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Our Consumer Duty

At Marlborough we always have investors at the heart of our business, and we ensure that your best interests are embedded into our culture. We welcome the introduction of the Consumer Duty as another opportunity to identify where we can make improvements for our customer.  

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What is Consumer Duty?

The Financial Conduct Authority (FCA), our industry regulator, has set higher and clearer standards of consumer protection across the financial services industry, and requires firms to put their customers’ needs first. This is a significant piece of regulation, called the Consumer Duty.

We welcome the FCA’s new rules, providing us with further opportunity to review and strengthen our focus on our customers and to build on our strong customer service culture. 

The Consumer Duty outlines four key outcomes that set out in detail the FCA's expectations of firms. Each of these are key elements of a firm's relationship with consumer and driving good outcomes.

Products & services:

Ensure that the design of our products and services meet (and continues to meet) the needs, characteristics and objectives of the target market.

Ensure that the distribution for the product or service is appropriate for the target market.

Price & value:

All products and services give fair value.

Consumer understanding:

Ensure consumers get the information needed, at the right time, and that it is presented in a way you can understand.

Consumer support:

Ensuring consumers are given everything needed to make an informed decision in their choice of our products and realising the benefits of that produce and our service.

Our approach to Consumer Duty

Over the past year, we have worked tirelessly to examine our products and services to ensure they are fit for purpose and we believe that our investors can have the confidence that their needs will be met and that they will have all the information and support they require.

 We have committed significant resource to reviewing the FCA regulations and have been working closely with industry bodies and our partner firms, to ensure that we are meeting the requirements of Consumer Duty to the highest possible standard.

Consumer Duty in practice


We have reviewed and strengthened how we approve and monitor our products and services.


We have set out and documented our processes for undertaking value assessment reviews of our products and services.  As this has been a requirement of funds for several years now, we have been able to call on the well-established framework already in place within IFSL.  You can find the latest value assessment reports for the funds in the literature section of the fund centre.


We’ve worked hard to ensure that those firms who distribute our funds have all relevant information available about our products and services, including the outcome of value assessments.  


We have developed our consumer testing of customer communications, to improve our assessment of how well a sample of our customers understand our key communication documents. We also have a new process for enhancing our communications, where needed.


We have been reviewing the journey our customers take when they choose any of our products and services, to ensure this is as straightforward as possible and provides them with all the help and support which they need.

We have also been working with our partners where consumer duty impacts them.


Our staff are critical to ensuring that we deliver good outcomes for all of our customers. We have focused on, and will continue to ensure, they are fully aware of the needs of the Consumer duty regulations, including providing relevant training and developing a culture of continuous improvement.

We have given our staff detailed training to ensure that the principles of Consumer Duty are embedded in our culture, and everyone is focused on ensuring the best outcomes for our customers. 

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