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Treating Customers Fairly (TCF)

How Swiss Vans Achieve Treating Customers Fairly

How we achieve this

We have considered all areas where we consider a risk or have used examples that other companies have found a risk and assessed each potential situation. Our actions will ensure that the Unfair Treatment of Customers is eliminated or kept to a minimal risk and that we monitor those areas. We also conduct surveys with our customers to provide best practise and identify new areas .

Why we have a policy
The policy has been written to communicate to thos working within our firm to deliver the best possible service to customers. This is in the interests of customers and staff alike.

TCF Outcomes These are the outcomes that regulators want fro customers and the outcomes we want for ourselves in order to provide a better service.If customers are disatissfied then we will take immediate action

1. If you deal with Swiss Vans you can be sure that treating customers fairly is part of our culture 2. Products and services used , sold and marketed are targeted to meet consumer needs. 3. Consumers are provided with clear precise information before during and afte r the point of sale 4. Advice is suitable for consumers circumstances 5. Products will perform as we claim, and the service is of a level that we have indicated. 6. We will not impose unreasonable barriers to change a product, a service provider or make a complaint.

Action Plan The way we will actively measure our performance is each area is as follows

Client Feedback We actiavely promote client feed back from the initial enquiry through to delivery and beyond. All lost sale customer receive and automated survey to give feedback.
During the sales process, we ask customers to fully review the new, used or vehicle modification document to ensure that the product matches their needs and that we have correctly identified their needs. We actively encourage Trustpilot Ratings in a transparent manner.

Real Time Staff Monitoring
Sales staff are subject to monthly monitoring in the course of the sales process using a backend CRM and call recording. An manager checks that customers are dealt with. All sals staff are subjected to weekly meetings to ensure compliance and to aid with sales. The meetings also serve to identify issues as they arise and take action accordingly.

File Audits
We have a regular file audit programme taken out by an independent consultant, who assess the clarity of the information provided and the suitability of our products offered to clients. Information gained is immediately fed back to Swiss Vans to report our failings

Advertising and Promotions Checking
All our own advertising and the website is checked by our Marketing Executive and signed off by the MD or Sales Managers to ensure clear non misleading advertising.

Remuneration Policy
Our policy of remuneration of sales and support staff will include Key Performance Indicators in compliance, training, and competence and treating customers fairly. The monitoring ensures that no pressured selling occurs, nor inappropriate methods. All staff are subject to an annual assessment to assist outcomes 1,3,4,5 and 6

Business Reviews
We conduct quarterly business reviews in which changes procedures and marketing strategies are considered and the impacts on our customers.

Statistics
We will review sales and persistency figures split by provider, product and advisor on a monthly basis to monitor any trends that emerge If an unusual pattern of change is noticed we will investigate this and take out corrective action, and document findings, to address outcomes.

Training and Competence Regime We will record our training competency procedures to ensure advisors have up to date knowledge of products in which they are involved. We will ensure regulatory standards are met to satisfy CONC requirements to address Point 4

Customer Concerns
We keep a log of all customer concerns and a summary response of the outcome.
Where the complaint is directed at a supplier or provider we will investigate and take the appropriate action

Continuous Improvement
Where specific issues arise we will add this to our policy where things come to light

Client Understanding We need to know how much knowledge customers have of our products

Risks
Assumptions such that customers already know our products could lead to a lack of clarity and confusion, and this in turn offer the wrong products that could have a negative impact on their fiscal wellbeing in the future tense. We cannot assume that a customer understands the agreement .

Systems
We will endeavour that simple terms and language is used to clients to facilitate their understanding and shall seek a clear process to ensure that the correct products are offered. To clearly point out cancellation rights and encourage customers to ask questions

Controls We monitor the suitability of what we recommend by undertaking internal file audits for compliance and quality. The results are subject to management meetings and business reviews. Reviews should be clear, features explained including exclusions and limitations. Descriptions of options if appropriate e.g Affordability vs Financial Commitment showing a risk warning If features are not present these need to be reported as a training issue

Complaints Risks
If a customer complains and does not receive a satisfactory outcome we are risking a poor business reputation. Obstructing complaints fails to treat customers fairly. Staff who are not familiar with this or do not follow procedure may mislead customers as to their rights.

Systems
Complaining customers must be treated seriously, and dealt with in accordance with the prescribed procedure and “Soft “ complaints that do not involve financial loss or material distress or inconvenience be rectified as soon as possible .

Staff must read and sign off the complaints training materials provided every 12 months and whenever personnel involved or changes made by the regulator of governing body. A copy is made available for staff to refer to and given to customers
on request.

Controls
We have an appointed complaints manager who will investigate any complaints made and act accordingly, looking for the root cause. All staff to be signed off for complaints training forming part of their appraisal and competency Addressing 6

Regulatory and Legal changes We need to keep up to date with legislation, regulation and best practise within the consumer credit sector in order to serve correctly

Risks
If we continue to suffer compliance failures we jeopardise our authorised status and this will impact on the business and the service of existing clients. Consumer regulation is usually brought in to make improvements so failure to adopt these measures could lead to a decline in services offered to the customers in comparison to the competition.

Systems
Our compliance officer ensures that legal updates are noted by undertaking professional development, subscribing to trade publications and reading literature from our providers and business partners. Changes as necessary .

Controls
Compliance issues are a standard topic in our business agenda.

Remuneration Policy
How we pay staff and contractors, how we appraise performance and what we reqrs with pay incentives

The Risks
A focus on items such as sales targets might lead to mi selling and poor record keeping and lack of diligence

Systems
The firms systems that relay on performance related pay is designed to reflect our commitment to complaint practices and treating customers fairly. Salary and bonus should not be dictated purely by sales performance. Also are customer retention, suitability and delivery within timescales .

Controls
Compliance performance is monitored by file audit reviews and business reviews. Review results feature in staff appraisals and key performance indicators, record keeping and used when reviewing pay and bonuses.

Management Information
This is the quantitative and qualitative information that we use when reviewing our business strategy and performance

The Risks
Failure to product accurate, timely and clear information will hinder us in identifying trends and to identify issues

Systems
The key to the information we provide is our back office recording system This is kept up to date and accurate We are looking for indicators such number of new enquiries, speed of service provided, level of conversions and lost sales

Controls
Record keeping is a key performance indicator.

Strategic Change
How we consider the effects of any strategic decisions made

The Risks
Customers may be adversely affected every time a change is made to the firm e. New Telephone or computer system Changes or other failures in the business can cause less hours being devoted to customer care within the business.

Systems
The management team ensure a business plan is in pace to anticipate these strategic changes. Controls If there is a major change in the business its necessary to clarify every staff members role and position to avoid panic to continue business without disruption. Conflicts Of Interest Means a financial or time involvement that conflicts with the service provided by an individual or create an unfair advantage

The Risks
If our interest conflict with those of a client for client detriment Close links with another group Higher commission rates or incentives placing orders with a particular provider such as gifts or incentives Or where customers may be involved in conflict with each other

Systems
We make sure all our services are independent of providers and do not create a tie to specific provider We record gifts or hospitality Any conflicts declared

Controls
Our files and audits will reveal the split of providers used so we can investigate any
abnormalities . Staff are aware of our policies and ensure customers needs are placed first . If a conflict of interest is noticed between clients we make them aware and let them choose

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