Policies protecting customers.

Our compliance policies outline how we expect our business to be conducted. Current policies that set out the regulatory principles, rules and guidance include:

  • Inducements. This sets out how we should act when any benefits are offered to us as individuals or as a company.
  • Conflicts of interest. This helps us make sure we identify and manage conflicts to prevent any adverse impact on our customers.
  • Complaints. This helps clarifies the standards we expect employees to follow to deliver good outcomes to 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.
  • Provider/distributor. This sets out how responsibilities for relationships should be established and maintained with the aim of delivering consistently fair outcomes for customers.

Our internal audit team reviews these policies and reports back on effectiveness in implementation.


Our product lifecycle management sets out the standards we require, and the approach we follow, when designing, launching and managing products, propositions and funds. This comprehensive framework covers areas such as how we expect stress and scenario testing, customer research and understanding target markets. It also includes guidance on running customer operations and regulatory risk assessments. Management guidance focuses on how we review product risks once they’ve been launched to make sure they are still right for customers.

Each business division has a product committee that approves product launches and is responsible for products once launched.

Communicating with customers in a way that is clear, fair and not misleading is central to our business. Our advertising standards team ensures we communicate with customers in this way, and that we comply with Financial Conduct Authority (FCA) rules and guidance, Prudential Regulatory Authority, UK advertising codes and our own brand values.

We also operate a fund panel to monitor funds and ensure they’re performing in a way that continues to be right for customers.

By doing this, we ensure that the products customers buy, the advice they receive and their choice of funds are fit for purpose.


All employees are expected, through comprehensive training, to understand deliver our internal governance framework. This includes computer based training on:

  • anti-bribery and corruption;
  • complaints;
  • data protection; and
  • financial crime.

Measuring progress

Treating customers fairly initiatives and conduct risk management information is used to help business managers, senior executives and non-executive directors understand how we’re delivering against our customer commitments and drive improvement. Examples of our monthly customer measures include:

  • Culture. Are we customer focused in everything we do, from setting our strategy to servicing our customers? Do we quickly put things right when things don’t go to plan?
  • Quality. Did you receive quality advice when the product was sold?
  • Product performance. Is the product doing its job?
  • Service performance. When you contact us or we contact you do we deliver good service?
  • Conduct. Do we demonstrate business performance is meeting the expectation of our auditors and regulator?


We think it's important that we’re accountable for our business performance and we do business in a way that’s right for our customers. Every year, the UK’s Financial Ombudsman Services publishes a report about their review of our business. The report shows the number of customers that ask for an independent review of a complaint decision made by us compared to our peers.

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