Treating Customers Fairly.

Legal & General remains committed to the principle of Treating Customers Fairly (TCF).  Since its inception in 2008, Legal & General has embedded TCF into its day-to-day culture and remains committed to its principles.

Legal & General has implemented the principle and has detailed plans in place to continue the embedding process.  The following provides a brief summary on where we are in respect of each of the consumer outcomes that the FSA would like to see.

What do we do to ensure that our customers can be confident that Treating Customers Fairly (TCF) is central to our corporate culture?
  • Senior Management engagement is being driven through the top level Executive Committee, chaired by our CEO and attended by top management and Executive Directors from across the business.
  • A committee chaired and attended by executive directors has been brought together to drive and monitor the delivery of our TCF plans across Legal & General.
  • Within our general insurance (GI) division, programmes of activity are in place to drive TCF down to the coal face with this being monitored through our Risk and Compliance Committee (RCC), Board and other management committees including a TCF oversight committee.
  • A computer based training package (CBT) has been developed which delivers a clear TCF message and is mandatory for all staff. An accountability specific to the role is included in the Job Descriptions of all senior managers.
  • We collate detailed management information that is issued to the senior managers responsible for that area of the business and also to the Board and other committees as necessary. We have made great progress in developing this MI and will continue to evolve.
How do we ensure that the products that we provide are designed to meet the needs of our customers?
  • We have a Product Lifecycle Management process (PLM), which is a framework for testing our products and proposition, and understanding the target markets that we sell to.
  • Driving consumer research on both products and literature, identifying risks relating to the product design, distribution and servicing including training.
  • Approval checkpoints at director level are built into the PLM.
  • We review existing products to ensure that the overall proposition continues to deliver according to Consumer Outcomes. Key elements of these reviews are literature and complaints.
How do we ensure that our customers are provided with clear information and are kept appropriately informed before, during and after point of sale and during the claims process?
  • We have a number of programmes and controls in place to ensure that our communications are clear and that they contain sufficient information as well as being timely and delivered in an appropriate manner.
  • We have a specialist Advertising Approvals team to ensure that the correct standards are maintained.
  • The Product Lifecycle Management (PLM) requires customer communication needs to be considered throughout the product life. Existing products are reviewed as mentioned above.
How do we ensure that where customers receive advice, the advice is suitable and takes account of their circumstances?

Sales of Legal & General Insurance products are carried out on a non-advised basis. Training and Competency Guidelines have been developed for staff involved in this activity to ensure customers understand we do not offer advice, clear information is given and customers do not buy if they are ineligible for the cover offered.  Where a distributor makes the sale we recognise our responsibilities as a provider.  In respect of the provision of information we ensure it is clear, fair and not misleading and this should assist our distributors when discharging their responsibilities to provide suitable advice.

How do we ensure that customers are provided with products that perform as you have led them to expect, and that the associated service is both of an acceptable standard and as they have been led to expect?
  • Our focus on relevant and effective MI will lead to a better understanding of the quality of service that we are delivering to our customers and will identify areas where improvements can be made.
  • The Product Lifecycle Management (PLM) sets requirements for product literature and service expectations. Weather catastrophe planning enables us to react to those rare events as we have demonstrated during previous years’ flood events.
  • We take complaints very seriously and regard them as a source of valuable information. These are reported to our Risk and Compliance Committee (RCC), oversight is achieved through a Group Oversight Committee. Forums are held where various parts of the business come together to look at root cause analysis and complaint resolution.  We have a central complaints function. All staff are required to complete a CBT at least every two years to ensure awareness and knowledge of what constitutes a complaint.
How do we ensure that consumers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint?
  • The design of products is key to ensuring customers are not subject to unfair terms and conditions that might act as barriers. Additionally ease of contact is key to enabling customers to exercise their rights under our products.
  • Specific contact details are given both on our customer website and in written communications with customers, making it easy for customers to reach people that can help them.  
  • We register claims and record complaints and have a customer-friendly process for doing this.
  • We log control failures or weaknesses and assess customer impact. Appropriate action is taken to address any customer detriment.
  • Root cause analysis of complaints is undertaken and actions taken to address issues.
  • All of this is reported to our Risk and Compliance Committee (RCC) and other management forums.
  • We have implemented and continue to embed as can be seen from our answers to the previous questions.

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