CAPITA PLC POLICY

Treating Customers Fairly

Classification Commercial in Confidence

Version 7.1
Date of Issue December 2015
Date of Next Review June 2016
 Capita plc Policy
Treating Customers Fairly

Contents

1. Key Matters...................................................................................................................................3
2. Purpose and Scope........................................................................................................................3
3. Regulatory Background.................................................................................................................3
4. Policy Statement...........................................................................................................................6
5. Procedural Requirements.............................................................................................................8
6. Document Control.......................................................................................................................11
Appendix 1: Definitions......................................................................................................................12
Appendix 2: TCF Culture ‘key drivers’.................................................................................................14
Appendix 3: TCF self-assessment checklist.........................................................................................15
Appendix 4: TCF dashboard/MI..........................................................................................................16
Appendix 5 TCF MI - Use and Review.................................................................................................17
Appendix 6: Complaint handling as part of
TCF.....................................................................................19

Page 2 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

1. Key Matters
1.1. TCF is about putting yourself in the place of the Customer and considering whether you
would regard yourself as having been treated fairly.

1.2. Evidence of practices, measurement of and actions relating to delivery of the consumer
outcomes is key to the demonstration of TCF.

2. Purpose and Scope

2.1. The purpose of this Policy is to set out the high level approach which all UK Financial
Conduct Authority (FCA) regulated firms (Firms) within the Capita plc group of Companies
(Group) must follow and what Management Information (MI) must be monitored in
relation to the FCA’s principle of Treating Customers Fairly (TCF). When reading this Policy,
Employees should refer to ‘Appendix 1: Definitions’ for a glossary of defined terms.

2.2. Capita Firms provide a wide range of services to a large number of Customers and Business
Partners and their Customers. Customer and Business Partner satisfaction relies on high
quality service and an ongoing commitment to improve the way in which Firms operate. A
successful TCF environment should create stronger Customer and Business Partner
relationships, which should lead to improved Customer loyalty and more efficient service
provision. This Policy applies to a Firm’s Customers and those of a Business Partner unless
the Customer is an Eligible Counterparty.

3. Regulatory Background
3.1. The FCA is the conduct regulator for financial services firms and financial markets in the UK.
One of its three operational objectives is to secure an appropriate degree of protection for
consumers. As a conduct regulator, the FCA looks at the way firms carry out their business
and how they treat customers. It expects firms to have their customers at the heart of how
they do business and of the products and services, they offer 1. The requirement for firms to
treat customer fairly is firmly rooted in the FCA’s eleven principles of business.

3.2. The FCA’s eleven principles are rules which must be observed in addition to the detailed
rules and guidance set out elsewhere in the FCA Handbook. Principle 6 drives the fair
treatment of customers: “A firm must pay due regard to the interests of its customers and
treat them fairly”, although the following Principles are also relevant:

 Principle 1: A firm must conduct its business with integrity.

 Principle 2: A firm must conduct its business with due skill, care and diligence.

1
FCA Approach – Advancing Objectives 2015

Page 3 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

 Principle 3: A firm must take reasonable care to organise and control its affairs
responsibly and effectively, with adequate risk management systems.
 Principle 7: A firm must pay due regard to the information needs of its clients, and
communicate information to them in a way which is clear, fair and not misleading.
 Principle 8: A firm must manage conflicts of interest fairly, both between itself and its
customers and between a customer and another client.
 Principle 9: A firm must take reasonable care to ensure the suitability of its advice and
discretionary decisions for any customer who is entitled to rely upon its judgment.
 Principle 10: A firm must arrange adequate protection for clients' assets when it is
responsible for them.

3.3. To aid firms further, the FCA uses six consumer outcomes which explain what it wants TCF
to achieve for consumers:

 Outcome 1: Consumers can be confident that they are dealing with firms where the fair
treatment of customers is central to the corporate culture. The ‘key drivers’ of culture
recognised by the FCA can be found in Appendix 2.

 Outcome 2: Products and services marketed and sold in the retail market are designed
to meet the needs of identified consumer groups and are targeted accordingly

 Outcome 3: Consumers are provided with clear information and are kept appropriately
informed before, during and after the point of sale

 Outcome 4: Where consumers receive advice, the advice is suitable and takes account
of their circumstances

 Outcome 5: 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

 Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms

to change product, switch provider, submit a claim or make a complaint

3.4. Not all outcomes will be relevant to all Firms or Businesses and precisely how the outcome
is achieved will vary dependent on the relationship with the Customer and the service being
provided. The approach taken to achieve an outcome should be appropriate and
proportionate to the circumstances, taking into account the capabilities of the consumer.

