Insight: Helping sales and marketing teams to success within rules and regulations – Simon Dawes, MD, ODM

ODM has set itself apart from the mainstream field marketing disciplines and focused in two key areas; a) financial services or more specifically retail consumer credit and b) loyalty programmes. The two, more often than not, sharing a symbiotic relationship.

The Financial Conduct Authority (FCA) is responsible for regulating the financial services industry and for ensuring that best practice is adhered to via a strict process of governance and reporting, providing improved transparency with the core objective of “delivering a fair customer outcome”.

The level of regulatory compliance, risk management and governance controls required to satisfy clients’ compliance teams has demanded a review of our business’s core values, with a focus on ensuring the appropriate culture permeates right through the business, ending with the most important element – the customer-facing staff.

The mainstay of this is our Risk Control Framework, designed with consideration for key areas of risk to the customer, the client and ODM. The highest tariff risk is one where there is potential customer detriment and these risks need to be tested and assessed more frequently. An example of this might be ensuring adequate protection for customer data or that we ensure that our staff are competent in what they do and say.

Training and accreditation is just the first step in an ongoing programme of continual assessment of field based staff promoting financial products. There is regular competency testing for customer-facing staff as well as a rigorous schedule of regulatory observations at point of customer interaction all of which are shared with our clients on a monthly basis.

How field based staff promoting financial products are remunerated has been redesigned to minimise the risk of customer detriment as a result of the way the staff are paid and it’s approved by each client. Long gone are large commission payments. Best practice is for variable pay or bonuses to be no more than 20% of total earnings and for the variable element to be unlocked only if a series of qualitative KPIs are achieved first. Any direct links to ‘sales’ volumes are actively discouraged by the FCA because of the risk of mis-selling.

Responsible use of data and insight tools enable near real-time micro-management which can be used to identify bad practice that could lead to poor customer outcomes. The data helps improve targeting as well as providing a suite of MI reports for the client. An example of this might be a report that drills down to customer age, which identifies that a certain member of field staff has targeted a higher proportion of more elderly customers. This would pose a risk to potentially vulnerable customers and the field manager would be required to provide remedial training.

The challenge is walking the tightrope between effective performance management and ensuring regulatory compliance. We are proving that you can deliver a cost-effective face-to-face acquisition channel in a heavily regulated market place.

Not only does ODM provide face-to-face customer engagement and outsourced sales services within the financial services market (typically located in retail stores), we also provide compliance training and regulatory monitoring services for retailers where it’s their staff that are talking to customers about the financial products they offer.

The culture of putting the customer first is something we espouse and are championing for our clients, whether that’s in a ‘sales’ role for their brand or helping them monitor their own staff’s performance.


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