Consumer Duty

Version 2.0 – Updated September 2025

1. Background & Governance

Quorum Fleet Solutions Ltd embeds "Consumer Duty," as defined by the Financial Conduct Authority (FCA), as the core principle of our business operations. We operate in strict adherence to Principle 12: "A firm must act to deliver good outcomes for retail customers."

Evolution of the Duty: Following our initial implementation plan (October 2022), the Duty is now fully operational across all business lines:

The Three Cross-Cutting Rules:

1. Act in good faith towards retail customers.
2. Avoid causing foreseeable harm.
3. Enable and support retail customers to pursue their financial objectives.

2. Outcome 1: Product and Service Outcomes

While primarily a distributor, we have reviewed processes and practices to consider this outcome to make sure that the products we broker are suitable for the clients offered to and that our processes ensure that good outcomes are delivered to customers, for example we don't recommend a product to a customer that is either not suitable or unaffordable. The following four areas have been addressed

• Ongoing Suitability: We verify that no product is recommended unless it is clearly suitable and affordable. Mark Batey (Managing Director) maintains accountability for the ongoing monitoring of these standards.
• Target Market Review: We regularly update our target customer profiles (socio-economic and need-based) to ensure our marketing and brokering remain appropriate.
• Data-Driven Improvements: We utilise product performance data, client feedback, and root-cause complaint analysis to proactively refine our offerings.
• Fact-Find Rigor: Our management meetings focus on the continuous enhancement of our suitability assessments to prevent financial over-extension by clients.

2.1.1 Initial client contact

• Customers advised of the right to withdraw
• Customer informed of the complaint's procedure
• Review of initial disclose information to ensure better customer understanding
• Review of commission disclosure to ensure it is clear and understandable for customers
• An increase in customer understanding of contractual obligations
• Clarity of any potential detrimental consequences understood
• How we assess suitability to compliment customer requirements and needs
• Review of how other products / services have been explored with the customer

2.1.2 Dealing with vulnerable customers

• We have clear policies in place for managing and assisting clients with debt issues, such as directing clients in financial difficulty to free sources of debt advice (see Vulnerable Customer Policy)

2.1.3 Entering into the contract

• Ensure the contract is explained and understood by the customer
• Ensure the client consider the contract meets identified needs
• Ensure the cost of the product is clearly and adequately explained. This includes total amount repayable, interest and other charges, monthly payments and optional fees.
• In the case of a finance product, the customer is clear as to how the loan is to be repaid. If in doubt we test the comprehension by asking relevant questions

3. Outcome 2: Price and Value Outcomes

Quorum conducts regular Fair Value Assessments (FVA) to ensure a fair relationship between the price a customer pays and the quality of the service received. We have reviewed whether the pricing we broker is reasonable, fair and in line with current market conditions. As a result of this review, and ongoing monitoring, we ensure customers can enter into financial commitments safely in the knowledge that fair value has been considered and to ensure the customer receives value for money. The FCA define value as the relationship between the overall price of the product to the customer and the quality of the product(s) and/or services provided. We determine the right to make a return on investment which compensates for the costs incurred in providing a service and the risks taken, profit by exploitation though is not acceptable. We regularly review charges to assess fair value as part of our compliance monitoring. The firm is confident that all charges and costs are fair to the customer and review this over time, changing as necessary.

3.1.1 Reasonable charges

Several measures exist to ensure the firm reflects positive outcomes on price and value. Some of these measures include:

• Fairness Standards: Our culture rejects profiteering via exploitation. We ensure our return on investment is balanced against the value and risk mitigation provided to the client.
• Market Benchmarking: We continuously review the market to ensure any product costs remain competitive and fair.
• Profitability Oversight: We monitor revenue and profit margins to ensure the business model remains consistent with the delivery of fair value.

4. Outcome 3: Consumer Understanding Outcome

The FCA require firms to help customers make informed decisions, and, to achieve this, communications are clear, engaging and relevant, whether verbal, written, on an advertisement, or on a website, and are easily understood by customers. We believe that simply providing a customer with information is not enough, we confirm that our customers understand information that is being given to them, we ask questions of the customer when providing information to confirm that it is understood.

We also canvass customers in general to seek their opinion on the adequacy of information that we have provided and how easy it is for them to understand. We identify any comprehension issues and seek to address by improving and enhancing communications such that easily understood by all customers, including those with vulnerabilities. we need to be certain that the clients we engage with fully understand the nature of the contract. If they don't then we shouldn't offer the service.

• Beyond Information Disclosure: We do not simply provide information. Our staff are trained to ask targeted questions to ensure customers understand contractual obligations and potential detrimental consequences.
• Vulnerability-Aware Comms: Communications are tailored to meet the needs of all clients, specifically those with identified vulnerabilities, to ensure no understanding gap exists.
• Transparency: All costs, including interest, total repayable amounts, and commission disclosures, are presented with absolute clarity.

5. Outcome 4: Consumer Support Outcome

Per the FCA, there is a close relationship between the Consumer Understanding outcome and the Consumer Support Outcome. Under the Consumer Support Outcome the FCA advise that firms should enable customers to act on their decisions without facing unreasonable barriers. To ensure all customers are supported through their journey of obtaining a suitable and affordable product the firm:

• Provides an appropriate standard of support to customers which meets their needs.
• Delivers support that meets the needs of customers, including those who are vulnerable and ensure that vulnerable clients are not disadvantaged.
• Ensures that customers are given sufficient opportunity to understand and assess their options, including any risks
• Regularly monitors the standard of support and make improvements where necessary.

Furthermore, the firm ensures adequate support includes:

• Responsive service, taking a reasonable length of time to respond to customer questions and requests
• Answering phone calls or emails from clients
• Recognising/identifying vulnerable customers and provide the required level of support
• As applicable, website functioning properly, or key information not prominently displayed and updated.
• Signpost clients to our complaint's procedure
• Signpost clients in financial difficulty to free sources of independent debt advice

An example of compliance with this Outcome would be in the case of a declined credit application on affordability grounds. Good support would be then signposting the client to a source of free independent debt advice.

For a vulnerable client, good compliance here would involve information being provided to the client in the form that is easiest for the client to understand, this may be verbal or in writing – whichever mode is the most appropriate for that client. Also ensuring that client queries are responded to promptly, adding staff if necessary to ensure that client enquiries are responded to promptly

We regularly monitor standards of service and ensure staff are fully trained. We also review any complaints or negative feedback to establish any root causes as part of our complaints policy process.

• Responsive Standards: We maintain service levels that ensure prompt responses to inquiries. If service standards lag, we commit to increasing resources to maintain support quality.
• Proactive Vulnerability Support: We identify vulnerable customers early and provide bespoke support modes (e.g., verbal vs. written) based on their specific requirements.
• Financial Difficulty & Signposting: In the event of credit declines on affordability grounds or signs of financial stress, we proactively signpost customers to free, independent debt advice.
• Continuous Monitoring: Our Board reviews the Complaints Log and customer feedback annually to ensure the support journey remains friction-free.

If anything here is unclear, contact us on 0191 380 4680 or email [email protected].