Treating Customers Fairly (TCF) and Consumer Duty Policy

1. Purpose

Finaap Ltd is committed to delivering good outcomes for customers and treating them fairly at all stages of their relationship with the business. This policy sets out how Finaap aligns with the FCA Treating Customers Fairly principles and the Consumer Duty, ensuring customer interests are embedded in product design, communications, data usage, and customer support.

2. Scope

This policy applies to all directors, staff, contractors, systems, and processes involved in delivering services to Finaap customers.

3. Our Customers

Finaap serves retail customers who wish to better understand and manage their personal finances using account information services. We recognise that customers may have different levels of financial literacy, digital capability, and vulnerability, and we design our services accordingly.

4. Treating Customers Fairly Outcomes

Finaap applies the FCA TCF outcomes by:

• Embedding fairness into its culture
• Providing clear and transparent information
• Designing services that meet genuine customer needs
• Ensuring informed consent
• Offering accessible support
• Avoiding unreasonable barriers to exit or complaints

5. Consumer Duty Alignment

Finaap supports the Consumer Duty by focusing on four key outcomes:

• Products and Services: Products and services that deliver value
• Price and Value: Fair pricing with no hidden charges
• Consumer Understanding: Clear and timely customer communications
• Consumer Support: Customer support that enables customers to act in their own interests

6. Consent and Data Use

Customers must provide explicit consent before any bank data is accessed. Data obtained via Finexer APIs is used solely to provide financial insights such as budgeting, transaction categorisation, and account visibility.

Customers may withdraw consent at any time without penalty.

7. Vulnerable Customers

Where vulnerability is identified, Finaap takes additional care to communicate clearly, avoid pressure, and provide appropriate support or signposting.

8. Complaints Handling

Finaap operates a fair and transparent complaints process. All complaints are:

• Logged and tracked
• Investigated objectively
• Acknowledged promptly
• Used to improve services and customer outcomes

For more details, please see our Complaints Policy.

9. Monitoring and Review

Customer feedback, complaints, and service performance are regularly reviewed to ensure positive customer outcomes. This policy is reviewed annually or when material changes occur.

10. Responsibility

Overall responsibility for Treating Customers Fairly and Consumer Duty compliance rests with the Director of Finaap Ltd. All staff and contractors are required to comply with this policy.