Meeting Consumer Duty Requirements


The Financial Conduct Authority’s new Consumer Duty Rules, which are effective from 31st July 2023, require product manufacturers and product distributors to work together to deliver good customer outcomes in respect of the products provided to them. This will involve a greater exchange of information between us than existed previously if we are to succeed in meeting the Regulator’s expectations. We all have to ensure that we comply with the following Cross Cutting Rules and achieve good Customer Outcomes in the four Outcome areas:


Cross Cutting Rules


  • Act in good faith toward retail customers.
  • Avoid foreseeable harm to retail customers.
  • Enable and support retail customers to pursue their financial objectives.


Customer Outcome Areas


  • Products and Services
  • Price and Value
  • Consumer Understanding
  • Consumer Support


An important part of our approach as a product manufacturer is to ensure you have the information we must provide you with as a product distributor. Therefore we are making available to you the following information as required by the FCA Rules at PROD 4 and PRIN 2.


Target Market Statements and Fair Value Assessments for the following products can be found by accessing the links:



We are aware that Consumer Duty Rules (PRIN 2) do not apply to Group Products (as they are excluded from “retail market products”) but we prefer to adopt a consistent approach to all our product governance processes and therefore will provide the same information across the portfolio.


There is also an obligation on us to obtain information from you concerning the fair value aspects of your own role in distributing our products and from time to time we will contact you to understand the basis of how you deliver fair value.