Effective Date: 25 April, 2024

1. Background 

As a licensed and regulated entity in the United Kingdom, Dresdner takes seriously its obligation to comply with the Consumer Duty and any other guidance from the Financial Conduct Authority (or any other regulatory authority or applicable industry body). These Dresdner Customer Protection Principles (“Principles”) take into consideration these requirements, in particular, the Consumer Duty.

These Principles shall apply where a Client (as defined in the relevant agreement between the Client and Dresdner) engages Dresdner to facilitate access to End Customers in the UK for the provision of regulated payment services and/or any other services provided by Dresdner from time to time (the "Dresdner Service”).

These Principles are incorporated into and form part of any agreement between Dresdner and the Client, including the Dresdner Platform Agreement or Dresdner Channel Partner Agreement (the “Agreement”). In the event of any conflict between these Principles and the Agreement, these Principles shall prevail.

2. Definitions 

Capitalised words not defined in these Principles shall have the same meaning as defined in the Agreement.

“Non-Financial Costs” include things such as unclear or misleading information making it hard for a customer to assess their options, the time and effort it takes to access, assess and act to buy, amend, switch or cancel a product or Dresdner’s use of customer data where customers knowingly or unknowingly ‘pay’ with their data, privacy or attention.

“Vulnerable Customer” means a customer who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. All customers are at risk of becoming vulnerable and this risk is increased by characteristics of vulnerability related to 4 key drivers; health, life events; resilience and capability. “Vulnerability” and “Vulnerable” shall be interpreted accordingly.

3. Who do these Dresdner Customer Protection Principles apply to?

Dresdner requires all of its Clients to comply with these Principles.

4. The Dresdner Customer Protection Principles

The Client shall, and shall ensure that any of its personnel, subcontractors and any other person acting on the Client’s behalf for provision of the Dresdner Services to End Customers, ensure that:

a. the Target Market is defined at a sufficiently granular level and periodically reviewed and the relevant Dresdner Service meets the needs and objectives of those in the Target Market;

b. the Client has in place processes to identify Vulnerable Customers and address customer vulnerability, which shall be provided to Dresdner on request, and must include that the Client will actively encourage customers to share information about their needs and circumstances where relevant;

c. there are at least two channels for an End Customer to engage with or seek support from the Client in regard to the Dresdner Services, including appropriate channels to provide support in End Customer emergencies or high-priority End Customer issues and any engagement channel used is:

1. aligned with the nature of the product or service provided;
2. easy to understand and use by customers in the target market; and
3. suitable for any customer with a vulnerability;

d. the Dresdner Services are regularly reviewed by the Client, and in any event no less than once every twelve (12) months;

e. pricing for the Dresdner Service is fair and any End Customer fees configured by the Client shall be submitted to Dresdner for approval and End Customers are notified in accordance with the applicable Dresdner End Customer terms and conditions;

f. pricing information about the Dresdner Service is shown at all relevant points during the customer journey and at a sufficiently granular level to allow each End Customer to fully understand the fees and/or charges, particularly where an End Customer is required to confirm acceptance and/or enter into a binding agreement;

g. all pricing about the Dresdner Service is clearly displayed and disclosed to End Customers in a manner that is consistent with applicable law and regulations to ensure that sufficient information is shared with customers to enable them to efficiently compare the relevant product or service with any other competitors on the market;

h. unless differences in pricing are justifiable and demonstrated:

1. End Customers using the same Dresdner Service are paying the same price; and
2. the Client’s pricing is not significantly higher than the pricing of any other competitors;

i. Non-Financial Costs incurred by customers are proportionate, justified and either better than or in line with industry standards;

j. any information provided about the Dresdner Service is tailored to, and understood by, End Customers in the Target Market (including those with vulnerable characteristics) and allows such End Customers to make informed decisions;

k. timely, and at least annually, check-ins or reminders are to be sent to End Customers to ensure the Dresdner Services provided continue to meet their needs and objectives;

l. the effectiveness of communications with End Customers is adequately tracked and recorded; and such records and communications are made available to Dresdner upon request;

m. information on how to switch, complain and/or cancel the relevant Dresdner Services is easily accessible by End Customers; and

n. The same or reasonably similar levels of support are provided to End Customers throughout the entire lifecycle of the Dresdner Services.

5. Self-Assessment; Suspension of the Dresdner Service

a. The Client must perform a self-assessment of its compliance with these Principles prior to going live ("Self-Assessment"). The Client’s ability to launch any program is subject to approval by Dresdner, including demonstrating thrClient’s compliance with these Principles, including but not limited to compliance with paragraphs 4(b), 4(c), 4(f).

b. Upon request by Dresdner, the Client must provide evidence of its compliance with these Principles, including having completed the Self-Assessment, along with providing any supporting documents as reasonably requested by Dresdner.

c. Dresdner reserves the right to suspend Client’s access to the Dresdner Service at any time if it determines that Client is not in compliance with these Principles.

6. Exceptions

Exceptions may be considered by Dresdner, on an End Customer level basis, where the Client requests and can demonstrate the End Customer does not fall into scope of these Principles.

7. Changes to These Principles

We may update or revise these Principles from time to time to keep up with changing laws and regulations and industry best practice. If we make any updates or changes, we will post a revised version of these Principles on this website and update the Effective Date at the top of these Principles. To stay up to date on any changes, check back periodically.