Treating Customer Fairly Policy

1. Statement

  • At all times, Amarah Automotive LTD trading as Penny Hill Motors will ensure all practices are carried out with the customers best interests central to the work carried out.
  • Customers will be given honest, transparent information to allow them to make an informed decision. 
  • Any possible employees or contractors of ours are expected to abide by the terms stated within this policy. 
  • We are committed to providing the customer with the best outcomes possible from our panel of finance partners and providing them with a product that meets their needs.
  • Treating Customers Fairly is central to our corporate culture, therefore it is important that the customers interests are considered at every stage of their journey, including before and after entering into a contract.

2. Regulation

a) The aim of FCA’s Treating Customers Fairly (TCF) initiative is to ensure that firms meet the requirements of Principle 6 to “pay due regard to the interests of its customers and treat them fairly”.

b) What constitutes fairness is evidenced differently for each firm, depending on their type of business, product and service range, target customers and the channels used to sell and support their products and services.

c) Below will detail the processes that we as a business carry out in order to Treat Customers Fairly at every stage of the journey. 

d) In order to assist businesses with TCF, the FCA has listed 6 consumer outcomes in which it expects businesses to act to- 

  • Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.
  • Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
  • Consumers are provided with clear information and are kept appropriately informed before, during, and after the point of sale.
  • Where consumers receive advice, the advice is suitable and takes account of their circumstances.
  • Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and also as they have been led to expect.
  • Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

3. Processes and Responsibilities 

a) Income and Expenditure evaluation and other proofs of identity 

  • We will validate income information with the consumer to ensure our partners will have the information to calculate a sensible max lend the customer can afford.
  • We will question the customer on a budget so the information goes over to the partner, meaning they can work on a max lend that meets the customers’ expectations. 
  • If any new income information comes to light such as a change in circumstance or incorrect information, this will be passed on immediately. 
  • Where required we will obtain the correct proofs needed from the lender, ensuring they are true copies and accurate.
  • Valid Photo ID will be required on every deal, this has to be in the form of a Valid Driving Licence or Passport. If this cannot be obtained, the deal must be referred to management.
  • Further checks may then take place to fully assess the customers identity and circumstance.

b) Products and Services

  • The customer will not be charged a fee for the service we provide them. 
  • We will provide the customer with all of the information regarding a product to allow them to make an informed decision, in good time before any agreement is signed.  
  • We will offer the customer the best rate or outcome we can from our panel.
  • In the event the customer has multiple acceptances, the customer will be provided with all of the information. 
  • Where we offer optional products, it will be made clear that these are optional. If the customer chooses to proceed with one of these products, we will obtain clear confirmation of their intention to do so.

c) Communication

  • All communication templates and scripts will be reviewed for compliance purposes. 
  • Compliance will be involved in subsequent disclosures involving our products and services.
  • We continually invite feedback from our clients to ensure that our services meet their needs and expectations. This can include testimonials and direct feedback.
  • Any phone conversations will be done from documented scripts evaluated for compliance purposes to ensure we are gaining all information and confirming details with the customer.
  • Calls will be recorded for training and monitoring purposes. Customers will be made aware of this on calls and within our privacy policy.

d) Training

  • A full training programme will be put into place to ensure competence and compliance.
  • TCF training will be done upon induction and at least annually. 
  • Amarah will ensure they remain knowledgeable and competent by carrying out compliance training such as SAF and additional compliance materials.
  • We will establish training materials for staff explaining new products and services as and when is necessary. 

e) Leadership and Management Information

  • Management Information is very important in analysing trends, forecasting the future and solving problems identified. 
  • We will use this to monitor customer treatment, expectations and outcomes. 
  • On at least on a monthly basis, we review and discuss compliance with a focus on TCF outcomes.
  • Compliance will be monitored on a weekly basis, with compliance monitoring filled in. This will be used to gain a full oversight into the business and product accurate and up to date Management Information as well as auditing and due diligence reports.
  • We will also look into training and competence reviews, ensuring staff have the skillset and knowledge to carry out their duties. 
  • Customer feedback will also be gained and reviewed in order to assess their experience and also if we have achieved the best outcomes. 
  • Directors will be accountable for ensuring the business follows all regulation and lawful requirements. 

f) Complaints

  • All complaints will be logged on a complaint log but will also be documented on our compliance monitoring plan to evaluate for any patterns. 
  • In the event the complaint is against a director, it can be outsourced to a compliance consultant for a third-party outlook to attempt to resolve the issue.
  • Complaints will be reviewed to establish any patterns with potential dealers or lenders. 

g) Marketing

  • All marketing will be clear, fair and not misleading. 
  • All representatives will be kept accurate and up to date to ensure consumers expectations are managed. 
  • All financial promotions will be reviewed to ensure compliance with CONC 3.
  • Recommendations will be taken into consideration when looking at marketing and put into place should it be required. 

h) Remuneration

  • At no time do we have an influence on the rate the customer receives.
  • Customers will be made aware that in order to introduce their details to finance partners, we receive a commission. 
  • We receive fixed commissions from all finance partners and do not have the ability to alter a specific customer rate.
  • Customers can request specific commission details, and this will be delivered in writing.
  • Any staff commission will be implemented to cause no detriment to the customer. 
  • Rates will be reviewed to ensure staff are providing customers with the best rates regardless of commission received. 
  • Any staff who are incentivised will be done so in a way that the customers outcome is not at risk.
  • Commission can be deducted at any time should process or procedure is not followed, or the customers interests and outcomes put first.
  • We have identified that incentivising staff or third parties could create a risk for the unfair treatment of a customer. To mitigate this risk all incentives and commissions will remain fixed to ensure staff and third parties always focus on the best outcome from the customer as detailed above.

4. Monitoring and Compliance 

  • It is extremely important that processes are monitored for compliance. 
  • Consumer applications will be monitored by our systems. 
  • All communications and records will be kept on our systems which are encrypted and kept secure at all times. 

5. Review 

  • This policy will be reviewed on at least an annual basis.
  • Any updates will be reissued on this policy.
  • All policy changes are approved by directors. 


  • By signing the below, you can confirm that you have fully read and understood the above policy, received adequate training on the subject and provided the opportunity to ask any questions.
  • Breaching the responsibilities in this policy may result in legal or disciplinary action, therefore you can confirm you will carry out the above duties in a compliant manner and in line with company policy.


Signed:                                        Date: