1.Anti Money Laundering Policy

What is Windmill Motors policy on money laundering? 

1. The maximum amount allowed for cash payments has been reduced from €15,000 to €10,000 (currently £8800) per transaction or 'series of transactions'.
2. This is not designed to prevent customers making payments for cars but to minimise the risk to the Company of high value cash transactions.
3. Our policy is to:
   · prevent, where possible, Windmill Motors and it’s employees being exposed to money laundering.
   · identify the potential areas where money laundering may occur and provide staff with guidance and training to help prevent money laundering.
   · report all suspicions to the Companies nominated Money Laundering Reporting Officer – contact details below.
   · use the Proceeds of Crime Act to recover any monies lost to money laundering.
   

Summary of current legislation and regulations 

The legislation which embodies the UK anti-money laundering regime is contained in:
- The Proceeds of Crime Act 2002 (POCA), as amended by The Serious Organised Crime and Police Act 2005 (SOCPA). POCA provides for civil recovery of the proceeds from crime.
- The Terrorism Act 2000 (TA 2000) (as amended by the Anti Terrorism Crime and Security Act 2001 and the Terrorism Act 2006). The TA relates to the proceeds of terrorism and terrorist financing.
- The Money Laundering Regulations 2007. These are concerned with measures to restrict the opportunities for money laundering.
POCA and TA 2000 contain offences which may be committed by individuals or entities, whereas the 2007 Regulations deal with the systems and controls which businesses are required to have and contain offences which may be committed by businesses as well as the key individuals within them. 

2. Anti-Corruption and Bribery

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption [in all the jurisdictions in which we operate]. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

3. Complaints Policy and Handling

How do I make a complaint?

We’re sorry that you’re not happy with our service. By making a complaint, you’re giving us the opportunity to investigate and improve our services for everybody.

You have a number of ways to contact us; you can call or write to us via post or email, whichever you prefer:

Write to us: Customer Care,Windmill Motors Ltd, Windmill Garage, Main Road, Rippingale, Bourne PE10 0SP

Email us: You can choose to send your complaint to us by email [email protected]. Our opening hours are 9:00am and 5:30pm weekdays.

Call us: 01778 440777

We are open 09.00 till 17.30 on weekdays, and 09.00 till 16.00 on Saturdays

*Please note that the transmission of information via the internet (including e-mail) is not completely secure. Although we do our best to protect personal data, any transmission is at your own risk.

What happens next?

Within five working days of receiving your complaint we’ll acknowledge that we have received and are looking into your complaint, and we’ll let you know when you can expect
a response. We will then conduct a full investigation of your concerns (we may call you for further details).

We will then provide a final response, providing an explanation of what we have found, what we plan to do as a result and why we made the decision. This will normally be in writing via letter.

Unfortunately, complex complaints can take longer to resolve if we need to liaise with 3rd parties etc. If our investigation is likely to take longer than 8 weeks, we will contact you with an update on your complaint - as well as provide you with your escalation options.

We will keep you updated but at any time if you feel there’s additional information that will help us resolve your complaint, you can contact us by phone or email at any time.

What if you’re not happy with the outcome of the complaint?

We pride ourselves on treating our customers fairly and are sorry if any customer is not happy with the decision we make. If you wish to take your complaint further, you can ask the Financial
Ombudsman Service to look into it for you.

The Financial Ombudsman is a free, independent service for resolving disputes between customers and financial services institutions. You'll need to contact them within 6 months of our final response letter – you may also need to send them our final response showing our investigation and decision of your complaint.

You can visit the FOS website http://www.financial-ombudsman.org.uk/ or you can contact them via writing:
The Financial Ombudsman Service
Exchange Tower
London
E14 9SR

Email: [email protected]

Phone: 0800 023 4567

Important Information:
Windmill Motors (Ltd) are registered in England: No 5260689. Registered Office: Dhc Business
Centre, 226 Dogsthorpe Road, Peterborough, PE1 3PB and regulated by the Financial Conduct
Authority under firm reference number 658714.

