Responsible products and services policy statement

We’ve a set of policies, tools and processes in place that help our people build products and services that work; are safe, and meet our members’ needs. A key part of this is the requirement to follow a set path of governance when we design each product/service, and then the ongoing monitoring of those products and services. This gives us opportunities to consider and make informed decisions about some important points, such as:

Critical to our design process is the need to ensure that any product or service offers a fair exchange for our members’ money, as well as whether the features and benefits are easy-to-use for the people for whom they’re intended. We also take into account whether members have reasonable alternatives across the rest of the financial market, and make efforts to ensure we do not disproportionately impact particular groups of members. Guidance documents exist to ensure the risk of this happening is thoroughly tested and controlled.

We‘re dedicated to ensuring vulnerability remains a priority consideration at all points when we’re thinking about our products and services. An internal Customer Vulnerability, Accessibility and Inclusion Standard is in place to make sure we’ve considered all of the different skills, capabilities and needs of our members. This is used when designing or changing products or services to make sure we don’t disadvantage these members. And that any reasonable adjustments to the design and operation of the product or service have been explored.

Our Terms and Conditions Monitoring Standard sets out how they should be written – to make sure they’re clear and fair in how they explain key information, as well as any risks that could be associated with the product or service. It’s important that our members can understand their options and make informed decisions on whether our contracts are right for them. Approval of these Terms and Conditions is managed through our Communications Policy. We also monitor those terms for any changes that need to be made, and measure whether they’re being followed by our members.

Guidance is available to make sure our people consider many different factors as they explore how to price products fairly. This includes considerations such as the cost of the product or service itself, what other banks or building societies are offering, and whether there are any offers or discounts that might be appropriate. These decisions are approved by our Pricing Committee, attended by Senior Managers from across our business.

Our internal Climate Change Standard sets out an approach for understanding climate change risk and how we can minimise any negative impact. This includes a requirement to document the impact of new or changing products or services to our overall climate change risk. This might include factors such as an increased reliance on people, processes or locations that could lead to increased energy outputs. Where a risk is identified, there’s a requirement to identify ways to mitigate it.

Embedded in our processes is the need to consider the financial and political landscape as a whole. To make sure we remain responsible and fair, we actively prohibit anti-competitive behaviours, such as the creation of monopolies, or anything that could negatively impact the integrity of the financial market. Our Market Abuse Policy further reinforces our commitment to this.

At regular points throughout the life of each of our products and services, risk assessments and testing take place to make sure we understand and manage any risks we find. Approval routes for our products are documented and take the form of reviews, forums, and committees attended by experts from across the business. Together, they must approve or endorse decisions.

We’ve documented sales journeys and processes in place that clearly outline our commitment to responsible marketing. This is backed by a responsible marketing policy, which outlines what, when and how we should share information with our members, and responsible selling practices. Doing the right thing for our members is deeply engrained within our culture, and is heavily reinforced in numerous ways, including:

All our customer-facing colleagues receive mandatory, formal training to make sure they’ve the right skills and knowledge to support our members. Colleagues in regulated advice roles, such as Mortgage Advisors, are also equipped with role-specific qualifications. This level of skill is maintained with regular training updates, and a percentage of all processes are quality checked to make sure they’re being followed correctly.

We prohibit any schemes that could encourage poor selling practices. This includes targets or rewards linked to individual sales performances. All eligible colleagues are enrolled in the same discretionary reward scheme. The outcome of this scheme depends on the business as a whole meeting certain financial, risk and customer satisfaction measures.

We make every effort to ensure members have all the information they need in a clear, fair and not-misleading manner. We also make sure that they get it in a timely way to allow them to make informed decisions on the products and services that are right for them. We want to make this as easy as possible, without the need to speak with us if they don’t want to. Featuring on external comparison websites helps members assess our products against a range of options, as well as provide some tools and advice services of our own. In the event a customer doesn’t qualify for their desired product or service, we tell them why.

It’s important that we provide a number of ways for our members to choose and use their products and services. And accommodate a wide range of accessibility needs and preferences without unnecessary barriers. Understanding the impact of not offering a product or services across all channels, at the point of design, ensures we’re well positioned to take reasonable steps to remedy this. We continue to monitor this throughout the product lifecycle and make changes wherever necessary.

We’ve documented sales journeys and processes in place that clearly outline our commitment to responsible marketing. This is backed by our responsible marketing policy, which outlines what, when and how we should share information with our members, and responsible selling practices. Doing the right thing for our members is deeply engrained within our culture, and is heavily reinforced in numerous ways, including:

Customer satisfaction is at the heart of what we do. To support it, we measure and report how satisfied our members are with their interactions with us through all stages of their journey. We’ve a range of ways to understand whether our members are receiving fair outcomes and what their overall levels of satisfaction are with our interactions. We also work with external, independent bodies to compare our performance against others in the industry.

We understand that circumstances can change, and that anyone can experience financial worries. We’re committed to treating everyone as an individual – making it easy for our members to get the information they need. And also working with them to explore how we can manage their debt. We’ve a dedicated Specialist Support Team who exist to give extra help to members who are vulnerable or have additional needs, as well as referring them to external agencies.

We take our responsibility to manage customer complaints seriously. And we aim to do so in a way that is fair and seeks to go beyond what is required by regulation. If unfair customer outcomes arise, or expectations haven’t been met, a set of processes, systems and guidelines are in place and fully trained employees will log, investigate and respond to all complaints. We’re committed to communicating clearly and in a timely way with our members; to fix these problems and make sure they receive any appropriate compensation.

Our main policy guiding the design, sale and service of our products and services is owned by our Director of Retail Products. It’s overseen and approved by internal committees that are attended by Senior Managers and experienced risk professionals from across the business. We also make an effort to engage with external stakeholders and initiatives to share best practice, expertise and ways of improving the financial services industry as a whole.