1

Offa Money has a set of rules called the Conduct Risk Framework that guides how we manage risks related to how we behave towards customers. This includes a duty towards customers. 

Conduct Risk is reduced at Offa Money by following clear rules and procedures for creating products and services, addressing customer needs, and managing employees through codes of conduct and training.

The main documents outlining how Offa Money aims to serve customers well through its products, services, prices, and value are the Consumer Duty Statement, the Conduct Risk Framework policy, and the Group’s Product Governance Policy. Throughout all its activities, Offa Money is responsible for treating customers fairly, avoiding harm, and supporting customers in reaching our financial goals.

Offa Group and Offa Money are committed to high standards of business behaviour and managing risks effectively to treat customers well, protect the company’s reputation, meet business goals, and comply with laws and regulations. 

We are always working to improve how we handle Conduct Risk.

1.1

The Financial Conduct Authority outlines what it expects from firms regarding Conduct Risk. 
While specific parts of the FCA Handbook directly address Conduct Risk, managing Conduct Risk goes beyond just following these rules and principles.

For Offa Group and Offa Money, it’s crucial to show that we recognize the risks that might stop us from providing good outcomes for customers. 

We must take appropriate steps to reduce these risks and encourage the right culture and behaviour. This means promoting attitudes and actions that prioritise customer well-being and positive outcomes.

1.2

Offa Money understands that customers deal with complex financial situations. To manage Conduct Risk effectively, Offa Money’s policies, processes, and behaviours are crucial.

Our approach involves embedding specific goals in all relevant policies to ensure we:

• Offer products and services that match customers’ needs, as outlined in the Group’s Product Governance Policy.
• Provide good value for money and support customers’ financial goals.Make it easy for customers to make well-informed and timely decisions.
• Remove unnecessary obstacles for customers when doing business with any part of the Offa Group.

Offa Group and Offa Money regularly check and review the experiences of our customers to ensure that the products and services we offer meet the requirements set by the Financial Conduct Authority principles of business. 

This includes measuring service delivery against agreed standards (like Service Level Agreements), comparing product usage to expected volumes, handling customer complaints, and taking corrective actions as needed.

As part of developing new products, Offa Money defines its target markets based on the Group’s Product Governance policy. 

For instance, with a Sharia-compliant Bridging product, Offa Money identifies specific target groups like traditional property buyers, or those seeking Home Purchase Plans secured against their primary residence. 

We also identify customer segments that shouldn’t use these products.

Moreover, Offa Money carefully plans how it will distribute these products to ensure we reach the right target market effectively. This comprehensive approach aims to offer suitable products and services that meet our customers’ needs while adhering to regulatory standards that promote the fair treatment of customers.

1.3

Offa Money is committed to ensuring our customers understand our products and services well. We achieve this through various policies and practices:

• Product Governance Policy and Execution Only Sales Policy: These policies outline how Offa Money manages customer understanding outcomes when developing and selling products.
• Adherence to MCOB Rules: Offa Money follows rules on financial promotions, under the Mortgage Conduct of Business regulations, to ensure clear and fair communication with customers.
• Consumer Support Policies: This includes training and competence policies, product governance, vulnerable customer support, complaints handling, and management of outsourced services to ensure customer needs are met throughout our interactions.
• Clear Communication and Feedback: Offa Money ensures all communications, including marketing, are easy to understand and provide customers with necessary information to make informed choices. We actively seek feedback through testing communications with non-financial services individuals, issuing surveys to customers, gathering feedback from intermediaries, and monitoring call interactions for clarity.
• Transparency: Relevant information, such as charges and complaints procedures, is readily available on our website and communicated clearly during customer interactions.

Offa Money is focused on transparency and clarity in our communications and services, ensuring customers have the information we need to make informed decisions and providing support throughout our journey.

1.4

Customer support is a top priority for us at Offa. We tailor our support services to meet the needs of our customers, including those who may require extra assistance due to vulnerabilities, like hearing impairments. Every part of our business considers this when designing, reviewing, and adjusting processes.

Our products are straightforward and designed to be easy to use, such as Sharia-compliant financing secured against property. 

