Treating Customers Fairly (TCF) & Consumer Duty Policy

Policy Statement

As an FCA-regulated broker, we are committed to treating customers fairly and delivering good outcomes in line with Principle 12 (Consumer Duty) and the overarching Treating Customers Fairly (TCF) framework. We place customers at the heart of everything we do, ensuring they receive products and services that meet their needs, offer fair value, are clearly understood, and are supported throughout their lifecycle.

Regulatory Background

The FCA’s Consumer Duty came into force on 31 July 2023 and enhances the existing TCF principles through four key outcomes:

1. Products & Services – Products must be designed to meet the needs, characteristics and objectives of target customers and be distributed appropriately.
2. Price & Value – Customers should receive fair value for the price they pay.
3. Consumer Understanding – Customers should receive the information they need, presented clearly, so they can make effective and timely decisions.
4. Customer Support – Customers should receive appropriate support so that they can enjoy the full benefits of the product or service.

Our Commitments

Product Governance

• We act as a credit broker, not a lender.
• We work with reputable UK funders who are responsible for designing products suitable for their target markets.
• We undertake our own periodic product reviews to ensure alignment with the needs and characteristics of our customers.
• We only distribute products where we believe we can achieve fair customer outcomes.

Fair Value

• We regularly assess charges and commission against the benefits provided to customers.
• Our pricing remains transparent, competitive and reflective of the market.
• We balance commercial viability with customer value to ensure fair outcomes.

Consumer Understanding

• All customer communications (digital, written and verbal) are clear, fair and not misleading.
• We present key product information, risks, fees and exclusions in plain language.
• We tailor communications where necessary to meet any vulnerabilities or reasonable adjustments required.
• We monitor communication effectiveness and adapt where needed to improve customer understanding.

Ongoing Customer Support

• Our relationship continues after agreement inception, with access to responsive customer support for the duration of the product.
• We proactively assist customers who may become vulnerable, experience difficulties, or need additional help to manage their agreement.
• We aim to resolve issues quickly and efficiently to minimise disruption to the customer.

Vulnerable Customers

We recognise that some customers may be vulnerable due to personal circumstances. These may affect their decision-making or ability to manage financial products. We train staff to identify potential vulnerability and offer additional support to ensure all customers receive fair outcomes.

Monitoring & Review

• We carry out regular compliance monitoring, including reviews of product performance, communications, complaints, and customer outcomes.
• We maintain documented records of product reviews and decisions made under Consumer Duty.
• This policy is reviewed annually — or sooner should regulations, business practices or customer needs change.

Escalation & Responsibility

The Board has ultimate responsibility for Consumer Duty. Day-to-day implementation lies with Senior Management and all staff are required to follow this policy. Any concerns around consumer outcomes must be escalated to the Compliance Officer immediately at info@ecovehicleleasing.com