Consumer Duty

We understand that the FCA’s Consumer Duty is a priority across our industry. To help you meet the regulator’s requirements, we’d like to reassure you that we’re just a phone call or email away, ready to offer our support and answer any questions you might have about our products and services.

The information below is:

  • designed to support you in complying with your responsibilities under PRIN 2A.3.16 R and PRIN 2A.4.16 R; and
  • provided to you to fulfil our responsibilities under PRIN 2A.4.15R and PRIN 2A.3.12 R (2).

Please note that you are ultimately responsible for meeting your obligations under ‘The Consumer Duty’.


The documents for each of our products below include the following information:

Target Market Statements

Designed to help you understand:

  • Our products and who they are, and are not, designed for.
  • The expected distribution strategy.
  • Other important information on product characteristics and benefits.

Fair Value Assessments Statements

The statements take account of:

  • The price paid by the end customer.
  • The distribution channel through which the product is sold.
  • A review of the product performance and quality of service.

We carry out fair value assessments at least annually, in line with our proposition governance process. The fair value assessment statements provide you with the outcomes and conclusions of the latest completed fair value assessments.

Care Funding 

Just For You Lifetime Mortgage 

Pension Annuity 

Secure Lifetime Income 

Our due diligence information includes important details for distributors on our products. Read it carefully to understand what we offer and if it's right for your clients. 

    We’ve recently updated our Terms of Business. They set out the terms and conditions upon which we’ll accept business from you and set out respective rights, obligations and responsibilities. To submit business to us, please use the terms of business documents below:

    We’ve taken vulnerable consumers into account at all stages of the product and service design process, including idea generation, development, testing and launch.  As part of the continuous development of products and services we review our approach to ensure we continue to deliver good customer outcomes.

    There are four identified key drivers which may increase the risk of vulnerability.  These are:

    • Health – health conditions or illnesses that affect the ability to carry out day-to-day tasks
    • Life events – major life events such as bereavement, job loss or relationship breakdown
    • Resilience – low ability to withstand financial or emotional shocks
    • Capability – low knowledge of financial matters or low confidence in managing money (financial capability).  Low capability in other relevant areas such as literacy or digital skills

    Some customer groups are more likely to display characteristics of vulnerability than others and may display more than one characteristic.

    Due to the age profile and nature of our products, customers within our target markets are more likely to experience characteristics of vulnerability.

    To ensure we provide good outcomes to all our customers, we’re committed to

    • Educating and training for colleagues, ensuring they have the appropriate skills and experience to recognise and respond to the needs of vulnerable customers.
    • Providing suitable customer service and communications.
    • Adapting our policies and procedures, where appropriate, to support specific customer needs.
    • Monitoring and evaluating relevant management information to support the identification of practical action and/or innovation that supports the delivery of good outcomes for our customers.

    We recognise the importance of Distributors in identifying and supporting customers with additional or different needs. Please get in touch if you want any further information about how we can support you or your clients, and ensure together, we continue to meet the needs of all our customers.

    In line with FCA rules and as part of our product governance we may from time to time request information from distributors with whom we have an agency agreement. The information will be used to help us assess whether our products are being distributed to the correct target market and that customers are experiencing good outcomes from across the distribution chain.

    The type of information that we may request, includes: 

    Management Information

    We may ask for the following to be provided over a specific time period. 

    • Management information to evidence how the distributor will recognise and respond to customers who may be in vulnerable circumstances or have different or additional needs.
    • Management information on reasons for cancellation and rates.

    Live examples of how to distribute

    • Evidence to demonstrate how the distributor ensures that all of the product features and benefits are fully explained to customers, particularly for non-advised journeys.
    • Evidence to demonstrate our products are being recommended and sold to customers in the right target market with the appropriate needs. 
    • Evidence of any sales and/or recommendations to customers that are not in the target market. 
    • Evidence to demonstrate how the distributor ensures customers fully understand the product and its features and benefits. 
    • Management information evidence to demonstrate our products are meeting customer needs both at the point of sale and/or advice and throughout the product lifecycle.

    Other factual info on firms’ distribution model(s), strategy and overarching governance

    • Details of the distributor’s business model. 
    • Distribution strategy.
    • Advice principles and process. 
    • How potential conflicts of interest and behavioural bias are managed by the distributor 
    • Adviser remuneration strategy, including details of any sales incentive schemes linked to our products. 
    • Details of the distributor charges to the customer. 

    We have a well-established product oversight and governance framework in place to oversee how we design, monitor and review our products. These robust processes ensure our propositions are fit for purpose, designed to meet the needs of our intended target market, and distributed appropriately. Check here for details.