Treating Customers Fairly

Johnsons Cars Ltd believes that the fair treatment of customers is fundamental to its business. The quality of the experience a customer receives whether in person, on the phone, by any other communication or touchpoint with our business has to be of the highest quality and make the customer feel they have been treated fairly.

As a motor retail business we influence the customer’s journey and experience when they wish to purchase vehicles and services from us, we do this in conjunction with our vehicle manufacturers, providers of consumer credit and suppliers of general insurance products.

Scope of this policy

This policy covers the sale of consumer credit and the general insurance products regulated by the Financial Conduct Authority and the principal of treating customers fairly or in the way anyone would want to be treated. In essence how does Johnsons Cars Ltd and its subsidiaries ensure its customers are treated fairly when introduced or sold such products?

Suppliers of general Insurance and consumer credit products and associated services

We have a very limited number of independent suppliers for such products, using only companies who can demonstrate they provide suitable and clear products, able to provide comprehensive training on their products and can demonstrate they hold the ‘TCF’ principal at the core of their business. The selection of such providers is one of the core parts to our ‘TCF’ approach.

With the selection of suppliers the design and marketing of such products is fundamental. We do not supply general insurance or consumer credit separately from the sale of a vehicle or service but require suppliers to provide us with information and tools to work with customers to select any suitable products.

Training and Monitoring of advising and selling Staff

A second fundamental part to ensuring customers are treated fairly is to ensure our staff who may advise or discuss such products have suitable training. This training will come from the following places

• Provided by an independent compliance supplier such as Proficiency Solutions and ITC, online, training record kept, annual accreditation. Audit quality of work.
• Provided by the supplier directly, online, face to face, training log maintained
• Provided by the management of the business on a day to day basis, coaching sessions, reviewing complaints, responding to training feedback from independent and supplier training test results
• Executive oversight of the above
• Complaint to any dealerships in writing or email is passed to Head Office for recording an assignment
• Complaints made to dealership staff are to be recorded by the staff member advising the customer to put the matter in writing and send to Head Office

Continuous improvement, we work to improve, company processes, staff development and knowledge at all times

Good Quality Advice

The third fundamental part is the quality of advice and ensuring it is fair, balanced, informative and able to be clearly understood. To this end we us the ITC system to record the advice and decision making process the customer and advisor are travelling, through to the eventual sale of consumer credit and general insurance products. It is a clear and consistent process followed by all staff for the products we provide. This ensures all customers receive the same level of care in the advising and sale of these regulated products.

Complaints

In the event of complaints Johnsons Cars Ltd has the policy to have these all recorded at its Head Office and assigned to a single Director to manage and ensure a resolution.

Our complaints process is as follows

All complaints are investigated and communication with the customer will occur at appropriate stages with any proposed resolution.

We will always give clear explanations of the process, what we will do, how we will approach the complaint and explain how we came to a decision. This will all be done in a timely manner.

We do monitor trends in cancellations, burn rates and complaints down to dealership and staff level to see if something is going wrong and needs investigating to address anomalies. This is all done in conjunction with compliance suppliers.

In the case of a complaint contact direct your correspondence to.

Finance Director

Johnsons Cars Ltd

Empire Court

Albert Street

Redditch

B97 4DA

Tel No 01527 590590

Email: complaints@jcar.co.uk

Complaints concerning Discretionary Commission Arrangements (DCA)

If your complaint relates specifically to commission disclosure on a finance agreement (Discretionary Commission Arrangement), on a vehicle sale dated 27^thJanuary 2021 or before, our complaints processes have temporarily changed pending the completion of the review by the Financial Conduct Authority (FCA). These timeframes have been summarised as follows (insert NFDA Annex 1)

The Financial Conduct Authority (FCA) (the regulator that regulates loans in the consumer motor finance sector) is reviewing the historical use of ‘discretionary commission arrangements’ between lenders and motor dealers who act as credit brokers (for example, we act as a credit broker when we arrange some loans with consumers). Generally, discretionary commission arrangements were arrangements where the broker was allowed by the lender to adjust the interest rates they offered customers for car finance and the broker’s commission was linked to the interest rate that was set. The review is not focused on any particular dealer or lender, but is a review of the motor finance sector generally.

Whilst it carries out its review, for complaints that could be affected, the FCA has introduced a temporary pause to the 8-week deadline that we usually have to respond to complaints. This pause started on 11 January 2024 and will continue until 25 September 2024. Following the pause, we will have the remainder of the 8-week deadline to provide customers affected with our final response. For complaints that could be affected, the FCA has also implemented an extension to the usual 6-month period that complainants have to escalate their complaint to the Financial Ombudsman Service (FOS). Complainants will have 15 months to escalate their complaint to FOS instead.

This pause only impacts complaints where the credit agreement was taken out before 28 January 2021 and involved a discretionary commission arrangement. Complaints not affected by the pause will continue to be dealt with in accordance with our usual processes. For further details about our complaints processes, you can refer to our Complaints Policy (which can be found at this link: [Treating Customers Fairly | Johnsons (johnsonscars.co.uk).

If you have a complaint that may be affected by the review, we will let you know and explain the consequences of this.

If you would like any further information about the reasons for the pause and extension, you should visit www.fca.org.uk/car-finance-complaints.