Providing compliant financial services and products

Our FSPs in South Africa, UK businesses that operate as authorised credit brokers and insurance intermediates, and our Australian operations, which are governed by an Australian Credit Licence or Point-of-Sale exemption, manage a complex range of financial services legislation. This requires robust due diligence processes and well-trained and compliant sales personnel.

What we are doing

Risk Management and Compliance Programme

Our Risk Management and Compliance Programme (in place for each FSP in South Africa) sets out our customer due diligence processes, including anti-money laundering and anti-terrorist financing controls.

Regulated products

Regulated products, and their associated processes and policies are regularly reviewed to ensure that commissions and disclosures are transparent in the sales process. External advisers are engaged, if needed, to ensure all our products and services comply with applicable legislation.

Training

Training is a critical enabler of meeting our compliance obligations. All employees in South Africa who are subject to the Financial Sector Conduct Authority's (FSCA) 'fit and proper' requirements receive the necessary training and continuous professional development (CPD) to maintain their accreditation to advise on and offer intermediary and binder services. All product representatives are trained and examined before being accredited by insurers to offer products. Similarly, senior managers in the UK who have control and oversight are vetted for fitness and propriety in alignment with the Financial Conduct Authority's (FCA) Certification Regime. All other regulated employees in the UK receive training and CPD.

How we measure our performance

In South Africa, our FSP subsidiary, F&I Management Solutions (FAIMS), provides the services of finance and insurance (F&I) business managers to the retailer dealer operations and limited services to select non-Motus independent dealerships. As part of its licencing conditions, FAIMS is required to conduct at least one audit per business manager every year. Going beyond this regulatory requirement, FAIMS audits each business manager at least once every quarter. Audits are conducted randomly without pre-warning.

Every deal transaction file for a vehicle sale must contain several key documents and be stored on a secure central platform. FAIMS provides assurance to the Group and our internal audit function on deal file compliance. This takes place as part of the F&I business manager audit where FAIMS will select a sample of dealership transaction files, which include the F&I sale, to audit for a full and correct view.

Our other FSPs in South Africa – LiquidCapital, MotorHappy and M-Sure – are audited by Mobility Solutions' compliance department every month and undergo internal quality assurance. M-Sure is also regularly audited by the insurers to which it provides services.

In the UK, the competency of all regulated consultants and managers is assessed regularly and they are monitored by regional F&I managers as well as a third‑party compliance service provider. F&I managers and the third-party compliance service provider also monitor dealership compliance to F&I regulatory requirements, and regularly audit the sales transaction files across the UK dealership network. Processes are in place to ensure that sales agents ask the right questions to understand a customer's needs.

In Australia, the sale of financial products is independently assured. As part of our Point-of-Sale Agreement¹, lenders are responsible for ensuring that our F&I team is appropriately trained, accredited and up to date with the latest legislation and regulatory requirements, including those related to anti-money laundering and terrorist financing, fraud, privacy and responsible lending.

The Social, Ethics and Sustainability (SES) Committee receives quarterly reports of the audit scores achieved by our operations.

Unlike our dealerships that can only finance a vehicle at point of sale, our Australian Credit Licence for our brokerage business, Liquid Capital Financial Services, means it can finance any asset (with some exceptions), including private sales and sales by dealerships outside the Group. To maintain the licence we must comply with Australia's National Consumer Credit Protection Act and responsible lending obligations, as opposed to the exemptions under the Point-of-Sale Agreement. Our brokerage system is designed to ensure we meet these obligations, and external audits take place quarterly.

Governance of ethics and compliance.

¹ A recommendation of the 2019 Royal Commission.