Treating customers fairly policy

Introduction

The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) initiative is primarily based on the obligation set out in Principle 6 requiring a firm to pay due regard to the interests of its clients and treat them fairly.

CCLA is fully committed to TCF and this policy has been designed to demonstrate the application of TCF during the course of our day to day activities. TCF is embedded throughout the FCA’s Handbook, however, the FCA has also identified six core consumer outcomes which explain what it wants TCF to achieve for consumers.

These are:

  • Consumers can be confident they are dealing with firms where TCF is central to the corporate culture.
  • Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and targeted accordingly.
  • Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
  • Where consumers receive advice, the advice is suitable and takes account of their circumstances.
  • Consumers are provided with products that perform as firms have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect.
  • Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Our TCF mission statement

We will act with integrity in everything that we do and aim to be in partnership with our clients.

Our TCF Principles

  • Customers will be provided with clear information and kept appropriately informed before, during and after the point of sale.
  • If we give advice to our customers, the advice will be suitable and take account of their circumstances.
  • Our level of service and product performance will meet the expectations of our customers as far as reasonably possible.
  • We will ensure that there is no barrier for customers to express their requests, concerns or complaints, and will always be responsive to them.
  • Products and services will be designed to meet the needs of clients.

Assessing and implementing our TCF principles

Marketing All CCLA’s financial promotions and marketing literature are reviewed to ensure that they are appropriate for the target audience and are presented in a clear, fair and not misleading manner. Sales, Advice, Management CCLA’s advisers obtain a detailed understanding of the clients’ investment objectives, their level of expertise and their attitude to risk so that their recommendations are suitable. We ensure that our clients understand the risks involved with any service or product offered and are aware of all applicable charges.

We classify all our clients correctly to ensure they are offered the appropriate level of protection. Investment and asset allocation decisions are regularly reviewed by the relevant committee.

Post-sale information and support

CCLA strives to keep its clients informed at all times. Appropriate records are provided as required and on an ongoing basis. We have appropriate capacity and processing arrangements in place to ensure continuous support and no post-sale barriers. Policies and Procedures CCLA has a number of policies and procedures that are relevant to the fair treatment of clients and also achieve adherence to FCA requirements, these are (this not an exhaustive list):

  • Order Execution Policy
  • Conflicts of Interest Policy
  • Data Protection Policy
  • Personal Account Dealing Policy
  • Training and Competence Policy
  • Complaint Handling Procedure
  • Financial Promotions Procedure
  • Investment Procedure
  • Compliance Manual

Management information

CCLA produces MI in order to assess its performance against TCF principles. We ensure that MI is accurate, timely, consistent and relevant in order to assist the business in making informed decisions in the best interests of our clients. CCLA produces MI reports which are reviewed regularly by senior managers, directors and board members in various committee meetings.

Awareness/training

CCLA ensures that all advisers and staff are familiar with the fundamental principles of TCF. In addition, where applicable, advisers and staff are trained in order to suitably advise on and efficiently explain and provide our products and services. We make sure that all of our advisers and staff achieve the necessary qualifications and training in order to carry out their job functions with the required competence level. We undertake regular monitoring and assessment of our advisers and staff so that we can be certain of their competence.

Compliance

CCLA has a compliance team who is independent and regularly monitors all key areas of regulatory compliance including TCF.

Remuneration

CCLA operates a remuneration model that mitigates sales bias and rewards non-sales staff in a way that would not negatively impact the treatment of its clients.

Complaints

CCLA aims to provide excellent customer service and complaint handling is a major component of its TCF measures. We deal with customer complaints fairly, objectively and in accordance with the rules laid down by the FCA. All complaints are recorded and monitored by our compliance team and reported and analysed in company MI and committee meetings.

