Treating Customers Fairly

1. Purpose and scope

OneCloud Pvt Ltd, trading as Serving Foxes, treats every customer fairly at every stage, from first advert to final complaint. This procedure sets out how our staff make that happen day to day. It applies to all directors, employees, contractors, introducers and partner installers acting for Serving Foxes.

Services covered

• Utilities: business electricity and gas, broadband and phone, water and waste, smart metering
• Business finance introductions: loans, merchant cash advance, invoice finance, asset finance, government-backed schemes
• Business insurance introductions: public liability, professional indemnity, cyber, key person, property
• Solar and low-carbon introductions: PV, battery storage, air source heat pumps, EV charging, insulation and grant applications (business and household customers)
• Payment solutions: card machines, POS and online gateways
• Business consulting: growth, sales, digital and cash flow

Customers covered: small and micro businesses, sole traders and partnerships, and household customers for solar and grant-funded work. Smaller businesses are often treated in law much like consumers, so the same standard applies to all of them.

Regulatory basis

This procedure supports, and does not replace, the rules that apply to each service:

This procedure is approved by the Board of Directors and reviewed at least every 12 months, or sooner after a regulatory change or a significant complaint trend.

2. Our fairness commitments

Serving Foxes commits to six outcomes, based on the FCA's Treating Customers Fairly outcomes and applied across every service line.

Where a service falls under the FCA Consumer Duty, partners must also deliver good outcomes on products and services, price and value, consumer understanding and consumer support.

3. Roles and responsibilities

The Board owns customer outcomes; every member of staff is responsible for applying this procedure in their own work.

4. Procedure across the customer journey

4.1 Marketing and promotions

1. All adverts, web pages, FAQs, social posts and scripts are approved by the Compliance Lead before use and logged with the approval date.
2. Savings claims must be backed by evidence on file, show typical results, and state key conditions.
3. Finance promotions must be balanced: speed and "bad credit considered" messages sit alongside the fact that approval, rates and security depend on the lender.
4. Grant and scheme references must be checked as still open before publication and reviewed monthly.
5. Testimonials must be genuine, from real customers, with written consent, and not edited to change their meaning. No fake or incentivised reviews.
6. Statements such as "independent", "whole of market" or "impartial" are used only if true for that service, and the number of suppliers on panel is kept current.

4.2 First contact and lead handling

1. Introduce Serving Foxes, the adviser's name, the service and that the comparison is free with no obligation.
2. Respect contact preferences and marketing consents; no cold calling to numbers on TPS/CTPS without consent.
3. Check early for signs of vulnerability (section 6) and adapt.
4. Never use pressure tactics: no false deadlines, "today only" prices or repeated calls after a customer says no.

4.3 Understanding needs

1. Complete a fact-find before any comparison or introduction: business size, current contracts and end dates, budget, usage, risk and cover needs, funding purpose and affordability.
2. Confirm who has authority to sign for the business and record a Letter of Authority where needed.
3. Record the customer's priorities in their own words (price, term, green energy, speed, flexibility).

4.4 Comparison and introduction

1. Explain the scope of the search: which suppliers, lenders or insurers were compared and any that were not.
2. Present options fairly, including the cheapest suitable option, and explain why any option fits the recorded needs.
3. Explain key terms before sign-up: contract length, unit and standing charges, fees, exit penalties, renewal terms, APR or factor rate, security or personal guarantees, policy exclusions and excesses.
4. Never put forward a product mainly because it pays us more.

4.5 Commission and fee disclosure

1. Before the customer agrees, tell them in writing how Serving Foxes is paid, who pays it, and that it is built into their price where that is the case.
2. For energy contracts, disclose the commission amount (for example pence per kWh and the total over the contract) as Ofgem rules require for micro and small businesses.
3. For finance and insurance, disclose the nature of commission and the amount where required or asked.
4. Any fee charged directly to the customer is agreed in writing before work starts.
5. Keep disclosures on file. Never describe the service as having "no commission" if the supplier pays us.

4.6 Contract and sign-up

1. Send the full contract, key facts and cancellation rights before or at the point of signing, and allow time to read them.
2. Use verbal or digital confirmation scripts that check understanding of price, term and commission.
3. Household customers get written cancellation information, including the 14-day cooling-off period for off-premises and distance contracts.
4. No work starts within the cooling-off period unless the customer asks in writing and understands the consequences.

