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Treating The Customer Fairly Policy

Prime Meridian Direct (“PMD”) has a strong focus on customer satisfaction and aims to be respected and recognised for the fair treatment of its
customers. PMD is fully committed to delivering service of the highest standard as its customers are its most valuable asset. PMD’s Treating the
Customer Fairly (“TCF”) policy is structured according to the guidance provided by the Financial Services Board (“FSB”) to ensure it consistently
delivers fair outcomes to its customers. TCF was clearly raised as one of the compliance objectives during PMD’s annual strategy meeting and
formally adopted by the Board. PMD will further ensure it reviews this policy annually and on an ad hoc basis but at least annually. In order to
implement PMD’s policies on TCF each of its affiliated Insurers, reinsurers, UMAs, administrators and employees are expected to understand and apply
this policy and are bound thereto in terms of the standards of service delivery set out below.

Approach to Service Delivery

The Financial Services Board has outlined six key themes, which are central to the TCF initiative. PMD will strive to comply with and contribute
to these 6 TCF fairness outcomes viewed from the perspective of its customers as follows:

Customers are confident that they are dealing with a provider where the fair treatment of customers is central to its culture.

Products and services marketed and sold in the retail market are designed to meet the needs of identified customer groups and are targeted accordingly.

Customers are given clear information and are kept appropriately informed before, during and after the time of contracting.

Where customers receive advice, the advice is suitable and takes account of their circumstances.

Customers are provided with products that perform as providers have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect.

Customers do not face unreasonable post-sale barriers to change products, submit a claim or make a complaint.

PMD will aim to demonstrate, through our behaviours and monitoring, that we are consistently treating customers fairly throughout the stages of
the product life cycle to which we can contribute. These may include:

Product and service design

Promotion and marketing



Information after point-of-sale

Complaints and claims handling

Standards of Service Delivery

PMD will aim to demonstrate, through its behaviours and monitoring, that it is consistently treating customers fairly throughout the stages of the
product life cycle to which it can contribute. In order to achieve these service standards, PMD and its employee members undertake to:

adhere to PMD’s corporate culture of ensuring that customers fully understand the features, benefits, exclusions, risks and costs associated with the financial products they buy;

ensure that customers are provided with clear, concise information and kept appropriately informed before, during and after the purchase of their
products allowing them to make informed decisions;

ensure that regular, clear and appropriate correspondence is maintained with customers at all times and that the relevant communication protocols
are strictly followed;

adhere to PMD’s phone etiquette standards and to provide excellent service to the customer;

follow the principle that customer service, at all stages, must meet customer expectations and that any promises or commitments made must be met;

NOT give any financial advice to customers but to direct them to the organisation’s Key Individuals or Representatives where such advice is
required or sought;

ensure that any request from a customer is attended to without any unnecessary barriers or delays;

fairly manage the customer’s expectation at all times;

leave the customer feeling pleased about their experience with the Company and confident that they are dealing with an honest, professional and ethical organisation where the fair treatment of clients is central to the company’s culture;

ensure all third parties contracted with are committed to treating our customers fairly;

Complaints Handling Service Standards

We respond in a timely manner to our customers and prospective customers questions and queries, addressing any issues or concerns promptly.

All customer complaints are dealt with and escalated appropriately in order to meet our obligations to our clients.

Complaints are therefore handled fairly, promptly and impartially.

All valid claims are paid promptly.

The principles of “fairness and equity” are applied in all decisions, always giving the customer the benefit of the doubt where information is not perfectly clear.

In dealing with complaints PMD will ‘treat like situations alike’ and give careful consideration to whether an error might have affected a wider class of customers and what should be done to remedy this.

PMD will investigate the root causes of complaints and obtain feedback from customers who have experienced our complaints process in order to improve the level of service that is provided.