Consumer Duty

CCLA is committed to ensuring that its products and services provide its clients with good outcomes and that it provides a high level of support that enables its clients to achieve their financial objectives.

All CCLA employees are encouraged to ensure, in relation to our clients, that they:

• act in good faith
• avoid causing foreseeable harm
• enable and support clients to pursue their financial objectives.

The Consumer Duty principle 

The FCA’s Consumer Duty principle requires that:

A Firm must act to deliver good outcomes for retail customers (Principle 12)

Principle 12 reflects a general expectation by the FCA that firms should conduct their business to a standard which ensures an appropriate level of protection for retail customers.

CCLA clients

The Consumer Duty applies to retail clients (and includes prospective clients).

Whilst most CCLA clients are organisations (Churches, Charities and Local Authorities) the overwhelming majority are classified as retail clients.

CCLA is committed to ensuring that it acts reasonably towards all its clients and will take into account particular characteristics that a client may have to ensure they are treated appropriately.  

CCLA will consider whether its actions provide good outcomes for all retail customers affected or only some; and if only some, determine why it does not work for all, and how best to identify additional actions which mitigate the outcome for those adversely affected.

CCLA will provide its employees with appropriate training and support to facilitate this.

CCLA approach to Consumer Duty 

CCLA and its employees are committed to ensuring that with respect to their clients they:

Act in good faith

CCLA will act in good faith with all its clients. 

All employees are required to deal with clients honestly, fairly and openly and act in a consistent manner meeting their reasonable expectations and interests. 

Avoid causing foreseeable harm

CCLA recognises that foreseeable harm may be caused by both act and omission in our direct relationship with a client and through our role in a distribution chain and that this applies throughout the lifecycle of a product.

Note: The distribution chain means all firms involved in the manufacture, distribution (provision and sale) and ongoing administration and management of a product or service.

CCLA will take necessary action to avoid causing foreseeable harm to its clients and to take appropriate action to mitigate the risk of actual or foreseeable harm, including for example by:

• updating or otherwise amending the design of the product or distribution strategy
• updating information about a product
• ensuring that retail customers do not face unreasonable barriers (including unreasonable additional costs), for example when they want to switch products or providers or to complain
• allowing time and support for retail customers to find suitable alternatives if a product is withdrawn.

Enable and support retail clients

CCLA is committed to ensuring that its products and services enable and support retail clients to pursue their financial objectives.

CCLA will:

• Ensure all aspects of the design, terms, marketing, sale of and support for its products meet and not frustrate the objectives and interests of retail customers.
• Make sure retail clients have the information and support they need, when they need it, to make and act on informed decisions.
• Enable retail clients to enjoy the use of their product and to switch or exit the product where they want to without unreasonable barriers or delay.
• Take account of retail clients’ behavioural biases and the impact of characteristics of vulnerability in all aspects of customer interaction.

CCLA will monitor the outcomes that its clients get to identify whether there are any risks that we are not acting to deliver good outcomes for retail clients.

Products and services 

CCLA will ensure that it has a suitable process to oversee the manufacture, operation, change/significant adaptation to and review of all products and services which: 

• ensure that the design of the product:
  • meets the needs, characteristics and objectives of the target market
  • does not adversely affect groups of retail customers in the target market, including groups of retail customers with characteristics of vulnerability
  • avoids causing foreseeable harm in the target market
• ensure that appropriate testing and scenario analysis is undertaken to ensure the product or service performs as expected
• ensure that the intended distribution strategy is appropriate for the target market
• takes all reasonable steps to ensure that the product is distributed to the identified target market.

CCLA will review its products and services on an ongoing basis taking into account any event that could materially affect the potential risk to the target market. 

Where any circumstances related to the product are identified that may adversely affect retail customers, CCLA will:

• take appropriate action (including ceasing marketing and distribution) to mitigate the situation and prevent any further harm
• promptly inform other relevant persons in the distribution chain about the circumstances that led to action being taken and the remedial action taken.

Value assessments 

CCLA will undertake value assessments on all its products and services before they are marketed or distributed to clients, when any significant amendments are made to the product or service and on an annual basis. 

Where CCLA identifies that a product no longer provides fair value it will take appropriate action to mitigate the situation and prevent further occurrences of any possible harm to its retail clients and redress any foreseeable harm that has been caused and inform any other distributors about the concerns and the action being taken.

Consumer understanding 

CCLA is committed to ensuring that its communications (including financial promotions):

• meet the information needs of retail clients
• are likely to be understood by retail clients
• equip retail clients to make decisions that are effective, timely and properly informed
• are clear, fair and not misleading.

CCLA will adapt its communications if it identifies there are areas of common misunderstanding among retail clients or retail clients are not experiencing good outcomes.

Consumer support 

CCLA is committed to designing and delivering support to retail clients such that it: 

• meets the needs of retail clients, including those with characteristics of vulnerability 
• ensures that retail clients can use their product as reasonably anticipated
• ensures that it includes appropriate friction in its customer journeys to mitigate the risk of harm and give retail customers sufficient opportunity to understand and assess their options, including any risks
• ensures that retail clients do not face unreasonable barriers (including unreasonable additional costs) during the lifecycle of a product, such as when they want to: 

  (a) make general enquiries or requests to the firm
  (b) amend or switch the product
  (c) transfer to a new product provider
  (d) access a feature which the product is intended to provide
  (e) redeem their investment
  (f) make a complaint
  (g) cancel their investment, agreement or arrangement or otherwise terminate their relationship with the firm.

CCLA will not prioritise new clients over existing clients and will treat all customers fairly.

CCLA will not remunerate employees in any way that would conflict with their obligations under the Consumer Duty or may lead to poor consumer outcomes. 

Vulnerable customers 

CCLA recognises that clients due to their personal circumstances, may need additional assistance or can be susceptible to harm, particularly when a firm is not acting with appropriate levels of care. This includes individuals representing entities. 

CCLA will ensure that all relevant employees have the necessary training so that they are able to recognise vulnerability and respond appropriately to individual clients’ needs so they can treat them fairly, whether the consumer has told them about a need or where there are clear indicators of vulnerability or where there is relevant information noted on the client’s records that indicates an additional need or vulnerability.

Clients who need additional support are encouraged to contact Client Services if they have any additional support needs. 

CCLA can provide different formats for product and marketing material including:

• large text 
• audio 
• contrast adjusted
• braille.

June 2024