Treating Customers Fairly Policy

1 PURPOSE

1.1. The purpose of this document is to set out the Firm’s TCF strategy (i.e. the Firm’s approach to ensure that paying regard to the interests of its customers and treating them fairly is embedded into its business strategy). This document sets out how the Firm meets the six TCF outcomes which underpin the FCA’s TCF initiative.

1.2. This document is for the use of all the Firm’s staff including the Firm’s senior management team, middle management and frontline staff.

2 REGULATORY REQUIREMENTS

2.1. Consumers are placed at the centre of the FCA’s regulatory regime and their protection is one of the FCA’s operational objectives. The FCA advances its consumer protection objective through its high-level principles, as set out in the Principles for Businesses module of the FCA Handbook, and specific conduct rules that apply to the Firm’s regulated activities.

2.2. The Principles for Businesses that underpin the fair treatment of customers are as follows:

2.2.1. Principle 1 - A firm must conduct its business with integrity;

2.2.2. Principle 2 - A firm must conduct its business with due skill, care and diligence;

2.2.3. Principle 3 - A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems;

2.2.4. Principle 6 - A firm must pay due regard to the interests of its customers and treat them fairly; and

2.2.5. Principle 7 - A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.

2.3. The relevant Principles for Businesses set out above give a rounded view of what the fair treatment of customers entails, underpinned by Principle 6 which sets out the Firm’s obligation to ensure that the fair treatment of customers is embedded in its corporate culture and reflected in all aspects of the Firm’s business strategy.

2.4. The FSA (the FCA’s predecessor) developed six consumer outcomes which explain what the TCF initiative seeks to achieve.1 Principle 6 and the associated six TCF outcomes set the baseline of the FCA’s expectation of how firms should treat consumers.2

3 TCF OUTCOMES

3.1 TCF Outcome 1 Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture. As a company we are dedicated to upholding the fair treatment of our customers at the heart of our corporate culture. We strive to build trust and confidence by prioritising ethical practises and ensure our customer's needs are met with the utmost care and respect. we also ensure that the practises we operate within our business and with our partners promote this approach for example ensuring that all customers using consumer credit services are offered the chance to provide feedback via Novuna Personal Finance and reframing from offering staff incentives for the sales of products that involve consumer credit.

3.2 TCF 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. As a responsible and customer-focused business, we fully understand the importance of meeting consumer expectations. Our commitment to this principle is demonstrated through our rigorous process of ensuring that the products we promote are accessible and suitable for all customer types. We take great care to monitor and evaluate our offerings to guarantee that they cater to a diverse range of needs and preferences. Moreover, we are committed to ethical marketing practices, and we intentionally refrain from targeting specific customers outside of those who genuinely require heating and hot water solutions. Our focus remains on delivering products that address the essential needs of our customers, ensuring that they receive the utmost value and satisfaction from our offerings. By adhering to these principles, we strive to build lasting trust with our customers and contribute positively to their lives.

1 Paragraph 2.1 of Financial Services Authority: Treating customers fairly – towards fair outcomes for consumers (July 2006) 2 Page 13 of Financial Conduct Authority: Our Approach to Consumers

Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale. As a business, we are committed to upholding the principle of providing clear and transparent information to consumers at every stage of their buying journey. Our dedication to this core value drives us to continually review and improve our processes, ensuring that we consistently meet and exceed these expectations. From marketing materials to product descriptions, we strive for clarity, accuracy, and compliance with consumer protection regulations. We work closely with our partners to ensure they also embrace these principles, conducting regular audits to verify their adherence to our high standards. Through our online sales platform, we offer comprehensive product details, clear pricing, and accessible customer support, empowering our customers to make informed decisions. By prioritizing transparency and consumer education, we aim to build trust and nurture lasting relationships with our valued customers.

