Treating customers fairly

Central Trust is committed to treating all customers fairly. All marketing and advertising is clear, fair and not misleading. All customer data is kept secure at all times, and sensitive data is encrypted if transferred to, or from, third parties.

Central Trust lends responsibly, ensuring customers receive recommendations on loans, mortgages and other products that are suitable and affordable to them. Any complaints are handled impartially and on their own merits. Central Trust is also sensitive to customers in financial difficulty – repossession is only considered as a last resort.

Policy for Treating Customers Fairly – May 2009

Central Trust is committed to the principles of TCF. Customers need to feel confident that we see the fair treatment of customers as central to our culture and to the long-term success of our business.

We have translated this commitment into a series of themes, which underpin our operating model, systems and processes. The themes have been designed around the “Customer Journey”.

Product Design and Governance

As a distributor of mortgages, secured loans and non-investment insurance contracts, we have a responsibility to ensure that we work in conjunction with lenders and providers to offer products that focus on the needs and circumstances of the end consumer.

The design of products extends beyond the product itself to encompass the sales delivery method/distribution channel and, more pertinently, the clarity and fairness of the supporting documentation. When assessing TCF in product design we consider the inherent risks and complexity of each product distributed.

Marketing and Financial Promotions

A central part of our approach to TCF is that all marketing materials/activities are clear, fair and not misleading. The fair treatment of customers is paramount throughout the whole sales process, ensuring the potential for misleading customers is eliminated.

We commit to ensuring that:

• We understand the expectation our marketing material sets in the minds of the customer
• We meet the expectation our marketing material sets in the minds of the customer
• We target known/understood customer groups with marketing that is appropriate for each audience
• We promote and reflect fair lending

All marketing material, including advertising, mailshots and website material, is approved before issue.

Fair Lending

We commit to ensuring that every sale passes three key tests:

• Eligibility – Is the customer eligible for a product offered?
• Choice – Have we provided the customer with the optimal choice of products based on their individual circumstances?
• Affordability – Is the customer able to afford their chosen financial commitment?

Complaints

Like any financial services organisation, we occasionally receive customer complaints. We ensure these complaints are addressed fairly and consistently.

Although the nature of complaints may vary, all complaints are considered with equal importance.

All complaints are reviewed as objectively as possible – the Complaints Team is independent of our Sales Teams.

We aim to respond in full to all complaints within eight weeks from receipt. This is monitored and reported to Senior Management Team and the Board.

We co-operate fully with the Financial Ombudsman Service, and respond within the deadlines they request.

Firm Name:	Central Trust PLC (303371)
Other firms included in this report:	Central Capital Limited Central Credit Limited Central Loans Limited Central Mortgages Limited Central Trust Insurance Brokers Limited Debt Problems Managed Limited
Period covered in this report:	1 January 2010 - 30th June 2010

1	A	B	C	D	E
		Number of complaints opened	Number of complaints closed	Complaints closed within 8 weeeks (%)	Closed complaints upheld by firm (%)
2	Banking	0	0	N/A	N/A
3	Home Finance	130	112	100%	25%
4	General insurance and pure protection	890	635	96%	28%
5	Decumulation, life and pensions	0	0	N/A	N/A
6	Investments	0	0	N/A	N/A

Arrears and Repossessions

The Collections Team operates under a comprehensive Arrears & Repossessions Policy. The Policy describes our responsibilities to customers who are in financial distress. The Policy requires that we treat every customer as an individual and that, wherever possible and practical, we will work with the customer to find ways to meet their contractual commitment to us. Repossession is only undertaken as a last resort, after the full court protocol has been met and every other option has been explored.

No repossession order can be made without the approval of any two of the Executive Chairman, the Group CEO, the Group Finance Director and the Head of Compliance. The Training and Competence arrangements within the Collections team are aimed at ensuring the Policy’s requirements are met. These are further monitored independently and regularly by Group Compliance and Group Internal Audit.

Client Communication

We aim to provide all communications with customers, whether oral or written, in a manner that is clear, fair and not misleading.

To this end, we are committed to:

• Informing customers of their rights and obligations
• Demonstrating appropriate timeliness in its dealings with customers and clearly informing them of applicable timeframes
• Obtaining sufficient information in order to understand our customers needs
• Managing conflicts of interest, with a clear demonstration of impartiality
• Providing consistency for all customers in our business dealings
• Acting to the highest ethical standards at all times
• Acting with integrity
• Demonstrating a high level of flexibility in all customer dealings
• Proving information in ‘Plain English’ and minimising the use of industry jargon in both written and oral communications
• Measuring, maintaining and enhancing the commitment to fairness and demonstrating accountability in our actions

Staff Remuneration

All our staff are salaried, with some employees being partly rewarded on performance.

Where bonuses/rewards are available to staff these are based on both results and behaviour (including full alignment with TCF). This is in line with the predominance of financial services organisations.

The Group does not reward any specific bias towards a certain lender or product.

Training Policy

A comprehensive Training and Competence programme is in force encompassing staff at all levels, including key senior management.

The on-going delivery of training and development ensures staff possess the necessary knowledge and skills to provide a service level that meets and surpasses the customer’s expectations.

All staff are subject to initial training and are then managed to ensure they maintain levels of competence. In addition, each employee has a personal development plan, tailored to their individual needs.

A skills gap analysis is performed on key personnel to ensure that the required skills and knowledge are maintained, or provided for, at all times.

We are committed to supporting all staff in their career development.

Management Information (MI)

We have comprehensive MI in place to monitor performance of each of our businesses.

Dedicated TCF MI is produced and reviewed on a monthly basis .

The TCF MI is not just numbers, it includes commentary and opinions to help provide a comprehensive and balanced view on each business.

Business Relationships

We maintain strong relationships with our lender panel, working closely to ensure product ranges meet the needs of our customers

Strategic Change

We consider how the treatment of customers may be affected after any strategic change and we have a robust check and challenge procedure in place to sign off any operational strategic change.

Data Protection

A comprehensive data security policy has been established to ensure customer data is secure at all times. This means that any customer data that is transferred to third parties, is encrypted. We require the same of any partners transferring customer data to us.

No customer data is stored on the hard drives of laptops. All PCs are configured to prevent the uploading of unlicensed software, and USB ports are disabled so that memory sticks and other such devices cannot be used.

All telephone calls with customers are recorded automatically and are retrievable only with the permission of designated individuals. No member of staff is permitted to use mobile phones to communicate with customers.

If there are any aspects of our advice, products or service which you feel fall short of these commitments please let us know at customer.feedback@centraltrust.co.uk