Treating Customers Fairly

1. Introduction & Scope

The Financial Conduct Authority (FCA) requires all regulated firms to put the well-being of customers at the heart of their business. This policy outlines our commitment to the FCA's six TCF outcomes and the 2023 Consumer Duty (PRIN 12), which requires us to act to deliver good outcomes for retail customers.

This policy applies to all directors, employees, and contractors of Quorum Fleet Solutions involved in the brokering of motor finance products.

2. The Higher Standard: Consumer Duty

We move beyond "fairness" to ensuring Good Outcomes across four specific areas:

• Products and Services: We only broker finance products (PCP, HP, Lease) that are fit for purpose and designed for the specific target market.
• Price and Value: We ensure that there is a reasonable relationship between the price paid by the customer and the benefit they receive.
• Consumer Understanding: We provide information that is clear and enables customers to make effective, timely, and informed decisions.
• Consumer Support: We provide support that meets consumers' needs throughout the life of the product, ensuring no "sludge" practices or barriers to exit.

3. Product Governance & Suitability

• Target Market Assessment: We analyze our lender panel to ensure we match customers with finance products appropriate for their credit profile and vehicle choice.
• PCP Awareness: Given the complexity of Personal Contract Purchase (PCP), we explicitly highlight the "Balloon Payment," mileage restrictions, and the implications of vehicle condition on return.

4. Remuneration & Transparency (CONC 4.5)

We are committed to full transparency regarding how we are paid to avoid conflicts of interest:

• Prohibition of Discretionary Commission: We do not operate any commission models where the broker can influence the interest rate to increase their own remuneration.
• Disclosure of Commission: We inform customers in writing of the existence of commission before they enter into a contract. If a customer asks, we disclose the exact amount of commission payable.
• Status Disclosure: We state clearly that we are a broker, not a lender, and work with a limited number of lenders.

5. Identification of Vulnerable Customers

In accordance with FG21/1, we identify drivers of vulnerability including health, life events, resilience, and capability. Our process includes:

• Training staff to recognise "red flag" behaviours on calls or in-person.
• Using the TEXAS model (Thank, Explain, eXplicit consent, Ask, Summary) for handling disclosures.
• Adapting communication methods (e.g., larger print, slower explanations, or involving a third party) where necessary.

6. Management Information (MI) & Oversight

Our TCF oversight is data-driven. We review the following quarterly:

• Commission Disclosure Rates - High volume of sales without documented disclosure.
• PCP Handback Rates - High volumes of returns suggesting the product wasn't understood.
• Arrears/Early Terminations - Indicating potential affordability issues at the point of sale.
• Complaint Root Cause - Trends suggesting misleading marketing or high-pressure sales.

7. Training & Culture

TCF is not just a compliance manual; it is our culture. All staff are measured against "Customer Quality" KPIs, not just sales volume. Any staff member found to be intentionally misleading a customer or bypassing disclosure rules will face disciplinary action under the Senior Managers and Certification Regime (SM&CR).

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