4. Corporate Social Responsibility Policy

We believe that a commitment to the principles of corporate social responsibility (CSR) not only makes good business sense but also complements our core business strategy and corporate values. Our policy is based on the following principles:

• To minimise the impact and maximise the benefits that our work has on the environment and people around us.
• To integrate our CSR considerations into all our business decisions.
• To comply with, and exceed where practicable, all applicable legislation, regulations and codes of practice.
• To review, annually report, and to continually strive to improve our CSR performance.

In developing our strategy and setting out our policy for the first time we aim to deliver gradual but continuous improvements in our performance every year. As a result, our approach continues to evolve as we learn lessons along the way. To help define our policy we have divided it into four key areas:

Community

We recognise that we play an important role in our local communities and we aim to make the communities in which we operate better places. We encourage and empower our employees to get involved with their local communities and use their skills and where possible the Company’s resources to help create a mutual benefit. We are passionate about supporting local, national, and international charitable initiatives to help the lives of people less fortunate than us. We proudly support three very worthy causes which are close to our hearts.

People

We strive to ensure all our staff enjoy their work and have opportunities to consistently amaze our customers through their friendly expertise. As such, we continue to invest in apprenticeship programmes and actively look for ways in which we can promote and increase the diversity of our workforce.

Environmental Management

Managing our impact on the environment in a responsible and ethical manner

We know that our work has an impact on the environment and that we have a duty to manage that impact in a responsible and ethical manner. We do this through identifying all significant environmental impacts and putting processes into place to prevent, reduce and mitigate them. This also makes good business sense.

Responsible Trading

Building and maintaining the highest standards amongst our suppliers

We are committed to maintaining high standards amongst our suppliers. We oppose the exploitation of workers and we will not tolerate forced labour, or labour which involves physical, verbal or psychological harassment, or intimidation of any kind. We will not accept human trafficking or the exploitation of children and young people in our business and undertake all reasonable and practical steps to ensure that these standards are maintained.

5. Equality, diversity and inclusion policy

Windmill Motors is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination.

The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best.

The organisation – in providing goods and/or services and/or facilities – is also committed against unlawful discrimination of customers or the public.

Our policy's purpose

This policy's purpose is to:

1. Provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time
2. Not unlawfully discriminate because of the Equality Act 2010 protected characteristics of: 

• age
• disability
• gender reassignment
• marriage or civil partnership
• pregnancy and maternity
• race (including colour, nationality, and ethnic or national origin)
• religion or belief
• sex
• sexual orientation

3. Oppose and avoid all forms of unlawful discrimination. This includes in:

• pay and benefits
• terms and conditions of employment
• dealing with grievances and discipline
• dismissal
• redundancy
• leave for parents
• requests for flexible working
• selection for employment, promotion, training or other development opportunities

Our commitments

The organisation commits to:

1. Encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense.
2. Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued.

This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.

All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public.

3. Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation's work activities.

Such acts will be dealt with as misconduct under the organisation's grievance or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.

Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.

4. Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.
5. Make decisions concerning staff based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).
6. Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.
7. Monitor the make-up of the workforce regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality, diversity and inclusion, and in meeting the aims and commitments set out in the equality, diversity and inclusion policy.

6. Vulnerable Customer Policy

​How do we identify Vulnerable Costumers?

In order for Windmill Motors to address the needs of Vulnerable Customers we will firstly need to be able to identify them. There are many risk factors involved including bereavement, illiteracy, illness, disability or other impairments which increase a consumer’s vulnerability.​

Our team remains alert to the signs that the person we are talking too may not have the capacity to make an informed decision regarding the implications of the services/agreement that we are making to them. 

​The Mental Capacity Act says, that a person is unable to make a specific decision if they cannot understand information about the decision to be made, cannot retain that information in their mind, cannot use or weigh that information as part of the decision-making process or cannot communicate their decision.

​As part of our customer experience at Windmill Motors we always look out for vulnerable consumers and we aim to help and support them by:​

• Training our customer facing staff so they are able to deal with vulnerable customers appropriately.
• Observing and involving other members of staff who can provide help and support.
• Being patient and taking time to listen and facilitate a conversation with the customer so that they fully understand.
• Sharing information with our Partners regarding the customer’s current situation.
• Understanding the customer’s needs and demonstrating compassion.
• Allocating a familiar primary contact for the customer ensuring consistency and trust.
• Rewarding, recognising and praising good practice in relation to vulnerable customers.
• Simplifying language so it is clear and easy to understand and avoiding use of industry jargon.

