Consumer Duty Statement

At Octopus, we always try to put the customer’s best interests at the heart of everything we do, and to ensure that the customer experiences a positive outcome. We therefore welcome the FCA’s Consumer Duty Principle to “act to deliver good outcomes for customers”. Our primary objective is to ensure that we put customer interests first, which maps to our company values of being: Helpful, Bold and Straightforward.

We believe that culture drives behaviour. We seek to promote good culture by all our employees, across all aspects of our organisation and it is clear that there is no room for misconduct. In addition to the behaviours of our employees, we also expect the behaviours of those acting on our behalf e.g. outsourced service providers to meet and reflect these behaviours and uphold our standards.

In embracing the Consumer Duty, Octopus is aiming to:

• Protect the interests of its customers at each stage of the product cycle
• Be open and honest with our customers and other stakeholders
• Ensure that customers feel that they have all the information and support that they need at each stage of their dealings with us.

Consumer outcomes

Octopus knows that every customer:

• Has different needs
• Has different levels of understanding of the products and services we provide
• Will want information delivered to them in a way that they can understand and use.
• Will want our products and services to deliver what you, the customer, should reasonably expect.

Guiding principles

When considering the FCA Consumer Duty, there are a number of guiding principles for firms to focus upon and Octopus’ employees must take these into account wherever appropriate:

Product Design

It is essential that products and services are designed to meet the needs of identified customers. Furthermore, the products should be targeted at these predefined customers. As part of our decision-making process, we ensure that the product or service actually suits the customer base we are designing it for and, just as importantly, remains that way. We look to test this with real customers as far as possible.

Identifying target markets and selection of distribution channel

The target market will be identified before undertaking product design. The main distribution channels will also be selected beforehand, as part of the business strategy and product design process. These important factors are kept under review, as part of our regular product assessments, as we know things can change.

Marketing and promotion of the products, including provision of information to distributors

Octopus shall communicate with its customers, as well as the distributors, in a way that is clear, fair and not misleading, and to ensure appropriate levels of customer / stakeholder understanding.

Pricing and Value for Money

A part of the design of the products and services we provide is ensuring that customers get value for money. We look to ensure that our products and services are priced appropriately, and continuously re-test.

Complaint Handling

Outstanding customer service is at the heart of everything we do. But that doesn’t mean we get it right every time. Octopus has rigorous procedures to ensure that any complaint is handled in a consistent, prompt and fair manner. Our complaints procedures follow the rules set out by the Financial Conduct Authority, responsible for regulating investment companies like Octopus, and the Financial Ombudsman Service, which has been set up to resolve disputes between consumers and companies.

Training

Octopus employees receive training across all of our business lines to ensure their knowledge is up-to-date and that the information they provide is clear and appropriate throughout their employment. Training is administered through computer-based modules and specific classroom-based training hosted by a number of teams, including Compliance, Risk and People/HR.

Octopus takes its responsibilities as a product provider seriously and continues to ensure that we provide good customer outcomes at every stage of our relationships.  We remain fully committed to the fair treatment of customers and closely monitor our standards on an on-going basis.

Octopus will ensure that, where appropriate, these outcomes are achieved and are fundamental to all parts of the company’s business.