Since 2023, every financial firm in the UK has had to work to a standard called the Consumer Duty. It requires us to act to deliver good outcomes for you — not merely to avoid breaking rules. This page sets out what that means in practice, in terms specific enough that you can hold us to them.
Most firms publish a summary of the regulation. That is not much use to you. What follows is what we have actually committed to doing, and what you should do if we fall short of it. If any of it reads as a promise we have not kept, that is a complaint, and we would rather have it than not.
The starting point
The Duty's core requirement is that we act to deliver good outcomes for retail customers. Underneath that sit three rules that shape how we work:
- We must act in good faith towards you.
- We must avoid causing you foreseeable harm.
- We must actively enable you to pursue your financial objectives.
That third one is the demanding one, and it is the reason our whole proposition begins with education rather than product. You cannot pursue a financial objective you have not been helped to understand. An adviser who answers only the question you knew to ask has not met this standard.
The four outcomes, and what we commit to
1. Products and services
What we recommend must be designed for people in your position, and must actually meet your needs.
What that means here:
- No product is recommended to you until an adviser has completed a documented assessment of your circumstances, your objectives and the risks you actually face.
- Every recommendation is checked against a documented advice standard, and any departure from it has to be justified in writing on your file.
- We will tell you when a product is not right for you, including when the right answer is to do nothing for now, or to spend your money on something else first.
- We will tell you if what you need is outside what we advise on, and where to go instead. Our scope is on the Legal & Regulatory page.
2. Price and value
What you pay must be reasonable relative to what you get.
What that means here:
- You will be told every cost — our fee, and any commission we receive — in writing, before you commit. How we are paid is set out in full on the Legal & Regulatory page.
- Cover has to be sustainable, not just adequate. A policy you cannot afford in three years' time is a bad outcome even if it is the right policy today, because cover that lapses protects nobody. We will discuss affordability over the whole term, not just the first premium.
- We will not recommend more cover than your circumstances justify in order to increase our commission. If you ever suspect we have, complain — it is precisely the kind of thing this Duty exists to catch.
3. Consumer understanding
You must genuinely understand what you are buying — not merely have been told.
This is the outcome our whole approach is built around, so we hold ourselves to something specific:
- Before you receive advice, you will be walked through the risks you face and what they would mean for your household — so that the recommendation answers a problem you recognise, rather than one we assert.
- Serious illness and critical illness cover will be explained including what is not covered and how severity affects what is paid. Exclusions are explained before you apply, not disclosed in the policy document afterwards.
- Nothing is left in jargon. If a word needs explaining, it gets explained, however basic it might seem.
- If English is not your first language, you can have the conversation in one of seven languages our advisers speak. Understanding a mortgage in a second language is hard enough without doing it under pressure.
- Your adviser will ask you to explain the recommendation back in your own words before you sign anything. If you cannot, that is our failure to explain, not yours to understand, and we will go again.
4. Consumer support
Getting help must be as easy as buying in the first place.
What that means here:
- You have a named adviser with direct contact details. You will not be routed through a call centre or a general enquiry queue to reach the person who advised you.
- We will help you make a claim, including dealing with the insurer on your behalf. Claims support is the point at which protection advice either proves its worth or does not.
- We will not make it harder to leave, change or reduce cover than it was to take it out.
- Complaining is straightforward, free, and set out on our Complaints page.
Customers who need extra support
The Duty requires us to pay particular attention to customers in vulnerable circumstances — and to understand that this is not a small or unusual group. Health, a recent bereavement, low financial confidence, language, a disability, caring responsibilities, insecure income: any of these can make a financial decision harder at a particular moment.
Our commitments:
- Advisers are trained to notice when someone needs more time or a different approach, and to adapt without being asked.
- You can ask for support at any point, and we will record what you have asked for so you do not have to keep explaining it. You can ask us to stop recording it at any time.
- We will never treat needing support as a reason to press on faster to get a decision. Where the right answer is to pause, we will pause.
- Where your situation needs help we cannot give, we will tell you and point you to someone who can — including free services such as MoneyHelper and Citizens Advice.
How to tell us what you need, and what we can do, is set out on the Legal & Regulatory page.
How to hold us to this
A published commitment is worth nothing without a way to enforce it. So:
- If you did not understand something you signed — tell your adviser, or tell us. We will explain it again and, if you want to change your mind, we will tell you honestly what your options are.
- If you were not told a cost before you committed — that is a breach of what is written above. Complain, and we will look at whether you are owed a refund.
- If you felt pressed — we want to know. Pressure has no place in advice and an adviser applying it is not meeting our standard.
- If you cannot reach the person who advised you — call 01270 747 989 and we will get you to someone who can help.
Client files are reviewed by our principal firm, which is accountable to the FCA for our advice. Complaints are recorded with their cause, not just their outcome, and feed into adviser training. Advisers work to documented advice standards rather than personal preference, so a recommendation can be tested after the fact against what the file shows about your circumstances. None of this is a guarantee we will never get something wrong. It is how we find out when we have.