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Sales process

Consumer Banking's approach to suitability

The global financial crisis has highlighted the importance of our commitment to responsible selling particularly in the wealth management arena. We responded rapidly to the crisis events by strengthening the resourcing and senior management oversight of our customer complaints processes.

While reviews of our Consumer Banking's sales and suitability practices generally found them to be robust, we have continued to enhance our processes in numerous areas including:

  • tightening procedures for identifying vulnerable customers (such as the elderly who may have no prior investment experience)
  • restricting the types of products made available to them and insisting managers ensure they have been offered fair treatment
  • throughout the sales process
  • introducing after sales assurance calls for all customers who are first-time buyers of more complex investment products to ensure the sales process has been conducted appropriately
  • refreshing staff training to make sure they properly understand our customers' requirements and that products sold are suitable for their needs and risk appetite
  • regularly reviewing our sales processes to ensure they meet or exceed regulatory standards adapting our policies and procedures to responding to extensive regulatory change affecting the distribution of wealth management products

Wholesale Banking approach

Procedural controls

Treating clients fairly is a requirement of both our Code of Conduct and our Financial Markets' Dealers Code of Conduct. At a transactional level, we have procedures in place for each transaction to ensure this is the case. These are regularly reviewed and improved.

Where client satisfaction levels need to be addressed, procedures are in place to ensure their complaints are treated consistently, fairly and speedily. A Distributor Transaction Approval Group was established this year to ensure that we manage the potential legal, regulatory and regulatory risks associated with the sale of structured products to a financial intermediary, who deals with their own clients. We want to make sure that these financial intermediaries are as rigorous at treating their clients fairly as we are.

Marketing materials

Our ABC approach guides the way we write and produce marketing materials for all Wholesale Banking products. This simple acronym stands for Accuracy, Brevity and Clarity. Any information we provide to clients will be accurate, relying on facts not hype, and we spell out the benefits of each product clearly. Finally, the design of our marketing materials is plain and simple, making sure that clients are not distracted by images or clever wordplay.

Mobile banking

Case Study: Mobile Banking

Our current mobile services include the following broad categories...

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Report tools

Annual Report and Accounts 2009