TFC Policy

POLICY INTRODUCTION

The main aim of Treating Clients Fairly (TCF) is to ensure that the fair treatment of clients is embedded within Truzo’s culture and business processes.  Treating Clients Fairly (TCF) is an outcomes based regulatory and supervisory approach designed to ensure that regulated financial services providers deliver specific, clearly set out fairness outcomes for financial clients.

These outcomes must be demonstrably delivered throughout the product life cycle, from product design and promotion, through advice and servicing, to complaints and claims handling – and throughout the product value chain.

Scope

In Scope

This policy applies to:

• Truzo Ltd (UK registered) and all its subsidiaries, of which Truzo (Pty) Ltd is part of, collectively referred to as “Truzo”.
• All employees and workers of Truzo. For the purposes of this document, “employees” includes permanent employees and fixed term employees; “workers” includes contingency workers (also referred to as agency workers) and secondees to Truzo from a third party, irrespective of their location, function, and grade or standing.

Out of Scope

This policy does not apply to:

• Any entity in which Truzo has any interest and which is a non-consolidated entity, or to any employee of any such entity.

6 TCF OUTCOMES

Truzo aims to demonstrate that they deliver the following 6 TCF Outcomes to their clients throughout the product life cycle, from product design and promotion, through advice and servicing, to complaints and claims handling – and throughout the product value chain:

• Culture and Governance – Our Clients are at all times confident that their fair treatment is central to our corporate culture.
• Product Design – Any products and services marketed and sold by us in the retail market are designed to meet the needs of identified client groups and that any related targeting of our clients are done so in accordance with this standard.
• Clear Communication – Our Clients are at all times provided with clear information and kept appropriately informed before, during and after point of sale.
• Suitable Advice – Where our clients receive advice, that the advice is suitable and takes into account the individual client circumstances.
• Performance and Standards – Our clients are provided with products that performs as we have led them to expect and that any associated services is of the standard that we have led them to expect.
• Complaints, Claims and Changes – Our clients do not face any unreasonable post-sale barriers should they wish to change their products, switch to another FSP, submit a claim or submit a complaint about our services.

OUTCOME 1 – CULTURE AND GOVERNANCE

Our Clients are at all times confident that their fair treatment is central to our corporate culture.

POLICY STATEMENT

It is our committed objective to ensure that all our clients or potential clients can be confident that they are dealing with an FSP where the fair treatment of clients is central to our corporate culture.

We use our best efforts to ensure that at all times we, our staff members and representatives render financial services honestly, fairly, with due skill, care and diligence and in the interests of clients and the integrity of the financial services industry.

Delivery of the TCF outcomes is a core feature of Truzo’s stated values, code of conduct and ethics policy and is embedded throughout Truzo’s DNA.

PROCEDURES IMPLEMENTED IN ORDER TO ACHIEVE POLICY OBJECTIVES

Leadership

• TCF is a standing item on the Truzo’s executive meeting agenda where Truzo’s approach to TCF is analysed and discussed.
• Senior management has adopted TCF deliverables and have been allocated specific responsibilities in terms thereof. Senior management in Truzo that contribute to the rendering of financial services to clients (whether directly or indirectly), understand their respective roles in delivering TCF outcomes to those clients.
• Senior management conducts regular reviews of the main business processes with a view to identifying areas that do, or may, require improved TCF deliverables. Explicit allowance has been made to allow for and consider TCF implications and deliverables during the strategic planning process of any new strategy or change in existing strategy.
• Adherence to the TCF deliverables is monitored as part of our Compliance Monitoring Programme. We ensure on a monthly / quarterly / bi-annual basis that accurate, meaningful and timely Management Information has been produced during the period and that senior management acts accordingly. Existing tests within our Compliance Monitoring Programme aid us in demonstrating our level of compliance and adherence to the TCF outcomes. Where there are TCF action points, these will be documented, actioned and monitored.

Decision Making

• All requests by Truzo’s executive management for the approval of product and service innovations or project expenditure, include due consideration of the possible impact it may have on TCF outcomes.
• Truzo has established accessible forums or structures through which staff members and management are able to debate TCF related matters and refer any TCF questions or concerns to executive management or appointed risk committee.

Governance and Controls

• Oversight and monitoring of TCF delivery has been assigned to our TCF Champion.
• Procedures have been implemented to ensure regular reporting to executive management on the progress in achieving TCF deliverables across all of Truzo’s activities and functional departments.
• Any identified TCF risk or failure will be reported to executive management.
• There is ongoing evaluation of whether Truzo’s governance framework as a whole has been effective in achieving TCF outcomes.
• Truzo have mechanisms in place to monitor and respond to changes in the broader environment such as economic and regulatory developments to enable us to proactively identify TCF related risks.

