© 2025 by Squirrel Away, All Rights Reserved
Treating Customers Fairly Policy
Introduction
The Treating Customers Fairly (TCF) initiative is a key component of the Financial Sector Conduct Authority’s broader consumer protection and market conduct mandate. Treating Customers Fairly is an outcomes-based regulatory and supervisory approach designed to ensure that specific, clearly articulated fairness outcomes for financial services consumers are delivered by regulated financial firms. Squirrel Away (Pty) Ltd, “the Company”, incorporates TCF into the way that we conduct business every day and in the way that we deal with our clients.
We may not outsource this responsibility to another party, although our compliance officer may provide guidance and assistance with regards to incorporating TCF into our business. Our Treating Customers Fairly (“TCF”) Policy is centred around the guidance provided by the Financial Sector Conduct Authority (“FSCA”). We are a client centric business with the end customer being at the forefront of all decisions and product development. We are committed to providing our clients with fair treatment and excellent service. We believe in the importance of treating our customers fairly and we strive to uphold the principles of the TCF initiative. Our approach to TCF is reflected into the following organisational structures and processes:
Leadership
In the context of TCF (Treating Customers Fairly), it is the responsibility of the Board and management to ensure that TCF outcomes are delivered to customers. This means that the Board and management are responsible for setting the strategic direction for the organization in regard to TCF and ensuring that this is communicated effectively throughout the company. To achieve this, the Board and management must establish a strong governance framework that includes appropriate policies, procedures, and controls to promote TCF outcomes.
This should be supported by regular training and awareness programs for staff, to ensure that they are equipped with the knowledge and skills necessary to deliver TCF outcomes to customers. Additionally, the Board and management should establish key performance indicators (KPIs) and metrics to monitor and measure the effectiveness of their TCF strategy.
This will enable them to identify any areas that require improvement and take corrective action to ensure that TCF outcomes are consistently delivered. The Board and management should also regularly review and assess the effectiveness of their TCF strategy and make necessary adjustments to ensure that it remains aligned with customer needs and expectationscustomers. This means that the Board and management are responsible for setting the strategic direction for the organization in regard to TCF and ensuring that this is communicated effectively throughout the company.
To achieve this, the Board and management must establish a strong governance framework that includes appropriate policies, procedures, and controls to promote TCF outcomes. This should be supported by regular training and awareness programs for staff, to ensure that they are equipped with the knowledge and skills necessary to deliver TCF outcomes to customers. Additionally, the Board and management should establish key performance indicators (KPIs) and metrics to monitor and measure the effectiveness of their TCF strategy.
This will enable them to identify any areas that require improvement and take corrective action to ensure that TCF outcomes are consistently delivered. The Board and management should also regularly review and assess the effectiveness of their TCF strategy and make necessary adjustments to ensure that it remains aligned with customer needs and expectations
Strategy
In the context of TCF (Treating Customers Fairly), strategy refers to the plan of action that an organization puts in place to ensure that TCF outcomes are delivered to customers. This plan should be aligned with the organization's vision and values and should be integrated into its overall strategic and business plans.
To ensure that TCF aims are not merely stated vision and values, but built into the strategic and business plans, the organization should consider the following
a) Conduct a TCF gap analysis: This involves reviewing the organization's current practices and identifying any gaps in relation to TCF principles. This will help to identify the areas that require improvement and inform the development of the TCF strategy.
b) Develop a TCF strategy: This involves defining the organization's approach to delivering TCF outcomes, including setting objectives,outlining the actions required to achieve these objectives, and allocating resources to support TCF initiatives.
c) Embed TCF in the organizational culture: This involves promoting TCF principles throughout the organization and ensuring that TCF is seen as a key priority at all levels. This can be achieved through training and awareness programs, as well as through the development of TCF-focused KPIs and metrics.
d) Monitor and measure progress: This involves regularly reviewing the effectiveness of the TCF strategy and assessing progress against the objectives and KPIs that have been set. This will enable the organization to identify any areas that require improvement and take corrective action as necessary.
e) Continuously improve: This involves a commitment to continuously improving TCF outcomes over time, by identifying new opportunities for improvement and making necessary changes to the TCF strategy.
