23 Appendix one - Co-manufacturer checklist Co-manufacturer checklist – Discretionary management product / service This checklist is designed for adviser firms who are seeking to establish whether they are a co-manufacturer under the Product and Services / Price and Value outcomes of the Consumer Duty. A co-manufacturing proposition may exist where two or more parties collaborate to manufacture a product or service. Examples of this could be a discretionary management service tailored to specific client segments of an adviser firm or a white labelled platform proposition. Whether or not a co-manufacturing arrangement exists will depend on the nature of the arrangements in place – including the ability of each party to influence client outcomes and make decisions. The questions below could be the starting point for firms to ascertain whether they are likely to be a co-manufacturer. You need to answer all the questions. 1. Have you set the parameters for. or commissioned, a product or service which you have then passed to another entity to design? Yes - indicates a co-manufacturing arrangement No 2. Do you collaborate with another entity to produce a product / service targeted at your own clients? Yes – indicates a co-manufacturing arrangement No 3. Are you involved in any way in the design of a product / service with another party? Yes – indicates a co-manufacturing arrangement No If you answered ‘Yes’ to any of the above questions, continue working through this document. The FCA guidance states ‘A firm would be considered a co-manufacturer where they can determine or ‘materially influence’ the manufacture of a product or service. This would include a firm that can determine the essential features and main elements of a product or service, including its target market’. Source: FG22/5: Final non-Handbook Guidance for firms on the Consumer Duty (Para 6.10). Whether or not a co-manufacturing arrangement exists will also depend on how decisions are made by the respective parties.
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