Treating Customers Fairly Policy

The Directors of Harwoods Limited ("The Company") has adopted this policy reflecting how it intends in context of its motor retail business, to operate to the "Treating Customers Fairly" (TCF) principle in the mediation of the sales of general insurance products with regard to FCA Principle 6. "pay due regard to the interests of its customers and treat them fairly" and the processes of putting customers’ interests at the heart of the business.


The Company believes that the fair treatment of customers is essential to the success of its business. Customer satisfaction is paramount to the Company’s retail business, both directly and because of the influence of the quality of the customer experience has on the businesses’ relationships with other notable business interest, principally vehicle manufacturers and supplier of general insurance products.

This policy is adopted for the purposes of the general insurance mediation business, and all references to the "products" are to general insurance products, and to "customers" are to customers for general insurance products. The Company recognises that the customer’s demand for or need of a general insurance product is ancillary to his/her requirement for a motor vehicle. Each customer for a vehicle is potentially a customer for a general insurance product.

Accordingly, the process for the selection, marketing sales and advice, aftersales service and complaint handling for general insurance is extricably linked with the sale or supply of a high value product (motor vehicle) which represents a considerable investment for most customers.

The fair treatment of the customers is therefore required to be embedded in the whole process and reflected in all the behaviours of the Company’s employees.

Values and TCF Policy Statement

To ensure that they are memorable and easily understood by our employees, our core values and TCF policy are encapsulated within the Company’s working environment.

The Company has adopted core values reflecting its relationship towards our customers and aims to offer ‘Integrity, Professionalism and Consistent Customer Satisfaction’ by providing good value and personalised service to existing and potential customers.

Treating Customers Fairly is an inherent requirement for the fulfilment of this core value.

The Company’s processes, policies and behaviours will ensure that customers are treated fairly at each stage of our relationship with them.

The Company selects and retains only those suppliers of general insurance products and associated services who are able to demonstrate their own respect and fulfilment of the TCF principles for the areas of the customer’s relationship for which they are responsible.

The Company’s core value for suppliers is to achieve and provide long term, profitable partnerships in return for quality service and competitive pricing.

Our core values and TCF policy is included in within the induction and training of all employees.

Product design, governance and marketing

We do not supply general insurance independently from the supply of a motor vehicle.

We require our product suppliers to provide us with information about the outcome of our sales to inform our decisions on our product portfolio and our assessment of the fair treatment of our customers.

As mediators of the products designed by third party suppliers, our concern is to ensure that our product portfolio meets the following requirements:

  • The supplier is of adequate financial standing and will enable us to fulfil our core values.

  • The products are suitable to our potential customers, as purchasers of new and used motor vehicles.

We regularly review product terms, conditions of sale and all customer feedback and engage with the product suppliers to redress imbalances against customer expectations.

Advice and sales processes

We mediate insurance products from multiple retail locations to customers for motor vehicles who potentially will have contact with a variety of employees. Our concern is to ensure that our customers’ experience meets with the following requirements:

  • Whether for general insurance or other products or services, only appropriately trained competent employees deal directly with the customer.

  • Employees receive the appropriate knowledge and skill training and support to provide a service to ensure they provide a service which treats the customer fairly.

  • Where practicable, our information systems incorporate means of assurance of the fair treatment of customers.

  • We regularly review the effectiveness of our sales process towards achieving the fair treatment of customers.

  • We use our management information to identify trends and behaviours which fall short of our high expectations and inform corrective training.

We indentify potential conflicts of interest within our sales process and ensure that individual and business objectives are linked not only to sales performance but also to customer satisfaction, TCF and regulatory compliance.

Complaint Handling

We provide customers with easy access to all employees, both those that handled the sale and ones unconnected with the sale, to receive, record, investigate and respond promptly to any type of complaints.

All employees are allocated clear responsibilities for handling any complaints:

  • Investigation of a complaint

  • Prompt resolution of a complaint

  • Communication with the customer at the appropriate stag

We give clear explanations of our complaints handling process and of conclusions reached at the end of our process.

We keep the customer informed in a timely manner of the progress and the status of their specific complaint.

We advocate on behalf of customers with any supplier which responds unreasonably to a legitimate claim or complaint.

We use identified trends in complaints received to inform our product and supplier selection.

Management support for TCF

Senior Management:

  • Prescribes management information disciplines which allow for regular reviews against our customer satisfaction objectives and TCF standards.

  • Ensures that line managers and employees role responsibilities clearly set out their TCF and regulatory compliance objectives.

  • Ensures there is available to all employees adequate training and coaching which equips them to understand their duties and responsibilities.

  • Regularly reviews and moderates remuneration schemes and individual performance objectives to ensure consistency with the businesses’ TCF approach.

  • Ensures that the Company rigorously promotes our customer core values in all training interfaces with our team members, to embed a culture of Treating Customers Fairly.

  • Ensures that our incentive schemes reward and recognise excellence in achieving customer satisfaction, embracing the fair treatment of customers.