performance with good MI. How the firm uses and collects MI is down to the directors and senior management of the firm.

Types of Management Information

Management Information can come in many different forms of which some common types are:

  • Training and competence requirements in accordance with the Senior Manager’s & Certification Regime (SM&CR)
  • Customer feedback
  • Complaints analysis
  • Compliance reports
  • Response times
  • Cancellations

The FCA expects firms to make use of suitable MI to monitor and measure their achievement of the 6 customer outcomes.

Principles of good Management Information

Management Information (MI) is information that is collected during a period of business activity. It may be about customers, staff, calls, visits, meetings, sales, opinions, parts of a process, predictions etc. MI is not just numbers. Quantitative data is valuable to any business, but commentary or opinions are also MI and can help provide a comprehensive, balanced view. All information relevant to a firm, from whatever source, can be described as MI. Good MI should enable management to make good decisions.

Synergy Automotive produces Management Information (MI) to assess its performance against TCF principles.  In order to ensure the business makes informed decisions to continue to treat our customers fairly, the MI is accurate, timely, consistent and relevant.  The MI is regularly reviewed by the Management Team and in Account Management Team meetings, and includes analysis of sales data and other types of information.

Consumer Duty

Consumer Duty sets higher and clearer standards of consumer protection across all financial services, with a focus on good outcomes for retail customers. . The Consumer Duty came into force on 31 July 2023 for new and existing products and services. The Consumer Duty applies to the regulated activities and ancillary activities of all firms authorised by the Financial Conduct Authority (FCA).

What is the Consumer Principle?

The Consumer Principle is a higher standard of customer protection where firms are required to act to deliver good outcomes for retail customers. This Principle 12 sets a higher level of standard and care than previously set out through the ‘Treating Customers Fairly’ Principle. The Consumer Duty is underpinned by the concept of reasonableness.

What are the Cross-Cutting Rules?

The Cross-Cutting rules define how firms should act to deliver good outcomes to retail customers:

  • Act in good faith towards retail customers
  • Avoid forseeable harm to retail customers
  • Enable and support retail customers to pursue their financial objectives

What are the four outcomes?

The four outcomes give more guidance to firms on key areas of Consumer Duty

  • Products and Services
  • Price and Value
  • Consumer Understanding and
  • Consumer Support

How does Synergy ensure it meets the requirements of Consumer Duty?

Synergy has undertaken a comprehensive review to ensure that the company meets the requirements of Consumer Duty as part of the Consumer Duty implementation plan.  Synergy also undertakes annual reviews to ensure the standards are still met and maintained, as well as daily, weekly and monthly data monitoring.

Meeting our Consumer Duty requirements includes but is not limited to:

Staff training on Consumer Duty requirement, with the requirements being driven by the board of directors and throughout the organisation.  It is also considered as part of the recruitment process.

Ensuring fair value for our customers through a focus on the four outcomes of:

Price and value – offering fair value and support services throughout the lifecycle of the product for our customers

Product and services - meeting the needs of our  target market and understanding the needs and requirements of our individual customers

Consumer understanding – ensuring our customers understand the nature of their leasing agreement and are given the right information through clear communications to make informed decisions at the right time.

Consumer support – supporting our customers throughout their leasing journey, meeting the needs of customers with characteristics of vulnerability and allowing for appropriate friction points. 

It is everyone’s responsibility in the organisation to ensure that customers receive good outcomes.

Conclusion

Synergy’s culture is and has been throughout the years in line with the outcomes specified by the FCA’s TCF initiative. In addition, Synergy frequently reviews its policies, procedures and practices to ensure that TCF remains an integral part of the business. Synergy asks its clients to provide feedback through an independent provider, Feefo, so that the firm can improve its service. The information collated from clients can be reflected in company management information and is regularly reviewed by senior managers and the management team to help shape any strategic decisions.