Direct Asset Finance
Terms of Business
Terms of Business
18th September 2015
How we do business:
The Directors of Direct Asset Finance (DAF) have established a reputation as one of the pre-eminent Asset Finance Brokerages in the United Kingdom.
Direct Asset Finance (DAF) takes the Values and Behaviours set out in this Terms of Business very seriously. This document and our commitment to it, constitutes a reference point covering all aspects of our working relationships, employees, customers, clients, regulators, business partners, suppliers, competitors and the broader community.
The behavioural standard set applies to every Direct Asset Finance (DAF) employee and to colleagues in the subsidiaries in which we have a controlling interest. Other subsidiaries in which Direct Asset Finance (DAF) has a minority interest, and joint ventures in which we participate, are encouraged proactively to adopt an equivalent approach, as are any other entities or individuals contracted by Direct Asset Finance (DAF) to do work on the company’s behalf.
The Direct Asset Finance (DAF) Terms of Business is aligned to the Code of Professional Conduct, published by the NACFB (National Association of Consumer Finance Brokers) which sets out the ethical and professional attitudes and behaviours expected of our industry. Direct Asset Finance (DAF) subscribes to this code and is committed to embedding its broad principles into our business.
Helping people achieve their ambitions - in the right way
- Integrity - A strong moral compass guiding our decisions
- Honest - Genuine, fair and honourable in principles, intentions and actions
- Reliable - Doing what we say we will do consistently
- Progressive - Never standing still. Progress through continuous improvement
- Professional - Delivering competently, placing our clients and customers at the centre of everything that we do.
We respect and value those we work with and the contribution that they make. We act fairly, ethically and openly in all that we do.
- Build trust with the colleagues and partners we work with
- Collaborate proactively with colleagues across all of Direct Asset Finance (DAF) to get the best results
- Show the courage to do and say the right thing
- Act in private as we do in public, and honour our commitments
- Take the time to understand clients’ and customers’ needs, regardless of our role
- Always strive to surpass clients’ and customers’ expectations
- Create and provide solutions for clients and customers that balance the short and long term.
- Aim for flawless delivery and learn from our mistakes
- Protect and enhance our reputation and legacy at all times
Our corporate Purpose, Values and Behaviours are fundamental to Direct Asset Finance (DAF)’ long-term success.
They represent the set of standards which govern the actions of all of us who work for the business and against which the performance of every one of us in Direct Asset Finance (DAF) will be assessed and rewarded.
Finance can play a critical role as an enabler of social and economic progress, growth and development, when undertaken in the right way. This means considering how our day-to-day decisions take account of external stakeholder needs in both the short and long-term, creating services that are not only commercially viable but also benefit society, and making a positive impact on the communities in which we operate.
We take pride in being an example of good practice through our consistent application of policies, standards of governance and ways of working. We play a broader role in the communities in which we live and work.
The Direct Asset Finance (DAF) Way...
We apply our Values and Behaviours consistently across the bbusiness in everything we do.
This means that we will act fairly, ethically and openly and abide by standards which are in many cases higher than those set by the laws and regulations which apply to our business.
Take account of the broader impacts of our decisions. This includes identifying those who may be affected (directly and indirectly) and making an evaluation of social, environmental and ethical impacts integral to our assessment of client financial propositions, supplier relationships and the development of new products.
At Direct Asset Finance (DAF) we strive to create and maintain mutually beneficial long-standing relationships with personal, business and institutional customers and clients, that meet their needs and exceed their expectations. This means making the time and effort to understand the financial advice and support that they need to achieve their goals, and ensuring that they are provided with creative solutions that enable them to make well-informed choices in support of their short and long-term goals.
Our objective is to offer good value and to deliver this via excellent and consistent customer and client service. We take pride in our reputation for delivering innovative products and ideas that allow us to help our customers and clients manage their financial affairs better.
Customer / Client
- Communicate clearly without jargon and are transparent about fees and charges, ensuring these are fair and reasonable
- Conduct sales, advertising and marketing of our services with integrity and do not make false or exaggerated claims
- Do not offer clients products that are not right for them
- Maintain confidentiality of customer and client information
- Deliver on our promises and take personal responsibility for putting things right when they go wrong
- Resolve complaints diligently, fairly and quickly and measure customer/client satisfaction
- Take a responsible approach to clients who find themselves in financial difficulty
- Evaluate the broader risks and impacts of business propositions and products to anticipate and rectify adverse effects
- Avoid undeclared actual or potential conflicts of interest, or behaviour that may be perceived as a conflict of interest. This may be a conflict between personal interests and the interests of Direct Asset Finance (DAF) (including our shareholders, supplier relationships, customers and clients), a conflict between the interests of two or more clients, or a situation where Direct Asset Finance (DAF) priorities its own interests over those of customers and clients. Where we cannot avoid such conflicts, we are transparent about their existence and the steps taken to manage them proactively.
At Direct Asset Finance (DAF) we use our energy, skills and resources to deliver high-quality, sustainable results, taking account of the longer term as much as immediate achievements.
We are committed to transparency in our disclosure and reporting and to delivering
a fair return to our shareholders. In managing our relationships with suppliers, we seek mutually beneficial relationships based on merit and work through our supply chain to ensure that related environmental, social and ethical impacts are identified and managed appropriately.
We respect our competitors and acknowledge that free and fair competition is good for business and customers and clients, driving innovation and improvements in service provision.
