Introduction
The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) initiative is primarily based on the obligation set out in Principle 6 requiring a firm to pay due regard to the interests of its customers and treat them fairly.

Purpose
The board of Low Rate Car Finance Limited is fully committed to treating customers fairly and this statement is designed to demonstrate the application of TCF during the course of our day to day activities.

Scope
This policy has been adopted by the Board of Directors and applies to everyone involved in our business. For the avoidance of doubt, this includes all officers and beneficial owners of the firm as well as all employees (i.e. permanent, contract, self-employed and temporary staff). If anyone covered by the scope of this policy statement has any queries, these should be raised with the Managing Director.

What Is Treating Customers Fairly (TCF)?
Treating Customers Fairly is about creating an open, transparent, fair and honest environment for customers in relation to financial services and products. It means providing only those products and/or services that are relevant and suitable for the customer, taking the time to establish what is required and what is not, ensuring that customers understand what we are providing and how it will benefit them. Providing a product or service that meets the expectations of the customer and does what we have advised it will do and removing any post-sale barriers to enable the customer to cancel a service or raise a complaint without encountering any obstacles The main aims of TCF are to increase consumer confidence in the financial markets and companies and to receive fair, clear and relevant products and services that are suitable and fit for purpose. The FCA has advised that they “expect customers’ interests to be at the heart of how firms do business. Customers can expect to get financial services and products that meet their needs from firms that they can trust. Meeting customers’ fair and reasonable expectations should be the responsibility of firms, not that of the regulator.”

FCA TCF Outcomes
The six TCF outcomes detail what the FCA is trying to achieve for consumers. They are used for guiding regulatory decisions and actions and remain at the core of what the FCA expects of firms. • Outcome 1: Consumers 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 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.

Policy Statement
Our firm is committed to ensuring the culture and philosophy of treating customers fairly and ensuring appropriate customer outcomes is central to our activity. We recognize, however, that to fulfil this objective we must:
• Conduct our business with integrity.
• Consider the information required by our customers and communicate with them in a manner that is timely, clear, fair and not misleading.
• Take reasonable care to ensure any advice that we give to our customers to aid them in their buying decisions is reliable and sound and products meet their requirements.
• Liaise with product providers where necessary; to ensure that product information can be readily understood by our customers.
• Invest in the training and development of our staff to ensure they are competent and focused on the importance of treating every customer fairly.
• Manage any complaints or conflicts of interest fairly and in line with a straightforward procedure of which we make our customers aware and ensure any errors are corrected.
• Ensure the firm’s remuneration structure is regularly reviewed to ensure that it does not cause any conflicts of interest.
• Continually assess the services we provide to ensure we can meet changing requirements.
• Strive to get our customer service right first time and deliver what we promise.
• Empower our staff to ensure any concerns raised by a customer are immediately addressed. We expect TCF to be delivered as a natural result of our commitment to the core values that underpin our culture but nonetheless, we plan to use the FCA framework by means of confirmation. This framework guides us to six business areas: 1) Conflicts of Interest We are committed to the identification and fair management of any conflict of interest which may arise in the normal course of business. In accordance with the Financial Conduct Authority (FCA) handbook and specifically Principle 8 and SYSC 10, we aim to manage conflicts of interest fairly, both between our firm and our clients. 2) Financial Promotions Our policy and procedures on any financial promotions or communications with customers and/or clients, have been developed and implemented with the regulatory requirements under FCA Principles for Business, Principle 7 and CONC 3.3 of the FCA Handbook, taken into consideration. Communication methods include post, email, e-commerce and telephone and we are dedicated to ensuring that all such communications are fair, clear and not misleading in any way. 3) Sales and Service process We endeavour to ensure that the products/service that we provide are fit for purpose and adequate for the customer’s needs whilst gaining an understanding of their knowledge and experience of the product/service. We aim to treat our customers fairly and deliver high quality products/services that meet their requirements and expectations prior to, and during, their relationship with us. 4) Complaint Handling We maintain an open and transparent complaints system which is continuously monitored and reviewed. An ongoing record of complaints is maintained and the appointed Complaints Officer is responsible for reviewing and monitoring outcomes and root causes to ascertain a compliant TCF environment 5) Remuneration Our remuneration structure aims to ensure that our director/s and staff are rewarded fairly and competitively and according to performance in four key business areas. Rewards are based on the long- term value generated for our business, which is dependent upon the management of risk, the long-term satisfaction of our clients, the smooth running of our working environment and profitability 6) Management Information Generating high quality and effective Management Information (MI) on TCF to allow staff and senior management to review and assess our ongoing compliance with the 6 outcomes and FCA’s principles Responsibilities For the avoidance of doubt, the firm’s Directors shall ensure that there is clear allocation of responsibilities for developing and maintaining a fair treatment of customers ethos across the Senior Management team. This shall be documented in job descriptions and shall be a consideration in individual performance reviews