Decision making
In the context of TCF (Treating Customers Fairly), decision-making refers to the process by which an organization makes choices that affect its customers. It is essential that all decisions are made in line with the TCF strategy and that protocols are in place to ensure that this happens.
To ensure that decision-making protocols are in place, the organization should consider the following:
a) Clearly define decision-making roles and responsibilities: This involves ensuring that all individuals involved in making decisions that impact on customers are aware of their roles and responsibilities. This can include senior management, customerfacing staff, and other relevant stakeholders.
b) Develop decision-making frameworks: This involves defining the criteria that should be used to make decisions that impact on customers. This can include factors such as customer needs, fairness, and ethical considerations.
c) Establish decision-making processes: This involves defining the processes that should be followed when making decisions that impact on customers. This can include clear and transparent communication with customers, as well as the involvement of relevant stakeholders in the decision-making process.
d) Implement decision-making protocols: This involves ensuring that decision-making protocols are implemented consistently across the organization. This can be achieved through regular training and awareness programs, as well as through the development of policies and procedures that support TCF outcomes.
e) Monitor and review decision-making practices: This involves regularly reviewing decision-making practices to ensure that they are aligned with the TCF strategy. This can include the use of feedback mechanisms, such as customer surveys or complaints processes, to identify areas that require improvement.
Governance and Controls
In the context of TCF (Treating Customers Fairly), governance and controls refer to the structures and processes that an organization puts in place to ensure that TCF considerations are integrated into its overall governance framework. This includes the development of TCF measurement systems and the identification of TCF risks.
To ensure that governance and controls are in place in the spirit of TCF, the organization should consider the following:
a) Define TCF responsibilities: This involves clearly defining the roles and responsibilities of individuals and teams responsible for implementing the TCF strategy. This can include senior management, compliance and risk management teams, as well as customer-facing staff.
b) Develop TCF policies and procedures: This involves developing policies and procedures that reflect the TCF principles and are consistent with regulatory requirements. This can include policies relating to customer engagement, product design, disclosure, and complaint handling
c) Implement TCF measurement systems: This involves developing appropriate metrics and indicators to monitor the effectiveness of the TCF strategy. This can include metrics such as customer satisfaction, complaint resolution times, and product suitability.
d) Identify TCF risks: This involves identifying potential risks that may impact the organization's ability to deliver TCF outcomes to customers. This can include risks related to product design, distribution channels, customer engagement, and complaint handling.
e) Implement TCF controls: This involves developing appropriate controls to mitigate TCF risks and ensure that the TCF strategy is effectively implemented. This can include control mechanisms such as compliance monitoring, risk assessments, and training and awareness programs for staff.
f) Monitor and review TCF governance and controls: This involves regularly reviewing and assessing the effectiveness of the organization's TCF governance and controls. This can include conducting audits and reviews to identify areas that require improvement and taking corrective action as necessary.
Performance Management
In the context of TCF (Treating Customers Fairly), performance management refers to the processes and practices that an organization puts in place to ensure that its staff and representatives are trained to deliver appropriate TCF outcomes, and that their performance is evaluated in terms of TCF competence and expectations.
To ensure that performance management is in the spirit of TCF, the organization should consider the following:
a) Define TCF competencies: This involves defining the competencies that staff and representatives are expected to demonstrate when delivering TCF outcomes. This can include competencies such as communication, empathy, and customer focus.
b) Develop TCF training programs: This involves developing training programs that are designed to equip staff and representatives with the TCF competencies required to deliver appropriate TCF outcomes. This can include training programs on customer engagement, complaint handling, and product design.
c) Incorporate TCF deliverables into performance contracts: This involves incorporating TCF deliverables into staff and representative performance contracts. This can include performance objectives related to customer satisfaction, complaint resolution times, and adherence to TCF policies and procedures.
d) Monitor and evaluate TCF performance: This involves monitoring and evaluating staff and representative performance in terms of their TCF competence and expectations. This can include regular performance reviews, customer satisfaction surveys, and compliance monitoring.
e) Provide feedback and coaching: This involves providing feedback and coaching to staff and representatives to help them improve their TCF performance. This can include regular feedback on performance objectives, coaching on TCF competencies, and training on TCF policies and procedures.
f) Recognize and reward TCF performance: This involves recognizing and rewarding staff and representatives who demonstrate TCF competence and deliver appropriate TCF outcomes. This can include performance-based bonuses, public recognition, and career advancement opportunities.
