Jenny Holt’s update on Consumer Duty

Customer Strategy and Experience Director, Jenny Holt talks about how Standard Life and the Phoenix Group has built on our existing foundations to support good outcomes for customers, our focus on enhancing customer understanding, and what comes next.  

Find out more by watching Jenny’s video
 

How we approached Consumer Duty

In 2022, we worked closely with independent consultants to conduct a gap analysis to identify areas of focus for the new Duty and to create a review structure for our program. The following six areas were identified:

  1. Considering Fair Value across all products and services
  2. Testing of Customer Understanding of key communications
  3. Tailoring of Customer Communications
  4. Designing an overarching customer communications framework
  5. Demonstrating customer support and service levels meet the needs of customers
  6. Defining (reasonable) foreseeable harm

 

This thematic approach has been applied across ‘group-wide’ frameworks and policies relating to the six review areas.

  • Andy Curran's video update on Consumer Duty

    Andy Curran's update on Consumer Duty

    Find out more about our approach to meeting the requirements of the Duty by watching Andy’s video.

    Watch our short video

  • Shaping customer outcomes is core to our purpose

    Jenny Holt, our Customer Savings & Investment Director, looks at our current approach to helping customers with the requirements of the Consumer Duty. 

    Read our Consumer Duty blog
  • Craig Hamilton's video update on how we're approaching Consumer Duty

    Craig Hamilton discusses Consumer Duty

    Find out more about how we have approached Consumer Duty and next steps from Craig Hamilton, Group Conduct & Compliance Director.

    Watch our short video

Meeting the deadline for open products

We’re pleased to announce that we have implemented the Consumer Duty requirements across our open products, in line with the FCA deadline of 31 July 2023. This includes the updating of our internal frameworks and policies. You can find more details on our approach for the cross-cutting rules and for the four outcomes below.

You can find a summary of our open products by viewing the link below.

View products table

What do you need to do?

Distributors are also required to meet the 31 July 2023 deadline in relation to the open products they offer to clients. The information published by manufacturers at the end of April supported Distributors to assess changes needed to their processes, such as suitability, to demonstrate their compliance with the Duty.  

To date, as we’ve worked through the requirements of the Duty, we did not identify any other management information needed as input to support our work. However, as we continue to embed the changes we’ve made, if we do identify anything further is needed, we’ll contact distributors to let them know. If a distributor identifies any concerns or requires additional information of our open products, the firm should let us know as soon as possible.
 

Our approach to the cross-cutting rules

The Consumer Duty cross-cutting rules define the standards of outcomes we align to; acting in good faith, avoiding foreseeable harm, and helping customers achieve their financial objectives.

  • Act in good faith

    Our aim is to have a standard of conduct characterised by honesty, fairness and openness when dealing with customers. 

    Read more

  • Avoid causing foreseeable harm

    We’ve completed extensive analysis of foreseeable harm scenarios so that our product development, governance and customer support work to avoid foreseeable harm.

    Explore now

  • Enable and support customers

    This is at the very core of our business purpose, which is to help people secure a life of possibilities.
     

    Learn more

The four outcomes

We have worked through the four outcomes of the Duty in relation to our open products to establish the changes or enhancements needed. Click on each section to find out more detail of our approach and outcomes.

  • Outcome 1: Products and Service

    Our product governance approach means that we’ve been focused on where the thematic requirements apply. This approach has been taken after working with independent consultants on a gap analysis, to identify where our focus needed to be. 

    View the outcome

  • Outcome 2: Price and Value

    Our Fair Value assessment considers the whole customer proposition, looking at product, investment, service, communications and support.

    Read more

  • Outcome 3 and 4: Consumer Understanding and Customer Support

    Find out how we’ve worked hard to update our frameworks and policies for the Duty and applied them to customer journeys and processes. We’ve also looked closely at our customer service proposition, including those provided by third parties and what’s changing for consumer duty.

    Learn more

More material to help you

You'll find further reading and a wide range of support material on the FCA website

This website is for financial advisers only and must not be relied on by anyone else. If you’re not an adviser, please go to our customer website for more information about our products and services.