19 Co-manufacturer responsibilities With a co-manufacturing arrangement, the roles and responsibilities of the ‘comanufacturers’ need to be very clearly articulated. There also needs to be a formal comanufacturing agreement in place which sets out very clearly which party is doing what. Being classified as a ‘co-manufacturer’ brings with it ‘manufacturer’ responsibilities. See section above. In any co-manufacturing agreement, the co-manufacturers need to be very clear about who is responsible for what under the Consumer Duty covering areas such as value assessments, data sharing (see below) and complaint handling. What is crucial with a co-manufacturing arrangement is that an adviser firm positions its role in the arrangements correctly, so that clients have an accurate understanding of which party is responsible for which elements of the service being delivered to them. As with any other business initiative, adviser firms should liaise with their PI insurers and gain their consent to the arrangement. Where adviser firms enter into a co-manufacturing arrangement and charge a fee for any additional activities they undertake in relation to that arrangement, for example a higher adviser charge to reflect their involvement in the arrangement, that additional fee needs to be factored into the adviser firm’s value assessment. In this guide we are looking at co-manufacturing mainly in the context of model portfolio services. However, advisers should also consider whether they are co-manufacturers of any products, for example funds, that they have material influence over in terms of their design and management. For example if a firm works with a fund manager to design a fund, and has a decision-making role on elements such as the target market or investment strategy, it would be regarded as a co-manufacturer under the products and services outcome and the price and value outcome. Source: FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty (Para 2.20)
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