Employee Participation

• All staff members (including senior management) whose role require delivery of TCF outcomes have been identified.
• Staff members are made aware of TCF principles and deliverables by way of this policy.
• Recruitment processes have been revised to ensure staff in relevant positions will have the necessary skills to achieve the outcomes of TCF.
• All staff members are aware of the requirement to treat clients fairly. This policy has been circulated to all staff members and staff members are encouraged to make suggestions to our TCF Champion on how the treatment of our clients might be further enhanced.

Management Information (MI)

• Existing MI measures have been reviewed to determine which are useful for TCF monitoring and new measures have been identified where necessary (See Annexure B).
• Processes are in place to:
• Collate and summarise TCF related MI in a way to present a meaningful picture of Truzo’s TCF progress;
• Analyse and act on MI findings to improve TCF outcomes for our clients; and
• Identify staff training needs and to align performance management measures.

Communication

• We communicate transparently with our stakeholders (including the Regulators) on progress in achieving TCF outcomes.
• We make information, regarding our progress in achieving TCF outcomes, publicly available on our Website.

OUTCOME 2 – PRODUCT DESIGN

Any products and services marketed and sold by us in the retail market are designed to meet the needs of identified client groups and that any related targeting of our clients are done so in accordance with this standard.

We develop and provide advice and certain intermediary services on products that fall within the categories and sub-categories of the financial products list in Annexure A.

PRODUCT APPROVAL AND SELECTION PROCESS

Our product approval and product selection processes include senior management confirmation that a product adequately meets the outcomes of TCF and that any such product will perform as clients are led to expect.

Our product approval and product selection processes also include the careful consideration of the elements listed below:

• When designing a product or selecting a product to distribute or to administer, we identify the particular client groups for which the product can be considered suitable for, whilst taking into consideration needs and various risk factors.
• We provide our staff members and representatives with information and guidance to determine the client group/s in respect of whom the products are best suited.
• In determining whether our distribution and administration methods are suitable for the product and target market, we take into account all known and foreseeable risks associated with the product.
• We have measures in place to identify and mitigate risks that a product or service may pose to a particular client group.
• When development and management of products and services are done, we have measures in place to ensure that the requirements and expectations of the identified client group is met.
• When approving or selecting any product for distribution:
• We assess the suitability of any promotional or other material that has been designed for the identified client group and take into consideration complaints and service call data available;
• We assess the suitability of any related and optional (‘add-ons’) products or services for the identified client group.
• Should any product be selected that includes ‘add-on’ products or services, we confirm that there are processes in place to ensure the fair treatment of clients with regard to such ‘add-on’ products or services, including ensuring that these products or services are appropriately targeted to the needs of client groups for which they are provided.
• We have measures in place to ensure that the client group has enough information available to them to make an informed decision in selecting products or service.
• We track sales to determine whether products are in fact sold to the identified client groups.
• We have processes in place to mitigate risks where it becomes apparent that the product or the distribution or the administration method, or any combination of these elements, was not suitable for the identified client group, or that the product has been distributed to inappropriate client target groups.

OUTCOME 3 – CLEAR COMMUNICATION

Our Clients are at all times provided with clear information and kept appropriately informed before, during and after point of sale.

• We assess the clarity, appropriateness and fairness of product information provided to clients, whether such information is produced by ourselves or by others and all product related information requires sign-off by senior management.
• Before any product information is issued, it is carefully tested to ensure that the content will be clear and understandable by the target audience and client group.
• We have implemented appropriate risk mitigation procedures that are designed to address any inaccurate, unfair or misleading information about our products or services that may be provided to clients by third parties.
• We have implemented appropriate procedures to ensure that any information we provide regarding any other party’s products or services is accurate, clear, and fair and is not misleading.
• We have implemented appropriate procedures to ensure that we are able, as far as reasonably possible, to rectify any situation where it becomes apparent that any product information already in circulation (whether produced by Truzo or not) is inaccurate, unclear, or unfair or is misleading.
• We regularly review standardised product information we use (whether produced by Truzo or not) to ensure that it remains accurate, clear and appropriate to the applicable client groups.
• We monitor and act on feedback, complaints and suggestions received from clients, staff members or any other parties that communicate the need for improvement in product information.
• We have a process in place to ensure relevant and adequate product information is provided to our clients, whether by our own staff members / representatives or by other parties, at an appropriate time to enable them to make an informed decision as to whether to enter into the relevant transaction.
• We provide all existing clients with online digital access to their profiles, transactions and wallet statement as they require.
• We ensure that clients are informed of any recent or pending changes to our products and that such information is provided in sufficient time to enable any client to reasonably respond to or act on that information.
• To the extent applicable, we control the accuracy and quality of any once-off or non-standard product information provided by staff members or representatives to clients or potential clients.
• We maintain up-to-date contact details of all our existing clients, as provided by the clients.
• We ensure that clients have current and accessible contact points if they need product or service information or need to get in contact with our functional departments for any reason.
• We have accurate, retrievable, secure records of all product information we have provided to clients and any other material.

OUTCOME 4 – SUITABLE ADVICE

Where our clients receive advice, that the advice is suitable and takes into account the individual client circumstances.