What do we look for?

In order to identify vulnerable customers, our staff are trained to ask themselves the following questions:​

• Do they ask us to speak more slowly?
• Do they understand what we are saying?
• Can they hear the whole conversation without missing bits?
• Are they aware of what is being discussed?
• Are they asking unrelated questions?
• Do they sound flustered or out of breath when they answer the phone?
• Do they say 'yes' to a question that they have not understood?
• Do they keep repeating themselves?
• Do they suggest another family member deals with things for them?
• Do they say they have not understood previous correspondence or communication?

Communicating with Vulnerable Customers

When we communicate with vulnerable customers we ensure that we:​

• Speak clearly to customers.
• Set the expectations for the discussion.
• Demonstrate patience and ensure we do not rush them.
• Do not assume we know the customers’ needs.
• Keep the discussion on the relevant topic.
• Offer the customer a different method of communication.
• Accept that customers can be forgetful.
• Double check the customer has heard what we have said.
• Check in case the customer does not have clear vision.
• Ask the customer if they need to speak to anyone before they make a decision.
• If a customer is not in a position to make a decision or does not have the capacity to do so, we try to find a family member, carer or someone with authority and with appropriate ID who can act on their behalf. We ensure that the authorised person knows exactly what is expected of them.
• If a vulnerable customer is identified, a senior manager then checks to ensure the customer’s needs have been met.

7. Data Protection

We do not ask for any personal data from you to browse cars on Windmill Motors website. However, when you are browsing, we will use cookies that collect information about your preferences (including information you give to us to help improve your search results) and information about your computer or device. For more information about our use of cookies, please see our Cookie Policy at the end of this policy.

If you decide to give us your personal data, including when you create an account, purchase a car from us, or ask to be put in touch with one of our approved dealers, then the idea of this Privacy Policy is to help you understand fully what data we have, how we use it, where it goes, and your rights to decide what happens with it. We will use personal data about you only because you provided it, and in line with all applicable laws and what is explained in this Privacy Policy.

This Privacy Policy may change from time to time, for example because of developments in technology, our business, or the law, so please check back when you visit Windmill Motors for the most current information. If we have your e-mail address, we may also notify you of any changes via e-mail.

1. Who is the data controller of your data?

A “data controller” is the organisation that decides on the purposes and ways that your personal data is processed (or, in other words, used).

Windmill Motor’s website and services are provided by, and these decisions are made by:

Windmill Motors Limited, Windmill Garage, Main Road, Rippingale, Bourne PE10 0SP

When we share personal data with third parties (see Section 4 below), they may become a data controller in respect of their own processing activities. We recommend you read their privacy notices as these will apply to their use of your personal data. We cannot take any responsibility for what is in those notices though.

2. Where does Windmill Motors store your data?

We operate within the UK. Some of our third-party service providers may process personal data on our behalf in locations outside of the UK or EEA. When they do, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the UK or EEA do not have adequate data protection laws equivalent to those in the UK and EEA. If you would like more information about the safeguards we have in place, please contact our office using the details in Section 1.

3. Why do we process personal data? What data do we process? And what is our lawful basis for that processing?

The types of data we process and the reasons for which we process it depends on how you are using Windmill Motors. We are required to have a ‘lawful basis’ that we rely on to use your data in the ways we describe below, and we’ve stated what this is under each section.

Improving your search results: you aren’t obliged to provide any personal data when you’re browsing Windmill Motors, but in order to improve the matches of the cars we’ll show you, you are able to enter some or all of the following:

• Must-haves (e.g. fuel economy, safety, boot space etc.)
• Budget levels you are considering
• Whether you would like to exchange your current car and whether you plan to borrow any money to buy the car

Lawful basis: our legitimate interests in providing you with a useful search function to assist you with finding the right car for your needs from our database of used cars.

Selling a car to you: when you find a car that you would like to buy from Windmill Motors, we will need the following information from you to enter into the contract of sale with you, process the payment and arrange delivery.

