It is important to embed the treating customers fairly ethos into every aspect and function of the business. An internal or external audit of your company should find that TCF flows through every area.  From product design and policy development, through to post-sale customer service and beyond.

You should be able to demonstrate employee knowledge, positive actions and business processes that engage with the 6 TCF outcomes. Outcome 1 means that TCF is a corporate culture and not just a tick box exercise. How customers are thought about, product suitability, effective communication and ongoing monitoring should be easy to evidence and evaluate.

The key words for TCF Outcome 1 are transparency and evidence! The only way to ensure compliance and instil consumer confidence is to prove you are doing what you say you are. Assess, analyse, review, evidence, repeat. A corporate culture of treating customers fairly means every process, every function, every action.

Outcome 2 is about defining your target market for every new or existing product. Consider who the product has been made for and how the target group of consumers will benefit from it. Also identify any product risks and target group vulnerabilities.

With TCF Outcome 2, the focus should be on ‘designed to meet the needs’. If products in the retail market are generic, such as a home insurance policy, is there enough flexibility in the product? Can it be tailored to meet the customers’ individual needs? In addition, ensure that you identify and define who the consumers are within the target group who may be vulnerable and need additional support.

Your processes should prevent mis-selling and tactics that promote an environment of ‘just getting the sale’. This means building effective and fair employee incentive schemes that focus on suitability and customer needs. Document and evidence how you have identified target markets and how you have accessed or contacted the people in those groups. Ensure that all targeted marketing is appropriate, ethical, clear, fair and not misleading.

Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.

TCF outcome 3 is all about your materials, communication and customer contact. It spans the whole customer journey, from product development through to post-sale and is a key regulatory requirement. All forms of communication must have customer awareness and knowledge at their core.

From basic contact and company information, through to terms and conditions and mandatory disclosures. Outcome 3 may appear simple, but it is anything but! B2C relationships can span years and involve vast amounts of communication and contact materials. Furthermore, what is suitable for one customer may not be appropriate for another. Ongoing reviews and revisions of all forms of customer communication is essential.

• Is the content clear, concise and easy to understand?
• Are any charges, interest or fees clearly defined, appropriate and applicable?
• Do you confirm all sales information in writing?
• Does the customer have multiple ways to contact you?

Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.

Not all firms who are regulated by the FCA will be providing advice to their customers. However, a large percentage will and if this applies to your firm, it is essential that any advice given is in the customers best interests. Outcome 4 focuses on all staff working in a role that sees them giving advice being trained, supported and knowledgeable.

Staff should have access to the necessary information essential to their role as an advisor. they must also have clear reporting lines and a program of continuous professional development for their learning and training needs. A skills gap analysis can form part of this employee assessment.

Providing advice to consumers must only be done within the remit of the relevant regulations and only by suitably qualified staff. Training is the key to Outcome 4, alongside good records management and ongoing employee assessments.

Outcome 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.

TCF outcome 5 means delivering on what your firm has advertised and promised that its products provide. Simply put, your products need to ‘do exactly what they say on the tin’! Customers should not be getting any surprises or unexpected outcomes during or after purchasing any product from you.

Outcome 5 revolves around continual product quality management, monitoring and auditing. Ensuring that products are measured against specific business objectives and still meet the needs of the target market. Gaining customer feedback is an excellent way to ensure products are meeting the needs and expectations of your target consumer group.

Customers who are unhappy do not always tell you about it! More often they will seek out a competitors product or leave a negative review. Word of mouth can do wonders for a businesses reputation. However, it can also do a lot of harm when what is being said is that your business and products do not do what you say they do! Audit, assess, measure, review and then do it all again – constantly.

Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Outcome 6 relates to post-sale barriers and making it simple for concerns to be raised. A customer wanting to switch products or raise a complaint is not a negative thing. More often than not it means that your processes need reviewing and revising. If a customer is not happy with something or feels a different product would be better, could it be that it was not suitable to start with?

Firms put a lot of effort into ensuring that introductory and sales processes are simple, straightforward and easy to access. However, the same cannot always be said for post-sale functions. It is essential to provide customers with multiple ways and formats for communicating with you after a sale. Questions and concerns can often be addressed and resolved quite easily if your staff are properly trained to communicate with customers.

Information that should be readily available to customers are ways to contact you, telephone numbers, email addresses, your physical address, complaints procedure and any regulating bodies. These should be provided on your website and in all correspondence made to the consumer. You should also avoid barriers such as no-reply email addresses and premium rate only numbers.