About Us
Treating Customers Fairly & Consumer Duty

We value our customers and treat them fairly by providing a professional service and only sell them products that fit their needs.

We have embedded treating customers fairly principles within our business and our service.

 Our Business

1. Our business operations are driven by the current and potential needs of our customers
2. We consider the impact of any changes to our business on our customers
3. Remuneration to our employees supports the sale of appropriate products and services
4. Our employees receive regular training on treating customers fairly
5. We always strive to achieve the best possible outcome for our customers by taking into account all the various elements within car leasing

Our Service

1. We explain key attributes of products and make sure that our documentation and advertising is clear, easy to understand and is not misleading 
2. We design our marketing campaigns and literature so that the key messages are clear, balanced and useful for our target customer segment
3. We regularly review our sales activities to ensure that we are selling products and services that meet the needs of our customers 
4. Where a customer complains about our service we treat their complaint seriously and positively. Our responses are clear and easy to understand
5. We use data to monitor and improve our customer service which includeds using feedback from customer surveys and/or complaints.

Abiding with all of the above ensures CVSL Ltd adheres to the core principles of Treating Customers Fairly as detailed below.

TCF – Core Principles

Consumer outcomes

There are six consumer outcomes that firms should strive to achieve to ensure fair treatment of customers. These remain core to what the FCA expect of firms.

• Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture.
• Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
• Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
• Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
• Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
• Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

In addition to these Treating Customers Fairly principles we are also committed to upholding the principles outlined in the FCA's Consumer Duty, which aims to ensure that our customers experience fair and beneficial outcomes

Our Commitment to the Consumer Duty

The Duty is comprised of the following components.
• A Consumer Principle -'to act to deliver good outcomes for retail customers', which reflects the overall standard of behaviour the FCA want from firms like CVSL Ltd and which is defined further by the other elements of the Consumer Duty.
• This includes 3x ‘cross-cutting rules’ and 4x ‘outcomes’

The three ‘cross-cutting’ rules are:

(1) Act in good faith, - which requires firms to act honestly, fairly, and openly with consumers.

(2) Avoid foreseeable harm, - which means identifying and mitigating risks that could harm consumers.

(3) Enable and support customers to pursue their financial objectives, - which means empowering customers to make informed decisions and achieve their goals.

The ‘four outcomes’  are a suite of rules and guidance setting more detailed expectations for CVSL Ltd's conduct in four areas that represent key elements of the CVSL-consumer relationship:

– the governance of products and services - ensure that products and services are fit for purpose and meet the needs of our customers
– price and value - ensure that pricing is fair and reflects the value offered to our customers.
– consumer understanding - provide clear and transparent communications to help our customers understand products and services
– consumer support -  provide appropriate customer support throughout the term of the lease contract, including for customers with vulnerabilities or disabilities.

By implementing and embedding all the above, CVSL ensure that we always put consumers at the heart of our business and focus on delivering good outcomes for customers.

CVSL will;

• provide products and services that are designed to meet customers’ needs, that we know provide fair value, that help our customers achieve their financial objectives and which do not cause them harm
• communicate and engage with customers so that they can make effective, timely and properly informed decisions about financial products and services and can take responsibility for their actions and decisions
• never seek to exploit customers’ behavioural biases, lack of knowledge or characteristics of vulnerability
• support our customers in realising the benefits of the products and services they buy and acting in their interests without unreasonable barriers
• consistently consider the needs of all our customers, and how they behave, at every stage of the product/service lifecycle
• continuously learn from our growing focus and awareness of real customer outcomes
• ensure that the interests of our customers are central to the culture and purpose and embedded throughout CVSL
• monitor and regularly review the outcomes that our customers are experiencing in practice and take action to address any risks to good customer outcomes

 CVSL also has a Vulnerable Customer Policy which is designed to ensure that the way in which we conduct our business does not have a detrimental impact upon vulnerable customers. For the purposes of this policy, vulnerable customers are customers and prospective customers whose ability or circumstances require us to take extra precautions in the way that we sell and provide our services to ensure that they are not disadvantaged in any way.

 What is a vulnerable customer? 

The Financial Conduct Authority (FCA) defines a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

 The FCA expects firms like ourselves to treat all our customers fairly and when dealing with people with vulnerable circumstances to take account of such vulnerability to ensure that the way that we sell and provide our services does not cause them detriment.

Identifying a vulnerable customer

Our staff are trained to identify vulnerable customers and to provide the additional level of assistance they may require in order to achieve a good outcome. However, it is not always easy to recognise these characteristics. Therefore, if you believe you meet the criteria for a vulnerable customer, please read this statement and notify us as soon as possible of your particular needs. You are encouraged to do this when you first make contact with us. 

Vulnerability groups

 We recognise that certain groups of customers may be vulnerable. Whilst not all customers in these groups may be vulnerable, we will consider a customer’s individual circumstances where a potential vulnerability is identified. These groups may include, but are not restricted to:

Customers with communication difficulties (including learning difficulties and English not being their first language, dyslexia)

A customer with a reduction in physical or mental capacity

Customer with health issues – illness, whether physical or mental illness, severe or long term

A sudden diagnosis of serious illness to the customer or close family member

Personal circumstances of the customer – factors such as financial difficulties, bereavement, caring responsibilities or redundancy

The customers age particularly older and younger people. For example, a younger person may be considered inexperienced and the older person may be less technologically able

Our key principles when engaging with a vulnerable customer

As soon we think we may be engaging with a vulnerable customer, whether this is through our identification or you are approaching us, we will seek your consent to immediately make a record of this and ensure we adhere to this policy

Provide additional opportunities for you to ask questions about the information we have provided

Continuously seek confirmation that you have understood the information that has been provided

Ask if there is anybody with you who is able to assist. If not, and we believe this will be beneficial, we will make arrangements to continue with the subject matter at another time

Offer you the opportunity to complete the transaction after a period of further consideration

If we can’t help a customer, we will try and make sure that they understand what alternative options are available to them.

CVSL Limited is authorised and regulated by the Financial Conduct Authority (FCA) for the provision of consumer credit related brokering services only.

We are a credit broker of vehicle finance, we are not a funder or lender.FCA Firm Reference No. 657777