Treating Customers Fairly

It is the policy of R. Raphael & Sons Plc, trading as Raphaels Bank (the "Bank") to treat its customers fairly and conduct its business in compliance with the guidelines issued by its regulators, the Prudential Regulation Authority and the Financial Conduct Authority (the "PRA & FCA"), so as to deliver fair outcomes and maintain a good reputation in the market.

The Bank takes every care to ensure that its staff are well trained and act in a professional, timely and competent manner in all its dealings with customers to ensure compliance with the Bank's Treating Customers Fairly (TCF) Policy.

In order to achieve the objectives of the Six TCF Outcomes set by the FCA, it is the Bank's policy to ensure that:

1. TCF is central to the way in which the Bank conducts all its business with customers. Regular training and appraisal of staff is designed to ensure TCF is embedded within the Bank's culture to give customers confidence they will be treated fairly in all their business dealings with us.
2. Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly.
3. Customers are provided with clear information and kept appropriately informed before, during and after the point of sale. Care is taken to ensure that all advertisements and promotions are clear, fair and not misleading.
4. The Bank is not permitted under the terms of its license from the FCA to give advice to consumers. Customers seeking advice should obtain such advice independently from a qualified person or firm licensed to give such advice by the FCA.
5. Customers are provided with products and services that perform as they have been led to expect and strictly in accordance with the terms and conditions under which they are offered. Every effort is made to ensure that customers receive an acceptable standard of service in a timely and efficient manner.
6. After a customer has concluded a sale or other transaction, the Bank will not seek to impose unreasonable barriers if a customer wishes to change the product or service offered by the Bank, or if a customer wishes to switch provider of such product or service. The Bank shall not seek to alter any material terms and conditions of the original agreement under which a transaction was concluded, or raise any obstacles if a customer wishes to make a complaint. Complaints received by the Bank will be fairly, promptly and impartially investigated and resolved within a reasonable time frame. All complaints will be recorded and monitored with the objective of achieving a satisfactory and fair outcome.

Any terms and conditions or procedures adopted by the Bank which appear not to treat customers fairly, or which are not clear in all material respects will be reviewed and amended to meet the stated objectives of the Bank's TCF Policy.

The Bank is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.

January 2013