TCF and Consumer Duty Policy

1. Introduction

Mercury Vehicle Solutions Ltd t/a carleasing-online.co.uk is committed to treating customers fairly and to delivering good outcomes for our customers, in line with the FCA’s Treating Customers Fairly (TCF) principles and the FCA Consumer Duty.

This policy sets out the standards that we expect every member of our team to uphold and explains how we have embedded these standards into our day-to-day operations.

2. The Consumer Duty — Principle 12

On 31 July 2023 the FCA introduced its Consumer Duty, which sits as Principle 12 of the FCA’s Principles for Businesses:

“A firm must act to deliver good outcomes for retail customers.”

Principle 12 sets a higher and more demanding standard of conduct for firms in retail financial markets than the previous TCF principle (Principle 6) and applies to all of our regulated activities.

3. The Three Cross-Cutting Rules

Principle 12 is supported by three cross-cutting rules that govern how we behave toward our customers at all times. We commit to:

• Act in good faith toward retail customers — meaning honesty, fair dealing, transparency, and not exploiting customer characteristics or behavioural biases for our commercial advantage.
• Avoid causing foreseeable harm to retail customers — through our products, our services, our communications, our pricing structures, and the conduct of our staff.
• Enable and support retail customers to pursue their financial objectives — by giving customers the information they need, helping them understand their options, and supporting them at every stage of the customer journey.

4. The Four Consumer Duty Outcomes

The Consumer Duty requires firms to deliver good customer outcomes across four specific areas. We have embedded each of these outcomes into our policies, procedures, training, monitoring and reporting.

Outcome 1 — Products and Services

We make sure that the leasing products we recommend are designed to meet the needs of our customers. We use detailed target market information from each of our funders, ensure that the risks and benefits of each product are clearly visible, and where a product not in our panel may be more suitable for a customer, we tell them so.

Outcome 2 — Price and Value

We make sure that our customer fee, our commission arrangements, and the overall cost of finance represent fair value to customers. Our broker fee is set at a level that is proportionate to the work we undertake to source, secure and manage the lease, and we document our fair-value assessment annually. Our customer fee is disclosed clearly in our Initial Disclosure Document and in the separate Fee Information Notice.

Outcome 3 — Consumer Understanding

We make sure that our communications, financial promotions and disclosure documents are clear, fair and not misleading. We test understanding through regular call monitoring, customer feedback (including Trustpilot), and root-cause analysis of complaints. Where we identify that customers are not understanding a particular communication, we update it.

Outcome 4 — Consumer Support

We make sure that customers receive the support they need, when they need it, throughout the lifetime of their lease. This includes responsive enquiry handling, clear after-sales support, sympathetic handling of cancellations and complaints, and tailored support for any customer who shows characteristics of vulnerability. We monitor outcomes for vulnerable customers separately to ensure they do not experience materially poorer outcomes than other customers.

5. How We Embed Consumer Duty in Our Business

• Governance: Consumer Duty is a standing agenda item at every Board meeting. The two directors share oversight, with one named as Consumer Duty Champion responsible for monitoring outcomes and reporting to the Board.
• Staff training: Every employee completes Consumer Duty training through the BVRLA platform and the Specialist Automotive Finance (SAF) accreditation. New staff complete training as part of induction. Refresher training is delivered annually and on any material rule change.
• Customer journey: Our documented customer journey identifies vulnerability checkpoints at the quote stage and at the proposal stage, with vulnerability considered at every stage of the journey.
• Communications: Our IDD, Fee Information Notice, Commission Disclosure, financial promotions and website are reviewed and signed off by Compliance Oversight (SMF16) before publication.
• Management Information: We produce a quarterly Consumer Duty MI pack covering the four outcomes, complaints trends, vulnerable customer outcomes, declines, cancellations and customer feedback. The pack is reviewed by the Board.
• Compliance monitoring: Adherence to Consumer Duty is tested through our formal Compliance Monitoring Plan, which includes call monitoring, sales file review, financial promotions review, and root-cause analysis of complaints.

6. Our Service Standards (TCF Principles)

Our TCF principles continue to underpin our day-to-day service. We commit to:

• Operating our business based on the current and potential needs of our customers and considering the impact of any business change on those customers.
• Ensuring that staff remuneration supports the sale of appropriate products and does not create incentives that conflict with customer outcomes.
• Providing regular training to all staff on TCF and Consumer Duty principles.
• Striving to achieve the best outcome for each customer, taking into account the various elements within their leasing arrangement.
• Designing our marketing campaigns and product literature so that key messages are clear, balanced and useful to our target customer segments.
• Reviewing our sales activities regularly to confirm we are selling products and services that meet the needs of our customers.
• Treating every complaint seriously and positively, with clear and easy-to-understand responses.
• Using data to monitor and continuously improve our customer service.

7. Vulnerable Customers

We recognise that any customer can become vulnerable at any time, whether through health, life events, capability or resilience. We train our staff to identify the indicators of vulnerability and to apply appropriate adjustments — such as additional time, written summaries, alternative communication channels and case-by-case empathy — to ensure that vulnerable customers achieve the same standard of outcome as other customers.

8. Document Control