3.5. The FCA’s TCF Principle applies to all Customers unless they are Eligible Counterparties (i.e.
retail customers and commercial customers that are not Eligible Counterparties).

3.6. The FCA recognises differing levels of risk associated with different products and services
offered by the financial services industry. TCF is a key element of the FCA’s consumer

Page 4 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

protection agenda and consequently focus is given to areas identified where there is
significant potential for customer detriment.

3.7. The FCA's website provides more information about TCF, for example:
1. Culture framework2
2. Guide to MI3
3. Responsibilities of providers and distributors 4
4. Guidance for NEDs5
Eligible Counterparty:
5. Glossary6
6. Rule7

3.8. The FCA’s TCF principle is underpinned by requirements such as the Unfair Terms in
Consumer Contracts Regulations and the Financial Ombudsman Service arrangements.

3.9. The FCA has said “TCF, with its focus on consumer outcomes, is central to our work in
ensuring a fair deal for consumers. It underpins the delivery of our statutory consumer
protection objective and the future objectives of the FCA. The FCA will put consumers’
needs at its heart and it will focus even more on ensuring there is a fair deal between firms
and their customers.”

3.10. In its 2013 ‘Risk Outlook’ document the FCA says “Firms need to ensure they are
putting the consumer and the integrity of markets at the heart of their business models and
strategies. This includes making cultural changes that promote good conduct outcomes
throughout the business; establishing appropriate oversight and governance around the
design and innovation of products and services; and ensuring they are transparent in their
dealings with consumers”.

3.11. TCF is therefore a key aspect of meeting our commitments as a business to act
in the interest of customers and manage the risks which may prevent this in line with Capita’s
Conduct Risk Policy.

2
http://www.fca.org.uk/firms/being-regulated/meeting-your-obligations/fair-treatment-of-customers/Culture
3
http://www.fca.org.uk/your-fca/documents/fca--treating-customers-fairly--guide-to-management-information
4
http://www.fca.org.uk/your-fca/documents/fsa-ps0711
5
http://www.fca.org.uk/static/FsaWeb/Shared/Documents/pubs/guidance/gc11_30.pdf
6
http://fshandbook.info/FS/html/handbook/Glossary/E
7
http://fshandbook.info/FS/html/handbook/PRIN/1/Annex1#DES25

Page 5 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

4. Policy Statement
Consumer outcomes
4.1. Businesses must treat Customers fairly through the consistent delivery of the consumer
outcomes defined by the FCA. Senior management within the Business (with guidance from
Compliance) must identify which and how the TCF outcomes apply to their business. Where
operations are outsourced, each party must be clear about its TCF responsibilities (see 4.9 and
4.10).

Risks and controls

4.2. Senior management must identify the risks associated with each of the applicable consumer
outcomes. Systems and controls which mitigate the risks must be implemented and maintained,
and senior management must ensure these remain effective in the fair treatment of Customers.

Definition of ‘fairness’
4.3. Compliance will advise senior management on FCA expectations and TCF approaches taken
elsewhere within the industry by similar businesses, however senior management must decide
for themselves what fairness means to their business, bearing in mind the size, structure and
nature of their business and customer base.

Culture
4.4. Senior management must fully embed the Capita culture in their business. ‘Respecting our
customers and treating them fairly’ and ‘Delivering what we promise’ are key elements of
Capita’s value set. It is in Capita’s interests to have satisfied Customers, so the interests and
expectations of Customers must be aligned with and not secondary to Capita’s financial and
reputational interests. Culture is about behaviour so senior management must lead by example.

Governance and oversight

4.5. Governance and oversight arrangements must involve staff at sufficiently senior levels within
the Business in order to adequately deliver the consumer outcomes, manage TCF risks,
challenge TCF practices and take action to resolve issues identified. Senior management must
ensure all relevant parts of the Business are involved in their arrangements so the escalation
and cascade of information through the Business and decision-making is effective.

4.6. The FSA published guidance for NEDs (as part of the wider Board of Directors), setting out its
expectations of them in the management of TCF risk and delivering fair outcomes to customers;
this guidance (available via the FCA’s website) is still relevant.

