Consumer Duty

The Consumer Duty (“Duty”) is a set of rules developed by the Financial Conduct Authority (“FCA”) that sets higher and clearer standards of consumer protection in retail markets and requires firms to put their customers' needs first. The key requirements of the Consumer Duty rules are outlined below.

1. Consumer principle
2. Cross-cutting rules
3. Four outcomes

Foresight is committed to embedding the Consumer Duty into its culture to deliver good outcomes to all our retail customers. We have updated our policies and procedures in line with the Consumer Duty and provided additional training to our employees.

Furthermore, Foresight has established a working group to implement and oversee the Firm’s adherence to the Consumer Duty rules. The Firm has appointed a Consumer Duty Champion to support the Chair of the Members Board in raising the Duty regularly in all relevant discussions and challenging the Firm’s governing body on how it is embedding the Duty. 

The Consumer Duty introduces a new consumer principle (Principle 12) which raises the standards of behaviour the FCA expects from the Firm. Under the Duty, firms must act to deliver good outcomes for retail customers.  

Foresight is committed to delivering good outcomes for retail customers. Delivering good outcomes for us means that our retail customers: 

• Receive communications which they can understand and enable them to make effective decisions in a timely manner. 
• Receive products and services that meet their needs. 
• Receive fair value for our products and services. 
• Have access to our experienced Investor Relations Team through the lifecycle of our products and services. 

There are three cross-cutting rules which articulate the standards of conduct the FCA expects under Principle 12. These are: 

1. Act in good faith towards consumers
2. Avoid causing foreseeable harm
3. Enable consumers to pursue their financial objectives

The four Consumer Duty outcomes set more detailed rules and guidance on expected firm conduct across the four areas which make up the key elements of the product or service lifecycle. These are: 

• the governance of products and services (i.e. product or service design), and sales and distribution to retail customers
• price and value (i.e. whether products and services represent ‘fair value’)
• consumer understanding (i.e. the way the firm communicates with customers), and 
• consumer support (i.e. how the firm interacts with customers during the lifecycle of the product/service)

Foresight acts as a manufacturer of products and services. This means that the Firm does not directly sell its products and services to retail customers, rather Foresight products and services are distributed to retail customers through an intermediary, either an FCA authorised financial adviser or via a platform or broker. We make sure that firms distributing our products and services have all the necessary information they need to understand the value that Foresight products and services intend to provide to a retail customer.  

Foresight is committed to delivering the following behaviours to ensure that our retail customers’ interests are at the forefront of what we do and to increase retail customers’ confidence in our products and services:

• Deal with retail customers honestly, fairly and consistently.
• Create products and services that helps customers to meet their needs and financial objectives.
• Provide clear, fair and not misleading information to retail customers so they can make informed decisions.
• Assess our products and services on a periodic basis to ensure that there is a low risk of causing foreseeable harm and retail customers receive fair value.
• Provide additional support to vulnerable customers to ensure that they receive fair value and support they need.
• Understand customer behaviour in selecting and using our products and services to ensure that the Firm’s practices do not exploit any potential behavioural biases.
• Review distribution arrangements to ensure that the intended distribution strategy for the product or service is appropriate for the target market;
• Ensure that customer facing staff have the right skills and capability to recognise and respond to the needs of vulnerable customers through training;
• Monitor the quality of the customer support Foresight is offering, looking for evidence that may indicate areas where they fall short of the outcome, and act promptly to address these.

Foresight has conducted fair value assessments in accordance with the Consumer Duty rules on all Foresight funds designed for retail customers. Our assessment is based on the Consumer Duty outcomes:

• Product & Services;
• Price and Value;
• Customer Understanding; 
• Customer Support.

As part of the assessment, Foresight looks at vulnerabilities and behavioural biases in the target market, customer support provided during the lifecycle of the product or service, financial and non-financial benefits, competitor pricing, retail customer feedback and distribution arrangements. 

Foresight will re-assess fair value assessment on a periodic basis to ensure that retail customers continue to receive fair value, that the risk of foreseeable harm to investors is low and, where applicable, that vulnerable customers receive support they need to pursue their financial objectives.

Please reach out to our Retail Sales Team at +44 (0) 2036678199 or via email at sales@foresightgroup.eu. If you wish to obtain more information on the Firm’s products and services in scope of the Consumer Duty rules.

To support the customer understanding objective, Foresight conducted a firm-wide customer understanding assessment. The goal of the assessment was to check whether retail customers understand information provided to them as well as to ensure that they receive information they need for them to make informed decisions. Based on the areas assessed, Foresight concluded that information available to retail customers is presented in a fair, clear and not misleading way and in a format retail customers can understand so they can make informed decisions.

Foresight is aiming to send periodic surveys to selected intermediaries to gather information from our distributors including data about customer understanding. This survey will further inform our customer understanding assessment to see if we are providing the right information, at the right time, in a format that the customers can understand so they can make informed decisions and act in their interests.

Please reach out to our Retail Sales Team at +44 (0) 20 3667 8199 or via email at sales@foresightgroup.eu. If you wish to obtain information on the Foresight measures to support customer understanding.

At Foresight, we pride ourselves on providing first rate customer support. If you have a customer that requires additional support due to their vulnerable circumstances, please contact our Investor Relations team to inform us on +44 (0) 2036678181 or via email at investorrelations@foresightgroup.eu.

The FCA has also issued guidance available for firms on the fair treatment of vulnerable customers, which provides information on identifying and supporting customers with specific needs due to vulnerabilities.