Duty of Care Documents

1. Complaints Procedure

We're dedicated to providing you with the best possible service. In the unfortunate circumstance that you have a complaint please contact us immediately by either one of the following means:
By Post: The Car Net, Unit 6, Midland Structures, Industrial Estate Bedford, Bedfordshire MK42 9JJ  

By Telephone: 07512 329906  

By Email: [email protected]

Acknowledging your complaint
If you are dissatisfied in any way with the service you have received and wish to make a complaint, we ask that you bring this to our attention as soon as possible so that we can try and resolve this for you. We will acknowledge receipt of your complaint within 5 working days. 

Investigating your complaint 

Our Customer Care Team will investigate your complaint fairly, consistently and promptly. They will assess: 

• The nature of your complaint. 
• Whether any third party is involved in the complaint (such as the lender). 
• How we should resolve the complaint. 
• Our Team will look at all the available evidence and the circumstances of your complaint. 

They'll also take into account any relevant laws or regulations. During the course of our investigation, the Customer Care Team may need to obtain detailed information from you or any third party involved in the complaint. In order to deal with your complaint promptly and thoroughly, we ask that you help by communicating openly and accordingly with our Team. We'll keep in touch throughout the process, and we'll be happy to answer any queries you may have about how we're progressing. 

Final Response 

Our Team will endeavour to send you a Final Response within 8 weeks from the receipt of your complaint. If we are unable to provide you with a Final Response within this time, we'll send you a response to explain why we've not been able to complete our investigation, and also give you an indication of when we expect to be able to provide you with a Final Response. If you are not happy with our response, and you are an eligible complainant, you can escalate your complaint to the Financial Ombudsman. If you would like the Ombudsman to look into your complaint, you should contact them within 6 months of the date of our Final Response. They may ask you to send a copy of this. 

Eligible complainants are: 

• A consumer 
• Companies within the EU definition of a microenterprise 
• Charities with an annual income of under £6,500,000 
• Trustees of a trust with assets of under £5,000,000 
• A small business (only an eligible complainant if the conduct took place after the 1st April 2019) 
• A guarantor The Ombudsman is a free and impartial service for resolving disputes between consumers and financial services institutions and their contact details are set out below. 

By Post: The Financial Ombudsman Service Exchange Tower London E14 9SR By phone: 0800 023 4567 or 0300 123 9123 

By email: [email protected] 

Website: www.financial-ombudsman.org.uk 

We'll maintain records and provide the Ombudsman or the Financial Conduct Authority, on request, details of all complaints handled by us.

2. Treating Customers Fairly

This policy is to outline the responsibilities of The Car Net towards our customers to ensure we treat them fairly under the FCA’s principle. 

All firms regulated by the FCA have to support the FCA Sourcebook’s principle that a firm ‘must pay due regard to the interests of its customers and treat them fairly’. The TCF (‘treating customer fairly’) principle aims to raise standards in the way firms carry on their business by introducing changes 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. 
• All firms must be able to show consistently that fair treatment of customers is at the heart of their business model and above all, customers expect financial services and products that meet their needs from firms they trust. 

What does treating customers fairly (TCF) mean? 

Firms are responsible for making sure customers are treated fairly. The FCA’s principles apply to all business behaviour and in particular Principle 6 says: ‘A firm must pay due regard to the interests of its customers and treat them fairly’. The TCF principles aim to raise standards and increase consumer confidence in the financial services industry. The TCF initiative aims to deliver six outcomes. 

• Outcome 1: Consumers can be confident 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 are 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 products, switch providers, submit a claim or make a complaint. 

At The Car Net, we are dedicated to treating customers fairly and putting our customers at the heart of everything we do in all areas of our day to day activities. As a result, TCF is an integral part of our culture and is embedded in all aspects of business and values. 

What you can expect from us:

Our STANCE on TCF shows what TCF means to us. It takes into account the six FCA outcomes: 

S – Suitable products – Outcome 2 

T – Transparent information – Outcome 3 

A – Appropriate advice – Outcome 4 

N – No post sale barriers – Outcome 6 

C – Confidence in our culture – Outcome 1 

E - Expectations fulfilled – Outcome 5

As a business we need to ensure TCF is bred in our culture and in our values, we will achieve this through:

Suitable Products 

• Carrying out income, expenditure and suitability checks to ensure affordability and sustainability. 
• Manually underwriting all customer applications to ensure the most suitable and appropriate funder is selected based on the customer’s credit profile, employment and vehicle, to reduce the negative impact on the customer credit history. 
• Ensuring the Consumer Credit Information document is provided before the customer enters into any agreement, ensuring the customer fully understands what they are committing to. 

