Consumer Duty – how we’re meeting the four outcomes

The Consumer Duty introduces the new Principle 12 (the ‘Consumer Principle’) which requires firms to ‘act to deliver good outcomes for retail customers’.

The FCA’s implementation timetable sets out its expectations ahead of the end of April 2023 and we wanted to take this opportunity to update you on the Aviva position.

The four Consumer Duty outcomes are:

  1. Products and Services
  2. Price and Value
  3. Consumer Understanding
  4. Consumer Support

The below sets out how we are meeting the four Duty outcomes:

Our position on outcomes 1 & 2

We’ve already implemented PROD4, and therefore already satisfy outcomes 1 (Products and Services) and 2 (Price and Value), with the associated processes now forming part of our business-as-usual trading environment. As part of our governance processes and the Fair Value assessments for outcomes 1 and 2 - which have a rolling calendar - should we identify any required alterations or enhancements these will be communicated to you by your relationship team in the normal course of business.

Our position on outcomes 3 & 4

We’re continuing to progress activity to test our processes and communications against outcomes 3 (Consumer Understanding) and 4 (Consumer Support) to ensure we deliver good customer outcomes. If any findings have relevance for your business, we’ll make you aware through normal engagement routes.

31 July 2023 onwards

We continuously strive to ensure we create a business that provides our customers with what they need when it matters most, to ensure we are with them today for a better tomorrow.

We have developed and will embed processes across all business units and channels that will continuously review and monitor all aspects of Consumer Duty to ensure good customer outcomes.

As an example, our existing governance frameworks will now be further enhanced to embed and oversee the outcomes and requirements set out in the Duty. Processes and frameworks enhancements will include but are not limited to;

  1. Customer journey support assessments
  2. Digital journey testing
  3. Communications testing
  4. Enhanced customer outcome Management Information and monitoring
  5. Expanded capability to monitor the characteristics of vulnerability

Whilst this has outlined the steps Aviva, as a manufacturer of insurance products and services, is taking to deliver compliance with Consumer Duty by the 31 July, we would also note our expectations that our Distributors are also taking appropriate steps aligned with their regulatory status to ensure adherence to the regulation by the same date.

Should you have any further questions about this, please do not hesitate to contact your relationship team.

If there are requirements specific to your relationship with Aviva, our team will be in contact shortly on this matter.