14 Manufacturer responsibilities As part of its distribution strategy, a discretionary manager working in partnership with an adviser firm will also need to consider what checks it should undertake on that adviser firm (distributor) before it onboards the adviser firm as a ‘distributor’ of its discretionary management service. • Regular review Regularly review the product or service and its distribution, and take appropriate action to mitigate the situation if it identifies circumstances that may adversely affect its customers • Information sharing Make available all appropriate information to distributors to allow them to: – Understand the characteristics of the product or service – Understand the identified target market – Consider the needs, characteristics and objectives of any customers with characteristics of vulnerability – Identity the intended distribution strategy – Ensure the product or service will be distributed in accordance with the target market – Obtain information from distributors on customer outcomes (see further below under Information sharing) Clients with characteristics of vulnerability In designing products and services, there is an obligation on manufacturers to consider the needs, characteristics and objectives of any customers with characteristics of vulnerability. Where the manufacturer has no relationship with the underlying consumer, characteristics of vulnerability will be considered at the product / service level. Any consumers for whom the product / service might not be appropriate will be set out clearly in the target market and negative target market. The distributor, for example the adviser firm, is typically the entity with the closest relationship with the end client and is consequently in the best position to determine whether a product or service has particular features that render it appropriate - or inappropriate - for individual clients with characteristics of vulnerability. Price and value outcome • Set charges to ensure that its product / service provides fair value • Undertake a value assessment on the product or service • Make the outcome of that value assessment available to firms distributing the product / service
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