About Us

Ensuring the Fair Treatment of Customers

The FSA has defined six consumer outcomes, which explain what they want TCF to achieve for consumers. Partnership have taken these outcomes and transposed them onto its business model.

Partnership, by its very nature as a specialist impaired life and enhanced annuity provider, conducts its business in a TCF manner. Its activities are also supported by a comprehensive TCF programme.

The fair treatment of customers within Partnership addresses the following key areas:

• Governance
• Product Design
• Consumer literature and Financial Promotions
• Sales processes and Care Fee Planning Advice
• After-sales information and service
• Complaints handling

This policy highlights the TCF measures and processes Partnership has in place. It illustrates the types of Management Information (MI) used to evidence our TCF responsibilities.

This MI has been collated to create an informed view of progress against each of the 6 consumer outcomes, which is reported to and scrutinised by the Board each month. 

This ensures that any TCF issues identified are considered at the highest level.

TCF Outcome 1: A fair culture

Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.

Partnership has developed a set of corporate values, which all staff should be aware of and core to these values is that ‘we put our customers and partners ‘FIRST’

• Fairness: Treat all clients, intermediaries and business partners fairly in all of our business dealings.
• Integrity: Act with integrity in matters of financial security and have the best interests of our clients at heart.
• Respect: Respect the confidence our clients and intermediaries place in us in dealing with sensitive issues.
• Service: Provide a first class service and to always deliver on our promises.
• Trust: Trust in our skills as leading experts in financial plans for people in ill health to deliver on our commitments.

Embedding TCF - how Partnership supports this outcome

• An internal set of value descriptors for FIRST which guide and inform our behaviour.
• We have appointed a Policyholder Liaison Representative from policyholders to help us ensure these principals are upheld.
• Job descriptions which state staff will remain compliant within both company and regulatory policy.
• Individual objectives specific to every staff member’s role to ensure TCF specific competence requirements are identified, monitored and achieved.
• Half yearly appraisals for every member of staff which include company specific objectives:
  o Demonstrates required behaviours and values to underpin TCF
  o Operate within TCF principles
• Training and development plans are actively encouraged for both compulsory and non-compulsory qualifications and personal development.
• Computer based training courses including a specific TCF course that all staff complete on an annual basis.
• Partnership product training modules that all staff complete.
• We seek staff views to identify whether there are any ways to improve the culture of Partnership.
• Comments and Questions section of the intranet allows staff to make suggestions to improve customer service.
• An Information and Consultative Council (ICC) has been established to discuss matters of mutual interest to include generally, the work environment and general conditions of employment, seeking wherever possible acceptable solutions regarding any problems collectively raised.
• Each department has its own TCF policy which describes how their behaviour/actions support each outcome relevant to their own work.
• Remuneration structures are consistent with FSA guidance and include appropriate Quality Assurance measures
• Each department within Partnership is subject to Systems & Controls Compliance monitoring programme to:
  o Ensure the department’s TCF policy is fully effective
  o Test the staff’s TCF awareness
  o Monitor the accuracy and relevance of departmental TCF MI
  o Ensure that each department has a robust governance arrangement
• The Executive Board and main board , on a monthly basis, assess whether customers are being treated fairly by reviewing Management Information. This is provided via a ‘RAG’ (Red, Amber, Green) status report based upon predefined parameters.  A variety of TCF areas are assessed to consider whether any remedial action is required.

Outcome 1 Management Information
Specifically the Management Information reviewed for outcome 1 includes:

TCF Outcome 2: Products and services

Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.

We believe our products are inherently TCF, by virtue of providing financial products for people with specialist needs, either a health condition or a lifestyle choice which may reduce their life expectancy.  Our experience in the specialist field of medical underwriting allows us to design and develop new products to meet the needs of our specific target audience.  The following processes actively incorporate TCF into the product design:

Embedding TCF - how Partnership supports this outcome

• Customer research is carried out prior to the development of new products to establish client needs and whether this product idea will meet those needs.
• Market research is carried out prior to the development of new Partnership products to check whether this product is already offered in the market and what enhancements can be made to make it more in line with our client’s needs.
• The Product design process will identify:
• Client needs and target market
• Known risks to the client
• Known risks to the company
• The complexity of the product
• Stress test performance against differing markets
• Any TCF considerations
• All consumer and broker material is subject to a comprehensive sign off process to ensure it is appropriate for the target market and sufficiently informative to ensure that authorised financial advisers fully understand the product.
• Post launch reviews are completed after the first twelve months following the launch of a new product/enhancement to ensure any issues are addressed immediately.
• Ongoing Management Information to ensure each product is sold to the target market where appropriate.
• On a monthly basis we track the number of cancellation and lapsed policies and complaints in this outcome category for all products so we are comfortable we are meeting outcome 2.
• While we do not currently offer a lifetime mortgage or home reversion plan, Partnership is a member of the trade body SHIP which means we incorporate SHIP principles in the design of our Equity Release products.  These SHIP principles are designed for consumer protection.

