1. CHO Code of Practice Alternative Dispute Resolution

2. The Objectives of the Code The Objectives of the Code The Code itself The Code itself Correspondence with TCF Correspondence with TCF Alternative Dispute Resolution (ADR) Alternative Dispute Resolution (ADR)

3. The CHO Code of practice Key objectives Demonstrate the standards expected of credit hire operators by its trade association Give customers and suppliers alike, confidence in the consistency of service throughout the industry Ensure all members are aware of the need to represent the industry with professionalism and competence Confirm adherence to the GTA principles to facilitate productive negotiations with insurers through the Technical committee

4. The Code Members Must : Abide by the code Conduct their businesses in accordance with applicable laws and regulations to which they are subject Act with integrity and act in a way that maintains public confidence in the services credit hire companies (CHCs) provide Run their business effectively and in accordance with proper governance and sound financial and risk management principles Where relevant take appropriate steps to protect client money they may handle (e.g. customer insurance excesses) Acknowledge that CHCs and their referral partners, may be the target of fraud and take appropriate steps to ensure that each claim is genuine Treat all customers fairly Ensure that the vehicles supplied to customers are insured, safe, roadworthy and have been adequately maintained

5. The Code Submit claims to insurers only after consideration that: - The claim is genuine - The circumstances of the accident justified the hire of a replacement vehicle - The customer NEEDED a replacement vehicle - The type of vehicle provided, or claimed for, is reasonable given the circumstances and the law - The length of hire is reasonable given the circumstances and the law - The amount claimed is reasonable given the circumstances and the law Ensure their employees are adequately trained and that a person, or a group of people is responsible for keeping policies, procedures and documentation compliant with good practice, the law, or any other regulation to which their business is subject Keep customers informed as to the settlement of claims and provide appropriate support to customers (including, where relevant, facilitating access to legal advice) if claims are disputed

6. The CHO Executive Committee Determines compliance to The code May suspend or terminate any member’s membership if it determines any member has breached the code or brought the integrity of the CHO into disrepute Demand members accept this process of determination Confirm that members accept that on suspension or termination - no subscriptions will be refunded - no longer may use the CHO logo - nor any documentation that purports that they are CHO members

7. Treating Customers Fairly (TCF) FCA Regulation Outcome based Code of Practice is more task oriented Strong correspondence between TCF Outcomes Code of Practice

8. The TCF outcomes Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and as they have been led to expect Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint

9. TCF Outcomes Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale Code of Practice Act with integrity and act in a way that maintains public confidence in the services credit hire companies (CHCs) provide Submit claims to insurers only after consideration that (etc) Keep customers informed as to the settlement of claims and provide appropriate support to customers (including, where relevant, facilitating access to legal advice) if claims are disputed

10. Treating Customers Fairly TCF is established throughout the firm: systems, controls, culture, strategy, training, remuneration and staff behaviours The company recognises that TCF is ongoing – not a short term project TCF must be monitored by adequate measurement and management information TCF should provide an improvement in the ‘quality of outcomes’ for a company’s customers

11. Alternative Dispute Resolution Government initiative to reduce litigation Trade bodies (and others) invited to become providers Not clear whether, if regulated, the ADR provider is a given. i.e. FCA and FOS. If The CHO could become an ADR provider it would add credibility and assist members

12. Alternative Dispute Resolution ABTA Association of Chartered Certified Accountants (ACCA) British Vehicle Rental and Leasing Association (BVRLA) Centre for Effective Dispute Resolution (CEDR), incorporating IDRS Dispute Resolution Ombudsman (DRO) Federation of Master Builders Furniture Ombudsman Home Improvement Ombudsman (HIO) Motor Codes National Conciliation Services NetNeutrals EU Office of the Independent Adjudicator for Higher Education Ombudsman Services Pro Mediate Property Redress Scheme Renewable Energy Consumer Code Small Claims Mediation

13. Final thought Regulation, if properly implemented and thought through is a source of profit, not a cost. 13