Confidence for customers

We’re committed to bringing financial security, as best we can, to our customers.

Our customers - whether they’re individuals, companies or institutions – need to be assured that the products and services they buy from us deliver the promises we have made to them. Customers also need to be able to confidently say that they were fairly treated during the sales process and can trust our actions.

Customers want the confidence that:

  • The product they buy will do the job we said it would.
  • We will be able to resolve any issues if they are not happy with our product or service.
  • The financial services organisation they’ve entrusted their money to is financially stable.

Our teams are dedicated to making sure we constantly refine what we do – making customers feel confident that we’re delivering our promises to them in everything we do.

Our Management Approach

Our Group policies and procedures underpin the commitments we make to our customers and investors. They set out the minimum standards and procedures that ensure effective management and control of our business. The policies are mandatory and it’s our responsibility that they are followed.

We have two senior committees whose primary function is to consider customer concerns and issues; the Conduct Risk Committee, and the Equalities, Diversity and Inclusion Committee.

Our compliance policies outline how we expect our business to be conducted. Current policies include:

  • Inducements. This sets out how we should act when any benefits are offered to us as individuals or as a company.
  • Conflicts of interest. This helps us make sure we identify and manage conflicts to prevent any adverse impact on our customers.
  • Complaints. This helps clarify the standards we expect employees to follow when delivering outcomes to customers. Complaint trends are monitored, reviewed and acted on in each business area and also at a quarterly complaints committee attended by senior business management.
  • Provider/distributor. This sets out how responsibilities for relationships should be established and maintained with the aim of delivering consistently fair outcomes for customers.

Our internal audit team reviews these policies and reports back on effectiveness in operation.

Designed for customer need

Our product life-cycle management sets out the standards we require, and the approach we follow when designing, launching and managing products, propositions and funds.

This complete framework covers areas including how we predict stress and scenario testing (analysing what could happen during a financial crisis), customer research and understanding who would benefit most from our products - including guidance on running customer operations and regulatory risk assessments. Our management guidance focuses on how we review product risks once they’ve been launched to make sure they are still suitable and relevant for customers. 

Each business division is responsible for products once launched.

Communicating with customers in a way that is clear, fair and not misleading is at the heart of our business. Our advertising standards team ensures we communicate with customers correctly and accurately – complying with regulatory rules, UK advertising codes and ensuring that funds are performing in a way that continues to be right for customers.

By having these procedures in place, we can promise that the products customers buy, advice they receive and their choice of funds are all fit for purpose.


All employees are expected, through extensive training, to understand and deliver our internal governance framework. This includes compulsory computer based training on:

  • anti-bribery and corruption
  • complaints
  • data protection
  • Financial crime.

Measuring progress

The relationships we build with customers are crucial to our success – always look to learn as much as possible so that our service is always helpful and provides value.

Examples of how we measure our relationship with customers include:

  • Culture. Are we customer focused in everything we do, from setting our strategy to servicing our customers? Do we quickly put things right when things don’t go to plan?
  • Quality. Did customers receive quality advice when the product was sold?
  • Product performance. Is the product doing its job?
  • Service performance. When in contact with customers, do we deliver good service?
  • Conduct. Is our business performance meeting the expectation of auditors and regulators?

Publication of complaint data

Every year, the UK’s Financial Ombudsman Services publishes a report reviewing our business. The report shows the number of customers that ask for an independent review of a complaint decision made by us, compared to our peers.

Vulnerable customers

Our insight into the needs of vulnerable customers helps us create products and investments which help people through difficult times. We liaise with charities and social enterprise experts to help guide us on how we can improve. In 2015 we delivered a number of initiatives relating to how we deal with vulnerable customers:

Our ‘Vulnerable Customer Policy’ is for employees, but is also shared with stakeholders, regulators and government so we are able to gain feedback on its focus and development.

1 in 4 customers have vulnerabilities

We conduct surveys with employees to help them to understand customer vulnerabilities. These surveys focus upon how well our employees are able to handle different situations and where they need training – information collected helps improve our employees’ knowledge and understanding of how to deal with vulnerabilities.

Recent research showed that 1 in 4 interactions with customers identified vulnerability.

Training our employees

Group wide information on our intranet provides employees with “How to” guides from external experts. These on-demand learning modules help employees prepare in advance for discussions with customers.

Organisations that helped train our employees in certain areas:

  • Ageing Population with Elderly Accommodation Counsel
  • Alzheimer’s and Dementia with Alzheimer’s Research UK
  • Flooding with the RNLI and Warrior Programme
  • Debt Awareness with Step Change
  • Terminal Illness with Marie Curie
  • Dealing with Disability with New Horizons
  • Tax help for older people with retirements on customers on low incomes and smaller pension pots.

Having ‘Critical Friends’ review our business

We have increased the number of charity sector professionals – known as ‘critical friends’ - who help us review our existing products and services offered to customers.

We will continue to use these surveys and consult with ‘critical friends’ to help improve our service, processes and innovate new products.

Read more in our CSR Report.