Our Consumer Duty

Since day one we've placed customer needs at the heart of everything we do, an approach that has helped make a positive difference to the lives of hundreds of thousands of people. Consumer duty means that this customer-first approach will now be practised across the industry, something we warmly welcome. This page provides a brief overview, Marlborough's response to Consumer Duty and what you, as a retail customer, should expect. Anyone looking for a more technical, in-depth summary is encouraged to scroll to the bottom of the page where a series of downloads have been made available.

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What is Consumer Duty? (in Summary)

Consumer Duty sets out guidance to help companies deliver good outcomes for retail customers.

It ensures you fully understand what's being communicated, you receive the right support and it helps you access products and services that match your needs whilst offering good value.

What is Consumer Duty? (in Detail)

The Financial Conduct Authority (FCA) has set out new rules and guidance that establishes clearer standards of consumer protection across financial services. It places a clear responsibly on companies to put the needs of their customers first.

The FCA's Consumer Duty guidance can be explained as follows:

1. The 'Consumer Duty Principle' has been released by the FCA. This Principle states that "Companies are required to deliver good outcomes for retail customers".

2. The FCA has provided greater clarity on how it expects firms to respond. This includes guidance in relation to products and services, price and value, consumer understanding, and consumer support.

3. Rules are now in place that require firms to consider the needs, characteristics and objectives of each customer. Firms must be able to demonstrate how all needs are being met at every stage of the customer journey.

Our approach to Consumer Duty (in Summary)

As mentioned at the top of this article, we've been a vocal advocate of the 'customer-first' approach since we first opened our doors in 1987.

Our purpose, Difference Made, places not just customer need, but also customer dreams, at the heart of all we do.

The evidence of this approach speaks for itself. At a high-level, we have redesigned our Group structure to better serve customers, we have simplified and streamlined our service offering, and we've also made our information clearer and accessible to all.

At an individual level, customers will experience the same Marlborough commitment to impartiality, fairness and transparency that they have always enjoyed. And purpose, mission and values that drive ensure we don't stop there. We will continue to innovate, adapt and stay ahead of customer demands, so your needs are intuitively met as your expectations change.

Our approach to Consumer Duty (in Detail).

Over the past year, we have worked tirelessly to review our products and services to ensure they are fit for purpose and offer good value for our customers.We have been working closely with industry bodies and our partner firms, to ensure that we are not only meeting the requirements of Consumer Duty, but delivering a response of the highest possible standard.

Our approach to consumer duty covers the four areas set out by the FCA:

(i) Price & Value: The price you pay for a product or service should reflect the value you receive from it. We've engaged in a thorough, ongoing process to ensure our products and services are tailored to your needs and offer outstanding value.

(ii) Products & Services: Our recent Group restructure creates further clarity for customers, and ensures more investors can benefit from a seamless, end-to-end experience. We have reviewed and strengthened our products and services, and established even more robust ways to monitor and approve them.

(iii) Consumer Understanding: We have set out new guidance on how we communicate across our Group. Financial services can be complicated, so with our communications we aim to simplify, clarify and empower. Our commitment extends to ensuring our communication is consistently strong across all channels and devices, empowers you to select the services and products best-suited to your goals, and is accessible to all. This website is an example of our strong commitment to this aim.

(IV) Consumer Support: Our purpose states that we should begin every conversation by asking customers what difference they are looking to make in their lives. We still use this question, and put your needs and goals at the very heart of everything we do with you.