• Name
• Mobile phone number
• E-mail address
• Current address (we will ask for your proof of address upon delivery too by asking for a photocard UK driving licence or other form of ID accepted by us)
• Payment details
• If you’re part exchanging your car, we’ll need information about that car – some of the documents relating to the car will contain your personal information (e.g. the V5, service records)

Lawful basis: performance of a contract (namely, our Car Purchase Terms and Conditions).

Helping to arrange financing for your purchase of a car: if you indicate that you would like to purchase a car using our finance option (which is arranged via our third-party finance broker), we will need to collect the following information from you which we will provide to our third-party finance broker:

• Title
• Full name (including middle names)
• Gender
• Date of birth
• Marital status
• Nationality
• Previous addresses if less than 3 years at current address
• Employment type and history
• Employer address
• Time with employer
• Mobile phone number
• Residential status
• Driving licence type
• Outgoings (including monthly mortgage/rent and other general outgoings)
• Gross annual income
• Type of proof of income
• Bank account number and sort code
• Number of years you have held that bank account

4. How long does Windmill Motors keep your data for?

Windmill Motors does not keep your personal data for any longer than necessary. If you buy a car from Windmill Motors, then we will keep data relating to the sale of a car, including your application for finance if you make one, for as long as it is necessary for us to comply with our legal obligations.

If you make an enquiry in relation to a car being sold, then we will keep data relating to that enquiry for as long as necessary to send invoices, understand whether your contacts with us were satisfactory, and resolve any outstanding questions.

If we need to keep your data longer for tax, accounting, reporting, regulatory or legal reasons then we will use it only for those purposes and for a period that is reasonably necessary to comply with the laws and policies that apply to us and to be able to deal with any legal or regulatory claims.

After these periods we anonymise data (so it does not contain any personal data and cannot be traced back to you) to use it for research or statistical purposes and improving our website and services.

5. What are your rights in relation to your personal data?

Windmill Motors is committed to ensuring that you can easily exercise your legal rights over your personal data under the laws that apply to us. You are entitled to ask at any time: for access to a copy of the personal data that Windmill Motors holds about you; to have any incorrect personal data about you corrected; for data about you to be erased (also referred to as the “right to be forgotten”) or if that is not possible (e.g. because the law requires us to keep data for longer) to have processing restricted; to object to particular processing (e.g. for marketing purposes or where we rely on legitimate interests); to contest a decision made about you based on automated processing (although Windmill Motors does not use any automated processing); and to receive an electronic copy of data you provided to us, for provision to a different service provider (also referred to as “data portability”).

You are also able to withdraw any consent given by you in the past. If you withdraw your consent, any processing of the data that took place before you do so will still be legal.

You can also opt out of future communications whenever Windmill Motors sends you any such material. Windmill Motors can always be contacted to resolve any issues or doubts you may have in relation to processing of your data or exercising your legal rights. If you believe that your rights have not been respected then you are also entitled to complain to the UK Information Commissioner (www.ico.org.uk) (or outside the UK, the Supervisory Authority in your country) to ask them for a decision.

6. Do you have to provide your personal data to Windmill Motors?

If you would like to purchase a car from us, then there’s certain information we need from you to make that happen – if we do not have this information, we cannot enter a contract of sale with you. Some of the cookies we use are ‘strictly necessary’ meaning that they are necessary to make certain parts of the website work – please see our Cookie Policy at the end of this policy for more information.

7. Where does Windmill Motors store your data?

We operate within the UK. Some of our third-party service providers may process personal data on our behalf in locations outside of the UK or EEA. When they do, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the UK or EEA do not have adequate data protection laws equivalent to those in the UK and EEA. If you would like more information about the safeguards we have in place, please contact our office using the details in Section 1.

Cookie Policy

Like almost all websites, Windmill Motors uses 'cookies' that store information to help us understand the use of our services and to make them easier to use. Some of the cookies we use are ‘strictly necessary’ meaning that they are necessary to make certain parts of the website work – please see our Cookie Policy at the end of this policy for more information.

This policy is designed to tell you about the cookies we use on our website. This Cookie Policy may change from time to time, for example because of developments in technology, our business, or the law, so please check back when you visit Windmill Motors for the most current information.