Conclusion

CCLA’s culture is and has been throughout the years in line with the outcomes stipulated by the FCA’s TCF initiative. However, we frequently review our policies, procedures and practices to ensure that TCF remains a crucial part of our business. We ask our clients to provide us feedback, sometimes formally through customer surveys, so that we can improve our service. The information we collate from our clients can be reflected in company MI and reviewed by senior managers, directors and board members to help shape any strategic decisions.

July 2014

Terms and conditions

Website terms of use policy

Welcome to CCLA's website for:

  • fund management services for The CBF Church of England Funds and the COIF Charities Funds (together referred to as "the Funds"); and for
  • discretionary investment management services for individual client portfolios.

This page provides you with information about CCLA and the legal terms and conditions ("Terms of Use") on which you can access and use this website.

By using or accessing any part of this website, you confirm that you accept these Terms of Use and that you agree to comply with them. Please read these Terms of Use carefully and make sure that you understand them before using this website. If you do not wish to be bound by these terms and conditions you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time and where this is the case we will do so by updating this page. We therefore recommend that you check this page periodically to ensure that you understand the terms which will apply from time to time.

  1. Information about CCLA

Any reference to "CCLA" on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable).

CCLA Investment Management Limited (a company registered in England and Wales with Company No. 2183088) and CCLA Fund Managers Limited (a company registered in England and Wales with Company No. 8735639) are each authorised and regulated by the Financial Conduct Authority ("FCA") under the Financial Services and Markets Act 2000 ("FSMA"), and are entered in the FCA Register under Registration Numbers 119281 and 611707 respectively. CCLA Fund Managers Limited is a wholly owned subsidiary of CCLA Investment Management Limited.

CCLA Investment Management Limited is the manager of The CBF Church of England Funds and provides discretionary investment management services for individual client portfolios. CCLA Fund Managers Limited is the manager of the COIF Charities Funds. The registered office of CCLA Investment Management Limited and CCLA Fund Managers Limited is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

2. Who may use this website

The information in this website is primarily intended for "charities" in the United Kingdom (and in particular the information in relation to the Funds is intended for UK "charities" only).  "Charities" for these purposes are charities or charitable organisations who are registered with the Charity Commission, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958 or section 24 of the Charities Act 1993, or equivalent organisations in Scotland or Northern Ireland. Certain investments or services to which this material relates may only be available to such persons. This material must not be relied upon or acted upon by any other persons in the United Kingdom.

3. The purpose of this website

This website is for information purposes only and is intended as a general introduction to CCLA and its products. The website content and any products and/or services described within it are subject to change without notice. We do not accept any liability to you, or any third party, for the accuracy, completeness or appropriateness of the information and materials made available on this website and your use of any information or materials is entirely at your own risk provided that nothing contained in this section or elsewhere in these terms shall limit or exclude our liability to you to the extent that such liability is attributable to a breach by us of the FCA's rules, FSMA or any other applicable law.

Any application or investment must only be made on the basis of the relevant investment documents which will be issued to you when you make an enquiry about investing in a CCLA fund, such as, for example, the scheme particulars and terms and conditions. Nothing contained on this website constitutes the provision of investment, tax, legal or other advice.

Persons who do not have professional experience in matters relating to investments are strongly encouraged to consult with a financial adviser before making any investment decision. Any opinions expressed on individual funds, services or products represent our views at the time of preparation and should not be interpreted as a personal recommendation to buy or sell any of the investments that may be referred to.

4. Risk warning

The value of the Funds’ units and/or shares and the income from them can fall as well as rise and an investor may not get back the amount originally invested. Past performance is no guarantee of future returns.

Please refer to the Funds’ scheme particulars for an overview of the investment risks identified by CCLA and the applicable terms and conditions for investing in the Funds, including rules concerning when sums invested may be realised by the investor. Any estimates of future capital or income returns or details of past performance on this website are for information purposes and are not to be relied on as a guide to future performance.

The investments and investment services referred to on this website may not be suitable for all eligible investors.