Transparent information 

• Offer a transparent and professional service to help customers make an informed choice. 
• Making sure that any promotional material is clear, compliant, jargon free and appropriately targeted. 
• Ensuring Sales Executives and all customer facing Employees have thorough training on all products, so they have a full understanding of the features and benefits to be able to pass this information on to the customer. 
• Providing customers with clear accessible literature and product information. 
• Making the customer journey as easy as possible and getting it right first time Appropriate advice 
• Providing ongoing feedback, coaching, developing and training for all our staff. 
• Training non-sales staff to implement TCF in their day to day business activities to improve the culture within the businesses. 
• Ensuring Employees are kept up to date with relevant training in relation to competence, data protection and other matters directly affecting the quality of service offered to customers. 
• Holding TCF focus groups where staff can provide feedback on the customer journey and processes and encouraging staff to submit process improvements and feedback on documents, criteria and the customer journey. 
• Keeping staff informed of issues identified through monitoring, recording of complaints and dissatisfaction. No post sales barriers 
• Having a process in place to record dissatisfaction and complaints and having a fully trained complaints handler to deal with these. 
• Keeping customer records of all conversations before and during the application and recording relevant information on company systems so we can deal with any complaints that may arise swiftly and fairly. 
• Making sure customer complaints are assessed fairly, promptly and impartially, and in line with FCA deadlines and rules. 

Confidence in our culture 

• Having processes in place to identify and combat money laundering and fraud. 
• Only proposing each customer with suitable lenders. 
• Continual monitoring and quality checks through call, case and process monitoring. Implementing sales remuneration packages that promote the TCF culture and customer satisfaction, rather than awarding sales volumes. 
• Department Managers to Complete monthly reviews as well as coaching/training sessions with all Employees. 
• Having strong ethical Values that are evidenced in the workplace. 

Expectations fulfilled 

• Having and encouraging a solution (process) in place for customers, dealers and funders to provide feedback. 
• Ensure we implement a contact questionnaire with clients after a deal has been concluded to help or improve on the service already offered. 
• Monitoring and reporting on all of the above TCF activities as part of the company’s monthly statistics/MI, to assess TCF performance across the businesses. 
• Ensuring that TCF values, which are set and communicated by Senior Management, are supported by all staff and understood in the same way. 

How we work with you 

We want to work with you in a way that is TCF so that you can enjoy the best possible service from The Car Net so that we can deliver this, we rely on you to: 

• Provide accurate information. 
• Ask us if you are uncertain about any aspect of the product or service. 
• Read any literature made available to you. 
• Use cooling-off periods to consider whether to go ahead. o Keep us up to date if any of your circumstances change. 
• Let us know straight away if you feel that you have been treated unfairly so that we can try our utmost to put this right for you.

What do you do if you feel you've been treated unfairly? 

If you feel that you have been treated unfairly then it is important that you let us know so that we can investigate this straight away. If you wish to make a complaint you can do so via our Complaints Handling Procedure.

3. Vulnerable Customers Policy

How do we identify Vulnerable Customers? 

In order for The Car Net to address the needs of Vulnerable Customers we will first need to be able to identify them. There are many risk factors involved including bereavement, illiteracy, illness, disability or other impairments which increase a consumer’s vulnerability. 

Our team remains alert to the signs that the person we are talking to may not have the capacity to make an informed decision regarding the implications of the services/agreement that we are making to them. The Mental Capacity Act says that a person is unable to make a specific decision if they cannot understand information about the decision to be made, cannot retain that information in their mind, cannot use or weigh that information as part of the decision-making process or cannot communicate their decision. 

As part of our customer experience at The Car Net we always look out for vulnerable consumers and we aim to help and support them by: 

• Training our customer facing staff so they are able to deal with vulnerable customers appropriately. 
• Observing and involving other members of staff who can provide help and support. 
• Being patient and taking time to listen and facilitate a conversation with the customer so that they fully understand. 
• Sharing information with our Partners regarding the customer’s current situation. 
• Understanding the customer’s needs and demonstrating compassion. 
• Allocating a familiar primary contact for the customer ensures consistency and trust. 
• Rewarding, recognising and praising good practice in relation to vulnerable customers. 
• Simplifying language so it is clear and easy to understand and avoiding use of industry jargon. 

What do we look for? 

In order to identify vulnerable customers, our staff are trained to ask themselves the following questions: 

• Do they ask us to speak more slowly? 
• Do they understand what we are saying? 
• Can they hear the whole conversation without missing bits? 
• Are they aware of what is being discussed? 
• Are they asking unrelated questions? 
• Do they sound flustered or out of breath when they answer the phone? 
• Do they say 'yes' to a question that they have not understood? 
• Do they keep repeating themselves? 
• Do they suggest another family member deals with things for them? 
• Do they say they have not understood previous correspondence or communication? 

Communicating with Vulnerable Customers 

When we communicate with vulnerable customers we ensure that we: 

• Speak clearly to customers. 
• Set the expectations for the discussion. 
• Demonstrate patience and ensure we do not rush them. 
• Do not assume we know the customers’ needs. 
• Keep the discussion on the relevant topic. 
• Offer the customer a different method of communication. 
• Accept that customers can be forgetful. 
• Double check the customer has heard what we have said. 
• Check in case the customer does not have a clear vision. 
• Ask the customer if they need to speak to anyone before they make a decision. If a customer is not in a position to make a decision or does not have the capacity to do so, we try to find a family member, carer or someone with authority and with appropriate ID who can act on their behalf. We ensure that the authorised person knows exactly what is expected of them. If a vulnerable customer is identified, a senior manager then checks to ensure the customer’s needs have been met.
• If at any time you feel you have not been treated fairly by any member of our staff, please contact us by writing to The Car Net, Unit 6, Midland Structures, Industrial Estate Bedford, Bedfordshire MK42 9JJ or by telephone 07512 329906