MI or measures
4.7. MI or measures which demonstrate the ongoing and consistent delivery of the consumer
outcomes and management of TCF risks must be identified by senior management. There must

Page 6 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

be evidence of regular monitoring of the results and records must be kept of decisions,
investigations and actions taken following review of the results.

Continuous improvement
4.8. Operational structures, products, services, customers and their expectations change, so TCF
must be seen as a continuous process. Businesses must therefore undertake a self-assessment
exercise at appropriate times of change (e.g. when making an acquisition, changing strategic
direction, or launching a new product), using the checklist provided in Appendix 3.

4.9. Businesses must use complaint and breach analysis reports to ensure lessons learned are used
to continuously improve TCF outcomes (see 5.11 and 5.12).

FCA rules and guidance

4.10. Rules and guidance set out in the FCA Handbook must be followed. Aspects such as
financial promotions and best execution carry detailed rules which are intended to ensure a
minimum standard in the treatment of Customers. Compliance will advise senior management
on rules and guidance relevant to their Business, but senior management is responsible for
ensuring compliance with FCA rules and guidance.

Outsourcing to a Capita Firm

4.11. Where a Business Partner outsources operations to a Capita Firm, the Business Partner
must have a clear understanding of Capita’s TCF activities so it can ensure alignment with its
own approach and values. Capita and the Business Partner must establish clear responsibilities,
agree how together they will demonstrate the Business Partner’s Customers are treated fairly
and ensure records of commitments made to or by the Business Partner are maintained e.g. in
the Service Level Agreement (SLA). Where the Business Partner’s operating practices conflict
with the TCF Principle, this must be escalated using Capita’s internal procedures (e.g. to the Risk
Committee) and the governance process for the contract. Where possible, Capita should try to
influence the Business Partner, keeping records of any discussions. Capita must consider the
significance of the conflict and whether the relationship with the Business Partner is one it
wishes to pursue.

Outsourcing by a Capita Firm

4.12. Where a Capita Firm outsources operations, either to an external party or intra-Group
(such as for the provision of IT services), it must have a clear understanding of the outsourcee’s
TCF activities so it can ensure alignment of approach. Capita and the outsourcee must agree
how together they will demonstrate Customers are treated fairly. Capita must regularly review
the outsourcee’s operating practices to ensure they remain appropriate. Capita must not
undertake an outsourcing arrangement if the outsourcee’s operating practices conflict with the
TCF Principle.

Page 7 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

5. Procedural Requirements
Risk management
5.1. The risks associated with TCF like any other risks must be assessed and reported on using the
Group’s risk management framework. Management of TCF risks must be evidenced through
monitoring of MI, so businesses must consider whether it is appropriate for them to maintain
records of TCF risks at a consumer outcome level (and what MI is used to monitor these risks).

Systems and controls

5.2. Systems and controls which mitigate TCF risks and deliver the consumer outcomes must be
documented and regularly reviewed to ensure they remain appropriate.

Definition of ‘fairness’
5.3. Businesses must articulate their definition of fairness with a ‘success looks like’ statement for
each applicable consumer outcome, or by setting a ‘fairness level’ or benchmark for the key
measures used to monitor TCF performance, or by a combination of these methods.

‘Vulnerable customers’
5.4. Businesses must take account of the needs of customers who could be considered to be
‘vulnerable’ in the context of providing financial and non-financial services/products. In 2015
the FCA issued ‘Occasional Paper 8 - Vulnerable Consumer’s’ which provides useful guidance
and further reading that should be taken into account by firms when considering their
vulnerable customer approach.

5.5. In the paper the FCA provide a definition of vulnerable consumers as “A vulnerable consumer is
someone who, due to their personal circumstances, is especially susceptible to detriment,
particularly when a firm is not acting with appropriate levels of care.” Examples include
customers who are visually impaired or who have limited financial capability, or customers with
mental illness/incapacity.

Culture
5.6. Businesses must take account of the culture ‘key drivers’ outlined in Appendix 2 and the self-
assessment checklist provided in Appendix 3. Specifically, they must ensure:

 Business strategy and objectives do not conflict with (but instead support delivery of) the
TCF outcomes.
 Senior management reinforce the importance of TCF in internal communications.
 Staff are encouraged to identify and report potential TCF issues and improvements.
 Job descriptions and personal objectives include TCF behaviours and tasks relevant to the
individual’s role.
 Staff feedback is sought and acted upon to improve the treatment of customers.
 Customer feedback is sought (where the circumstances are suitable to do so), with action
taken as appropriate to manage the Customer’s expectations.

