Paragon Car Ltd and the Consumer Duty

​

At Paragon Car Ltd, we are committed to delivering good outcomes for customers by embedding the FCA’s Consumer Duty across all areas of our business. This means acting in our customers' best interests, from strategic decisions to individual interactions.

 

Overview of the Consumer Duty

​

The Consumer Duty comprises three core elements:

​

1. Consumer Principle

​

A firm must act to deliver good outcomes for retail customers. This principle sets the overall standard of conduct expected by the FCA and is reinforced by the other elements of the Duty.

 

2. Cross-Cutting Rules

 

These apply across all areas of firm behaviour and require us to:

• Act in good faith towards retail customers

• Avoid causing foreseeable harm to retail customers

• Enable and support retail customers to pursue their financial objectives

 

3. Four Customer Outcomes

 

These outcomes set expectations for the firm–customer relationship:

​

• Products and Services

​

Products and services must be designed to meet the needs of customers and be distributed appropriately.

 

• Price and Value

 

The price of products and services must represent fair value for the customer, relative to the benefits provided.

​

• Consumer Understanding

​

Communications must support customers in making effective, timely, and well-informed decisions about financial products and services.

​

• Consumer Support

 

Customer service must meet customer needs, helping them to realise product benefits and make decisions without unnecessary barriers or friction.

​

Monitoring and Oversight

​

To comply with the Consumer Duty, we are required to assess, test, understand and evidence the outcomes our customers experience. To achieve this, we:

• Monitor and regularly review the outcomes our customers are experiencing

• Ensure our products and services are delivering appropriate results in line with their design and the Duty

• Identify and address any areas where customers may be experiencing poor outcomes or harm

 

Using Management Information to Monitor Outcomes

​

We use a range of data sources to assess our performance and identify any risks to customer outcomes, including:

• Management meeting minutes

• Customer retention, claims, and cancellation analysis

• Audits of the customer journey, interactions, and drop-off rates

• Product line distribution and communications reviews

• Review of fees, charges, and pricing strategies

• Internal process and policy effectiveness reviews

• Complaints trends and root cause analysis

• Training records, CPD logs, and staff feedback

• Sales observations, call monitoring, mystery shopping, and file audits

• Feedback from customers and third parties, including informal sources such as social media

• Compliance reports and results of regular testing and monitoring

• Independent surveys and external benchmarking

Where issues are identified, we take appropriate action. Potential interventions include:

• Withdrawing or redesigning products or services

• Adjusting fees, charges, or distribution methods

• Providing redress where customers have suffered harm

 

Governance and Ongoing Assurance

 

The Consumer Duty applies across all our operations, from board-level planning to day-to-day service delivery. Internal processes are regularly reviewed to ensure alignment with Duty requirements.

​

We conduct routine gap analyses to assess compliance and maintain high standards. We are proactive in ensuring that our products are fit for purpose, offer fair value, and meet the evolving needs of customers.

​

As part of this commitment, we have developed a comprehensive Product Oversight and Governance Policy, along with individual Fair Value Assessments for each of our core product groupings.