Customer Reviews and Marketing Policy

1. Scope

This Customer Reviews and Marketing Compliance Policy (“Policy”) applies to all Central Trust Limited (“CTL”) employees, introducers, and affiliates who engage in review-related activities.

2. Amendments and Review Principles

Any amendments to this policy will require approval by the Head of Compliance and Conduct Risk and Chief Executive.
This Policy will be reviewed on at least an annual basis or more frequently as required by business activities and/or regulatory requirements.

3. Purpose and Scope

The Digital Markets, Competition and Consumers Act 2024 (“DMCCA”) introduced strict legal requirements regarding the collection, publication and use of consumer reviews to prevent misleading practices. CTL does not host its own reviews but actively encourages customers to provide feedback via an independent third-party platform; Trustpilot.

This Policy outlines CTL’s approach to complying with the DMCCA and ensuring transparency and fairness in how reviews are solicited, used in marketing, and monitored for fraudulent activity. CTL’s commitment to compliance includes:

fair and neutral solicitation of customer reviews;
accurate representation of customer feedback in marketing materials;
proactive detection and mitigation of fraudulent or misleading reviews; and
clear responsibilities for ensuring compliance across business functions.

Failure to comply with DMCCA obligations could expose CTL to regulatory enforcement, reputational harm or financial penalties. This policy mitigates these risks by implementing robust controls and oversight mechanisms.

This policy also reflects CTL’s obligations under:

FCA Principles for Business;
the CAP Code (UK Code of Non-broadcast Advertising); and
Consumer Protection from Unfair Trading Regulations, especially as they relate to the use of testimonials and consumer perception.

4. Interaction with Consumer Duty

In addition to the DMCCA, CTL aligns this policy with the FCA’s Consumer Duty (Principle 12 and PRIN 2A), which requires firms to deliver good outcomes for customers. This includes:

acting in good faith by ensuring customer reviews are accurate, representative and fairly presented;
enabling informed decision-making by providing unbiased access to customer feedback; and
avoiding foreseeable harm by preventing misleading, fake or manipulated reviews that could distort consumer choices.

5. Soliciting reviews

Under Section 219B (2) of the DMCCA, businesses must not solicit, commission, or encourage fake reviews or engage in practices that mislead consumers about the authenticity of reviews.
CTL ensures compliance by applying a consistent, non-selective approach across customer interactions. This means during the underwriting process, all customers, regardless of their experience, are given an equal opportunity to provide feedback.

Customers are invited via email to provide feedback on Trustpilot once their loan has completed. Customers are also informed during the security call, prior to pay-out, that an email containing a link to Trustpilot will be sent to them if they want to leave a review about their experience with CTL. This forms part of the security call script so all customers are informed of the opportunity to provide feedback. Sample reviews of the security call are reviewed as part of first and second line quality assurance to ensure the scripts are followed correctly.

The Trustpilot reviews are checked by the Head of Operations and feedback is communicated to the Underwriting Manager and the team as needed. The reviews also form part of the Consumer Duty MI presented to the Board on a quarterly basis.

Any negative feedback is responded to on Trustpilot directly so customers can see our response. We would also try to initiate contact directly with the customer to determine if they want to raise a complaint or if any other action is needed.

6. Preventing fake or misleading reviews

Under Section 219C of the DMCCA, businesses must take reasonable and proportionate steps to prevent fake or manipulated reviews.
All Trustpilot reviews are monitored by the Head of Operations to identify any fake reviews. If we identify a review which is spurious, we report this to Trustpilot.

CTL responds publicly to false claims, ensuring misleading content is not left unchallenged.

7. Marketing and use of reviews

Under Section 219B (1) of the DMCCA, businesses must not misrepresent customer feedback by selectively publishing positive reviews or displaying misleading star ratings.
All reviews are visible on Trustpilot to ensure customers can always see the full, unfiltered review history. This ensures that potential customers see a balanced and real-time reflection of customer feedback.

All marketing material featuring customer reviews include an overall average rating and all customer facing marketing material is reviewed by Compliance to ensure these guidelines are followed.

If a customer quote is used in advertising, it must be accompanied by CTL’s most recent rating to prevent cherry-picking. The use of customer feedback / reviews is not permitted where the review is outdated. Customer reviews may be considered outdated where the business, service or product has changed significantly since the review or where the review is no longer reflective of the recent customer feedback and average review ratings.

8. Enforcement against third parties

If an introducer, affiliate, or broker is found to have engaged in misleading review practices, CTL will take the necessary action to maintain compliance. This could include; issuing formal feedback, formal warnings or terminating third party relationships.

9. Rewards and recognition

No employee or third party may be rewarded for securing a positive review.
Recognition is based on overall customer service performance and compliance with this policy.

10. Record Keeping

All review solicitation communications, monitoring logs, customer responses, and quality assurance activities must be retained for a minimum of 6 years and made available to regulators upon request.