Page 8 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

 Significant decisions that impact customers are documented, with a clear indication of the
considerations which informed the decision, who was involved in the decision making
process, and the date of the decision.
 Quality assurance activities are undertaken e.g. call reviews and letter sampling, where this
aspect is fundamental to delivery of an outcome, and the results are acted upon as
appropriate.
 Service levels are regularly reviewed to ensure both the time and quality standards
represent fairness.
 Recruitment procedures include an assessment of TCF related behaviours, and senior
appointments are compatible with TCF aims.
 TCF training is provided to staff, their understanding of it is tested, and shortfalls are
addressed.
 Staff are competent to fulfil their roles and performance is assessed in line with the Group’s
performance management system, and training and competence policy/scheme where
applicable.
 Resource is sufficient to deliver the outcomes.
 Reward and recognition structures do not encourage behaviour contrary to (but instead
encourage behaviour conducive to) TCF.

Management Information
5.7. TCF MI must be produced at least monthly, in line with the requirements outlined in Appendix
4. MI must be provided by appropriate people and responsibilities for the provision of
information must be documented. Businesses must ensure MI is used and reviewed in
accordance with Appendix 5.

Governance and oversight

5.8. Responsibilities in relation to TCF must be apportioned and documented. Businesses must
consider whether it is appropriate to delegate responsibility for certain controls to a committee
such as a New Product Development or a TCF Committee, or to an individual such as a TCF
Champion. Policies and significant decisions must be referred to these committees or individuals
as appropriate. Adequate oversight of TCF means MI must be escalated through Businesses for
analysis and consideration at different management levels.

Self-assessment
5.9. A self-assessment must be completed at appropriate times of change within the Business, or if
additional guidance is provided by the FCA or Compliance. When undertaking the self-
assessment using the document found in Appendix 3, Businesses must identify additional
Business specific systems and controls or contractual requirements relevant to their TCF
environment. Records of the assessment exercise must be maintained, including details of
action plans arising from the findings.

Other Policies
5.10. Where applicable, the Due Diligence and Integration Policy must be followed to ensure
TCF arrangements are assessed as part of an acquisition or contract for the provision of third
party administration services. Where applicable, the Outsourcing Policy must be followed to

Page 9 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

ensure TCF arrangements are assessed as part of the consideration of operational risk. Other
Group and local Policies which affect how customers are treated must also be followed.

Procedure documentation
5.11. Processes and procedures with direct relevance to TCF must be documented e.g. when
producing Customer communications, when selling or giving advice, or when handling
complaints. Procedures must be regularly reviewed and an ‘end-to-end’ review of procedures
must be completed to ensure TCF arrangements flow through the product lifecycle e.g. ensure
the claims procedure corresponds to the policy document issued as part of the sales process.

Complaint handling
5.12. Complaints can be a key indicator of unfair Customer treatment and a robust procedure
to deal with them must therefore be in place. Root cause analysis must be conducted to identify
systemic issues which can be addressed to prevent or reduce future complaints; staff training or
procedural changes must be considered as part of actions taken following the root cause
analysis. Records of complaints and decisions and actions taken must be maintained. Relevant
information must form part of the TCF MI pack. The list provided in Appendix 6 should be used
by Businesses to ensure their complaint handling procedures are appropriate.

Breach, incident, error and issue escalation

5.13. There must be a procedure for staff to escalate breaches, incidents, errors and issues
identified with TCF implications. Records of escalations and decisions and actions taken must be
maintained. Relevant information must form part of the TCF MI pack.

Adherence to this Policy

5.14. Senior management must ensure staff comply with this Policy as part of their standard
day-to-day supervisory arrangements; this includes staff employed in non-regulated parts of
Capita involved in activities relating to a Firm.

Local policy
5.15. Senior management must decide if a local or divisional TCF policy is needed outlining the
detailed approach to be taken locally, and if so, it must ensure consistency with the Group
Policy.

Compliance monitoring
5.16. TCF must be considered as part of Compliance monitoring programmes as appropriate
to the risks identified and in the wider context of conduct risk.

