Treating Customers Fairly Policy

Genesis Capital (Finance & Leasing) Ltd ("Genesis Capital") places clients at the centre of our business, which ensures fair outcomes are achieved. Employees at all levels are trained to understand the six TCF outcomes and the cross-cutting rules and four consumer outcomes of the Consumer Duty. We promote this culture throughout the organisation using a "message from the top" approach to set the right standards from the outset.

The FCA's six TCF outcomes, derived from their Principles of Business, are:

• Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture.
• Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
• Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
• Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
• Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.
• Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Learning the six outcomes is not on its own enough to demonstrate that they are embedded in our culture. Below we set out how each one is implemented and achieved throughout our business.

• Each employee understands the importance of fair treatment of customers. Our clients are essential to our business model, and TCF supports both developing and established client relationships.
• Genesis Capital is a developed commercial business and our management team is directly involved with our activities.
• Employees are regularly trained on the fair treatment of customers, and we maintain a 'tone from the top' mentality that consistently promotes TCF throughout the business.

• Any marketing material we develop is proportionally targeted to the needs of our clients; for example, we do not send material about mortgage finance where a client requires vehicle finance. We make it clear that we are a broker and not a lender of financial products.
• We do not tend to issue financial promotions. Our website contains information about what we do and complies with the FCA Handbook CONC 3 financial promotion requirements. Amendments to the website are signed off by our Managing Director and Operations Manager prior to issue to certify compliance.

• The nature of our products and services means we interact closely with all our clients. As part of that process we become aware of any need to provide further information in a different way.
• Our website holds clear, simple guidance on how to contact us.

Genesis Capital acts as a broker of finance for our clients. We tailor our introductions specifically to the needs and suitability identified through a robust KYC and fact-find process.

• We provide clear information to our clients and are ever mindful of non-disclosure risk — for example, failing to mention a specific feature such as a minimum term lease, agreement fees or other charges as they become applicable.
• We have an ethos of no small print and are as open and transparent with our clients as possible, ensuring full disclosure.

• We have a complaints procedure and policy in place that comply with the FCA Handbook (DISP) Dispute Resolution section, and we apply these standards to all complaints from eligible complainants. Details of how to complain are clearly set out in our complaints policy, with a non-premium rate contact number and the option to contact us electronically.
• Genesis Capital is a member of the National Association of Commercial Finance Brokers (NACFB) and adheres to its code of conduct.

The FCA's Consumer Duty, the 12th Principle of Business, sets out expectations on regulated firms when engaging with retail customers, under the overriding principle that "a firm must act to deliver good outcomes for retail customers". In support of it, the FCA created three cross-cutting rules requiring firms to:

• Act in good faith towards clients;
• Avoid causing foreseeable harm to clients;
• Enable and support clients to pursue their financial objectives.

The FCA also set out four consumer outcomes. Firms are expected to ensure:

• Products and services offered meet the needs of the firm's target market;
• The price of products and services represents fair value to that target market;
• Appropriate measures are in place to support consumer understanding, enabling target markets to make an informed decision;
• Appropriate consumer support is available at all stages of the relationship.

Under the Duty, Genesis Capital will provide customers with products and services that meet their needs and offer fair value. Our customers will receive communications they can understand and get the support they need, when they need it.

We recognise that the Consumer Duty extends beyond the six TCF outcomes and places an onus on regulated firms to evidence that they are actively achieving the four consumer outcomes for retail customers. We have appropriate systems and controls in place to monitor consumer outcomes and, where we identify potential harm to our target markets, we will act swiftly.

We ensure all people within our firm are appropriately trained to understand and deliver against the expectations of the Consumer Duty, and we review and adapt our policies and procedures to reflect the most up-to-date information supporting its application, as set out in PRIN 2A.1.