TSB Bank Fair Conduct Programme

The Fair Conduct Principle is a legal term and means we must treat customers fairly in all aspects of business and in all interactions. 

For our customers this means:

• We pay due regard to customers’ interests.
• We act ethically, transparently and in good faith.
• We assist customers to make informed decisions.
• We ensure the products we provide are likely to meet the needs and objectives of likely customers.
• We do not subject customers to unfair pressure, tactics or undue influence. 

It applies when:

• We are designing, reviewing and maintaining our products and services.
• We are offering and providing our products and services.
• We are dealing or interacting with our customers in relation to our products and services. 

We aim to design and maintain products so that they are suitable for our customers’ ongoing needs, provide value, and work as customers' expect. We have transparent communications and information that support customers’ decision-making. 

What does this mean for you? 

• The products and services we offer help meet your needs and you are given information that can support you to make an informed decision.
• Our products and services operate as they are meant to, and when they don’t, you can feel confident that our processes help us to find issues and address them.

How do we do this? 

We endeavour to govern and monitor the design, distribution and communication practices for products to help ensure each product meets the ongoing needs of our customers. Opportunities identified for improvement are prioritised and then progress tracked.

We aim to understand our customers and their needs, and provide them with appropriate information, advice and support for them to make informed decisions. 

What does this mean for you? 

• Our people endeavour to understand your needs and support you to make informed decisions with the right information.  
• If you find yourself in a vulnerable circumstance or require extra care, we will do our best to support your needs where we can.  
• We make it simple and easy for you contact us for help and support. 

How do we do this? 

We train our people and make sure they are supported so they understand our customers’ needs, provide the right information and are equipped to provide support. We make sure our people are trained to support customers who are experiencing vulnerabilities or hardship and may require extra care. 

Our people are encouraged, capable, appropriately trained and supported to act in accordance with our values and deliver fair customer outcomes. 

What does this mean for you? 

• Our people are provided with training, so they can give you the information and support that you need. 
• We monitor our people to help ensure that they are providing the right information and support to you and that they remain equipped with the right knowledge and skills to support you.  
• We set clear expectations for how our people should act and behave and we take appropriate action when they do not meet expectations. 

How do we do this? 

Our Code of Conduct sets out how we expect our people to behave, and we have appropriate consequence frameworks in place where expectations are not met. Our learning frameworks are designed to ensure our people have the right knowledge and skills to provide support to our customers. 

Our systems and processes are designed and maintained to provide continuity of service to an appropriate level and protection of customer information. 

What does this mean for you? 

• Our systems and key processes are managed so that they are reliable, and we are prepared for situations that could impact your ability to access products and services.
• Our systems are designed and managed to keep your information secure. 

How do we do this? 

We take reasonable steps to monitor our systems and have plans in place when events or incidents occur that disrupt access. We have processes so that when we make system changes, we manage and limit impacts. 

We have oversight, checking and reporting processes to help us identify where we may not be treating our customers fairly, and we take action to resolve this. We promote a culture that positively challenges any behaviours and actions that may cause unfair outcomes.  

We know that we will not always get it right. But when we do identify that customers have been, or may be unfairly impacted, we prioritise making it right for those that have been impacted. Our governance, remediation principles, frameworks, and processes support a fair, efficient and consistent remediation for our customers as promptly as reasonably possible.

We leverage our approach to risk management and governance to ensure conduct risks are appropriately identified, treated and reported, and we regularly review the conduct framework to ensure it remains effective in driving fair customer outcomes. Our conduct risks are proactively managed, and our people understand their role in managing these and how this programme applies to them. 

Our issue and incident management processes helps ensure we can investigate and act when something is not right to reduce potential harm to customers. We encourage our people to speak up when they feel something is not right, and we have ways for our people to do this without fear of repercussion. 

We use data and reporting to drive insightful, thoughtful and efficient decision-making to improve outcomes for our customers, and we proactively identify where to look deeper because “things don’t look right” or we could improve how we do things. Our Board and senior leadership receive regular and comprehensive reporting on our compliance with our Fair Conduct Programme and the Fair Conduct Principle.