CISI Platforms (IOC) study materials
CISI Platforms (IOC) study resources

CISI Platforms (IOC): Ethics, conduct and treating customers fairly

CISI Platforms (IOC) · Work through your exam, one topic at a time.

All guide sections

Ethics, conduct and treating customers fairly

What this domain tests

Values and behaviours rather than rules alone: how the FCA Principles, Consumer Duty and the treating customers fairly outcomes are applied and evidenced in a platform business.

Principles and Consumer Duty

  • The FCA Principles for Businesses include integrity, skill care and diligence, management and control, customers' interests, communications, conflicts of interest, and relations with regulators.
  • Consumer Duty requires good faith, avoidance of foreseeable harm, and enabling and supporting customers to pursue their objectives, measured through four outcomes.
  • The six treating customers fair outcomes run from confidence in fair treatment through products designed for needs, clear information, suitable advice, products that perform, and no unreasonable post-sale barriers.

Conflicts, remuneration and culture

  • Inducements must not impair acting in the client's best interests; they are prohibited for independent advice.
  • Gifts and hospitality registers and personal account dealing rules must be enforced, not merely written.
  • Remuneration must not reward volume in a way that creates mis-selling incentives.
  • SM&CR conduct rules apply to all staff; the certification regime covers material risk takers; SYSC 18 requires whistleblowing arrangements and notification to the FCA.

Vulnerability and complaints

  • Vulnerability must be identified and responded to across the whole customer journey.
  • Complaints must be handled fairly and promptly, with the eight-week final response and clear signposting to the Financial Ombudsman Service.

Worked example

A platform pays its transfer team a bonus linked to the volume of DB pension transfers completed. Compliance flags that this rewards volume over suitability. The remedy is to remove the volume link, monitor conversion and take-up rates by adviser, and refresh training. Reason: remuneration that rewards volume conflicts with the client's best interests and risks breaching the Principles and the Consumer Duty good faith rule.

Traps that cost marks

  • Reciting the TCF outcomes without linking them to evidence a firm could actually show a supervisor.
  • Assuming a client's agreement is a defence when the underlying recommendation was unsuitable.
  • Treating complaints handling as transactional rather than a conduct outcome.
  • Overlooking that vulnerability obligations apply at every stage, including in arrears and at withdrawal.