Consumer Duty
Support for financial advisers

Supporting good customer outcomes

Since the introduction of Consumer Duty in 2023, firms are required to continually demonstrate that they’re acting in the best interests of customers and putting their needs first, to provide good customer outcomes. This presents an opportunity for financial advisers to improve processes, enhance relationships, and build greater trust, when providing advice and recommendations to customers on financial products and services; and it aligns with our own ambitions to help make retirement more rewarding.

This page is designed to help financial advisers when considering their ongoing approach to Consumer Duty and provides an overview of what we do to ensure Consumer Duty remains a key focus for our business.

How we can help support you

We’ve created some documents to help you during ongoing conversations with clients, to ensure you’re providing good customer outcomes and remaining compliant.

Detailed information on products and services

Please find links below to our target market statements.

Our target market statements identify who a product is designed for, their characteristics, and how their needs and objectives are met, as well as the distribution strategy, to help you ensure you’re offering suitable products and services to your clients. These documents also include a summary of our fair value assessments outcome to ensure the price a consumer pays for a product or service is reasonable compared to the overall benefits received. 

Consumer Duty outcomes

The four outcomes are a suite of rules and guidance which help financial firms to meet the needs of retail customers throughout their relationship. 

Outcome 1

Products and services

Firms should offer products and services that meet the needs of their target customers, are distributed appropriately, and are designed to deliver the expected benefits. 

Outcome 2

Price and value

Products and services should be priced fairly and transparently throughout the product and customer lifecycle. 

Outcome 3

Consumer understanding

Firms should communicate with customers in a clear and understandable way, ensuring they have the information they need to make informed decisions. 

Outcome 4

Consumer support

Firms should provide a level of support which helps customers meet their financial objectives, making it easy for them to access information, make changes to their products or services, or resolve any issues. 

Frequently asked questions

We’ve answered the most common questions from our financial advisers on Consumer Duty below:


How have you tested your open products and services to meet the requirements of Consumer Duty?

We completed a Product and Service and Price and Value assessment on all of our products against the first two outcome rules. The details and results of which can be found in our Target Market documents (please see links above). Customer journey reviews have been carried out on key services both to identify improvements, remove barriers and ensure positive friction points for Consumer Duty as well as further reaching proposition improvements. All customer touchpoints have been identified, recorded and reviewed against centralised frameworks, including our customer understanding toolkit (SOLVE), a communications guide developed with leading behavioural science consultancy, Cowry Consulting. This aims to maximise clarity for the customer’s reading experience and provides guidelines for good practice in producing collateral. Key customer communications are also regularly tested via external third parties - by their experts and with our existing customers. This is to make sure these guidelines are working as intended when it comes to enhancing Customer Understanding.

How often will testing of your products and services be reassessed?

Assessments will be completed regularly in line with our internal scheduling review. The Customer Outcomes Committee oversees the ongoing monitoring and review of customer outcomes on a regular basis. Additional customer journey and communication reviews can be triggered at any time should poor customer outcomes be identified, through regular monitoring and customer feedback.

How will you identify clients that don't fall within your target market for your products and services?

We'll review new business on a regular basis to assess whether the product has been distributed in accordance with the information in the Target Market document. However, in line with FCA guidance, it remains the responsibility of each distributor to ensure that the relevant target market is followed, as they're best placed to consider client personal circumstances, needs, objectives, characteristics and suitability.

If we've concerns about plans distributed to clients that we believe are unsuitable, we'll first contact the distributor to raise and discuss our concerns. 

What governance do you have to oversee Consumer Duty within your company?

We've a dedicated Customer Outcomes Committee, who report into our Executive Committee and oversee customer outcomes. Further approval is provided by the Group Board with challenge from our Consumer Duty Non-Executive Director.

Will you provide Management Information on products and services assessments to distributors?

There are no FCA requirements to provide specific Management Information (MI) in our assessments to distributors. If you require further information, please contact the Business Development Team who will be happy to discuss.