Treating Customers Fairly & Consumer Duty Policy

About Us

Vans Northwest Ltd t/a Leasing Pro (“the Company”, “We”, “Us”, or “Our”) is authorised and regulated by the Financial Conduct Authority for consumer credit activities (Firm Reference Number: 648909).

We are registered with the Information Commissioner's Office (ICO) for the processing of personal data under the UK GDPR and Data Protection Act 2018 (Registration reference: ZA073401).

We are a member of the British Vehicle Rental and Leasing Association (BVRLA) and abide by their Code of Conduct.

We act as a credit broker and not a lender.

Purpose of This Policy

This policy sets out how we ensure fair treatment of customers in line with the FCA’s Principles for Business, including Principle 12: Consumer Duty, which requires firms to act to deliver good outcomes for retail customers.

Treating Customers Fairly (TCF) remains central to our culture and is embedded within our Consumer Duty approach.

Our Commitment

We are committed to:

• Acting honestly, fairly, and professionally in the best interests of our customers
• Delivering good customer outcomes across all stages of the customer journey
• Ensuring communication is clear, fair, and not misleading
• Avoiding foreseeable harm to customers
• Supporting customers to make informed decisions

Consumer Duty Framework

We apply the four key Consumer Duty outcomes as follows:

Products and Services

• We only introduce customers to finance products that meet the needs of identified target markets
• We work with a carefully selected panel of funders
• We regularly review our lenders, products, and suppliers to ensure suitability and quality

Price and Value

• We ensure that customers receive fair value, considering both cost and service
• All fees (including documentation, cancellation, and extension fees) are clearly disclosed upfront
• We receive commission from funders; however:
  • Commission structures are monitored to ensure they do not create customer harm
  • Recommendations are based on customer needs, not commission levels
  • Customers have the right to request disclosure of commission

Consumer Understanding

We provide information that is:

• Clear, concise, and jargon-free
• Timely and appropriate to the stage of the customer journey

Customers are given sufficient information to make informed decisions, including:

• Key product features
• Costs and fees
• Risks and obligations

Consumer Support

• We provide accessible and responsive customer support throughout the customer lifecycle
• We ensure customers can:
  • Ask questions and receive prompt responses
  • Make changes where appropriate
  • Raise complaints easily

• We do not impose unreasonable barriers to:
  • Cancelling agreements
  • Switching products
  • Making complaints

Vulnerable Customers

We recognise that some customers may be in vulnerable circumstances and may require additional support.

We:

• Train staff to identify indicators of vulnerability (e.g., financial difficulty, health issues, life events)
• Adapt our communication to meet customer needs
• Allow additional time for decision-making where required
• Provide clear and supportive explanations to ensure understanding
• Act with sensitivity and discretion at all times

How We Deliver Fair Customer Outcomes

We achieve this by:

• Training staff to deliver high standards of customer service
• Ensuring all financial promotions and marketing are clear, fair, and not misleading
• Listening to customers to understand their needs and circumstances
• Providing appropriate information to support informed decisions
• Monitoring customer interactions and outcomes

Complaints Handling

We take all complaints seriously and use them as an opportunity to improve our service.

• Complaints are handled promptly, fairly, and consistently
• We aim to acknowledge complaints within 2 working days
• Root cause analysis is undertaken where appropriate
• Complaint trends are reviewed to identify potential issues or risks

Customers have the right to escalate complaints to the Financial Ombudsman Service where applicable.

Monitoring, Management Information & Governance

We monitor our performance to ensure we are delivering good customer outcomes through:

• Complaint volumes and trends
• Customer feedback and satisfaction
• Conversion rates and customer drop-off points
• Product performance and lender feedback
• Outcomes for vulnerable customers

Governance

• The Head of Business is responsible for compliance oversight, including Consumer Duty and TCF
• This policy is reviewed annually, or sooner if regulatory changes occur
• Findings from monitoring activities are used to improve processes, training, and customer outcomes

Training and Culture

• All staff receive training on Treating Customers Fairly and Consumer Duty principles
• Our culture promotes customer-first decision making
• Staff are encouraged to escalate concerns where customer outcomes may be at risk

Continuous Improvement

We are committed to continuously improving our processes, products, and services by:

• Reviewing feedback and complaints
• Updating policies in line with regulatory changes
• Enhancing staff training and awareness
• Ensuring ongoing alignment with FCA and BVRLA expectations

Policy Review

This policy is reviewed annually and approved by senior management.