Treating Customers Fairly

Treating Customers Fairly


The Financial Conduct Authority’s (FCA) Treating Customers Fairly (TCF) initiative is based on the requirement set out in Principle 6; “ a firm must pay due regard to the interests of its customers and treat them fairly.” Mainspring is committed to TCF and this Policy outlines how TCF is embedded in our overall business, culture as well as our day to day activities.

The FCA provide six core consumer outcomes which firms should follow to ensure the fair treatment of consumers, these are:

Outcome 1: Consumers are confident they are dealing with firms where the fair treatment of customers is central to its corporate culture

Outcome 2: Products and services marketed and sold in the retail market are designed to meet the needs of identified consumer groups and are targeted accordingly

Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.

Outcome 4: Where consumers provide advice, this is suitable and takes account of their circumstances

Outcome 5: Consumers are provided with products that perform the way in which firms have led them to expect and the associated service is of an acceptable standard and as they have been led to expect.

Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.

Mainspring’s Clients

Mainspring’s clients have primarily been FCA authorised fund managers to whom it has provided safekeeping and administration services to, including holding client money.  These managers are treated as Professional Clients. In addition to engaging with Professional Clients, Mainspring will be offering its services to Retail Customers.

Mainspring’s TCF Principles

Mainspring is committed to satisfying the FCA’s TCF Framework and Outcomes applicable to its current business and customers. In extending it’s customer base to include Retail Customers, it will continue to effectively implement these by:

  • Maintaining a culture where TCF is a core aspect, ensuring TCF values set by Senior Management are understood and supported by all staff
  • Providing customers with clear information
  • Ensuring all customers are able to express their requests and concerns in confidence
  • Offering a level of service which will meet and where possible exceed customer expectations
  • Handling and assessing customer complaints in a fair, prompt, impartial manner and in line with regulatory deadlines
  • Ensuring any areas concerning TCF are reported and monitored to assess performance


Assessing our TCF Principles


Mainspring will make certain all staff are aware of the key principles of TCF and are comfortable and confident in how these apply to Mainspring. Regular training sessions are to be provided to assess competence.


The Compliance Team will independtly monitor and record all areas of regulatory compliance including TCF.


Mainspring aims to provide exceptional customer service and complaint handling

Policies and Procedures

Mainspring have appropriate policies and procedures in place, relevant to the fair treatment of our customers and clients, these include

  • Compliance Manual
  • Conflicts of Interest Policy
  • Complaints Policy
  • Data Protection Policy
  • PA Dealing Policy