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Treating Customers Fairly

The governing body of Waldorf Risk Solutions has taken a decision to formally adopt the Treating Customers Fairly (TCF) outcomes and principles as part of the values of the business. This ensures that each employee embraces and enforces the principles of fairness and objectivity in their daily tasks and the processes of the business.

Our ethos and culture is to:

Operate with transparency and honesty;

Empower our customers so they can make informed decisions;

Aim to “Wow” all customers during our service delivery;

Work with purpose and as a team, delivering simple and practical solutions to complex problems;

Accept nothing less than the best for our customers in terms of service, customer-centricity and all business-related communication; and

Be sensitive to and understanding of our customers’ needs.

The Six Outcomes Of Treating Customers Fairly

TCF is embedded throughout the FCA’s Handbook and WRS supports the TCF initiative and satisfies the FCA’s six core consumer outcomes which explain what it wants TCF to achieve for consumers. These are:

Consumers can be confident they are dealing with firms where TCF is central to the corporate culture.

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

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

Where consumers receive advice, the advice is suitable and takes account of their circumstances.

Consumers are provided with products that perform as firms have led them to expect and the associated service is both of an acceptable standard and as they have been led to expect.

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

Achieving The Outcomes

We realise that the success of achieving the above-stated outcomes lies in the way we manage. We are convinced that quality management systems, policies, procedures, controls and appropriate training are necessary for bringing to fruition our best intentions which arise from these Outcomes.

We further agree that each role player within our Organization must embrace the TCF outcomes and understand that each individual contributes to the Organization successfully achieving these Outcomes on a consistent basis and as a collective.

We also aim to demonstrate that we are consistently treating customers fairly through our behaviour and monitoring which is influenced by our governance structures as well as throughout the stages of the product life cycle, which are summarised hereafter.

Upholding the WRS culture and core values by enabling and empowering employees to make informed and appropriate decisions to deliver fair outcomes for its customers.

Maintaining and operating sales processes that ensure customers are listened to and are offered appropriate products and services that meet their needs.

Undertaking regular review of sales activity (volumes, channels, margins etc.) to ensure that business units are selling products and services that meet the needs of customers.

Ensuring that all policy literature and financial promotional material is clear, fair and not misleading and accurately reflects the product and services being offered.

Ensuring that all disclosures are made to customers in sufficient time allowing for them to make informed decisions.

Considering TCF in all Business Change activities to ensure the impact on customers is taken into account.

Continual monitoring of business processes to ensure that they meet customer expectations.

Collecting, analysing and using information about sales activities, trends and volumes, distribution channels, customer service, complaints and claims data, staff surveys, and customer research and feedback – as appropriate for the customer category and location - to identify improvements within the business unit.

Handling complaints in accordance with the Complaints Handling Policy and Procedures.

Handling claims in accordance with the Claims Handling Policy and Procedures.

Managing Conflicts of Interest in accordance with the Conflicts of Interest Policy & Procedures.

Policies And Procedures

WRS has a number of policies and procedures that are relevant to the fair treatment of clients and also achieve adherence to FCA requirements, these are (this not an exhaustive list):

Complaint Handling Procedures

Data Protection Policy

Conflicts of Interest Policy

Whistleblowing Policy

Management Information

WRS produces MI in order to assess its performance against TCF principles. We ensure that MI is accurate, timely, consistent and relevant in order to assist the business in making informed decisions in the best interests of our clients. WRS produces MI reports which are reviewed regularly by senior managers, directors and board members in various committee meetings.


WRS ensures that all advisers and staff are familiar with the fundamental principles of TCF. In addition, where applicable, advisers and staff are trained in order to suitably advise on and efficiently explain and provide our products and services. We make sure that all of our advisers and staff achieve the necessary qualifications and training in order to carry out their job functions with the required competence level. We undertake regular monitoring and assessment of our advisers and staff so that we can be certain of their competence.


WRS has a compliance team who is independent and regularly monitors all key areas of regulatory compliance including TCF.


WRS operates a remuneration model that mitigates sales bias and rewards non-sales staff in a way that would not negatively impact the treatment of its clients.


WRS aims to provide excellent customer service and complaint handling is a major component of its TCF measures. We deal with customer complaints fairly and objectively and attempt to put things right as quickly as possible, in accordance with the rules laid down by the FCA. All complaints are recorded and monitored by our compliance team and reported and analysed in company MI and committee meetings.


WRS’s culture is and has been throughout the years in line with the outcomes stipulated by the FCA’s TCF initiative. However, we frequently review our policies, procedures and practices to ensure that TCF remains a crucial part of our business.

We ask our clients to provide us feedback, sometimes formally through customer surveys, so that we can improve our service. The information we collate from our clients can be reflected in company MI and reviewed by senior managers, directors and board members to help shape any strategic decisions.