In managing our business, we appreciate that adherence to high standards of ethical conduct is fundamental to maintaining our license to operate. We will not compromise the controls or compliance requirements which govern our activities and behaviour and apply consistent standards across the bbusiness, including risk management, anti-money laundering and financial crime prevention, application of sanctions, bribery and corruption prevention, gifts and entertainment, conflicts of interest, anti-competitive practices and communication with internal and external stakeholders.
Where we engage with the regulator on issues relevant to our business, we are honest and transparent in our communication with them.
Ensuring good financial outcomes for our customers and clients is fundamental to the way Direct Asset Finance (DAF) conducts business and core to our strategy. We proactively consider the impact of our strategy and service along with how they are sold and managed, on customers and clients. We consider customer and client needs over the long term when making decisions.
Our strategy is to develop long term relationships with customers and clients by providing products and services that meet their needs and do not cause detriment.
We do not disadvantage or exploit customers or clients, customer segments or markets.
We do not distort market competition.
We address customer detriment and dissatisfaction in a timely and fair manner.
We proactively identify conduct risks and intervene before they crystallise by managing, escalating and mitigating them promptly.
Our service and distribution channels are designed, monitored and managed to provide value, accessibility, transparency and to meet the needs of customers and clients.
We safeguard the privacy of personal data:
Privacy and data protection:
Direct Asset Finance (DAF)’ approach to privacy and data protection is to ensure we respect and protect all personal information which we hold. Privacy and data protection laws set out requirements for handling personal information, this means that colleagues must:
- Collect and use personal information fairly and lawfully
- Make sure that personal information held is secure, accurate, relevant and up to date
- Respect individuals’ rights in respect of their personal information e.g.: provide a copy of their information on request, including details of how we use their information and where it is sourced; ensure that marketing suppression markers are applied correctly; ensure inaccurate information is corrected or deleted
- Only disclose personal information to those authorised to receive it
- Not hold excessive amounts of information or keep it longer than is necessary
- Complete relevant data protection training annually. In addition to these outcomes, we strive to deliver excellent customer service:
- Our marketing materials are clear, balanced and accurate, enabling customers and clients to make an informed decision
- We understand the different roles and responsibilities of provider and distributor and ensure there are no actual or potential conflicts of interest that could harm the customer or client
- We consider each complaint promptly and on its merits and treat each customer as an individual
- We continually collect, analyse and use information about our service and product sales to identify ways to improve our service to, and products for, our customers and clients.
Protecting Direct Asset Finance (DAF)’ assets
All colleagues are custodians of Direct Asset Finance (DAF)’ property and assets including its brand and intellectual property and have a responsibility to ensure they are used for Direct Asset Finance (DAF)’legitimate business purposes only.
Communication with the media and public speaking appearances
Direct Asset Finance (DAF) engages with the media in a fair, straightforward and responsive manner,
using true and accurate information and data.
Conflict of interest
An actual or potential conflict of interest may impair ability to make fair and objective business decisions on Direct Asset Finance (DAF)’ behalf, cast doubt on a colleague’s integrity and be damaging to Direct Asset Finance (DAF)’ reputation. All potential conflicts of interest must be avoided altogether, or properly managed if allowed to exist.
While impossible to define every situation where a conflict may arise, this may occur when:
- Direct Asset Finance (DAF)’ interests conflict with those of a customer/client
- The interests of one customer/client are in competition with another
- Our business practices place Direct Asset Finance (DAF)’ interests ahead of the customer/client
- A colleague’s personal interests compete with the interests of Direct Asset Finance (DAF) or customers/clients.
Direct Asset Finance (DAF) expects that colleagues will exercise sound judgment, in accordance with our Values, and take advice where appropriate so that high ethical standards are maintained.
Anti-money laundering Terrorist financing Sanctions Fraud:
Financial institutions are at the forefront of the fight against criminals who attempt to use our products or systems to launder the proceeds of their crimes, to finance terrorism or to bypass applicable national and international sanctions laws, including trade embargoes. We share a legal, regulatory, ethical and social responsibility to restrict the access of criminals to financial services markets and our systems, to protect our customers and clients, colleagues and others with whom we do business and to support governments, regulators and law enforcement in wider crime prevention.
The law imposes personal liability for failing to adhere to anti-money laundering rules.
It is essential that Direct Asset Finance (DAF) colleagues are familiar with both the policy and the procedures necessary to support our efforts to prevent Direct Asset Finance (DAF) from being used by criminals, be it carrying out customer due diligence and what to do when a suspicion or knowledge of criminal activity arises or assisting with law enforcement enquiries. Direct Asset Finance (DAF) also has zero tolerance to fraud and other dishonest actions perpetrated by employees. All colleagues are required to complete the relevant financial crime training on taking up their role and regularly thereafter.
Management and use of information:
Direct Asset Finance (DAF) may hold information in oral, paper based and electronic form relating to customers/clients, employees, suppliers and other third-parties, as well as our own intellectual capital and property. This information is confidential and may also be commercially sensitive. Colleagues must ensure that confidential information is handled with integrity and discretion and in accordance with applicable laws and guidelines.
Direct Asset Finance (DAF) must:
- Presume that information is confidential and treat it as such
- Be aware of legal and regulatory obligations not to disclose such information to third parties
- Only use or disclose information for appropriate business purposes
Transparency and co-operation with our regulators:
Direct Asset Finance (DAF) operates in a highly regulated environment. We need to comply with all relevant laws and regulations and to be open and transparent with our regulators. Sometimes
Direct Asset Finance (DAF) itself, a regulator or another external body will conduct an investigation into our conduct or practices. Colleagues are required to participate openly and constructively in these investigations.