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Elephants Don’t Forget and Square 4 form strategic partnership to support firms under Consumer Duty

Leading employee competence improvement organisation, Elephants Don’t Forget, is delighted to announce the launch of a new strategic partnership with specialist compliance consultancy firm, Square 4.

The partnership – specifically designed to support financial services firms under the FCA’s Consumer Duty – brings together Elephants Don’t Forget’s multi-award-winning continual assessment technology, Clever Nelly, with Square 4’s regulatory advisory services and its proprietary technology offering, Assure 4.

Together, the organisations will provide a more connected approach to regulatory interpretation, colleague learning, knowledge retention and the validation of customer outcomes by bringing together the two disciplines of ongoing employee competence assessment and outcome testing.

The collaboration is founded on a shared belief that good customer outcomes cannot be achieved through policies, processes and one-off training alone. Organisations must ensure that colleagues understand what is expected of them, retain critical knowledge and apply that knowledge consistently when supporting customers.

Joint research from both organisations shows that poor customer outcomes typically stem from two distinct issues. First, employee competence is rarely maintained over time; staff pass initial training but struggle to retain and apply that knowledge during complex customer interactions. Second, underlying policies, processes and controls are often deficient, meaning staff correctly follow guidance, but the framework itself creates systemic failures.

This gap is reflected across the sector. In an April 2026 webinar hosted by both firms, just 6% of the 470 senior financial services professionals surveyed said they systematically link staff competence with outcome testing. Furthermore, 67% admitted they still rely on activity-based metrics to evidence good outcomes to the FCA.

The research reinforces the need for firms to look beyond training completion rates and consider whether employees genuinely understand, retain and apply the knowledge required to serve customers effectively.

By combining this insight with the personalised learning and knowledge-retention capabilities of Clever Nelly, the partnership will help organisations identify individual and collective knowledge gaps, reinforce critical regulatory information and generate meaningful evidence of colleague competence.

This evidence can then be considered alongside Square 4’s regulatory advisory services and its proprietary technology offering, Assure 4.

Assure 4 provides AI-enabled customer outcomes testing and validation, helping firms assess whether their products, communications, processes and customer interactions are delivering the outcomes intended under the Consumer Duty. Its technology-led approach combines scalable analysis with specialist regulatory judgement and human oversight.

Together, Clever Nelly and Assure 4 create the opportunity for firms to connect two essential dimensions of Consumer Duty:

  • whether colleagues possess and retain the knowledge needed to support customers effectively; and
  • whether customer journeys and interactions are, in practice, delivering good outcomes.

The combined proposition will enable organisations to move beyond traditional, activity-based measures such as training attendance, course completion and limited manual file sampling. Instead, firms will be able to build a more complete, evidence-led view of the relationship between colleague competence, operational behaviours and customer outcomes.

Through the partnership, Square 4 and Elephants Don’t Forget will work together to:

  • deploy Clever Nelly to identify and address individual knowledge and competence gaps, including within the Square 4 Managed Service business;
  • use colleague knowledge and retention data to support Consumer Duty governance and Board reporting;
  • use Assure 4 to test and validate outcomes across key customer journeys; and
  • develop innovative, evidence-led solutions tailored to each organisation’s regulatory and operational environment.

As part of this collaboration, Square 4 will roll out Clever Nelly across its own Managed Service operation based in Leeds, using the platform to strengthen and evidence colleague competence within the teams delivering regulated services on behalf of clients.

Luke Wootton, Chief Commercial Officer at Square 4 Partners Limited, said:

“Consumer Duty has raised expectations around the evidence firms must provide to demonstrate that they are delivering good outcomes. Processes and controls remain important, but the competence of the colleagues applying them is equally critical.

“Our research has shown the important relationship between colleague knowledge, competence and the outcomes experienced by customers. By combining Clever Nelly’s ability to identify and address knowledge gaps with Square 4’s regulatory expertise and the outcomes-validation capabilities of Assure 4, we can help firms understand not only whether their people know what to do, but whether that knowledge is translating into better customer outcomes. We look forward to deploying this technology with both our client base and within our own Managed Service operation based in Leeds.”

Ryan Hampson, Sales and Marketing Director at Elephants Don’t Forget, said:

“Traditional training often measures attendance or completion rather than whether critical knowledge has genuinely been retained. Clever Nelly provides organisations with continuous, individualised insight into what their colleagues know, what they have forgotten and where intervention is required.

“Square 4’s regulatory expertise, Consumer Duty research and Assure 4 technology create an exciting opportunity to connect colleague competence with real customer outcomes. Together, we can provide firms with stronger evidence, clearer insights and a more effective way to embed good customer outcomes throughout their organisations.”

The partnership will also support regulated firms as they prepare their Consumer Duty assessments and Board reports. Data and insights generated through Clever Nelly can provide evidence of an organisation’s commitment to maintaining colleague competence, while Square 4’s specialists can help firms interpret that evidence within the broader context of customer understanding, consumer support, vulnerability and overall outcomes delivery.

Assure 4 can complement this evidence by validating outcomes across customer journeys, including onboarding, servicing, vulnerability, collections, complaints and offboarding. This creates a more comprehensive picture of whether an organisation’s culture, people, processes and controls are working together effectively.

The partnership represents a significant step towards a more integrated model of regulatory compliance, one that connects what an organisation expects, what its colleagues understand and retain, how they behave and what customers ultimately experience.

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