There are no complicated features or choices to confuse customers. What matters most to consumers is:

• Quick and Clear Information: Customers can quickly find out if our Sharia-compliant financing suits their needs.
• Efficient Processes: Our procedures are straightforward, ensuring a fast and efficient service. We keep a close eye on these processes as part of our risk management.
• No Unnecessary Delays: We don’t create unnecessary barriers or slow down processes that aren’t in the customer’s best interest. For example, we don’t delay providing redemption statements just to earn more profit.
• Consistent Post-Completion Service: We provide a post-completion service just as efficiently as we do before the transaction. Some tasks, like calculating redemption statements, may take longer, but we prioritise keeping the process smooth and timely.
• Equal Support After Sales: We don’t favour sales over customer support. For instance, we offer a freephone number for both sales inquiries and support needs.
• Easy Contact Options: We make it as easy as possible for customers to reach us—whether by phone, email, or letter.
• Accessible Complaint Process: We don’t make it difficult for customers to raise concerns. Customers can easily complain, and our staff are trained to handle complaints promptly. We aim to resolve complaints within three working days whenever feasible.

Our goal is to provide excellent customer service at every step, ensuring our products and processes are user-friendly and responsive to our customers’ needs.

1.5

In everyday language, the Financial Conduct Authority has outlined six outcomes we want to achieve for consumers, which guide our regulatory decisions and actions. 
These outcomes are fundamental expectations for firms like Offa Money:

• Outcome 1: Fair Treatment Culture
• Consumers should feel confident that firms prioritise fair treatment of customers in our corporate culture.
• Outcome 2: Targeted Products and Services
• Products and services offered in the market are designed to meet specific consumer needs and are aimed at relevant consumer groups.
• Outcome 3: Clear Information
• Consumers should receive clear information before, during, and after making a purchase so we can make informed decisions.
• Outcome 4: Suitable Advice
• When consumers receive advice, it should be appropriate for our individual circumstances.
• Outcome 5: Expected Product Performance
• Products should perform as firms promise, and associated services should meet acceptable standards as indicated to consumers.
• Outcome 6: No Post-sale Barriers

Consumers should not face unreasonable obstacles from firms when trying to change products, switch providers, make claims, or file complaints after a sale.

To ensure that everyone at Offa Money understands and upholds these outcomes, all colleagues undergo training when they join and receive annual training on FCA requirements and the company’s commitment to delivering fair customer outcomes, following the Group’s Treating Customers Fairly Policy. 

This training helps ensure that customer needs and fair treatment remain central to how Offa Money operates.

1.6

Offa Group and Offa Money take several steps to ensure good customer outcomes throughout the lifecycle of our products:

• Product Design and Distribution Assessments: we assess products during the design phase and throughout the sales process to ensure we meet customer needs and comply with regulations. 
• Regular Audits and Gap Analyses: we conduct regular audits to ensure our processes comply with standards to identify any gaps that need to be addressed.
• Continuous Improvement: we continuously challenge ourselves to recognise what constitutes both positive and negative customer outcomes as these expectations evolve over time. This involves collecting data on various indicators and identifying the root causes of poor outcomes.
• Turning Data into Action: we use this information to make meaningful changes to products, policies, and practices. For instance, if certain data indicates that customers are experiencing difficulties or dissatisfaction, we will take actionable steps to improve the situation, such as refining products, updating policies, or adjusting practices.

Offa Group and Offa Money are committed to actively monitoring customer outcomes, addressing issues promptly, and making continuous improvements to ensure customers receive the best possible experience throughout our interaction with the company’s products and services.

1.7

Outcome Testing involves thoroughly reviewing a customer’s experience to determine if we have received a positive outcome from our company overall, based on our unique circumstances. It’s important to note that there are limitations to how representative our sample can be in these tests.

We offer straightforward products designed for customers with specific financial goals related to property ownership, contract revisions, product switches, or prompt finance redemption. Our customer base is relatively narrow in terms of demographics and geographic reach.

This approach to outcome testing will be tailored to our business size, conducted with appropriate frequency and scale, and cover a sufficient sample of customers. The testing will ensure:

• Customer Journey Evaluation: We assess how the customer’s interactions with us contribute to achieving a positive outcome.
• Consideration of Individual Circumstances: We look at how our actions align with each customer’s unique situation.
• Intermediated Sales: For sales through intermediaries, we ensure that our actions were appropriate for the customer and that proper processes were followed.
• Direct Sales: For direct sales, we ensure that our products and actions are suitable for the customer’s needs, and that proper processes are followed.

Outcome Testing helps us ensure that our customers are getting the right products and services tailored to our needs, with a focus on delivering positive outcomes across different types of sales processes.

