Consumer Duty Policy

Policy Statement

1.1

It is the policy of CrowdProperty (“the Firm”) to put its customers at heart of everything we do, including a commitment to always deliver good outcomes for our retail customers.

1.2

CrowdProperty is committed to complying with all applicable laws, rules and regulations in the markets and jurisdictions it operates in, including, but not limited to, the FCA Handbook (and PRIN 2A in particular).

1.3

This policy is supported and endorsed by the Firm’s Board of Directors and should be read in conjunction with the Firm’s policy on Treating Customers Fairly and Vulnerable Customers.

The Principle

2.1

Principle 12 requires a firm to “act to deliver good outcomes for retail customers”, a higher and more exacting standard of conduct than Principles 6 and 7. CrowdProperty is committed to complying with the Consumer Duty Principle and all applicable rules in PRIN 2A.

The Cross-cutting Obligations

3.1

The cross-cutting rules set out the FCA’s expectations as to how firms should behave and helps them interpret the requirements of the Four Outcomes.

• Act in good faith to retail customers: CrowdProperty is committed to acting in good faith, as characterised by honesty, fair and open dealing, and acting consistently with the reasonable expectations of retail customers in our target market.

• Avoid foreseeable harm to retail customers: we take all appropriate steps throughout the lifecycle of our products to avoid causing foreseeable harm to retail customers as a result of our actions or omissions.

• Enable and support retail customers to pursue their financial objectives: we are committed to enabling and supporting our retail customers to pursue their financial objectives by empowering them to make good choices in their interests, providing them with the information and support they require, and taking into account their needs and characteristics, including characteristics of vulnerability, in all aspects of customer interaction.

The Four Outcomes

4.1

The customer outcomes set out the FCA’s expectations as to how firms will deliver good outcomes to customers in practice.

• The Products and Services Outcome: the design of our products and services meet the needs, characteristics and objectives of our target market and are solely distributed by CrowdProperty.

• Price and Value Outcome: we ensure our products provide fair value throughout the product and consumer lifecycle.

• Consumer Understanding Outcome: our communications support and enable our retail customers to make informed decisions throughout the product lifecycle. Customers are given the information they need, at the right time and presented in a way that is clear, fair and not misleading.

• Consumer Support Outcome: we provide a level of support that meets customers’ needs, enables them to benefit from our products and helps them achieve their financial objectives.

Application

5.1

This policy applies to all permanent, full-time or part-time employees, senior managers, directors, agents, consultants, contractors and any other third parties who perform any form of service on behalf of CrowdProperty.

Obligations on the Firm

6.1

All CrowdProperty employees and relevant third parties (as per section 5.1) must complete mandatory Consumer Duty training, Vulnerable Customer training, and any role-specific training as and when assigned.

6.2

All CrowdProperty employees and third parties (as per section 5.1) must report any known or suspected breaches of the Consumer Duty Rules or the Firm’s relevant policies and procedures to either the Head of Compliance or the Consumer Duty Champion.

6.3

Failure to comply with the requirements of this Policy may lead to disciplinary action, up to and including dismissal or regulatory action.