Thames Underwriting Limited FCA Policy Statement PS22/9, A New Consumer Duty

As you will be aware, the introduction of the new Consumer Duty (Policy statement PS22/9) which centres on a new FCA Principle (PRIN12) will come into force on 31st July 2023.

More details can be found on the FCA website.


We already have in place a well established conduct and risk framework, supported by robust processes and controls which put the customer at the heart of everything we do. We are looking to further strengthen these to ensure it covers the entire breadth of the new consumer duty.

We very much welcome and support the new Consumer Duty and have established a project team, led by our CUO function with representation from across our business, to ensure:

  • a high level implementation plan is in place (this was completed and approved by the Geo Board in October 2022)
  • a Geo Board member is appointed as the Consumer Champion (a Non Executive Director has now been appointed).
  • a comprehensive gap analysis has been undertaken (we are on track to meet the 30th April 2023 deadline)
  • we meet the requirements of the Consumer Duty by the 31st July.

With regard to our progress on the specific outcomes


As referenced by the FCA, those firms that already comply with the General Insurance Pricing Practices and Fair Value Assessment (FVA) requirements, as detailed in PROD 4, will substantially meet the requirements for price and value.

We are proud of the robustness of our product review process, whether our role is that of a (Co)Manufacturer or a Distributor, and that we do indeed meet the necessary levels for adhering to these outcomes.


A full gap analysis is in progress, with a supporting action plan agreed, to ensure we meet these requirements in full. This includes:

  • reviewing our frameworks, policies, business standards and controls and their alignment to the Consumer Duty (including how we support vulnerable customers)
  • reviewing and testing our customer journeys, touchpoints and communications across our channels of distribution
  • reviewing our policy wordings and associated literature to ensure they are clear and easy to understand
  • assessing what additional MI needs to be collated and reported on so we can appropriately monitor customer outcomes
  • assessing how we best educate our teams with relevant training material to help embed Consumer Duty into our culture


We are aware that many Insurers and Intermediaries may be requesting information from their partners to support their Consumer Duty projects. As a Lead Co-Manufacturer we may require certain information to be shared and will be in touch directly when we do. It would also be helpful if we have sight of any potential dependencies or requirements that you may have at the earliest opportunity to help us facilitate within the impending regulatory timelines.

We would also very much welcome any feedback you may have on any elements of the products we sell or the services we provide which we can take into consideration as part of our review.

You can contact the Geo CUO team on the email address below or speak to your normal business level contact:

Thames Underwriting Limited is authorised and regulated by the Financial Conduct Authority (firm reference number: 533504). Registered Address: 2 Minster Court, Mincing Lane, London EC3R 7PD. Registered No.7136128.

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