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Compliance Monitoring 

Compliance Monitoring Plan

Premier Vehicle Leasing is authorised and regulated by the Financial Conduct Authority (FCA) for credit brokering. Our firm's reference number is 932037. You can verify this on the FCA’s Register or by contacting them at 0300 500 8082.

As an FCA-regulated firm, Premier Vehicle Leasing must adhere to the FCA’s 11 principles for business and maintain written procedures to ensure compliance. This compliance manual outlines the procedures that Premier Vehicle Leasing, its employees, and agents must follow to ensure adherence to FCA rules. Non-compliance is a serious matter and may lead to disciplinary action. All employees and agents are required to familiarize themselves with this compliance monitoring plan.

FCA’s Principles for Business

The following are the 11 principles that all regulated firms must comply with:

  1. Integrity: A firm must conduct its business with integrity.
  2. Skill, Care, and Diligence: A firm must conduct its business with due skill, care, and diligence.
  3. Organisational Control: A firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
  4. Financial Resources: A firm must maintain adequate financial resources.
  5. Market Conduct: A firm must observe proper standards of market conduct.
  6. Customer Interests: A firm must pay due regard to the interests of its customers and treat them fairly.
  7. Information Needs: A firm must pay due regard to the information needs of its clients and communicate information to them in a way that is clear, fair, and not misleading.
  8. Conflicts of Interest: A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client.
  9. Suitability of Advice: A firm must take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgment.
  10. Client Assets Protection: A firm must arrange adequate protection for clients' assets when it is responsible for them.
  11. Regulator Interaction: A firm must deal with its regulators in an open and cooperative way and disclose to the appropriate regulator anything that the regulator would reasonably expect notice of.

BVRLA Code

In addition to FCA authorisation, Premier Vehicle Leasing is a member of the British Vehicle Rental and Leasing Association (BVRLA). As a BVRLA member, we commit to the following principles:

  1. Clear Pricing: Provide clear pricing for all products and services across all sales channels.
  2. Accuracy: Avoid misrepresenting information about any products or services.
  3. Integrity: Behave with integrity and ensure agents follow the BVRLA Code of Conduct.
  4. Regulatory Compliance: Understand and comply with all rules and regulations related to our services and products.
  5. Informed Decisions: Provide customers with the information needed to make informed decisions.
  6. Professional Standards: Operate from an established place of business maintained to a professional standard.
  7. Advertising: Avoid misleading or inaccurate advertising material and comply with regulatory codes and standards.
  8. Complaint Resolution: Resolve customer complaints according to BVRLA standards.
  9. Training: Ensure employees are adequately trained to adhere to the Code of Conduct.
  10. BVRLA Logo: Display the BVRLA logo.

Approved Persons Responsibilities

Certain roles within Premier Vehicle Leasing that are classified as ‘controlled functions’ by the FCA must be formally approved by the FCA. This primarily affects the role of the Managing Director, Tom Johnston, who is responsible for appointing roles within the business.

Before an individual can be proposed for FCA approval, Premier Vehicle Leasing will:

  • Require completion of FCA Form A
  • Obtain an employment history for the last 10 years
  • Request references from previous employers covering a minimum of 5 years
  • Obtain evidence of relevant qualifications
  • Require an up-to-date credit report from Experian

Tom Johnston will review this information to determine if the individual is fit for FCA approval. If so, he will countersign Form A and submit it to the FCA. The role will not commence until FCA approval is granted.

Before beginning their role, the individual must read and understand the statements of principle and code of practice for approved persons in the APER section of the FCA handbook. Additional training may be provided if necessary.

Premier Vehicle Leasing will notify the FCA of any changes in personal details of approved persons. Approved persons must inform Tom Johnston immediately of any changes to the information provided on the original Form A.

Recruitment and Training Procedures

Premier Vehicle Leasing ensures that employees have the necessary skills and experience for their roles. Prior to appointing a new employee or agent, references will be obtained from their previous employer.

Financial Promotions

All financial promotions must comply with FCA rules. This includes any form of advertising or marketing related to FCA-regulated vehicle hire agreements, such as:

  • Websites
  • Press releases
  • Leaflets and brochures
  • Banner and pay-per-click advertising
  • Social media marketing
  • Posters
  • Email and SMS campaigns
  • Radio/TV advertising
  • Newspaper/magazine advertising
  • Voice broadcasting

Financial promotions will meet the following requirements:

  • Be clear, fair, and identifiable as a financial promotion
  • Specify Premier Vehicle Leasing’s name as the advertiser
  • State prominently that Premier Vehicle Leasing is a broker and not a lender
  • Be legible, accurate, and balanced
  • Use plain and intelligible language
  • Not disguise, omit, or obscure important information or warnings
  • Be presented in a way likely to be understood by the target audience
  • Include fair and meaningful comparisons if applicable

All financial promotions will be checked and approved for FCA compliance by Tom Johnston. The internal marketing team submits promotions, and Tom Johnston maintains a register of all approved financial promotions. This register includes:

  • The name of the individual who submitted the promotion
  • The submission date
  • The type of promotion
  • The approval date
  • The person who approved it
  • The duration of approval

Records of approved financial promotions will be kept for at least 6 years from the date of issue.

