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Consumer Duty

Comparison Creator Limited and Consumer Duty

Consumer Duty requires us to focus on consumer outcomes, putting the customer’s interests at the heart of all our activities.

There are three key elements of the Consumer Duty:

Consumer Principle

  • ‘A firm must act to deliver good outcomes for retail clients’


Cross-cutting rules

  • act in good faith towards retail customers.
  • avoid foreseeable harm to retail customers.
  • enable and support retail customers to pursue their financial objectives.


Four outcomes

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

Consumer Duty applies to all Personal Lines products that Comparison Creator provides.

Comparison Creator’s approach to Consumer Duty

A key element of the Consumer Duty is the requirement for us to assess, test, understand and evidence the outcomes the customers are receiving.

We therefore

  • Monitor and regularly review the outcomes that our customers are experiencing
  • Ensure that the products and services provided are delivering the outcomes that our customers expect in line with the Consumer Duty, and
  • Identify where they are leading to poor outcomes or harm to consumers.


Management Information

We use data to measure our performance to ensure that we meet the requirements and examples of this are:

  • Management meeting minutes
  • Analysis of customer claims, cancellation rates & complaints
  • Auditing of the customer journey, customer interactions and drop off rates
  • Reviewing our distribution of product lines
  • Fees and charges applied
  • Process and policy effectiveness reviews
  • Ensure that staff training/CPD records are up to date
  • Mystery shopping
  • Auditing providers
  • Staff feedback
  • Results of regular testing and monitoring.


Where issues are identified, they will be addressed appropriately. Potential interventions could include:

  1. Discontinuing a product or service
  2. Adapting product design/fees/charges
  3. Changing operations or distribution channels
  4. Offering redress where customers have suffered harm.

Consumer Duty applies across all of our activities – from high-level strategic planning to individual customer interactions. Internal processes are constantly being reviewed and customer service processes evaluated.

We have produced a Product Oversight and Governance Policy document and individual Fair Value Assessments are gathered from each provider/insurer for all our products.