Treating Customers Fairly

Introduction

FedGroup Financial Holdings (Pty) Ltd (FedGroup) is a licensed financial services provider and is authorised to provide financial and intermediary services in terms of the Financial Advisory and Intermediary Services Act. As such we have certain specific duties to you, our clients.

One of these duties is to ensure that Treating Customers Fairly (TCF) is firmly embedded in our culture and in our policies, which enables us to execute or duty towards you the client effortlessly. To Fedgroup our clients are our main priority and therefore we understand that client satisfaction is the cornerstone of our business.

Treating Customers Fairly

The FSB has published its TCF principles of that the financial industry has to integrate and embed within their various company structures. These TCF outcomes and principles are integrated into FedGroup values.The six TCF outcomes are:

Outcome 1: (Culture) Customers are confident that they are dealing with a financial institution where the fair treatment of customers is central to the company’s culture.

Outcome 2: (Products and Services) Products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly.

Outcome 3: (Clear and appropriate information) Customers are given clear information and are kept appropriately informed before, during and after the time of contracting.

Outcome 4: (Customer advice) Where customers receive advice, the advice is suitable and takes account of their circumstances.

Outcome 5: (Product performance and expectation) Customers are provided with products that perform as FedGroup has led them to expect and the associated service is both of an acceptable standard and what customers have been led to expect.

Outcome 6: (Post-sale barriers) Customers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint

FedGroup fully backs the TCF Outcomes outlined by the FSB. Most of the principles that support the Outcomes are expressed in our Corporate Values.

The FedGroup’s focus on TCF is not just because of the FSB requirements, but because:

It is good business practice (it’s the right thing to do)

It is beneficial for customers and for busines

It expresses what FedGroup already has committed itself to: the fair and honest treatment of clients.

We have a governance and compliance process in place whereby we periodically evaluate ourselves against the outcomes. We always strive to improve our adherence to the TCF principles. The TCF principles are a business imperative, embedded in our strategy, governance and daily processes, as highlighted below:

Outcome 1: CULTURE

To ensure that fair treatment of customers is embedded in FedGroup’s culture.

To ensure that TCF principles are supported and understood in the same way by our management, and that their strategies and decision making demonstrate the TCF outcomes.

To create positive attitudes and actions towards the fair treatment of customers.

To strive to ensure that our people understand the purpose of TCF and how their decisions and activities impact on fair outcomes.

To ensure that our people receive appropriate training in order to understand how to deliver consistent operational excellence to achieve the six fairness outcomes.

To ensure that anyone who reasonably suspects or identifies any instance of unfairness to customers’ raises their concern at an appropriate level within FedGroup.

All identified risks are linked to the appropriate TCF outcomes where relevant, with effective control measures.

To regularly monitor and report on the TCF practices noted in this section to assess our performance and to implement changes as appropriate.

Outcome 2: PRODUCTS AND SERVICES

To ensure that our products are based upon research and a clear understanding of our customer segments and their requirements.

To ensure that our products are tested for target market suitability and are marketed to the appropriate target markets accordingly.

To ensure that prior to launch, all necessary systems, resources, training and structures are in place to adequately support the product or service at and post launch to customers.

To ensure where reasonable that the customers are on the product options most suited to them throughout their lifetimes, always providing fair value.

Outcome 3: CLEAR AND APPROPRIATE INFORMTAION

To ensure that our policy wording, communication, marketing content, website content and other documentation presented to customers is written in clear, simple and unambiguous language, in an easy-to-read format, appropriate for the target market and is not misleading in any way.

To ensure that customers are clearly informed of their products, the associated risks, and the decisions or actions required of them for their benefit on the product.

To take all reasonable steps to keep our customer data accurate and up to date.

Outcome 4: CUSTOMER SERVICE

In line with relevant legislation, provide proper advice and keep the relevant documentation.

In line with relevant legislation, ensure that third parties keep detailed records of advice and engagements with customers, including the rationale used to determine the suitability of a product or service and record of relevant customer circumstances.

In line with relevant legislation, ensure that people (internal or external) giving advice on our products or services are properly trained and tested on such.

Outcome 5: PRODUCT PERFORMANCE AND EXPECTATION

To understand customers’ reasonable expectations in respect of our service, product benefits and value provided, and ensure that those expectations are met.

To ensure that we make use of what we learn through our ongoing engagement with customers and other stakeholders; including the answering of queries and resolving complaints; to drive improvements in our business.

Where reasonable, to monitor the performance of third party service providers that impact on our ability to keep our promises and meet customer expectations.

To continuously seek ways to improve the customer experience and meet customer expectations.

Outcome 6: POST SALES BARRIERS

To ensure that our procedures and processes are designed and communicated to customers in such a way that it is easy for them to lodge claims and amend or cancel the products or services that we provide, where reasonable (not all customers can cancel our services e.g. members of funds).

To provide a mechanism that will allow customers to easily lodge complaints and to address such complaints in a clear, objective and timely manner.

To analyse customer complaints, feedback and survey results to correct or improve upon factors impacting on the delivery of fair outcomes.

Governance

Fedgroup maintains a vigorous corporate governance structure. This governance structure finds its efficacy through our board of directors, our various subcommittees, management forums, the appointment of an independent internal auditor and other independent assurance providers. FedGroup’s strong corporate governance structure ensures that we develop a culture of proactive behaviour rather than a reactive culture.

Our governance, risk and compliance department, with advice from external risk, legal, regulatory and compliance experts, ensures that we comply with the full regulatory universe applicable to our business. The principles supporting the TCF outcomes are at the centre of our board’s decision-making processes. Our TCF policy is applied in conjunction with the following documents:

Complaints management policy

Conflict of interest policy

Disciplinary policy

Regulators and Industry Bodies

FedGroup has, since inception, undertaken to engage in an open and transparent manner with our regulator, the FSB. FedGroup is also a member of various industry bodies, through which we are able to voice our concerns as well as express our opinions on various regulatory matters and industry standards.

Technology Advancements

Because of our commitment to treating our customers fairly, FedGroup has invested heavily in technology. Our administration system was designed and implemented in-house, to avoid the use of legacy systems, which often make it difficult for service providers to provide a service in line with the outcomes of TCF. FedGroup’s system allows us to improve our responsiveness, turnaround times and to decrease the amount of the fund held in cash, all to the benefit of our clients.

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