Sales Process

When speaking to customers, employees must be aware of their information needs and communicate clearly, fairly, and without misleading them. Key features of the finance agreement that must be communicated include:

  • Initial and monthly costs
  • Clarification that the vehicle is on a hire agreement and will not be owned
  • Whether maintenance is included
  • Duration of the agreement
  • Mileage restrictions and excess mileage charges
  • Potential additional charges for early contract termination
  • Possible charges related to fair wear and tear at the end of the agreement

Following the initial discussion, customers will be provided with:

  • An initial disclosure document outlining our services
  • A link to the proposal form to complete if they wish to proceed, requesting relevant information such as employment details, income, and expenditure for suitability assessment
  • An order form detailing the vehicle and terms selected
  • Details of the finance arrangement

If the customer wishes to proceed, they will complete the proposal form and sign the order form via e-signature. This documentation will be stored in our Customer Record Management System.

Pre-contract information, the hire agreement, and full terms and conditions will be communicated clearly before the hire agreement commences. Customers are advised to read these documents carefully before signing. Records of sales are kept for a minimum of 8 years.

Customer Vulnerability

We recognize that some customers may experience financial difficulties. We take responsibility for treating customers fairly and ensuring each individual is handled appropriately. Our procedures for identifying and dealing with vulnerable customers are designed to ensure:

  1. Fair and appropriate treatment
  2. Individualized attention and consideration
  3. Suitable support
  4. Ethical communication tailored to their circumstances and limitations

Our Customer Vulnerability Policy is a key part of our operations and is reviewed and updated regularly. Day-to-day monitoring of vulnerable customer cases is conducted, and any issues are escalated to the appropriate line manager for action.

Commission Disclosure

Premier Vehicle Leasing will disclose that it earns a commission for arranging finance. If requested by a customer, we will also disclose the amount of any commission or fee paid by a third party or funder in good time before entering into any finance agreement. Requests for commission details will be referred to Tom Johnston for confirmation of the correct amount.

Cancellations

Customers generally have a 14-day cooling-off period to cancel any finance agreement and receive a refund of any fees paid for arranging the funding. Cancellation requests will be referred to Tom Johnston for action.

Complaints Handling Procedure

Premier Vehicle Leasing aims to provide high service standards and resolve complaints swiftly and satisfactorily. If you have a complaint, contact us via:

To assist with our investigation, please provide:

  • Your full name and contact information
  • Full details of your complaint
  • Lease agreement details
  • What you would like us to do to resolve the issue
  • Photocopies of any relevant paperwork

We will attempt to resolve complaints immediately, but if not possible, we will keep you informed of progress and provide a final written response detailing our findings and actions. If you are dissatisfied with our resolution, you may refer the matter to the Financial Ombudsman Service within six months of our final response. We will provide a copy of the Financial Ombudsman Service’s explanatory leaflet with our final response. For more information, visit Financial Ombudsman Service.

Financial Crime Policy

While Premier Vehicle Leasing (PVL) is not covered by the Money Laundering Regulations, we are committed to implementing systems and procedures to mitigate the risk of financial crime. Any suspicious activity must be reported immediately to Tom Johnston. Tom will then determine the necessary actions, if any, and maintain a log of the date, time, recorded call, customer name, and contact details.

Conflicts of Interest

As an FCA-regulated firm, PVL must manage any conflicts of interest that may arise. This involves ensuring that the interests of PVL or its employees do not conflict with those of our customers, potentially leading to poor outcomes. Examples include situations where an employee has relationships with a supplier or customer that might influence decisions.

All employees are required to report any potential conflicts of interest to Tom Johnston. Tom will keep a register of these conflicts and implement controls to prevent them from negatively impacting customer outcomes.

Data Protection

PVL is committed to complying with the Data Protection Act and upholding the following eight Data Protection Principles regarding personal data:

  1. Fair and Lawful Processing: Personal data must be processed fairly and lawfully.
  2. Specified Purpose: Personal data must be obtained for specified, lawful purposes and not processed further in ways that are incompatible with those purposes.
  3. Adequacy: Personal data must be adequate, relevant, and not excessive in relation to the purposes for which it is processed.
  4. Accuracy: Personal data must be accurate and kept up to date.
  5. Retention: Personal data must not be kept for longer than necessary for the purposes for which it is processed.
  6. Rights of Data Subjects: Personal data must be processed in accordance with the rights of data subjects under the Act.
  7. Security: Appropriate technical and organisational measures must be taken to prevent unauthorised or unlawful processing of personal data and against accidental loss, destruction, or damage.
  8. International Transfer: Personal data must not be transferred to another country unless that country ensures an adequate level of protection.

Customers have the right to request information about what PVL holds about them. Requests are managed by Tom Johnston. All systems are password-protected to ensure the security of electronic data, and paper files are stored in a locked cabinet. When handling such requests, we ensure that customer identities are verified by asking for two of the following:

  1. Contract or account number
  2. Date of birth
  3. Mobile phone number
  4. Driving licence number
  5. Vehicle details

Compliance Monitoring and Reporting Procedures

PVL is responsible for ensuring that employees comply with FCA rules and other requirements. This may include disciplinary action when appropriate. For queries regarding the procedures outlined in this manual, employees should contact Tom Johnston at 0161 546 9600. Tom Johnston oversees cancellations, declines, and complaints to ensure PVL's performance meets high standards for customer satisfaction.

FCA Reporting Requirements and Procedures

As a regulated firm, PVL must make periodic returns to the FCA using the online service FCA GABRIEL. Failure to submit these returns on time results in a £250 fine and potential disciplinary actions. Tom Johnston is responsible for preparing and submitting these returns on time. We are also required to deal with the FCA in an open and cooperative manner, disclosing any relevant information promptly. Any breaches within the office are reported directly to Tom Johnston.