Better Cover. Better Value.

A registered Financial Service Provider (FSP 45834).

TCF (Treating Customers Fairly)

1.     Introduction to TCF

1.1  What is Treating Customers Fairly (TCF)

On the 31st March 2011, the Financial Sector Conduct Authority (FSCA) introduced a program called Treating Customers Fairly (TCF) to financial institutions, TCF approach seeks to ensure that fair treatment of customers is embedded within the culture of financial institutions. TCF will use a combination of market conduct principles and explicit rules to drive the delivery of clear and measurable fairness outcomes

TCF aims to be a holistic and coordinated consumer protection regulatory framework that applies consistently across the financial services sector and is designed to address the specific conduct risks appropriate to the sector! The regulation on TCF ensures that fairness outcomes (as they apply to financial services customers) are demonstrably delivered by regulated financial firms. Financial services providers should always apply these principles keeping the customer in mind.

1.2  What TCF is not

  • TCF does not mean creating satisfied customers.
  • A satisfied customer could still be treated unfairly and simply not know it.
  • TCF does not mean that every company must offer the same level of service.
  • Our different ways of doing things create healthy competition.
  • TCF does not mean that customers are no longer expected to make decisions or take responsibility for these decisions.

 

1.3  What TCF is about

TCF is simply about three factors tied together in a causal loop with each activity impacting the next.

  • Improved customer confidence.
  • Appropriate products and services.
  • Enhanced transparency and discipline

 

It is aimed at achieving six very specific desired outcomes that concern the customer.  TCF requires regulated firms to be able to provide evidence or demonstrate these desired outcomes at every stage of the product life cycle. TCF principles must be driven by the firms’ culture and the way it does business as opposed to a set of defined rules.

2.     The 6 TCF outcomes

Outcome 1: Customers are confident that fairness is central to our company culture.

Outcome 2: Customers are sold and enjoy products and services that are applicable to them and meet their needs.

Outcome 3: Customers receive clear information, that is relevent and that is easy to understand with a clear layout and timely.

Outcome 4: Customers receive suitable advice that takes their circumstances in to account.

Outcome 5: Customers have their expectations met through products and services that are up to standard and deliver what was promised.

Outcome 6: Customers do not face unreasonable post-sale barriers to change product, switch provider, submit claims and complaints.

3.     Application of this policy

Africa Direct Life and Investments acknowledges that the fair treatment of its clients and the provision of excellent service is central to its success and sustainability.

The purpose of this TCF Policy is to communicate how we aim to ensure that the above outcomes are embedded in our approach to dealing with our clients.

The policy applies to all Africa Direct Life employees and non-compliance will bear serious consequences.

4.     Our approach to TCF compliance

4.1  Leadership

The company acknowledges that the TCF initiative is not a Compliance function but rather a concept that is noticeable throughout the company’s operations. Therefore, its Board of Directors and Senior Management, in conjunction with the company’s Compliance function, has:

  • Adopted the TCF objectives.
  • Communicate the initiative to all staff.
  • Assess the company’s TCF readiness.
  • Identify gaps.
  • Put in place the necessary processes that will address the gaps.
  • Put in place the necessary management information to monitor TCF.
  • Embed TCF in the company’s stated Values, Ethics and Srategy Policy.

4.2  Strategic planning & decision-making.

Our strategic plans and budgets must make allowance for TCF implications, with deliverables allocated to appropriate personnel. Business cases and company projects that directly impact on our clients will consider TCF implications. The company has existing structures and forums where TCF-type matters can be discussed and debated.

4.3  Governance & controls

We have assigned our TCF monitoring structure and forums within our company. Africa Direct Life And Investments has  appointed a TCF champion who reports to anagment and is responsible for:

  • Updating this Policy document.
  • Implementing appropriate systems that will assist the company in achieving the outcomes that are relevant to the company.
  • Compliance monitoring and reporting on the company’s progress with regard to the integration and embedding of TCF.
  • Making relevant proposals to management in terms of TCF agendas.
  • Representing the company at relevant internal and external forums that promote most productive methods in the TCF area.

4.4  Performance management and recruitment

Our Recruitment Policy and related processes provide the company with relevant human resources that are able to deliver on the company’s TCF objectives.  Personnel who have been allocated TCF deliverables must undergo the necessary training.

4.5  Measurement & management information.

Africa Direct Life and Investment  has developed appropriate management information systems and controls that allows it to measure TCF effectiveness, analyse and act on findings, monitor and respond to TCF-related  regulatory developments and improve TCF outcomes for its clients.

4.6  Products & services

Our company has developed processes that ensure the fair treatment of clients in terms of, but not limited to:

  • Product design and approval
  • Pricing
  • Managing conflicts of interest where they cannot be avoided
  • Products and service levels meeting our clients’ expectations
  • Our client’s ability to raise complaints and for those complaints to be fed into new product design

4.7  Product information & communication

Within the context of the company operating in a market segment that contains many technical and complex information, save disclosing information that will reduce the company’s competitive advantage, any product information provided to our clients is to the company’s best ability, accurate, timeous, regular, clear, appropriate and does not contain hidden conditions. The company has developed approval processes for the distribution of all its product information with sign-off at an appropriate level of authority.

4.8  Product performance & client confidentiality

The company has developed processes for the on-going monitoring of environmental, economic and regulatory developments that could impact on the extent to which the company’s products will meet its clients’ reasonable expectations. Similarly, processes and controls have been put in place to protect the confidentiality of all customer information. The company’s service standards are documented in client mandates.

4.9  Post-sale barriers

Africa Direct Life and investments does not impose unfair post-sale or product-switching barriers on its clients. We responds in a timely manner to our clients and prospective clients questions and queries, and address any issues or concerns promptly. All customer complaints are dealt with and escalated as appropriate and as required by us in order to meet our obligations to our clients and our regulator.

5.     Conclusion

TCF is embedded in the statutes that are regulated by the FSCA, Africa Direct Life require to comply with the TCF Outcomes and have them embedded within the day to day business activities as failure will result in administration fines.

6.     Contact Details

Africa Direct Life and Investment (PTY) Ltd
Tel no: 0861 91 91 91
Fax no: 0866 12 27 12

Ombudsman: 011 72680900

Customer Care Email: customercare@africadirectlife.co.za

Complaints email: complaints@africadirectlife.co.za
Africa Direct Life website: www.africadirectlife.co.za