GOJI FINANCIAL SERVICES LIMITED (“GOJI”) TREATING CUSTOMERS FAIRLY POLICY
Hello. We’re Goji. We’re a retail asset manager and platform focussing on delivering good customer and investment outcomes. We do this through product innovation and active management across our range of innovative debt-based securities.
We aim to treat customers fairly, deliver good investment outcomes and ensure that we engage with customers in a manner that is open and transparent through communications that are fair, clear and not misleading.
Our sustainability depends upon building long-term relationships of trust with customers, financial advisers, platform partners and other third parties, so this approach is soundly commercial. However, we also have to comply with the principles of our regulator, the Financial Conduct Authority (FCA) and specifically as a retail firm the core principle that we must pay due regard to the interests of our customers and treat them fairly. This policy outlines how Goji meets that requirement.
Other key FCA Principles for Business are:
– A firm must conduct its business with integrity.
– A firm must pay due regard to the information needs of its clients and communicate information to them in a way which is clear, fair and not misleading.
– A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.
– A firm must arrange adequate protection for clients’ assets when it is responsible for them.
The FCA introduced the TCF initiative to deliver improved outcomes for retail customers of the firms they regulate, such as Goji. The outcomes that are expected are summarised below and overleaf:
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. Please note that Goji does not provide investment or tax advice.
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.
Goji aims to deliver the FCA’s TCF outcomes in the following ways:
” The responsibility for ensuring that TCF is implemented in the systems and culture of Goji lies with the firm’s Management Committee.
” Senior managers and staff are responsible for ensuring that TCF outcomes are effectively managed within their area. This includes working to ensure that everyone in Goji understands how to deliver the TCF outcomes.
” We aim to demonstrate the achievement of TCF objectives in regular reporting under the FCA’s Senior Management Systems & Controls arrangements. This reporting is also subject to monitoring by Goji’s Head of Compliance.
” Goji aims to describe clearly the different investments it offers, including their aims, objectives and other features, to ensure customers understand our approach and the risks and costs involved.
” The TCF requirement applies to all Goji staff and this is made clear by inclusion in the induction programme for all new employees, and a statement in the Goji Staff Handbook and Compliance Manual, supported by regular communication with all staff.
” Where Goji delegates an activity which impacts its customers, financial advisers, distributors or other third parties, to a regulated company or otherwise, Goji looks to ensure that the principles of TCF are maintained by that delegate. It also arranges to receive regular feedback on the TCF activities of any advisers or platforms and to ensure that they have access to appropriate technical information and literature concerning Goji products.“
“Goji aims to act consistently with applicable guidance around TCF from the FCA, TISA and, where appropriate other industry bodies.
“Listening to our customers through obtaining regular feedback and having an accessible and transparent policy for dealing with any customer complaints.
Committee structure: The Goji Management Committee, which consists of senior managers from different departments within the business is responsible for co-ordinating the monitoring of TCF at Goji and meets weekly.
The committee’s role includes consideration of TCF matters including aiming to ensure all parts of the business are involved in delivering the TCF outcomes and co-ordinating appropriate remedial action where necessary. Additional reporting is provided to the Boards on a regular basis.
Signed: Jake Wombwell Povey, CEO, 16.10.2018