1.8

Offa Group and Offa Money are committed to gathering valuable insights directly from customers to improve our services and ensure customers are well-informed and satisfied:

• Structured Feedback: We actively seek feedback through customer satisfaction and sentiment surveys at different stages of our relationship with customers. While customer satisfaction is important, any dissatisfaction helps us identify areas for improvement and challenge our assumptions about delivering fair outcomes.
• Clear and Fair Communication: We ensure all our communications, including marketing materials, are clear, fair, and easy to understand. This applies to both spoken and written communications.
• Passive Feedback Collection: We collect informal feedback from customers through open-ended invitations on our websites/apps and through interactions with third-party service providers. This more informal data can highlight areas not covered in traditionally structured testing processes.
• Testing Communication Understanding: We test our communications with people outside the financial industry to ensure we are easily understandable and identify areas for improvement.
• Surveys and Intermediary Feedback: We regularly survey customers to gather feedback and also ask intermediaries for insights gained from customers.
• Monitoring Call Clarity: We listen to customer calls to ensure our staff communicate clearly and address any issues promptly.
• Timely and Informative Communications: We review the timing of our communications to ensure we meet regulatory requirements and provide additional beneficial information beyond mandatory requirements. This helps customers understand our situation and make informed decisions.
• Transparent Information: We publish relevant and easily accessible information, such as tariff of charges and complaint procedures, on our website and provide this information to customers throughout our interaction with us.

Overall, these efforts help us understand our customers’ needs and experiences better, allowing us to continuously improve our services and ensure fair treatment and clear communication with all our customers.

1.9

Offa Group and Offa Money are committed to supporting customers who may be vulnerable or facing difficulties. 

Here’s how we ensure our needs are met throughout our interaction with our products and services:

• Responsive Approach: We operate in a way that is sensitive to the needs of vulnerable customers, considering our circumstances at every stage of our journey with us. This commitment is outlined in our Vulnerable Customers policy.
• Tailored Solutions: When customers are facing challenges, we take into account any vulnerabilities we may have and strive to find solutions that work for both us and our company. For example, if a customer is struggling with repayments, we may adjust our approach based on our situation to prevent further financial harm.
• Individualised Assessment: Our staff are trained to assess customers on an individual basis rather than applying a standard approach. This ensures that we understand each customer’s unique circumstances and can provide appropriate support.
• Clear Communication: We ensure that our written material is clear, straightforward, and free from confusing jargon.
• Multiple Communication Options: Customers can reach us through various channels like post, email, telephone, online chat, or face-to-face meetings, allowing us to choose the method that suits us best.
• Data Protection: Any sensitive information about a customer’s vulnerability is handled securely and in accordance with data protection laws.
• Customer Recognition: Our systems can easily identify and flag vulnerable customers, ensuring that we receive the additional support we need during interactions with us.
• Flexible Product Offerings: Our products are designed to be flexible to meet the specific needs and requirements of customers, especially those who may be vulnerable.
• Staff Training: Our employees receive ongoing education and training to recognize and respond effectively to the needs of vulnerable customers.
• Monitoring and Review: We continuously monitor and review our processes and product launches to ensure we are appropriate and aligned with our commitment to supporting vulnerable customers.

Overall, we are dedicated to treating vulnerable customers with empathy and providing us with the necessary support to navigate our financial challenges while accessing our products and services effectively.

1.10

Offa Money carefully assesses the price and value of each product to ensure it offers fair value to customers. This assessment considers several important factors:

• Fair Value for Price Paid: Customers should feel they are getting good value for the price they pay.
• Total Cost Throughout Lifecycle: The price includes all expected costs over the product’s lifespan, including additional fees and charges based on typical customer performance.
• Distribution Strategy Cost: The cost of distributing the product is considered to ensure it’s appropriate and doesn’t inflate prices unnecessarily.
• Market Positioning: Offa Money ensures its pricing is fair relative to the market and doesn’t take advantage of monopoly situations to maximise profits, especially in its niche market of Sharia-compliant products.
• Acceptable Risk Pricing: Pricing accounts for the level of risk involved and is reasonable.
• Cost of Funding: The cost of obtaining funding for Offa Money is factored into pricing decisions.
• Consideration of Vulnerability: The pricing strategy ensures that vulnerable customers receive fair value despite any specific vulnerabilities within the target market.
• Compliance with Regulations: Charges related to payment shortfalls, finance redemption, and early payments are compliant with regulatory requirements and reflect actual costs, not profit-making.
• Transparency of Fees and Charges: Fees and charges are clearly communicated to customers upfront, allowing us to make informed decisions and verify that we have been charged correctly.

These assessments are regularly reviewed to maintain fair value, especially when making changes to existing products or introducing new ones. 

Additionally, all staff receive training on FCA requirements and the company’s commitment to treating customers fairly. Offa Money integrates Consumer Duty policies into its product governance and development processes to ensure customer behaviours and outcomes align with its duty to consumers.