A cookie is a small file that our website may place on your device and which can be useful for recognising you as a returning visitor, saving settings and providing us with information about how the website is used. Some cookies are required so the site can work but other than those, you are not obliged to accept cookies, and you can accept, decline, or delete cookies using the settings in your web browser or by clicking on the Cookie Settings button below.

Windmill Motors uses the following types of cookies:

“Strictly necessary cookies” – these are needed to enable you to move around the website and use all its features. Without these cookies, some features cannot be provided – for example, remembering previous actions or saved items, or keeping you logged in while browsing, or permitting communications through the website (e.g. online chat or calls).

“Analytical or Performance cookies” – these gather information about how Windmill Motors is used, for example, how many users visit different pages, how long they spend there, the items they click on, or how they arrived at Windmill Motors (e.g. from an advert or social media). These cookies are only used to monitor, test, and improve ease and speed of navigation, and analysing Windmill Motors’s marketing activities.

“Functional cookies” – These are used to recognise you when you return to our website. They enable information you enter to be saved for your next visit (such as your username or postcode), so that you do not need to re-enter it and any personalised features are remembered.

“Targeting cookies” – these cookies are used to remember that you have visited Windmill Motors in the past and may enable Windmill Motors adverts or other adverts relevant to you to be shown to you on other sites you visit later. They are also used to limit the number of times you see an advertisement, or measure views, clicks, and purchases.

Some cookies are provided to us by third parties who provide services to us. These cookies are used in order to record which car ads you have viewed and whether you have called, emailed or requested a contact from a dealer, and your interactions with our customer services e.g. by chat or email. These third parties use this information only to provide services to us – we do not permit them to reuse the information for their own purposes or to provide it to their other clients.

To use Windmill Motors, you will normally need to have cookies enabled on your browser and device. If cookies are not enabled, then your browsing experience may be limited and you may not be able to use certain sections, such as your account, saving ads, or communicating with us and dealers, in the ways they were designed. If you clear cookies or change devices, then you may be asked again for your consent to use cookies as explained in this policy.

8. Data Retention Policy

Overview

The need to retain data varies widely with the type of data. Some data can be immediately deleted and some must be retained until reasonable potential for future need no longer exists. Since this can be somewhat subjective, a retention policy is important to ensure that Windmill Motors guidelines on retention are.

Purpose 

The purpose of this policy is to specify Windmill Motors guidelines for retaining different types of data. 

Scope 

The scope of this policy covers all company data stored on company-owned, company-leased, and otherwise company-provided systems and media, regardless of location. Note that the need to retain certain information can be mandated by local authorities, industry regulations and will comply with EU General Data Protection Regulation 2018 (GDPR) and the Data Protection Act 1988 and the Data Protection (Amendment) Act 2003. 

Where this policy differs from applicable regulations, the policy specified in the regulations will apply. 

Policy

Reasons for Data Retention 

Some data, must be retained in order to protect the company's interests, preserve evidence, and generally conform to good business practices. Some reasons for data retention include: 

• Litigation 
• Accident investigation 
• Security incident investigation 
• Regulatory requirements 
• Intellectual property preservation

Data Duplication 

As data storage increases in size and decreases in cost, Windmill Motors often stores data in several places on the network. A common example of this is where a single file may be stored on a local user's machine, on a central file server, and again on a backup system(s). When identifying and classifying the company's data, it is important to also understand where that data may be stored, particularly for duplicate copies, so that this policy may be applied to all duplicates of the information. 

Retention Requirements 

This section sets guidelines for retaining the different types of company data. 

• Personal customer data: Personal data will be held for as long as the individual is a customer of the company plus 6 years. 
• Personal employee data: General employee data will be held for the duration of employment and then for 6 year after the last day of contractual employment. Employee contracts will be held for 6 years after last day of contractual employment. 
• Tax payments will be held for six years. 
• Records of leave will be held for three years. 
• Recruitment details: Interview notes of unsuccessful applicants will be held for 1 year after interview. This personal data will then be destroyed. 
• Health and Safety: 7 years for records of major accidents and dangerous occurrences. 
• Public data: Public data will be retained for 3 years. 
• Operational data: Most company data will fall in this category. Operational data will be retained for 5 years. 
• Critical data including Tax and VAT: Critical data must be retained for 6 years. 
• Confidential data: Confidential data must be retained for 7 years.