Page 10 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

6. Document Control
Document History

Issue Date Purpose Author

1.0 December 2008 Policy Creation Wendy Owen

2.0 January 2009 Annual Review Wendy Owen

3.0 December 2009 Annual Review Wendy Owen

4.0 January 2011 Annual Review Wendy Owen

5.0 January 2012 Annual Review Wendy Owen

6.0 January 2013 Annual Review Wendy Owen

7.0 January 2014 Annual Review Wendy Owen

7.1 December 2015 Annual Review Martin Hince

Distribution
Name Organisation Role

Capita Connections Capita plc Corporate Intranet

Reviewers
Name Organisation Role

Chris Terry Capita plc Group Risk and Compliance

Director

Page 11 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

Appendix 1: Definitions

A number of words and phrases have particular meanings in this Policy, as set out below. Defined terms
are capitalised and appear in bold when first used in the Policy, for example, Customer.

Business Partner The party with whom a Capita Firm has contracted to provide services
on an outsourced basis. The Customer relationship in the context of
TCF is indirect i.e. the Customer ‘belongs’ to Capita’s Business Partner
where the Business Partner has direct regulatory responsibility for the
Customer.

Business(es) The operating units or sites which comprise a Firm.

Capita Capita plc and any of its affiliates.

Customer(s) The person(s) who ultimately receive(s) the service being provided by
a Capita Firm unless they are an Eligible Counterparty. The Customer
relationship in the context of TCF may either be direct i.e. the
Customer ‘belongs’ to Capita where Capita has direct regulatory
responsibility for the Customer, or indirect i.e. the Customer ‘belongs’
to Capita’s Business Partner where the Business Partner has direct
regulatory responsibility for the Customer. The TCF Principle applies to
activities carried out from establishments in the UK; this includes
activities carried out from UK establishments with overseas customers.

Eligible Counterparty Click here for the FCA Glossary definition (and scroll down)

Click here for the associated FCA rule

Firms may categorise certain clients as an eligible counterparty for the

purposes of the Principles for Businesses. The most likely reason for
this categorisation by a Capita Firm is where it is dealing with another
Firm or an associate of a Firm. If this categorisation is to be relied
upon, the definition and rule must be read and the required steps
taken.

Page 12 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

Employee(s) Full-time, part-time, temporary and contract staff of the Group,

including Board Directors, whether Executive or Non-Executive.

Firm(s) Companies within the Group who are authorised and regulated in the
UK by the FCA to conduct regulated activities.

FCA The Financial Conduct Authority; responsible for the conduct

regulation and supervision of all authorised financial services firms in
the UK and for the prudential regulation of those firms not authorised
by the PRA.

FSA The Financial Services Authority; the FCA’s predecessor.

Group Capita plc and any of its affiliates.

MI Management Information.

Policy This TCF Policy.

TCF Treating Customers Fairly. Because of the wide range of activities Firms
carry out, the FCA feels it is not possible to define ‘fairness’ in a way
that applies to everyone. Firms must decide for themselves what
fairness and TCF means to them, bearing in mind the size, structure
and nature of their business, and the FCA’s six consumer outcomes.

Page 13 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

Appendix 2: TCF Culture ‘key drivers’

The following table is taken from the FSA’s July 2007 publication ‘Treating customers fairly - culture’.
The FCA believes that if the culture of a Firm is good, then Customers are likely to be treated fairly.

Page 14 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

Appendix 3: TCF self-assessment checklist

Operational structures, products, services, customers and their expectations change, so Businesses
must undertake a TCF self-assessment exercise at appropriate times of change. Records of the
assessment exercise must be maintained, including details of action plans arising from the findings.

TCF self-assessment
checklist - Jan 14.doc

Page 15 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

Appendix 4: TCF dashboard/MI

The attached dashboard is an example of an approach taken within Capita in respect of TCF
reporting; the format is not mandatory however, its use is encouraged. Businesses that choose to
use another style of reporting must ensure:

