Our Intentions:

Best Car Finder Group Ltd (BCF) is committed to abiding by the Principles for Business laid down by the FCA.  This Policy provides guidance on how we will meet our objectives to look after the best interests of our customers by treating them fairly, ensuring that the information we give them is clear, fair and not misleading and that we handle all matters with integrity, due care, skill and diligence and manage fairly any conflict of interest that may arise.  Our aim is to provide suitable products at the best value prices for our customers.


How we will do this:

We have identified all the areas where we consider, or it has been found elsewhere, that problems may occur and we have assessed the risk presented by each potential situation.  We have then described the action we have taken to prevent or minimise the potential unfair treatment of customers.  Lastly we have set out the controls that we have put in place to monitor our performance in each area. We will also gather feedback from our clients and from ourselves, which will be considered regularly so that any new issues can be identified and addressed promptly when they occur.


Why we have a Policy:

The policy has been written in order to communicate the issues to all our stakeholders and especially those working within our firm to make sure they understand the potential problems that may occur and to give them the best possible chance to deliver excellent service to our clients.  This is in the interests of the company, the staff as well as the client and the regulator.


Principle 6: A firm must pay due regard to the interests of its customers and treat them fairly.

In adopting the TCF principle we recognise that fair treatment of our customers is about adding value to the service, we recognise that a satisfied customer could still be treated unfairly and not know it, and so we aim to protect the interests of our customers at each stage of the sales process, from initial contact by the customer right through to dealing with any queries or concerns, and meet as best we can the unique needs of each customer by offering a transparent, efficient and professional service, and constantly reviewing our processes to identify areas for improvement.


The FCA’s 6 TCF Outcomes

These are the outcomes that the regulator wants for customers and are also the outcomes we would like to achieve for ourselves, as they will contribute greatly to our success as a commercial enterprise. Our policies and procedures are designed to promote these outcomes. Our management information is used to demonstrate that we are meeting these objectives at all times and where we find that customers have been dissatisfied or disadvantaged, or if we consider we are not meeting these targets completely, we will take immediate steps to rectify the position.


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


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


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


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


5. Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and as they have been led to expect.


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


‘TCF’ Action Plan

The way we will actively measure our performance in each area is as follows:


Client Feedback

We have a comprehensive client questionnaire which directly asks client for feedback including their understanding of the products provided and whether or not we have understood their needs and attitudes, if they feel we have treated them fairly and with good levels of service. We actively encourage clients to respond and tell us how we are perceived. This information is acted upon if necessary and it is stored in our system. We use this to demonstrate outcomes 1, 3, 4 and 5.


We comment on all feedback whether solicited or not from our clients where it has been received from clients and discussions are included in our business review records.


File Audits

We have a two stage file checking process; each file is checked for the accuracy of the information provided, the thoroughness of our fact find and signed off by two parties.


We have developed a file audit programme undertaken by independent consultants who will assess the clarity of the information provided and the suitability of the products offered to the particular client and the appropriateness of our recommendations. Information will immediately be fed back to advisers if there are any failings on our part to fulfil our objectives. This will demonstrate how we are meeting outcomes 3 and 4.


Advertising & Promotions Checking

All our own advertising and our web site will be checked by appropriately skilled individuals to ensure they are clear, fair and not misleading. We will also take advice on the target market for promotions from the product providers or appropriate advisors before we undertake any marketing campaign. This will address outcomes 2, 3 and 5.


Remuneration Policy

Our policy with regards to remuneration of our advisers and support staff will include key performance indicators in compliance, training and competence and treating customers fairly.  This is designed to assist in outcomes 1, 3, 4, 5 and 6.


Business Reviews

We hold regular business reviews, normally monthly, which will be recorded and in which we will discuss the impact of any changes, procedures or marketing strategies on our customers. All key members of staff are included in the review process.



We will review sales figures split by provider, product and adviser on a monthly basis to monitor any trends which may emerge. If we see any unusual bias then we will investigate the reasons for this and take corrective action where necessary. We will document out findings, actions and further monitoring during business reviews. This is designed to address all outcomes.


