The group considers that Treating Customers Fairly (“TCF”) has always been part of its business culture. It ensures its regulated businesses comply with the FSA principle that “a firm must pay due regard to the interests of its customers and treat them fairly” and supports the FSA’s initiative to embed TCF in business culture. The group aims to deliver to all customers for all products and services fair outcomes based on high standards of conduct and considers that every business has implemented TCF thoroughly.

During the year, all businesses completed a TCF gap analysis to identify any areas for review and each board has adopted a TCF policy statement developed by the business. Compliance with the FSA’s TCF objectives is monitored through management information provided periodically at board meetings. All new products and services are reviewed at inception to ensure those objectives have been addressed. TCF is a continuous process and the group will continue to develop its policies and procedures taking into account best practice guidance which the FSA issues from time to time.