Treating the

Customer Fairly

Our Approach towards Fair Treatment, Conduct Risk and Good Outcomes (Consumer Duty)

We will pay due regard to the interests of our customers and treat them fairly, acting in their best interests at all times.

We will act to deliver good customer outcomes by acting in good faith, by avoiding causing foreseeable harm to customers, and by enabling and supporting customers to pursue their financial objectives.

Giles Insurance Consultants specialise in the provision of cost-effective insurance packages and personal lines for all types of cover including Commercial Insurance. 

What fair treatment means to us:
In practice, we will endeavour to ensure that we:

• Offer our customers the best product(s) that we can, which are suitable for the target market that they represent, and which provide fair value
• Provide a first-class service for our customers
• Handle complaints sensitively, doing our best to resolve concerns and mistakes as quickly as possible
• Show customers consideration, empathy and flexibility
• Are clear, fair and not misleading in all our communications with customers
• Exhibit transparency and clarity in all customer dealings
• Give the customer what we have promised to provide
• Never give priority to the interests of the firm over the interests of the customer
• Do not take advantage of the customer
• Can be measured against common standards 
  

Our policy

Control and Supervision

Giles Insurance Consultants focuses on a particular program of insurance from which there is no divergence. The Owner, Mr Neil Giles, and Business Manager are located in the same open office. ‘Demands and Needs’ are checked on a regular basis. If necessary, customers are contacted a second time for any clarification of information.

Clear presentation of Quotations

Each quotation includes a clear ‘Key Facts’ Summary, Schedule of Insurable Values clearly stating any special conditions (alarm/security requirements, flat roof warranty, deep fat frying provisions etc.), Terms of Business Agreement, Statement of Facts/Proposal.

Disclosure Information Procedures

Are in place to ensure all disclosures are made in sufficient time for clients to make informed decisions about a purchase particularly prior to renewal. We will also ensure that Demands and Needs and Suitability Statements reflect a full and personal assessment of the customers’ needs and those customers are advised to read the documentation, particularly the Policy Summary. In the Interests of ‘Contract Certainty’ every effort is made to issue formal policy documents within 30 days of the inception of cover or receipt of completed Proposal, if appropriate. See Privacy Policy. 

Training & Competence

All staff will be suitably trained on all products they deal with, understand customers’ requirements and are competent to carry out their jobs and provide the best possible service to our customers.

Sales

We will ensure that all staff advising the customer, are competent to do so and that their competence is checked regularly.

We will provide customers with ongoing levels of service and support that meet the standard of the services provided at point of sale including sufficient, easy to understand information, in a timely manner, to allow them to make informed decisions.

We will retain appropriate records of customer instructions and profiles and of the options/advice given to customers before, during and after a sale.

Where appropriate, we will make contact with customers to correct or improve upon the service already provided;

We will regularly review the products sold and the distribution strategy applied to them to ensure that they are continuing to offer fair value. Where it is identified that products are not offering fair value, these will be removed from sale or suitable action taken to resolve the issue;

We will ensure the culture of Consumer Duty is embedded in all levels of the firm and regular training is provided. 

Financial Transparency

In all quotations administration fees are clearly stated, as is insurance premium tax together with the basic premium. Our Terms of Business also sets out the basis of our remuneration.

Remuneration Strategy

We have a remuneration policy in place. In simple terms none of our insurance professionals receives commission as part of his/her remuneration package. We therefore ensure that the risks of any inducements that are potentially unfair to our customers are removed or the risks recognised and minimised and that the interests of the firm are never given priority over the interests of the customer;

Unfair Inducements

In any event all volume over riders, placement service agreements and corporate days will be assessed to determine whether they are ‘likely to conflict to a material extent with any duty the firm owes to its customers’.

Insured’s obligations

Duties of disclosure, the implications of any breach of warranty or policy condition are highlighted in any offer we make to you.

Offering a fair cost-effective deal

We recognise the reality that customers seek best price for the cover they need. We ensure that the quality of cover offered is first class and strive to achieve the lowest price for that cover. We never trade elements of cover against premium.

Management Information and Meetings

We will also capture, collate and analyse timely, informative and relevant management information to monitor the effectiveness of our fair treatment strategy. We will act on this information to investigate any indications that we may not be achieving fair treatment of our customers. We will resolve any identified deficiencies as soon as is possible. 

Advertising and Promotions

We have a robust procedure is in force to ensure that financial promotions are FCA and Advertising Standards Authority (ASA) compliant. We will also monitor the application of such procedures. We will ensure that all sales material, promotional material and advertising material is clear, fair and not misleading, compliant, jargon-free and provide a balanced picture of the product or our service. We will endeavour to identify and understand our target audience to ensure we treat them fairly.

Conflicts of interest

We will do all we can to minimise conflicts of interest and promote an open and blame free culture to encourage reporting of all potential situations. Where appropriate, any conflict of interest will be disclosed to you as a customer.

Complaints Handling

We will handle all complaints in an open and honest manner, aiming at all times to settle complaints in an amicable and timely means. We will ensure that customer complaints are assessed fairly, promptly and impartially. We welcome all customer comments and use them as a learning tool. In no instance will the party at whom the complaint is directed handle ‘the’ complaint. Levels of redress or ex-gratia payments, where offered, will always be fair to the complainant.

Accounts

No payments of client credits and claims under scheme business will be delayed unnecessarily.

Systems and Controls

We have in place suitable senior management arrangements, systems and controls that will ensure that, at all times, the interests of our customers are given top priority and all areas of the business have this principle embedded in them.

Vulnerable Customers

We ensure that vulnerable customers are identified and given suitable support to ensure that their needs are consistently met, that they are not disadvantaged, and that they achieve outcomes at least as good as the firm’s other customers;

And lastly, in the interest of full transparency we send this charter to each and every customer.

The success of this policy is dependent upon the total commitment of everybody in the company and our belief that the customer comes first in everything we do.

If you feel we have not fulfilled the obligations either in the setting up of your policy or the handling of any claim please contact our Consumer Duty Champion on 01628 667707. We need you to tell us if there are any issues and your call will be welcomed and appreciated.

Disclosure of the status of premiums paid to us is clearly set out in our ‘Terms of Insurance Business’. Customers can be reassured all premiums paid to us are held as Agent for the Insurer (or the Insurer’s Agent) under what is termed ‘RISK TRANSFER’. This means that money paid to us is deemed to have reached the Insurer. For information the FCA CASS rules do not apply to monies held solely under RISK TRANSFER. More information on this is available from http://www.fca.org.uk

We are committed to ensuring that the FCA’s Consumer Duty Principle and the Customers’ Best Interests Rule is applied in all areas of our day-to-day business activities, not simply to satisfy regulatory requirements but as an integral part of our business ethos.