4.7 After the sale

1. Confirm the switch, funding or policy in writing and give a named contact.
2. Track supplier transfers, installs and grant applications through to completion and tell the customer about any delay within 2 working days.
3. Contact customers ahead of renewal or contract end and review whether the product still fits. Do not roll customers onto worse terms by default.
4. Help with claims, billing disputes and supplier problems without charge where this is part of our service.

5. Service-specific requirements

5.1 Energy and utilities

• Only place micro and small business customers with suppliers we are permitted to work with, and keep Energy Ombudsman membership current.
• Disclose commission per kWh and in total before the contract is agreed.
• Check the customer's current contract end date and any exit fees before a switch; never cause a customer to pay a termination fee without telling them first.
• Explain fixed versus flexible tariffs, standing charges, and what happens at the end of the term.
• Use a valid Letter of Authority and only act within its scope and dates.
• Apply the same principles to broadband, phone, water and payment solutions.

5.2 Business finance

• Explain that we are an introducer, not a lender, and which lenders we work with.
• Do not put forward borrowing a business cannot reasonably repay.
• Make sure the lender explains total cost of borrowing, APR or factor rate, fees, security, personal guarantees and what happens on missed payments. For merchant cash advance, the customer should see the total repayable and an example timescale.

5.3 Business insurance

• Introduce customers only to insurers and intermediaries with the right permissions, who carry out a demands and needs assessment and provide the insurer's key documents before cover starts.
• Remind customers of renewal in good time and help them through claims.

5.4 Solar, heat pumps and grant-funded work

• Use only MCS-certified installers and products, and require the relevant consumer code for household customers.
• Customers get a written quote with total price, what is included, deposit, payment stages and the expected timetable.
• Savings and payback estimates are based on the property's survey and the MCS method, and explained as estimates.
• Never tell a customer work is "free" unless it is fully funded and no charge can arise; explain grant eligibility conditions and what happens if funding is refused.
• Deposits are protected and an insurance-backed workmanship warranty is offered as the consumer code requires.
• Take extra care with household customers on means-tested benefits (section 6).

5.5 Business consulting

• Scope, fees and deliverables are agreed in writing before work starts; the first conversation is free with no obligation.
• Avoid conflicts: if we introduce a product we earn commission on, we say so.
• No one guarantees revenue or growth results.

6. Customers in vulnerable circumstances

A customer, including a small business owner, may be vulnerable because of health, a life event, low resilience (financial strain) or low capability (language, literacy, digital skills). Staff must adapt so they get an outcome as good as anyone else's.

1. Spot it: listen for cues such as confusion, stress, bereavement, illness, mentions of debt or benefits, a third party speaking for them, or difficulty with English.
2. Ask and record: with consent, record what support is needed (not a diagnosis).
3. Adapt: slow down, use plain English, offer written summaries, allow a trusted person to join, offer extra time to decide, or change channel.
4. Check suitability twice: a Team Leader reviews any sale to a customer flagged as vulnerable before it completes.
5. Don't sell if it isn't right: stop or pause if the customer cannot understand the commitment or it is not in their interest.
6. Signpost: to free help where relevant, such as Citizens Advice, Business Debtline or a supplier's priority services support.

See our Vulnerable Customer Policy and Need extra help? page.

7. Complaints and putting things right

Any expression of dissatisfaction, however made, is a complaint. We accept complaints by phone, email, WhatsApp, letter or in person, never ask customers to put it in writing first, acknowledge within 2 working days and give a final response within 8 weeks, explaining ombudsman rights. Where we are at fault we put the customer back where they should have been. Full details are in our Complaints Procedure.

8. Training, monitoring and review

• All new staff complete fairness, vulnerability, complaints and data protection training before speaking to customers, with refreshers every 12 months.
• Team Leaders listen to at least 5 calls per adviser per month; the Compliance Lead checks a sample of sales files each month.
• Partners are reviewed yearly for complaints, cancellations and conduct.
• The Board reviews quarterly information on complaints, early cancellations, commission levels, file checks, vulnerable customer outcomes, delays and customer satisfaction.
• We keep fact-finds, disclosures, call recordings, contracts and complaint files for at least 6 years. Breaches are logged, affected customers are put right, and serious breaches are reported to the Board and, where required, the regulator.

OneCloud Pvt Ltd trading as Serving Foxes · Company No. 16991609 · 13 October 2026