Reward
In the context of TCF (Treating Customers Fairly), performance management refers to the processes and practices that an organization puts in place to ensure that its staff and representatives are trained to deliver appropriate TCF outcomes, and that their performance is evaluated in terms of TCF competence and expectations.
To ensure that performance management is in the spirit of TCF, the organization should consider the following:
a) Align rewards with TCF principles: This involves aligning rewards with TCF principles, such as fair customer outcomes and avoiding conflicts of interest. This can include developing reward policies that prioritize customer satisfaction, complaint resolution times, and adherence to TCF policies and procedures.
b) Avoid conflicts of interest: This involves avoiding conflicts of interest in reward policies by ensuring that staff and representatives are not incentivized to prioritize their own interests over those of customers. This can include prohibiting staff and representatives from receiving rewards that are based on sales targets or quotas that may encourage them to sell products that are not suitable for customers.
c) Encourage TCF behaviour: This involves using rewards to encourage TCF behaviour by recognizing and rewarding staff and representatives who demonstrate TCF competence and deliver appropriate TCF outcomes. This can include performance-based bonuses, public recognition, and career advancement opportunities.
d) Measure and monitor rewards: This involves measuring and monitoring the effectiveness of reward policies in promoting TCF outcomes and avoiding conflicts of interest. This can include conducting regular audits of reward policies, monitoring customer satisfaction and complaint resolution times, and assessing the impact of rewards on staff and representative behaviour.
e) Disclose reward policies: This involves disclosing reward policies to customers to ensure transparency and promote trust. This can include disclosing information about how rewards are calculated, who is eligible for rewards, and the impact of rewards on staff and representative behaviour.
The Six Treating Customers Fairly fairness outcomes
We have incorporated the following six TCF outcomes into our business operations:
Outcome 1: Clients are confident that they are dealing with a firm where the fair treatment of clients is central to the firm culture.
Respect and Dignity:
Clients can expect to be treated with respect and dignity by all employees of the company. This includes being listened to, having their concerns and complaints addressed in a timely and professional manner, and receiving courteous and helpful service.
Active listening:
The company actively listens to our clients when we are communicating with them. This means giving them our full attention, asking questions to clarify any confusion, and responding in a clear and concise manner.
Empathy:
The company takes steps to understand our clients' perspectives and demonstrate empathy towards their concerns and needs.
Courtesy:
The company always treats our clients with courtesy and politeness. This includes using appropriate language and tone, and addressing clients by their preferred title and name.
Confidentiality:
The company respects our clients' privacy and maintains confidentiality about their personal and financial information.
Accessibility:
The company is accessible to our clients by providing multiple communication channels, such as phone, email, or in-person meetings. We ensure that our facilities are accessible to clients with disabilities.
Equality:
We treat all clients equally, regardless of their race, ethnicity, gender, religion, sexual orientation, or any other characteristic. They should avoid discrimination and bias in all their interactions with clients
Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified client groups and are targeted accordingly.
Providing clear and transparent information:
We will provide our clients with clear and transparent information about our products and services, including any fees or charges. We will ensure that our clients understand the terms and conditions of our products and services, and we will provide them with any additional information they require.
Clear and concise information:
We ensure that communication materials, such as brochures, websites, and promotional materials, are written in clear and concise language. Technical jargon and complex terminology are avoided, and information should be presented in a manner that is easy to understand.
Outcome 3: Clients are given clear information and are kept appropriately informed before, during and after the time of contracting.
Fees and charges:
We provide clear and transparent information about the fees and charges associated with our products and services. This includes disclosing all applicable fees, charges, and interest rates upfront, and providing clients with a breakdown of the costs involved.
Terms and conditions:
We provide clients with a clear and concise summary of the terms and conditions of their products and services. This includes information about any limitations, restrictions, or exclusions that may apply.
Performance reporting:
We provide clients with regular updates on the performance of their investments or other financial products. This includes disclosing the investment returns or other relevant metrics, as well as any associated costs or fees.
