The Financial Services Board (FSB) introduced TCF to ensure that the fair treatment of customers is embedded within the culture of regulated financial firms. TCF is an outcomes based regulatory approach that seeks to ensure that specific, clearly articulated fairness outcomes for financial services consumers are delivered by financial institutions.
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.
TCF will form a key component of the new Market Conduct Regulator’s mandate in the Twin Peaks model.
The FSB has already started taking TCF into consideration in a supervisory approach.
Hollard’s approach to TCF was to “expand our DNA”, by creating an internal campaign to raise awareness on this initiative by training our staff, and then rolling out externally once we were confident that TCF had become central to our culture.
The six outcomes of TCF are as follows:
Outcome 1 | Culture and Governance
Clients are confident that they are dealing with firms where the fair treatment of customers is central to the firm culture.
Outcome 2 | Product Design
The products and services marketed and sold are designed to meet the needs of identified customer groups and are targeted accordingly.
Outcome 3 |Clear Communication
To give clear information to clients and keep them informed before, during and after the time of contracting.
Outcome 4 | Suitable Advice
Where clients receive advice, the advice is suitable and takes account of their circumstances.
Outcome 5 | Performance and Standards
The performance of products and service levels are according to our clients’ expectations.
Outcome 6 | Claims, Complaints and Changes
Clients do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint.
The Hollard vision is “To go beyond the basic principles of TCF by building win-win relationships with our policyholders and embedding the fair treatment of customers in our culture, strategy, and processes. In doing so, we earn the right to a sustainable future.”
We worked on the initial implementation date of 1 January 2014 to guide our internal campaign, and concluded gap assessments in September 2013. This determined key focus areas.
We created the Hollard TCF program which comprises of a Steering Committee, represented by each Business Unit Exco Member and chaired by our CEO Nic Kohler. In addition, there is a Working Committee, with representation from each Business Unit and Support Area, which meets on a monthly basis. During this session business units have an opportunity to raise TCF related risks and debate TCF matters. Each area provides feedback to the group on the progress made on their own TCF journey. This way the various areas hold each other accountable. The Steering Committee meets on a quarterly basis to review the overall progress made on the Hollard TCF journey, to discuss issues on which the Working Committee has not been able to meet consensus and to address any non-performing areas.
To ensure staff buy into the concept of TCF our internal campaigns were fun, factual and linked to the Hollard Way, our values and our company goals. The first campaign was a game show, Hollardites received a Rubik’s cube with the six outcomes and were given an opportunity to participate in a game show during the Hollard socials. Later we gave all Hollardites playing cards with the outcomes and the detail so Hollardites could match the outcome to the description. This is kept on the Hollardites desk to remind them daily. Once we were comfortable that Hollardites knew what we were talking about we launched the “mouth burn” insurance product in our coffee shop. Hollardites would collect serviettes from the coffee shop with their coffee and answer the riddles in terms of fairness of the product.
To ensure TCF remains top of mind all Hollardites received TCF lunch boxes – each time they opened their lunch box they’d be reminded of our TCF commitment.
Since TCF is not an event but a way of life for Hollardites, we have regular electronic campaigns and campaigns around the Hollard buildings reminding Hollardites that the customers are at the heart of everything we do.
In addition, all Hollard team members are required to complete the TCF e-learning module and assessment, ensuring that they understand their responsibilities and impact in terms of TCF.
Embedding TCF in the Hollard culture has led to the following great initiatives:
Hollard developed a claims philosophy which sets out our commitments in terms of claims payments, the ethos that needs to be applied when making claims decision, as well as the principles that need to be applied and our position around claims decisions in certain circumstances. This philosophy is linked to the Hollard Way and Purpose to ensure that our service culture is driven through everything we do. We insist that our partners who deal with our customers at claims stage are well versed in the claims philosophy and that they apply it in the same way that we would.
We created forums to review claims. The forums consist of various experts from all parts of the business and value chain. The claims are reviewed in light of the contract, legal aspects and TCF in order to make a final decision on the claim outcome. The forum ensures that decisions are aligned and similar situations enjoy similar outcomes to ensure overall fairness.
Complaints Management Process
Complaints are a massive part of TCF and we have committed to making sure that we have adequate processes in place to ensure fair treatment of our customers even when things went wrong. To that end we created the a detailed Complaints Management Process which is applied across Hollard and our partners in order to ensure consistent processing of complaints, decision making and root cause analysis.