3.3 TCF Outcome 4 Where consumers receive advice, the advice is suitable and takes account of their circumstances. As a customer-focused business, we strive to meet the expectation of providing suitable advice that considers each individual's circumstances. However, we do not offer direct advice. Instead, we encourage our customers to seek independent guidance from qualified professionals to tailor recommendations to their unique needs and financial situations. We provide transparent and comprehensive information on our products, empowering customers to make well-informed decisions and compare different offers and payment solutions. Our commitment to "Treating Customers Fairly" lies in respecting their differences and supporting them in finding the best solutions aligned with their specific goals. Trust and customer satisfaction are at the heart of our approach, ensuring a customer-centric environment that prioritizes the success and well-being of our valued clients.

3.4 TCF 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. At our company, we take the FCA's principle of ensuring that consumers receive products and services as expected very seriously. Our commitment to meeting this expectation is at the core of our business practices, and we continuously strive to deliver on our promises to our valued customers. We firmly believe in transparent and accurate communication with our customers. When promoting our products and services, we ensure that all information provided is clear, precise, and reflective of what customers can genuinely expect. This includes highlighting product features, benefits, and potential risks in a straightforward manner, enabling our customers to make informed decisions. Our focus on customer satisfaction extends to the quality of our service. We work diligently to maintain an acceptable standard that aligns with what we have led our customers to expect. Our customer support teams are readily available to address any inquiries or concerns promptly, ensuring a seamless and positive experience throughout their journey with us. To validate our commitment to this principle, we regularly seek feedback from our customers. We take their input seriously and use it to improve our offerings and services continuously. By actively listening to our customers, we can identify areas of improvement and adapt our practices to better meet their expectations. By upholding the FCA's principle, we aim to build long-lasting relationships with our customers based on trust and reliability. We understand that providing products and services as expected is the foundation of a customer-centric approach, and we remain steadfast in our dedication to fulfilling this expectation at every step of our interaction with our valued customers.

3.5 TCF 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. As a customer-oriented business, we wholeheartedly support the principle of not imposing unreasonable post-sale barriers on our valued customers. We take great pride in providing multiple mediums for our customers to raise their concerns, submit claims, or make complaints. Our dedicated customer support teams are readily available through various channels, ensuring that customers can easily reach out and have their queries addressed promptly and efficiently. Moreover, we place a strong emphasis on delivering clear and comprehensive information about our offerings. By ensuring that our customers have a complete understanding of what is provided, we empower them to make informed decisions that align with their needs and preferences. We also extend this ethos to our partners, collaborating with them to ensure that our customers receive the same level of accessibility and transparent communication throughout their journey. Together, we strive to create a customer experience that is free from unnecessary barriers and fosters mutual trust and satisfaction. At the heart of our business philosophy is the belief that putting customers first and providing them with a hassle-free experience is fundamental to our success. By embracing the principle of removing unreasonable post-sale barriers, we reinforce our dedication to "Treating Customers Fairly" and fostering long-lasting, positive relationships with those we serve.

4 GOVERNANCE

4.1 APPROVAL It is the responsibility of our board to approve all company policies and the approved person to oversee the review of this policy on an annual basis.

4.2 INTERNAL AUDIT All policy’s of this type are reviewed by the consumer credit team on an annual bases overseen by the Approved Person who is also a legal board member.

4.3 REVIEW All company policies are reviewed on annual basis by the board of directors to ensure they meet the company requirements. In addition auditing is completed by the wider parent company as and when needed.

5 RECORD KEEPING

5.1 RECORD STORAGE In general due to our business model, we keep very limited records on our customers. Normally only if a complaint is raised directly with us will we make a customer record. However in the case that we do the following applies. • If we identify particular communication needs, we store that information so future contacts are handled appropriately with their permission • We record that we are satisfied that the customer completely understood everything that was discussed • We allow customers to make a personal declaration about their capabilities or communication needs and store this information with their permission • Any records that are held are with the full knowledge and consent of the customer and are deleted when the relationship no longer exists in accordance with GDPR

5.2 RECORD RETENTION In line with the process identified in Section 7, holds all records inline with GDPR requirements as set out in our data protection policy and deleted when the relationship expires.