Disclosure of conflicts of interest:
We disclose any conflicts of interest that may exist in their relationship with their clients. This includes any potential conflicts of interest that may arise from the provider's ownership structure, compensation arrangements, or other business relationships.
Outcome 4: Where clients receive advice, the advice is suitable and takes account of their circumstances.
By ensuring the suitability of investments, we can help our clients achieve their financial goals and build long-term relationships based on trust and mutual respect. We are committed to providing suitable advice and products that meetour clients' individual needs and circumstances and maintaining the highest standards of professionalism and integrity in all our interactions with clients.
Ensuring suitability:
We will ensure that our products and services are suitable for our clients' needs and requirements. We will take into account our clients' financial situation, investment objectives, and risk appetite when recommending products and services to them.
Understanding our clients:
We take the time to understand our clients' financial situation, investment objectives, risk tolerance, and any other relevant factors that may impact their investment decisions. This helps us to recommend products that are suitable for each client.
Conducting a risk assessment:
We conduct a risk assessment for each client to determine their risk profile. This helps us to understand the level of risk that our clients are comfortable taking and recommend investments that align with their risk tolerance.
Providing clear and accurate information:
We provide clear and accurate information about the risks and benefits of each investment product. This includes disclosing any potential risks, fees, and charges associated with the product
Monitoring investments:
We monitor our clients' investments regularly to ensure that they remain suitable for their needs and circumstances. If any changes occur, such as a change in the client's financial situation or investment objectives, we will review and adjust their investments accordingly.
Ongoing communication:
We maintain ongoing communication with our clients to ensure that their investments continue to meet their needs and circumstances. This includes providing regular updates on the performance of their investments, discussing any changes in the market or regulatory environment, and answering any questions or concerns that they may have.
Outcome 5: Clients are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and what they have been led to expect.
Ensuring that our clients receive what they expect and are not misled about the performance of their investments is critical to treating clients fairly. As a financial service provider, we are committed to providing clear and accurate information about the performance of our products and services. Here are some ways that we ensure that our clients receive what they expect and are not misled about performance.
Providing accurate information:
We provide accurate information about the performance of our products and services, including investment returns, fees, and charges. This includes using reliable sources of data and presenting the information in a clear and understandable format.
Avoiding misleading advertising:
We avoid using misleading advertising or promotional materials that may create false expectations about the performance of our products and services. We ensure that all our advertising and promotional materials comply with industry regulations and are truthful and accurate.
Disclosing risks:
We disclose the risks associated with our products and services to ensure that our clients are fully informed about the potential risks and returns. This includes providing information about the volatility and potential losses associated with investments and other financial products.
Providing regular updates:
We provide our clients with regular updates on the performance of their investments and other financial products. This includes providing accurate and timely information about changes in market conditions or other factors that may impact the performance of their investments
Monitoring performance:
We monitor the performance of our products and services regularly to ensure that they meet our clients' expectations and are consistent with our marketing and advertising materials.
Outcome 6: Customers do not face unreasonable post-sale barriers to change product, switch provider, submit a claim or make a complaint.
Accessibility:
We make ourselves easily accessible to our clients by providing multiple channels of communication, such as phone, email, and inperson meetings. We ensure that our clients can contact us quickly and easily with any questions or concerns.
No Hurdles to Change:
We make it easy for clients to change their products if their needs or circumstances change. We ensure that there are no unnecessary hurdles or obstacles to making changes to their accounts or investments. We provide our clients with clear and simple instructions on how to make a complaint. We ensure that our complaints process is easy to understand and that clients are not required to navigate complex procedures or legal jargon
Prompt Response:
We respond to our clients promptly and with clear and accurate information. We understand that our clients' time is valuable, and we strive to provide efficient and effective customer service. We ensure that all complaints are handled in a fair and objective manner. We investigate each complaint thoroughly and provide a transparent explanation of our findings and any action we take to address the issue.
Flexibility:
We provide flexible solutions and options to our clients to help them achieve their financial goals. We understand that each client's situation is unique, and we tailor our services and products to meet their individual needs
REVIEW
The Treating Customers Fairly Policy will be reviewed annually.