Consumer Duty and TCF Policy

CONSUMER DUTY 

At First Vehicle Leasing, customer service has been our passion and part of our company ethos since we were founded in 1998.

Linked to our service levels is the Consumer Duty, one of the principles set out by the Financial Conduct Authority (FCA).

Consumer Duty sets the standard of care that firms should give to customers in retail financial markets. It better protects consumers and provides firms with their expectations in accordance with the FCA.

We interpret the guidance that we (First Vehicle Leasing Ltd) are a Manufacturer of our own sales process, but a Distributor of vehicle sales using a panel of finance companies. Consumer Duty progresses from our existing ethos on “treating customers fairly” (TCF) (see below for more information on TCF) and seeks to ensure we are recognising and putting procedures in place to stop any “foreseeable harm” to customers.

Consumer Duty comprises of the following:

Consumer Principle - Overall standard of behaviour that is required from firms.

Cross-Cutting rules - Explains how firms should act to deliver good consumer outcomes and apply this across their business.

Four Consumer Outcomes - The four outcomes are:

• Consumer Support – Communication is a priority.
• Consumer Understanding – All features and benefits of the product, plus all the potential risks.
• Governance of Products and Services – This applies to the brokerage services we offer.
• Price and Value – Value assessing our services.

Pinpointing any potential areas for harm is vital in reducing the possibility of harm occurring. Examples include:

• Affordability - Incorrect income and expenditure, disproportionate figures to budget if the applicant is a homeowner / tenant.
• Qualification - suitability of the product, the term of the product doesn’t fit circumstances, incorrect contract mileage, unexplained excess mileage charges.
• Financial Promotions – Clear, fair and not misleading.
• Vehicle running costs - Maintenance packages, MOT, tyre costs, insurance, breakdown.
• End of Contract / Contract amendment opportunities. Additional costs for this.
• Vulnerability – ensuring that all customers understand the risks and benefits of the product and it suits their needs.
• Remuneration – incentives and remuneration do not undermine Consumer Duty
• Adequate explanation – communication, questioning their decision.
• Training – lack of training / understanding could have a negative impact on the consumer.

The customer needs to fully understand what they are agreeing to, and even if the customer is unhappy with the outcome, it doesn’t mean it was the wrong one. The service we provide aims to give the best possible outcome, even if that means the customer doesn’t get what they wanted originally as it didn’t fit their budget, needs or circumstances.

We act with honesty and good faith, but we are not an advice service. We will explain the positives and negatives of the contract (product) to the customer, and ensure they understand it fully before they proceed.

To ensure that our company is limiting foreseeable harm to the customer we monitor all stages within the service we provide. Management Information plays a key role in our continued progress:

• Sales management, by holding one – to – one’s with each member of the leasing team, checking call recordings, monitoring their level of customer service and organising any additional training they may require (in addition to the basic regulatory training). These are logged by the Sales Manager on a monthly / quarterly basis and follow ups on a case-by-case basis. 
• All staff complete the British Vehicle Rental and Leasing Association (BVRLA) annual regulatory training, plus any finance company training and where necessary any other forms of training we see fit for them to carry out their roles competently.
• The leasing team will have conversations with the customer regarding their requirements as well as providing quotations in a digital format.
• The finance company will check the customer criteria for their product and if they feel it is suitable, they will approve the customer. Any issues with suitability and affordability would be raised prior to approval (where visible).
• We already have an “aftersales” team in place to manage customer expectation and deal with any potential vehicle delays. All customers receive multiple communications from the point of order through to delivery.
• The aftersales team communicate with the customer after delivery to ensure the customer is happy with the delivery process, and to remedy any issues that may have occurred. All dissatisfactions / complaints are logged and monitored by the compliance team.
• Through the duration of the contract the customer will receive a variety of communications (calls, texts, and emails) ensuring continued suitability, MOT and service reminders, tyre replacement, vehicle maintenance and any issues that may arise from use of the vehicle.

By having these processes in place, it allows us to support the customer’s financial objective accordingly.

We currently charge a fee of £291.66 excl. VAT (£349.99 inc. VAT) for our service, which we feel, based on our processes, service level and interaction, is good value for money.

TREATING CUSTOMERS FAIRLY

Treating Customers Fairly (TCF), one of the principles set out by the Financial Conduct Authority (FCA).  TCF applies to our business or commercial customers, and where the leasing agreement is not regulated by the FCA. 

Below we cover what TCF means and how it will impact your dealings with First Vehicle Leasing. There are six outcomes which the FCA has identified as the core features of TCF; these are:

Outcome 1: Customers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.

Outcome 2: Products and services are designed to meet the needs of identified customer groups and are targeted accordingly.

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

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

Outcome 5: Customers 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: Customers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint. 

WHAT DOES THIS MEAN FOR YOU?

First Vehicle Leasing adopted the idea of TCF right from the outset of our formation in 1998. Our business and commercial customers can therefore expect the following when dealing with us: 

• We listen to our customers and assess their needs and requirements on an individual basis.
• Any information provided by us is stated clearly and accurately to ensure there is no ambiguity or misleading of our customers.
• Our pricing is clear and transparent on the website and any quotation or documentation you may receive from us.
• We are open about fees we charge or receive in our Initial Disclosure Document.
• We will remain in contact throughout the product lifecycle to ensure everything is ok and providing answers to any queries you may have.

HOW DOES FIRST VEHICLE LEASING INTEND TO TREAT CUSTOMERS FAIRLY?

TCF is a continuous process that evolves with the needs of our customers and with any industry changes. To ensure we continue to comply with TCF, we have implemented several procedures, including:

• Regular auditing of telephone and electronic correspondence between staff and customers.
• Monthly development training for our staff to ensure that we do all we can for our customers and remain FCA compliant.
• Continuous investment and improvement of both our internal systems and our website.
• Ongoing review of FCA materials and attendance to workshops and conferences to further our knowledge base to ensure that we provide only our best possible service to customers.

IS THERE ANYTHING YOU CAN DO TO HELP US?

There are many things that our business and commercial customers can do to help us deliver the best possible service to you, including:

• Ensure any information you provide is as accurate as possible.
• Review any information you receive from us carefully, this includes adverts and correspondence sent directly to you.
• Many of our products include a “cooling off” period as part of the process, this period is required by law, and you should use it to fully consider whether to proceed.
• Review your financial position by utilising one of the many credit report services which are now available.

If you are unsure about anything or have any questions, please contact us to discuss them.

What to do if you feel you haven’t been treated fairly?

A key point in our adherence to the philosophy of TCF is how we treat our customers in the event of a complaint. If you’re not happy, full details of our complaints procedure can be found here.

Version - DP/25/2 - 12/08/25