Financial Promotions Policy v1.0
Purpose
This policy applies to all Penny Hill Motors employees, and they are expected to follow the steps of this policy should it be required when it comes to Financial Promotions.
Rules and responsibilities have been put in place based on regulation set out by the FCA (where financial promotions are concerned specifically within COBS 4 and CONC3), The Advertising Standards Authority (ASA)/Committees of Advertising Practice (CAP) and are enforced by Penny Hill Motors to ensure the fair treatment of our customers.
Definition
A Financial Promotion can be defined as ‘an invitation or an inducement to engage in investment activity.’ In our industry, this can be applied to vehicle finance.
It is important that the team can differentiate what is classed as a financial promotion and training will be carried out to ensure that they have this understanding.
Rules and Responsibilities
No member of the team is permitted to post on social media or other marketing avenues on behalf of the firm without prior written permission from Amarah.
All financial promotions must be reviewed for compliance purposes.
All financial promotions must be clear, fair and not misleading and can clearly be identified as a financial promotion as detailed in COBS 4.3 and CONC 3.3.1
Financial information will be kept accurate and up to date and list all required information as required in CONC3.
This will be reviewed and updated every quarter.
Any representative APR must be calculated using the 51% rule and we will ensure that it is clearly visible in a prominent manner where required as detailed within CONC 3.5.7.
Representative Examples will be made clear and consist of all information required in CONC 3.5.5
At no time will our financial promotions include ‘restricted expressions’ as detailed within CONC 3.5.12.
Technical systems will be kept secure with strong protection to avoid infiltration.
No consumer or company information should be marketed or posted on social media by any employee.
In all Financial Promotions we will make it clear we act as a broker, not a lender and ensure that COBS 4.5.2 is considered in each promotion.
We ensure we comply with the term ‘prominent’ and where required ensure all information is clear and visible.
We have compliance contacts that can assist us by reviewing our Financial Promotions where required. Recommendations will be passed to Amarah to implement accordingly.
Non-Real Time Financial Promotions will be documented to include all information such as a copy of the financial promotion itself, dates, platform etc. within our compliance monitoring plan in a clear section dedicated to financial promotions.
Copies of all promotions and information within these promotions will also be kept for record.
Whilst we do not anticipate a ‘real time’ financial promotion taking place within our process due to scripts and a certain call process in place, all calls are recorded for training and monitoring purposes, kept for record against the customers application and can be accessed by management at any time for review.
If required, these will also be recorded for evidence.
Records
All records and financial promotions will be documented on our financial promotions register, which is located within our master Compliance Monitoring Plan.
Any additional documentation or record will be saved, and comments added as to where this can be located.
Review and Approval
This policy, along with all others in this document, is reviewed on an annual basis and version controlled.
All changes and updates are approved by directors before being rolled out to staff.
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