Consumer Duty

Frequently Asked Questions

• How are you preparing for Consumer Duty?

  As per the FCA Consumer Duty requirements, we’re applying a set of consistent frameworks and reporting across our CLUK product portfolios. This includes our offshore business, despite there being no direct application of the requirements to that legal entity. This is to ensure we offer all of our customers a consistently high standard of care.

  Our approach so far

  A full programme is now in place working towards the implementation milestones, reviewing our processes, product suite, servicing, customer journeys and communications. We have mobilised eight work streams to lead on:

  • Customer and Distributor understanding
  • Customer service
  • Customer communications
  • Proposition
  • Fair Value Pricing
  • Governance, monitoring and MI
  • Distribution
  • Enterprise alignment

   

  We have completed the required product reviews and put in place broader distribution support. Regulatory and project scope is finalised for each legal entity and mapped to the rules and guidance. 

  Our key milestones

  All key milestones have been met or are on track including customer strategy analysis, development of new customer segmentation models, target market analysis and customer journey mapping to pinpoint key touchpoints and moments of truth, as well as identification of areas that could present harm.

  Our closed products

  As we have a number of customers within closed products, we are aligning our Consumer Duty approach to these customers within the FCA timetable. Alongside this we have an existing risk - based schedule of product reviews for our closed products to ensure that products continue to meet the needs of customers and that customers are being treated fairly.

  Our product review process

  The Consumer Duty requires us to provide wider disclosures on products fair value assessments, target markets and other product related details.

  As part of our product review process, we assess our data to ensure that our products are distributed to the intended target market. Where any outliers are identified, these will be investigated.

  Our testing framework

  To support the launch of Consumer Duty we are conducting research on potential customers to help enhance our customer understanding. We also use regular customer surveys across our product range to provide feedback and insight into customer expectations and outcomes. This is combined with other sources including ad hoc information such as any customer complaints to assist us in gaining comprehensive customer insight.

  Our fair value statements and target market statements

  Any outcomes that fall below our required standards will be addressed and highlighted - if deemed appropriate - in fair value statements.

  We assess fair value through four key areas – features, services, price and distribution. We monitor a range of metrics underlying these four areas to ensure that products continue to provide fair value to our customers. These assessments are performed regularly and outcomes reported annually to the Canada Life Board.

• How will you ensure good outcomes specifically for vulnerable customers?

  We recognise that all of our customers are individuals with different needs, some of whom need additional care, and we’re committed to supporting the fair treatment of vulnerable customers. Since the publication of the FCA’s guidance on the fair treatment of vulnerable customers, we have been delivering a number of improvements to reach a higher standard of care, such as:

  • Our Customer Strategy is helping us gain a better understanding of the needs of our target market and customer base, through detailed customer segmentation, which includes consideration of existing and potential vulnerabilities

   

  • Internally, we have launched a new annual mandatory vulnerable customer awareness training module for all employees alongside more in-depth training on key vulnerability support topics such as resilience, bereavement, dementia awareness, communication, financial vulnerability, and suicide

   

  • A new customer vulnerability champion community has been formed to offer guidance and support to colleagues across the business alongside a vulnerable customer support hub which hosts key processes, tools and guidance that our employees have access to. Where our employees may need additional support, a vulnerable customer referral group can convene at short notice to provide guidance and make decisions outside of our normal processes

   

  • Our Conduct Risk Operating Policy and Standard set out the requirements for identifying and responding to customer vulnerability, which are incorporated into supporting processes and procedures across the product lifecycle (e.g. product design, service provision and communications). In addition, we have enhanced our product lifecycle management framework to include a focus on vulnerability and developed a vulnerable customer risk assessment framework

   

  • Our design principles, brand guidelines and tone of voice guidelines are regularly reviewed to consider vulnerable customers, alongside an accessibility review of our website. We have also standardised and simplified our process for customers requesting information in alternative formats

   

  • We use the results from call monitoring and complaints to assess whether we’re meeting the needs of our customers. We have also enhanced our current quality assurance frameworks to specifically reference the identification and handling of vulnerability – and implemented improvements where needed. Customer vulnerability case studies are regularly discussed within our customer experience & complaints forums, with improvement actions agreed

   

  • We’re investigating how our systems can capture who our vulnerable customers are, through an ‘Additional Care’ marker alongside details of the vulnerability characteristic and support requirements. We’re also building a suite of vulnerability scorecards to allow us to understand how we’re performing for vulnerable customers and those needing additional care

• How will you measure customer outcomes?

  We’re building customer journeys and feedback loops to ensure all touch points are identified, with good outcomes defined, and all management information and processes documented within a reporting framework. This started with all customer journeys being mapped, identifying key moments of truth (points of customer decision making and any areas more likely for harm), and agreeing what makes a ‘good’ or ‘bad’ outcome at these points – along with lead indicators and MI required, and any acceptable tolerances.

  We’re also introducing a new customer feedback tool, customer analytics, a new complaints feedback process and enhancing our current fair value assessment metrics. All of this will build on our existing suite of customer MI.

• What Consumer Duty and conduct outcomes training is taking place within Canada Life?

  We have an integrated communications, engagement and learning approach that has been in place since early 2023. It aims to equip all colleagues to be able to clearly articulate what Consumer Duty means and how they personally contribute to the delivery of good customer outcomes.

  Our board members were trained, briefed and approved high level plans before the October 2022 deadline, and Consumer Duty Board Champions are in place.
  
  We introduced a shared customer objective from 2023 onwards to make sure every colleague considers how their individual role influences the customer experience and ensures we place the customer at the heart of everything we do.

  Consumer Duty has been embedded into all of our relevant mandatory e-learning modules for our colleagues, including ‘Customer Outcomes’, ‘Conduct Rules’ and ‘Customers with Vulnerabilities’ training. We have rolled out additional Vulnerable Customer and Behavioural Bias training and our customer-facing teams are going through deeper learning on vulnerable customers to ensure they’re fully equipped to take reasonable steps to avoid causing foreseeable harm for our customers as part of the new regulations.
  
  As well as ongoing communications and engagement activities to raise awareness of Consumer Duty, we’re also rolling out company-wide customer learning to give all our colleagues at all levels across the organisation a firmer understanding of Consumer Duty, what it means for us and how we can better serve our customers.

• What support will you have in place for intermediaries?

  We understand the critical role that our distribution partners play in helping us create good customer outcomes. Therefore, we will be working to ensure that:

  • We set out the target markets for our products and services, including understanding the difference between groups within the target markets
    
    
  • The roles, and risks arising from those roles, that 3rd parties play in the distribution chain are understood
    
    
  • Distributors have access to the appropriate information for them to understand our products and services
    
    
  • We can support distributors in their product and service compliance monitoring programme
    
    
  • Management information, with key risk and performance indicators, related to distribution (MI to support distributors and our MI to monitor distributors) is available and understood
    
    
  • Policies/procedures are in place to evidence how Consumer Duty has been embedded
    
    
  • How information flows between different parties is considered
    
    
  • How third parties are onboarded (initial assessment/ongoing monitoring/action where issues are found)
    
    
  • There is a process for monitoring for good/poor outcomes
    
    
  • There are appropriate arrangements in place with third parties and we ensure each is clear on their responsibilities
    
    

  Through our normal business and product development processes we gather formal and informal information and feedback from advisers. This will remain a business as usual activity.