Consumer Duty at FirstBank UK

Putting good customer outcomes at the heart of everything we do

Last updated: 3 February 2026

The FCA’s Consumer Duty sets higher standards of consumer protection across financial services and requires firms to act to deliver good outcomes for retail customers. It applies to products and services that are open to sale or renewal, and also to closed products and services.

This page explains what the Consumer Duty means, how FirstBank UK applies it, and where you can find help if you have a concern.

What the FCA Consumer Duty means

The four outcomes

  • Products & services:
    designed to meet the needs, characteristics and objectives of a defined target market and distributed appropriately.
  • Price & value: fair value for customers, considering the nature, benefits and total cost of the product or service throughout the lifecycle of the product.
  • Consumer understanding:
    communications that meet information needs, are likely to be understood, and enable informed, timely decisions.
  • Consumer support:
    effective, responsive support that helps customers realise benefits and avoid unnecessary barriers.

The cross‑cutting rules require firms to:

Act in good faith

This means acting with honesty, openness, and consistency with the reasonable expectations of customers.

Avoid causing foreseeable harm

Firms must proactively take steps to prevent customers from suffering harm, whether through poor product design, misleading information, or procedural hurdles.

Enable and support consumers to pursue their financial objectives

Firms must create an environment where customers can make choices that are in their own best interests.

Our commitment to customers

FirstBank UK Limited is authorised by the Prudential Regulation Authority (PRA) and regulated by the Financial Conduct Authority (FCA) and the PRA. We are committed to delivering good outcomes for all customers, including those with characteristics of vulnerability, through the following measures:

1. Robust governance and accountability

  • A dedicated Consumer Duty Committee (CDC) provides oversight and challenge on customer outcomes and supports the ongoing embedding of Duty principles across policies and processes.
  • Each year, our Board reviews and approves an Annual Consumer Duty assessment, based on outcomes monitoring and management information, in line with the FCA Handbook.
  • Although the FCA no longer expects firms to appoint a specific Consumer Duty Board Champion, FirstBank UK has chosen to retain the role. Our Consumer Duty Board Champion, together with our Board and senior management, continues to provide active challenge and oversight of customer outcomes.

2. Clear policies and frameworks

  • Our Consumer Duty Policy sets out the Bank’s standards, governance and monitoring arrangements, including the annual Board assessment cycle.
  • Our Communications Development & Testing Framework supports the review and testing of customer communications (including financial promotions), helping us assess clarity, fairness and customer understanding before and after issuance, where appropriate.
  • Our Vulnerable Customer Policy and procedures guide how we identify needs and provide appropriate, tailored support throughout the customer journey.

3. Outcomes testing and continuous improvement

  • We run a structured Outcomes Testing across all four outcomes (Products & Services, Price & Value, Consumer Understanding, Consumer Support) and report results to our CDC and Board.
  • Regular dashboards and thematic reviews track complaints, service levels, communications quality, fair value metrics and vulnerability MI, with actions raised and followed through.

How we deliver the four outcomes

A. Products & Services

  • Design & Review:
    All in‑scope products and services are designed to meet the needs of a clearly defined target market and periodically reviewed to ensure they remain appropriate.

  • Closed products:
    For products and services no longer on sale, we continue to assess fair value and provide appropriate support and communications in line with the Duty’s requirements for closed books.

  • Distribution:
    We work with our distribution partners to share relevant information so that products continue to reach the right customers, and to identify any emerging risks early.

B. Price & Value

  • Fair value assessments:

    We assess overall value by weighing price, service and benefits over time and benchmark where appropriate. Governance includes CDC oversight and Board reporting.

C. Consumer Understanding

  • Plain‑language communications: Our Communications Development & Testing Framework sets standards for clarity, tone, layering of information, and accessibility; communications are tested with target groups where appropriate.

D. Consumer Support

  • Barrier‑free support:
    We aim to provide responsive, empathetic support across channels, including tailored assistance where vulnerability is identified or suspected.

  • Service quality monitoring:
    We capture and review service metrics (for example, timeliness and resolution) and complaint insights to drive continuous improvements.

Our monitoring, data and reporting

We use quantitative and qualitative data to evidence outcomes and identify where we can improve. This includes product reviews, fair‑value metrics, service MI, complaints analysis, communications testing results and vulnerability MI. Findings are reviewed by senior management and the Consumer Duty Committee, and feed into the Board’s annual Consumer Duty assessment.

Working with our partners

Where we work with third parties in the distribution chain, we share and obtain appropriate information to help us assess customer outcomes, including value, understanding and support. We also use this information to identify and respond to risks affecting customers.

If you need to raise a concern

If you’re unhappy with any aspect of our products or services, please contact us and we’ll do our best to put things right. If you remain dissatisfied after we have investigated your complaint, and your complaint falls within the Financial Ombudsman Service’s jurisdiction, you may be able to refer the matter to the Financial Ombudsman Service. We will explain this in our final response.

Read our Complaint Process.

Helpful resources

Useful external resources

About FirstBank UK

FirstBank UK Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority.

Notes on compliance and currency

  • Duty effective dates reflected above (open books 31 July 2023; closed books 31 July 2024).

 

  • FCA governance expectation on a named Board Champion was removed on 27 February 2025; our governance remains outcomes‑focused with robust Board and committee oversight.