PiP Manager Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) and must comply with the FCA Handbook. Amongst the requirements is the principle that a firm ‘must pay due regard to the interests of its customers and treat them fairly’
The Treating Customers Fairly (“TCF”) principle aims to raise standards in the way firms carry on their business that will benefit consumers and increase their confidence in the financial services industry.
Specifically TCF aims to:
- help customers fully understand the features, benefits, risks and costs of the financial products they buy;
- minimise the sale of unsuitable products by encouraging best practice before, during and after a sale.
Desired consumer outcomes of TCF
The FCA has outlined six core consumer outcomes that it wishes to see as a result of the TCF initiative. These are:
Outcome 1 – Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture
Outcome 2 – Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly
Outcome 3 – Consumers are provided with clear information and kept appropriately informed before, during and after the point of sale
Outcome 4 – Where consumers receive advice, the advice is suitable and takes account of their circumstances
Outcome 5 – Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect
Outcome 6 – Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint
PiP’s* approach to TCF
It is the basic, underlying principle at PiP that THE CLIENT ALWAYS COMES FIRST. The PiP Board(s) will not tolerate any behaviour that fails to adhere to this principle. Any breach of this principle will constitute gross misconduct and will be subject to disciplinary action.
PiP has various policies and procedures in place, to promote sound conflicts of interest management, including but not limited to;
Personal Account Dealing Policy – A policy is in place that is applicable to all Employees. Any dealing undertaken by Employees which may give rise to a conflict is prevented.
Gifts, Benefits and Inducements Policy – A full Company policy is in operation and is applicable to all advisers and staff. Any corporate hospitality and gifts are to be declared to the Company’s compliance department. No instances of accepting a gift or hospitality whereby it gives rise to a conflict with one or all of our customers will be permitted.
Compliance Manual – The Company has a detailed Compliance Manual which all Employees must adhere to.
Data Security Policy – We treat Customer privacy extremely seriously and have in a place a comprehensive policy which ensures that all data is kept safe.
Financial Promotions – All forms of financial promotion material are subject to compliance review and approval to ensure that they are fair, clear and not misleading and that is it issued to customers only for whom it is intended.
PiP provides its products and services exclusively to UK Pension Funds. The PiP mission has been supported by a number of large UK pension schemes (“Founding Investors”) and it is therefore, ‘by pension schemes, for all pension schemes’.
The Founding Investors collaborate with PiP in the design of products to ensure they deliver the exposure and return profile that the pension schemes want.
Communications with investors will be open and transparent at all times and Founding Investors get the opportunity to comment on fund documentation before it is finalised.
Our Founding Investors have monthly update meetings and other investors can contact any member of the PiP team directly to discuss any concerns or to make a complaint.
*PiP refers to Pensions Infrastructure Platform Limited and its subsidiaries including PiP Manager Limited