How does Evelyn Partners intend to meet the Consumer Duty outcomes?
Consumer Support
Consumers and their financial advisers can contact us through a number of channels whether that be digital, telephone or face to face. Dedicated qualified teams and colleagues are available to provide support through these channels.
Service is monitored through a range of metrics across our digital channels, ensuring consumer and colleague impacting service issues are prioritised and addressed across core channels and platforms.
The level of support required by a consumer will vary, we ensure that we understand the vulnerabilities of our consumers in our communication with them.
All colleagues are provided with the appropriate level of training relevant to their role to ensure they have the necessary knowledge, skills, and capabilities, including access to appropriate systems and processes to recognise and respond to a range of characteristics linked to consumer vulnerability and to answer and respond to consumer queries or concerns.
All in-house managed products and services are free from any exit penalties and fees, allowing consumers the opportunity to move at ease, subject to market liquidity. If an external platform is utilised, exit penalties or fees may be payable.
Consumer Understanding
Our sales and marketing brochureware are designed to provide an overview of the product and services available.
Our qualified Investment Managers will spend time with the consumer or financial adviser; explaining the features, benefits and charges of the products or services that would be most suitable. In addition, our online coaches, telephony teams and support colleagues are available to answer any queries relating to these.
Our products and services collateral is reviewed based on priority and in adherence to our internal framework that considers aspects such as use of plain language, with testing where applicable. In any situation, our service provider can produce on our behalf, communication and information in braille and audio format to meet the needs of our consumers. Feedback is driven by colleague and consumer reviews and interactions directly or via our digital channels.
Should a consumer have a need to complain, a robust complaints process is in place to ensure appropriate contact; action and redress is undertaken as required. We also undertake root cause analysis in order to monitor trends, including those linked to Consumer Duty outcomes.
Price and Value
Fair value is assessed at inception of a new product or service and periodically thereafter.
Our Fair Value framework sets out the criteria by which we assess, as summarised below. Please note this list is not exhaustive and other factors relevant to the product or service are also considered.
- Quality of Service - What level of service is expected; have we met or exceeded this level of service; has there been any complaints; how have our service providers performed in supporting the delivery of the service. Assessment will be made using information directly from clients and financial adviser feedback, along with trust pilot reviews and net promoter scores.
- Performance - How do we anticipate this product will perform against its investment objective; how has it performed against the benchmark and does the benchmark remain suitable.
- Costs – What is the cost to serve for this product or service; where does this sit in line with other products and services offered; Are the fees justifiable, are they reflective of the actual costs incurred to provide the product or service.
- Economies of Scale - What is the expected economies of scale in 1 / 3 / 5 years as the business grows and is there an opportunity to pass benefit back to the consumer.
- Comparable market rates – How this product or service compare from a cost perspective to similar offerings available in the marketplace at inception and ongoing.
- Comparable Services – How this product or service compares from a features, benefits and service perspective to similar products or services offered by Evelyn Partners.
In line with industry standards, Evelyn Partners will be requesting management information from our distributors on a periodic basis.
Products & Services
Our updated Product Governance framework strengthened our review process to ensure alignment with Consumer Duty requirements. All products and services are reviewed and assessed via this framework, before inception and periodically to ensure they are fit for purpose, offer fair value and are in line with all Consumer Duty outcomes.
We are committed to review all open products and services in line with our updated process by July 2023 and closed products and services by July 2024. Any concerns identified within the review will be further investigated and distributors notified if appropriate.
Consumers in vulnerable circumstances may be less likely than others to be able to represent their own interests and are more likely to suffer severe detriment if something goes wrong. The nature and scale of characteristics of vulnerability that exist in our target market and client base are taken into account when designing products and services to avoid potential harmful impacts. Our framework ensures this is core in our assessment when designing and reviewing our products and services.
In addition, we ensure:
- All communication and information about our products and services are understandable for clients in our target market and client base, including vulnerable consumers.
- All complaints that are received will follow a robust process to ensure appropriate contact; action and redress is undertaken as required. Root causes are monitored to enable trends linked to Consumer Duty to be identified and inform decisions around changes required to the product or service.
Supporting you to get ready
The Consumer Duty outlines the above four key outcomes that is set out in detail the FCA's expectations of firms. Each of these are key elements of a firm's relationship with consumer and driving good outcomes.
To help you meet the regulator's deadlines, we have created Product Information documents, detailing our:
- Target market statement
- Distribution and accessibility
- Main features
- Who the product is and isn’t likely to be suitable for
- Fair Value Assessment
- Foreseeable harm
- Conflicts of interest
- Key risks
- Point of contact
You can access the Product Information Sheets for each service specifically designed for external distributors by the below links:
Core Managed Portfolio Service
Active Managed Portfolio Service
Sustainable Managed Portfolio Service
Discretionary Portfolio Service