Our approach to the Duty

Working with consultants we’ve completed a gap analysis, identifying areas of focus and a review structure for our program. We’re applying a group-wide thematic approach aligned to the six key review areas:

  • Considering fair value across all products and services
  • Testing of customer understanding of key communications
  • Tailoring of customer communications
  • Group communications framework
  • Demonstrating customer support and service levels meet the needs of customers
  • Defining (reasonable) foreseeable harm

Our progress to date:

We are working hard to make sure our products and services meet the required standards of the new regulatory framework as they come into force. To date we’ve:

  • Embedded new customer standards and clear definitions of what good customer outcomes mean at Phoenix  
  • Completed reviews and fair value assessments of products, communications, and customer journeys to identify and address areas of foreseeable harm and fair value ahead of regulatory deadlines 
  • Implemented new or improved policies, processes and frameworks across the business focused on delivering customer understanding and supporting good outcomes  
  • Enhanced our governance, oversight, monitoring, reporting and evidence for customer outcomes to meet requirements of Consumer duty
  • Delivered regular group-wide communications and training to embed consumer duty into everything we do

Closed product rules in force from 31 July 2024

  • For closed products, fair value assessments are progressing and are on track for 31 July 2024 when the rules take effect.


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