Royal Liver Group

TCF allows businesses like ours to take responsibility for the way we act without being constrained by a rigid list of rules that see a broad brush approach to regulation, instead applying a set of principles that let us take a flexible approach to operating in the best interests of our own customers.

Our challenge has been to show the FSA that we have fully embedded TCF into our business operations. That means, when we are audited, we must:

> Prove that the fair treatment of customers is established throughout our business culture; including strategy, training, remuneration and staff behaviours.

> Produce adequate management information for our senior management teams to monitor TCF.

> Demonstrate that we are engaged in a process of continuous improvement.

In 2008, we built upon the previous year’s award-winning implementation of TCF, by restructuring the TCF Programme into three workstreams to carry out the core TCF activity across the business:

> Culture

> Management Information

> Best Practice

Culture
We started by defining what a TCF culture would look like and then developed a strategy that would achieve it.

Using a framework published by the FSA, the Culture workstream assessed Royal Liver Group at both corporate and business levels against key drivers which make up the culture of a firm: Leadership, Strategy, Reward, Controls, Decision Making and Recruitment, Training & Competence.

Key achievements in 2008 were:

> The completion of gap analyses and action planning against the cultural framework. Corporate level actions were weaved into the Human Resources business plan for 2008/09 and work is ongoing with individual business units to bridge gaps were identified.

> Senior management engagement; individual roles and responsibilities for senior management were defined, reinforcing the importance of performance management to support TCF aligned objectives and drive competencies at all levels.

> The roll-out of an innovative and engaging TCF communications and education plan, tailored to individual teams to show the links between the day-to-day work of staff and the TCF Consumer Outcomes.

Management Information
The workstream ensured that management information achieved alignment with:

> TCF Consumer Outcomes (TCF end result alignment).

> The product lifecycle (operational application alignment).

> FSA expectation of key management information (regulatory framework alignment).

Best Practice
The main aim of this workstream was to provide a mechanism of continuous improvement that would see us achieve a level of industry Best Practice.

It adopted the guidance issued by the Association of British Insurers (ABI) through its Customer Impact Scheme and completed audit and action plans across the business. These plans have improved the way we work in the best interests of our customers.