Retention of Encrypted Data

 If any information retained under this policy is stored in an encrypted format, considerations must be taken for secure storage of the encryption keys. Encryption keys must be retained as long as the data that the keys decrypt is retained. 

Data Destruction

Data destruction is a critical component of a data retention policy. Data destruction ensures that Windmill Motors will use data efficiently thereby making data management and data retrieval more cost effective.

When the retention timeframe expires, the company must actively destroy the data covered by this policy. If a user feels that certain data should not be destroyed, he or she should identify the data to his or her supervisor so that an exception to the policy can be considered. Since this decision has long-term legal implications, exceptions will be approved only by a director of Windmill Motors. 

Windmill Motors specifically directs users not to destroy data in violation of this policy. Destroying data that a user may feel is harmful to himself or herself is particularly forbidden, or destroying data in an attempt to cover up a violation of law or company policy. 

Enforcement 

This policy will be enforced by the director of Windmill Motors. Violations may result in disciplinary action, which may include suspension, restriction of access, or more severe penalties up to and including termination of employment. 

Where illegal activities or theft of company property (physical or intellectual) are suspected, Windmill Motors may report such activities to the applicable authorities. 

Definitions 

Backup: To copy data to a second location, solely for the purpose of safe keeping of that data. 

Encryption: The process of encoding data with an algorithm so that it is unintelligible and secure without the key. Used to protect data during transmission or while stored. 

Encryption Key: An alphanumeric series of characters that enables data to be encrypted and decrypted.

9. Financial Promotions Policy

All financial promotions issued by Windmill Motors must comply with FCA rules. FCA defines a financial promotion as an invitation or inducement to engage in an FCA regulated activity. This will cover any form of advertising or marketing issued by the firm in respect of FCA regulated vehicle hire agreements. This includes:

• Websites
• Leaflets and brochures
• Pay per click advertising
• Banner advertising
• Pop up advertising
• Social media marketing (Facebook, Twitter etc)
• Posters
• Email marketing
• SMS campaigns
• Radio/TV advertising
• Newspaper/magazine advertising
• Voice broadcasting
• Certain types of press releases

All financial promotions will meet the following requirements:

• They will be clear, fair and not misleading;
• They will be clearly identifiable as a financial promotion;
• They will be accurate;
• They will be balanced and, in particular, will not emphasise any benefits without also giving a fair and prominent indication of relevant risks;
• They will be presented in such a way as they are likely to be understood by the people to whom they are directed;
• They will not disguise, omit or obscure important information or warnings;
• They will use plain and intelligible language; 
• They will be clearly legible; 
• They will specify GB Vehicle Contracts’ name as the advertiser; 
• They will state prominently that GB Vehicle Contracts is a broker and not a lender; 

and

• If they include comparisons with other products or services, they will be fair and meaningful.

All financial promotions must be checked and approved for compliance with FCA rules before issue. 

A Financial Promotions Checklist to confirm this. Windmill Motors management will keep a register and copy of all approved financial promotions together with the completed Checklist. The register will record:

• The name of the person who submitted the financial promotion
• The date the financial promotion was submitted
• The type of financial promotion
• The date the financial promotion was approved for issue
• The person who approved the financial promotion
• The duration for which the financial promotion is approved.

Records of approved financial promotions will be kept for at least 6 years from the date that the financial promotion was last issued.

10. Treating Customers Fairly

FCA Principle 6 requires authorised firms to pay due regard to the interests of their customers and to treat them fairly. FCA has specified six treating customers fairly (“TCF”) outcomes that firms should seek to achieve for their customers:

• Outcome 1: Consumers can be confident they are dealing with firms where the fair treatment of customers is central to the corporate culture.

• Outcome 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.

• Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.

• Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.

• Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect.

• Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint. 

Windmill Motors is committed to treating all customers fairly and monitors this on a regular basis through compliance reviews and the review of relevant MI. If any employee considers that one or more customers may not have been treated fairly this should be reported immediately to either Farooq Azam who will review the matter and determine what, if any, action is required.