1. Purpose

This policy sets out Earnly’s commitment to delivering fair outcomes for all customers in line with the expectations of the Financial Conduct Authority and broader UK regulatory standards, including principles aligned to Consumer Duty.

Earnly is committed to ensuring that customers are treated fairly throughout their entire lifecycle—from onboarding and data consent through to ongoing use, support, and disengagement.

2. Scope

This policy applies to:

All Earnly products and services
All customer segments (individuals, sole traders, and limited company users)
All employees, contractors, and third-party providers acting on behalf of Earnly

3. Core Principles

Earnly adopts the following principles to ensure fair customer outcomes:

3.1 Transparency and Clarity

We ensure all communications are clear, fair, and not misleading. Customers are provided with:

Transparent explanations of how their data is used
Clear descriptions of product features and limitations
Upfront disclosure of pricing, assumptions, and risks

3.2 Customer Understanding

We design the platform to support informed decision-making by:

Presenting tax estimates and insights with appropriate context and disclaimers
Avoiding overstatement of accuracy or certainty
Highlighting assumptions, especially where projections or AI-driven insights are used

3.3 Product Suitability

Our services are designed to meet the needs of our target users, including:

Freelancers, contractors, and small businesses
Individuals managing personal and company tax obligations

We continuously assess whether our features deliver genuine value and avoid unnecessary complexity.

3.4 Fair Value

Earnly ensures that:

Pricing is proportionate to the value delivered
Free and paid tiers are clearly differentiated
Customers are not subject to hidden fees or unexpected charges

Customers retain control over their data at all times:

Users can connect and disconnect financial data at their discretion

Consent mechanisms are explicit and granular

Data is only used for agreed purposes

3.6 Support and Accessibility

We provide accessible support channels and ensure:

Customer queries are handled promptly and professionally
Complaints are acknowledged and resolved in a timely manner
Users can easily access help and guidance within the platform

3.7 Fair Treatment During Issues

In the event of errors, outages, or disputes:

We communicate openly and promptly
We take responsibility where appropriate
We aim to resolve issues with minimal customer impact

4. Customer Lifecycle Approach

Earnly embeds TCF across all stages of the customer journey:

Onboarding: Clear consent, transparent data usage, no hidden terms
Usage: Accurate insights, responsible AI usage, clear limitations
Ongoing Engagement: Regular updates, proactive alerts, no misleading nudges
Disengagement: Easy data disconnection, clear retention policies, no barriers to exit

5. Governance and Accountability

Responsibility for TCF sits with senior leadership
TCF considerations are embedded into product design and development processes
Regular reviews are conducted to assess customer outcomes and identify risks
Feedback loops (support tickets, complaints, usage data) inform continuous improvement

6. Monitoring and Continuous Improvement

Earnly will:

Monitor customer feedback, complaints, and behavioural data
Review product performance against expected customer outcomes
Update policies and processes in line with regulatory developments
Ensure alignment with evolving standards, including Consumer Duty

7. Training and Awareness

All team members are expected to:

Understand the importance of fair customer outcomes
Consider TCF in their day-to-day responsibilities
Escalate any risks or concerns that may impact customers

8. Review

This policy will be reviewed at least annually or in response to:

Regulatory changes
Material changes to the product or business model
Identified risks to customer outcomes

Treating Customers Fairly