Market conduct · 5 min read

Fair is a design decision.

Treating Customers Fairly isn’t a compliance checklist.
It’s six promises your product either keeps or breaks.

Most conversations about Treating Customers Fairly happen in compliance meetings.

Most unfair moments happen on a screen, in a call centre or in a letter nobody tested.

The FSCA’s six TCF outcomes read like legal language. Put them next to a real customer and they turn into design questions.

Six outcomes, six design questions.

Is fair treatment part of how the business works, or a policy on the intranet?
Was the product designed for a specific group of customers, and sold to them?
Is the information clear before, during and after the sale?
Where there’s advice, does it fit this customer’s circumstances?
Does the product do what the customer was led to expect?
Can customers switch, claim or complain without unreasonable barriers?

Most unfairness is accidental.

Nobody sets out to design a hostile experience. It happens one reasonable decision at a time.

In one merchant sign-up we reviewed, identity verification took more than five attempts. The next screen asked for banking details the provider already held. Then came a request for three months of bank statements.

Nobody designed that to be unfair. It is.

Each step had a reason. Together they told the customer something the business never meant to say: your time doesn’t matter to us.

Compliance and experience want the same thing.

When we reviewed a micro-lending journey for AVBOB, the compliance checklist included NCA, POPIA, TCF and FIC requirements. One item stood out: were the consent clauses adequate from the client’s point of view, not just present?

That’s a TCF question and a usability question at the same time. If a customer can’t understand what they’re agreeing to, they haven’t really agreed.

Test the exit as hard as the entrance.

Outcome six is the one most often left to chance. Businesses test sign-up obsessively and rarely test cancelling, claiming or complaining. Those are the moments customers remember, and the ones regulators look at.

Design them with the same care: a visible path, plain language, a clear owner and no dead ends.

Find where fair breaks in your customer journey.

The Promise-to-Proof Diagnostic shows where your promise holds, where it breaks and what to change first.