As the Funds are not authorised unit trusts within the meaning of FSMA, investments or deposits in the Funds are not covered by the Financial Services Compensation Scheme (FSCS).

However, unitholders and/or shareholders may be eligible for compensation under FSCS if CCLA cannot meet its obligations. There are limits on who can claim and the amount of compensation available. Further information about FSCS is available at www.fscs.org.uk

5. CCLA's liability for website content

The information on this website does not necessarily reflect our views and opinions. Neither should any suggestions or advice contained on the website be relied upon in place of individual advice. You are responsible for checking the accuracy of relevant facts, instructions, suggestions and/or opinions given on the website before entering into any commitment based upon them. We do not accept any liability arising from any inaccuracy or omission in the information.

CCLA is not responsible for the accuracy of information contained within websites provided by third parties, which may have links to or from our pages.

The information on this website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. Under no circumstances should this information or any part of it be copied, reproduced or redistributed.

Due to the inherent nature of the Internet, errors, interruptions and delays may occur in the service at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. CCLA shall have no liability, contingent or otherwise, to you or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between CCLA and you, regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

CCLA shall have no liability, contingent or otherwise, to you or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data and services available on this website or for any other aspect of the performance of this service or for any failure or delay in the execution of any transactions through this service. CCLA makes no warranty whatsoever to you, express or implied, regarding the security of the website.

This service may provide links to certain websites sponsored and maintained by third parties. CCLA makes no representations concerning the content of such third party websites. The fact that CCLA may provide a link to another website does not constitute an endorsement, authorisation, sponsorship, or affiliation by CCLA with respect to that website, its owners, or its providers. Your use of the products and services on this website may be monitored by CCLA.

6. Copyright and trade marks

CCLA is the owner or the licensee of all intellectual property rights in this website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You must not use any part of the materials on this website for commercial purposes without obtaining a licence to do so from us or our licensors.

No use of CCLA's name, logos and/or other trade marks (whether registered or unregistered) may be made by you without separate express written agreement being given by us, which shall be at our sole discretion.

7. Data protection

We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with the Data Protection Act 1998. CCLA is the data controller of any such information for these purposes. CCLA will use any such information for the administration and servicing of your investments and all other related activities. We may disclose your information to our agents and service providers. Where a financial adviser acts on your behalf, we may disclose such information to that financial adviser.

By accepting these Terms of Use, you agree to the processing and disclosure of personal information as above. You are entitled to request details of information we may hold about you upon payment of a fee and to require us to correct any inaccuracies in your personal data.

If you supply such information to us via this website, CCLA may use your personal data to contact you by post, e-mail or telephone to bring to your attention additional products or services which may be of interest to you. You may inform CCLA at any time if you do not want to receive such communications.

Full details of CCLA’s Data Protection Policy, including its Privacy Notice are available on request.

8. Cookies

This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website.

Please note that when you confirm you have read this page we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this website on future occasions. The cookie will expire after six months, or sooner should there be a change to this important information.

Please note that you can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. To help us provide a more personalised viewing experience we recommend that you view this website with a JavaScript enabled browser.

For more information about cookies, including how to set your Internet browser to reject cookies, please visit www.allaboutcookies.org.

9. General

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your information (including personal data), we cannot guarantee the security of your data transmitted to this website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. However, CCLA accepts no liability in the unlikely event of a breach of our secure computer servers.

We will use reasonable endeavours to ensure that this website does not contain or promulgate any viruses or other malicious code. However, it is recommended that you should virus check all materials downloaded from this website and regularly check for the presence of viruses and other malicious code. We exclude to the fullest extent permitted by applicable laws all liability in connection with any damage or loss caused by computer viruses or other malicious code originating or contracted from this website.

Each of the paragraphs of these Terms of Use operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.

If we fail to insist that you perform any of your obligations under these Terms of Use, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations.

These Terms of Use are governed by English law and are available only in English. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction over any dispute or claim arising under these Terms of Use.

September 2015