Outcome 2 Management Information

TCF Outcome 3: Clear information

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

Embedding TCF - How Partnership supports this outcome

We aim to provide our customers with clear information and ensure they are kept up-to-date as appropriate by:

• Having a strict marketing and advertising approval process to ensure all communications (including client letters) are clear, fair and not misleading, and comply with all the appropriate FSA, TCF and other regulatory considerations. This includes a system to ensure that only up to date and current literature is used.
• Sending newsletters to our policyholders.
• Regular emails and mailings to advisers to keep them up-to-date with product developments and changes in legislation.  Such updates are also held on our website which has a specific area for advisers.
• We have suitability guides for each product to aid the advisers in ensuring the right product/options are considered for the client.
• We review IFA feedback which is received from sales and operations and act on the findings to provide a process of continuous improvement.  Additionally a quarterly online IFA survey is conducted.
• Annual client surveys are sent to check understanding of products/service.
• Our compliance monitoring programme checks that the right documents are sent at the correct time in the sales process i.e. Key Features Documents.
• Considering staff feedback and suggestions on processes, communications, whether internal or to our customers.
• Case update emails are available to advisers who subscribe to the Case Update Service on the Partnership Website which keep them informed of the status of cases as they progresses to ensure both the advisers and clients are kept informed.
• Partnership supports the Association of British Insurer’s (ABI’s) Customer Impact Scheme, which provides guidance on the production of customer facing literature.
• Conducting Root Cause Analysis of complaints thus identifying any perceived deficiencies in marketing material.

Outcome 3 Management Information

TCF Outcome 4: Appropriate advice

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

Embedding TCF - How Partnership supports this outcome

• Our sales team promotes our products to intermediaries, and generally provide support and product guidance to them. Staff are trained on the Company’s products.
• All staff are aware that we do not provide advice on the products except for the Partnership Care Direct service (long term care products only).  This is fully documented in the compliance manual which also provides an example of how to deal with advice queries.  This is also tested through the monthly departmental reviews that are carried out by Compliance. 
• We track on a monthly basis the number of cancelled and lapsed policies and complaints in this outcome category by broker to identify any trends for potential mis-selling of our product by our Financial Advisers. 
• We also monitor the number of advised and non-advised sales.
• We have suitability guides for each product to aid the advisers in ensuring the right product/options are considered for the client.
• We constantly monitor the regulatory status of the financial advisers/brokerages advising on our products to ensure they are authorised to do so. 
• We ensure that all the financial advisers recommending our long-term care products hold the CF8 examination.
• We monitor brokerages where there is evidence of poor persistency rates.
• We campaign for greater awareness of the Open Market Option (OMO) to ensure retirees are aware of the multitude of annuities, potentially offering a higher retirement income, available to them.
• We monitor complaints via Root Cause Analysis to provide Management Information on the percentage of complaints attributable to allegations of poor quality advice.

Care Direct – Advice to Clients

• All Care Direct advisers are encouraged to study for advanced qualifications and are members of the CII and subject to the CII code of practice.  Additionally the CF8 examination is compulsory.
• Annual Fit and Proper test are carried out which review the adviser KPI’s and includes a credit check.
• There is a Care Direct T&C scheme which outlines the competency requirements of the advisers and Care Direct Supervisor
• We have a Care Direct Compliance Monitoring programme that checks the relevant compliance stages of the sales process.  This includes checking cases that have been reviewed by the Care Direct Supervisor for consistency.  
• All Care Direct clients are provided with a client servicing survey when their policy is issued.
    

Outcome 4 Management Information

TCF Outcome 5: Product & service performance

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.

We aim to provide our customers with the products, and a high quality service, that we have promised to deliver:

• The root cause of every complaint is identified and action assigned where a systemic issue is suspected.   This may result in process change or staff training to improve our service. The root cause categories have been linked to the 6 TCF outcomes so that we can measure whether our consumers are benefiting from improved outcomes.
• Products are designed as part of a robust product development process to ensure they are stress tested and appropriately targeted.
• We have a documented internal service level agreement (SLA) for Underwriting, Operations, Actuarial, Sales and IT departments, which are reviewed by the Board as part of the TCF management information.
• We have a Quality Assurance team who review client cases to check for errors to identify training needs across the business.
• We have a compliance monitoring programme that checks the relevant compliance stages of the sales process.
• We are also running a policyholder research program focused specifically on checking quality of service and product satisfaction at various stages in the product lifecycle.
• We were winners of a five star award in the 2006 & 2007 Financial Adviser Service Awards and winners of a four star award in 2008 and 2009.
• Partnership supports the Association of British Insurer’s (ABI’s) Customer Impact Scheme, which is designed to improve the customer experience of the pensions, protection and investment industry.  As one of the 32 companies supporting this valuable initiative, we have formally resolved to:“Continue to put customers’ needs at the heart of our business and to follow the three core customer commitments”. To develop and promote products and services which meet the needs of customers. To provide customers with clear information and good service when they buy products. To maintain appropriate and effective relationships with customers, providing them with good service after they have bought a product

Outcome 5 Management Information

TCF Outcome 6: Post-sales service

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

We aim to ensure our post sale service continues to be of a high standard by:

• Providing our customers with easy access to us – phone, fax, email, internet.
• A clear procedure for complaints when clients are not satisfied. We have a dedicated internal complaints handling team to ensure that these are dealt with by competent staff that review the merits and provide compensation where appropriate within the set regulatory timescales.
• Compliance monitoring programme to ensure the correct and compliant complaints handling process is adopted.
• Online channels for communication with brokers - online enquiry form and a call back facility.
• Our broker support staff to offer help and seek resolution whenever it is required.
• Claims are dealt with in set timescales to ensure appropriate timescales for settlement.  These are also monitored by Compliance as part of the compliance monitoring programme to ensure they are handled in accordance with FSA regulation.

Outcome 6 Management Information