Are you treating customers fairly?

A few weeks ago, I attended The Entrepreneurs Forum workshop on culture and core values, where we were entertained with stories of why it is so important for a business to get this right, and what can happen if they don’t. This got me thinking of our internal values at Apricity, and the approach to values across financial services as a whole.

At Apricity, and across The Verve Group, we feel we have set core values that everyone embodies throughout the business when working with our clients. However, does everyone do this? I’ve reflected back to previous jobs and I couldn’t tell you if they had any clear values, and if they did, I was not made aware of them.

I’ve always believed that if values are made clear to everyone and are embodied at the top of the chain, this will feed through the entire business and eventually to clients. Each company will have its own values, but one that should be applied in addition, to all financial firms, is Treating Customers Fairly (TCF). If this is applied as a value, rather than just as an FCA requirement, it will have the effect of filtering right through the business and impacting on every area, which will make it far more effective.

As a reminder, here are some examples of how you can assess the depth of TCF in your business:

Financial Promotions

  • Do you review financial promotions and marketing literature closely to ensure that they are appropriate for the targeted audience and are presented in a clear, fair and not misleading manner?
  • Do you assess the impact these promotions have?
  • Do they attract the right type of customers?

Advice & Sales Process

  • Have your advisers obtained a detailed understanding of your clients’ investments objectives?
  • Have your advisers gathered enough soft facts on the client to understand their needs?
  • Do you ensure that all of your clients understand the risks and consequences of any service or product and are aware of all applicable charges?


  • Are your advisers trained regularly in order to suitably advise on and efficiently explain and recommend products and services?
  • Do you make sure that all of your advisers achieve the necessary qualifications and training in order to carry out their job functions with the required competence level?
  • Do you undertake regular monitoring and assessment of your advisers and staff so that you can be certain of their competence?

Disputes & Complaints Handling

  • Do you deal with customer complaints fairly and objectively while attempting to put things right as quickly as possible, in accordance with the rules laid down by the FCA?
  • Are all complaints recorded and monitored by your compliance team and analysed in your company MI and committee meetings?
  • Do you identify areas for training off the back of complaints made to help minimise the risk of this happening again?


  • Do you operate a remuneration model that mitigates sales bias and rewards non-sales staff in a way that would not negatively impact the treatment of your clients?

So, maybe now is the perfect time to review your approach to TCF, (a client feedback questionnaire is a great way to do this) and, if you find it lacking, add it to your company values, applying it in the same way, to impact on the behaviours throughout the firm, and, ultimately, the client experience.

We have a number of guides and templates for our clients in the Knowledge Base to help. Have a look at the following to get you started:

  • TCF Review
  • TCF Plan
  • TCF Management Information
  • TCF Gap Analysis
Hannah Scott – Junior Adviser Support