BEFORE ADVICE IS GIVEN BY TRUZO

• Prior to making any decision to market a particular product, we assess whether or not we have the appropriate skills and business processes in place to render the appropriate financial service and that the particular product will be suitable for the target market and client concerned.
• Prior to contracting with any product supplier to market their products, we conduct an appropriate level of due diligence to satisfy ourselves that their products and service levels are likely to meet our clients’ reasonable expectations.
• We have implemented procedures that ensure that all representatives, prior to providing advice to a client conduct an analysis, for purposes of the advice, based on the information obtained and take reasonable steps to ensure that the client understands the advice and that the client is in a position to make an informed decision.

ADVICE GIVEN BY TRUZO

• In order to ensure that the highest level of financial services are rendered to our clients and potential clients, we identify any risk of inappropriate financial service and we monitor feedback or complaints received from clients, product suppliers or other third parties regarding the quality of financial service they may have received from our representatives.
• We have implemented procedures to identify instances where our representatives have provided inappropriate advice or misleading information to clients and have implemented further procedures that seek to mitigate the risk to clients should such events occur.
• We provide product suppliers and other third parties in the client value chain with feedback in relation to any aspects of their products or services which inhibit our ability to provide suitable advice or the delivery of other TCF outcomes to clients.
• We have controls in place to identify and address any conflicts of interest between ourselves, our clients and product suppliers whose products we market.
• There are clear agreements between ourselves and any product suppliers whose products we market, that set out our respective responsibilities in relation to providing clients with appropriate financial services, information and service support. These agreements are structured to ensure that clients understand who they should look to in relation to different aspects of the financial products or service provided to them.

OUTCOME 5 – PERFORMANCE AND STANDARDS

Our clients are provided with products that perform as we have led them to expect and that any associated services is of the standard that we have led them to expect.

Our point-of sale and information post-sale, include the careful consideration of the elements listed below:

• Processes are in place to mitigate the risk that products and services are unable to satisfy the reasonable expectations of clients.
• We analyse the product behaviour of our clients to identify the possible risk that products or services are not meeting expectations.
• We have clear service standards in place for client service processes and communicate these to our clients.
• We research and test our service standards to determine whether they are in line with client expectations.
• We monitor and act on feedback, complaints and suggestions received from clients, intermediaries and staff members that identify the need for improvements in our services or service standards.
• Where it becomes apparent that products are not performing or are unlikely to perform as clients have been led to expect, we have implemented processes to mitigate the risks to our clients.
• We have adopted “Management Information” on client expectations (See Annexure B).
• Processes are in place to protect the confidentiality of all client information.

OUTCOME 6 – COMPLAINTS, CLAIMS AND CHANGES

Our clients do not face any unreasonable post-sale barriers should they wish to change their products, switch to another FSP, submit a claim or submit a complaint about our services.

Truzo is committed to ensuring that clients do not face unreasonable post-sale barriers when making complaints, and consider all client criticism, whether positive or negative, as a critical feedback mechanism.

COMPLAINTS HANDLING (refer to the Complaint procedure)

• We test our complaints process to ensure it is accessible and appropriate to our client group/s.
• We have a robust complaints management, record keeping and root cause analysis process, and have devoted sufficient resources to ensure effective complaints handling when needed.
• We inform clients (before complaint stage) of the process that must be followed in order to submit a complaint, and of the various options available for further recourse if the client is dissatisfied with the outcome of the complaint.
• Once a complaint has been received, whether we are dealing with the complaint ourselves or where we have referred the complaint to another party, we keep clients informed of its progress (including the contact details of the person responsible for processing the complaint).
• When responding to a complaint, we provide clear reasons for our response (including where the response is favourable to the client), with supporting evidence where relevant.
• Where a request for redress is declined, wholly or partially, we inform the client of the steps that may be followed in order to have the decision reviewed.
• We have clear service standards in place for processing complaints and we communicate such standards to our clients.
• Complaints processes are structured in such a way as to ensure that there are no conflicts of interest and that all decisions are based on objective facts and criteria.
• Follow-up processes are in place to determine the client satisfaction levels of complaints that have been finalised.

TCF CHAMPION

• Truzo has appointed a TCF (Treating clients fairly) Champion as part of its commitment to treat its clients fairly. The appointment of the TCF Champion is confirmed (see Annexure C).
• The general duties of the TCF Champion include:
• To be actively involved with embedding the TCF principles into the organisation.
• To help instil a culture where the fair treatment of clients is embraced and adopted.
• To assist the senior management of the organisation to implement and adopt business processes aimed at ensuring that the organisation is at all times achieving the outcomes of TCF as set out in this document.
• The TCF Champion has the authority to approach and speak to staff members at all levels about the delivery and achievement of TCF outcomes.
• The TCF Champion need not have any specific qualifications but must have a thorough knowledge of the organisation’s functional departments, business processes and the principles associated with treating clients fairly.