Training and Competence Regime

We will keep up to date and record our training and competency procedures and ensure that our advisers are up to date and competent in their knowledge of the products that they are advising on. We will ensure that regulatory standards and relevant professional qualifications are met. This will primarily address outcome 4.


Issue Recording

We undertake to keep a record of all issues that crop up in the course of our business where clients express dissatisfaction, or have any other adverse comment; also issues that we find material such as poor performance of products, poor provider service or queried communications. This will show us where matters of understanding, efficiency or clarity could be improved without having to rely upon complaints data that we do not anticipate will arise. This is designed to measure outcomes 3, 4, 5 and 6.


Complaints Data

We will keep a log of all complaints and the outcomes of our investigations. Whatever the outcome we will always fully investigate the root cause of any complaint made against us. Where the complaint is directed at one of our providers we will work with them to investigate the root cause.


Analysis of Specific Issues

We have already looked for potential issues and set out in this document our observations and the measures we will put in place to pursue actively our objectives of meeting the desired outcomes in full. We will add to our policy any issues which later come to light that we may not have considered at the outset.




Consumer Duty

Consumer Duty covers all or our activity, from strategic planning all the way down to individual customer interactions. The purpose of the Duty is to introduce a higher level of protection for consumers.


Principle 12: A firm must act to deliver good outcomes for retail customers.

This is an extension of Principle 6, and refers specifically to retail customers. 


This principle is underpinned by the cross cutting rules that apply across all areas and provide clarity on the standards of conduct the FCA expects under the Consumer Principle.


The cross cutting rules are:

·         Avoid Causing foreseeable harm

·         Act in good faith toward retail customers

·         Enable and support customers to pursue their financial objectives

In summary, the Duty means consumers should get the support they need, when they need it, receive communications they can understand and have products and services that meet their needs and offer fair value.


Our approach has been to put in place training, systems and controls and Management Information which are all regularly reviewed, discussed and acted upon by senior management. There is clear communication to staff so that we consistently and continuously analyse the risks to our firm, and to our customers, with reference to the following four consumer outcomes.  


Consumer Outcomes

The outcomes have been set by the Board and are a guide of the minimum standards that the Board expect the company to deliver to consumers.


Product and Services

·      Our Products and Services are designed to meet the needs, characteristics, and objectives of a targeted set of consumers.

·      Our Products and Services are distributed via the appropriate channels for those consumers in the intended target market.

·      Our Products and Services are regularly (and proactively where needed) reviewed so that they continue to meet the needs of the identified target market throughout their lifecycle.


Pricing and Value

·         Our Products and Services provide Fair Value to consumers across all groups in the target market, so there is a reasonable relationship between the price paid and the overall benefit consumers receive.

·         Our Products and Services provide Fair Value to consumers with vulnerable and / or protected characteristics.

·         Our Products and Services are regularly (and proactively where needed) reviewed so they continue to provide ongoing Fair Value to consumers.

·         Our Products or Services that have been assessed as not providing Fair Value are addressed swiftly with appropriate action taken to avoid causing foreseeable consumer harm.


Consumer Understanding

·         We provide the right information, at the right time, in a way that allows our consumers to understand their products and services and make timely, informed, and effective decisions.

·         We tailor our communications to take account of consumer characteristics, the communication channel used and the complexity of products.

·         We regularly test, monitor and update communications to support good consumer understanding.

·         We proactively seek to identify whether consumers understand communications and staff are trained on how to identify misunderstanding.


Customer Support

·         We support our consumers to allow them to use their products as intended, regardless of the channels used.

·         We provide appropriate support to our consumers, including those with vulnerable/protected characteristics, to enable them to realise the benefits of the products and services they receive.

·         Our consumers do not face unreasonable barriers or costs during the lifecycle of a product and service, and it is at least as easy to switch product, leave a service or make a change, as it is to buy the product or service in the first place.

·         Our support services are regularly (and proactively where needed) reviewed so they continue to provide ongoing effective support.