Checks and balances on our work with customers.


We have a wide range of products, propositions and funds. We have a governance framework and robust processes to ensure we develop, manage and exit them in a way that delivers the right outcomes for customers.

Internal governance

  • Our Advertising Standards Function ensures we communicate with customers in a way that is compliant with FSA rules and guidance, UK advertising codes and our own brand values. It also makes sure customers are treated fairly.
  • Each business channel has a Product committee which approves product launches and oversight of ongoing products.
  • Complaints are a key way of getting feedback from our customers. Complaint trends are monitored, reviewed and acted on in each business area and also at a quarterly Complaints Committee attended by senior business management.
  • We have a Conflicts of Interest policy, which sets out our framework to make sure we identify and manage conflicts to prevent any adverse impact on our customers. Read more in Policies and standards
  • We have reviewed our Anti Bribery and Corruption policy to show our customers that we take our role seriously when protecting their finances from financial crime. Read more in our Policies and standards

EXTERNAL GOVERNANCE

There are a number of ways in which we ensure external checks and balances on our work commitment to customers. Highlights include

  • We measure the degree of loyalty that our customers have for our brand in terms of likelihood to re-purchase the product/service in the future. This is increasingly important with the RDR (Retail Distribution Review) regulatory environment in which consumers need to be clearer about who provides their financial services. This brand metric is also an indicator of customer satisfaction with the product and service, and hence retention.
  • The Financial Ombudsman Service (FOS) also publishes industry data on how many clients ask for an independent review of a complaint decision made by a financial services provider. Performance against our competitors is published online here http://www.ombudsman-complaints-data.org.uk/ In 2011 the FOS overturned a lower proportion of our decisions on complaints compared to the industry average in each sector. This helps to show that we are handling complaints fairly, although we have taken steps to improve further, especially on General Insurance.
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