1. Measures are reported for each of the applicable consumer outcomes.

2. Where a consumer outcome is not relevant, a statement explaining why this is the case is
included in the report, for example, Capita is not authorised to give advice - if Capita becomes
aware of information relevant to this outcome, it will pass this on to external parties such as
Business Partners.
3. The type and number of measures used are aligned with the example as appropriate to the
Business and the TCF risks faced.
4. If the measures are not presented by outcome, which measure(s) relate(s) to which outcome is
recorded somewhere (normally within the MI pack being used to monitor TCF).
5. Why a measure demonstrates delivery of an outcome has been recorded, bearing in mind the
criticism of Firms measuring ‘process’ not ‘outcome’.
6. The ‘fairness benchmark’ for each measure is recorded and why this standard is being used e.g.
industry standard. Industry standards must be used to inform decisions rather than lead them.
When setting benchmarks consideration must be given to the degree of control the Business has
over the aspect being measured (with the higher the degree of control, the higher the likely
benchmark).
7. Results for at least 3 months are reported so trends can be seen.
8. There is qualitative commentary in respect of the results which have been analysed.

Example TCF
dashboard - Jan 14.xls

Page 16 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

Appendix 5: TCF MI – Use and Review

The list below has been compiled from feedback Capita is aware the regulators have given Firms and
Business Partners following visits to assess delivery of TCF outcomes. Issues such as the frequency of
TCF risk reviews must be discussed with your local Compliance team.

1. Ensure top-down TCF risk reviews are regularly undertaken in order to assess whether your
existing MI/measures sufficiently monitor delivery of the outcomes. Ensure consumer protection
issues previously raised by the regulators with Capita and known regulatory ‘hot spots’ are
addressed. Projects present risks and corresponding MI should therefore be considered.

2. Ensure your MI/measures monitor outputs and you have recorded why a measure demonstrates
fairness/delivery of an outcome, particularly in respect of SLA reporting.

3. Ensure your MI includes both proactive measures such as customer feedback surveys, and
reactive measures such as numbers and types of complaints received.

4. Use the ‘wider’ information you hold (in addition to the results regularly reported on your
dashboard) to identify potential TCF issues. So, for example, if a database of customer
communications is maintained, analyse it periodically to see what it tells you – how long is it
since you last corresponded with a certain group of customers?

5. Ensure you have a TCF MI pack which draws together information on all your key risks, which is
then considered from a fairness angle.

6. Ensure results for an appropriate timeframe are reported so trends can be seen.

7. Ensure appropriate people receive appropriate TCF MI so that decision making is informed by it.

8. Ensure results are analysed and challenged (particularly where they are inaccurate, inconsistent,
anomalous or unexpected) and there is ongoing assessment of the success of actions taken.

9. Ensure summaries of MI allow adequate senior management oversight.

10. Ensure the escalation and cascade of information through the business, to/from governance and
oversight forums, and to/from external parties such as Business Partners, is as agreed and
effective.

11. Ensure approaches and results are shared across businesses where appropriate.

12. Ensure there is a clear and consistent process for setting RAG ratings/benchmarks for
MI/measures. Where distinct criteria are not set, provide guidance to individuals on the factors
to take into account when determining a rating.

Page 17 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

13. Ensure the content and presentation of your TCF MI pack is regularly reviewed to consider what
further enhancements can be made, and ensure RAG ratings/benchmarks are reviewed to
ensure levels remain appropriate.

14. Ensure quantitative results are supported with corresponding qualitative commentary.

15. Ensure ‘green’ results are also reviewed to consider emerging or low level risks.

16. Assign ownership and deadlines to investigations or actions identified from TCF MI/measures
and ensure records are kept of actions taken to improve customer treatment.

Page 18 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016
 Capita plc Policy
Treating Customers Fairly

Appendix 6: Complaint handling as part of TCF

The quality of a Firm’s complaint handling is an important aspect of TCF. In 2010 the FSA published a
report containing the results from its review of complaint handling in banking groups, and the
assessment template used as part of its review.

The following diagram describes in simple terms some of the key elements of fair complaint handling and
how they should link together.

Attached is a list which should be used by Capita Businesses to ensure their complaint handling
procedures are appropriate:

Further information on treating complainants fairly can be found in the following documents:

1. Review of complaint handling8

2. Complaint-handling file review template9

Complaint handling
as part of TCF - Jan 14.doc

8
http://www.fca.org.uk/your-fca/documents/fsa-review-of-complaint-handling-in-banking-groups
9
http://www.fsa.gov.uk/pubs/other/ch_assess_template.pdf , http://www.fsa.gov.uk/pubs/other/ch_assess.xls

Page 19 of 19 COMMERCIAL IN CONFIDENCE © 2015 Capita plc

Date of Issue: December 2015
Date of Next Review: June 2016