Treating customers fairly

Our Commitment to Treating Customers Fairly

Treating customers fairly (TCF) is central to the delivery of the Financial Conduct Authority’s regulatory agenda. It is primarily aimed at those serving the individual or consumer investor, however, as Darwin is almost exclusively advise corporate clients, we have adapted the principles accordingly to ‘Treating Clients Fairly’.

What does treating clients fairly mean to us?

The Financial Conduct Authority have identified 6 key outcomes that organisations are required to demonstrate in respect of TCF:

1: Our clients can be confident that they are dealing with a business where their fair treatment is central to the corporate culture.

2: Our solutions, strategies and products are designed, marketed, sold to meet the needs of our clients.

3: Our clients are provided with clear information and are kept appropriately informed before, during and after they contract with us.

4: Where our clients receive advice, the advice must be suitable and take account of their circumstances.

5: Our clients must be provided with solutions, strategies and products that perform as we have led them to expect and are of a sufficiently high standard.

6: Our clients will not face unreasonable post-contract barriers imposed by us if they want to change solution, strategy, product or switch provider or submit a claim or make a complaint.

How Darwin's clients are treated fairly

We recognise our responsibilities to ensure that all our clients are treated fairly and, as such, we have crafted these key principles that support our commitment to TCF.

We will always strive to do business according to our company values

Our values are – ‘Being Brilliant Together’, ’Challenging Everything - Delivering Excellence’ and ‘Maximising Potential’. We developed these values in full consultation with our clients and employees. These values drive our commitment to our clients and each other. Employee commitment to embracing these values is assessed as part of our appraisal process.

We regularly assess and record our clients' views relative to TCF using ‘The Ultimate Question’ (TUQ) methodology.

Measuring how we treat our clients, and what our clients feel about how we deliver to them, is core to our culture and to TCF being effective. We have been measuring what our clients think about us using TUQ since 2007 and this assessment is carried out quarterly across a range of clients from HR Director level to administrators and managers. Our TUQ score is also reported at the Darwin Board each month as one of our key performance indicators.

We always act honestly and with integrity and seek to ensure that commercial decisions are aligned to our customers' needs.

We pride ourselves in putting our clients first and in building lasting relationships with clients, who often become more like friends, and so all of our employees fully understand the importance of long-term business relationships built on trust.

We always ensure that our people are properly trained, competent and diligent.

We have a committed and dedicated internal training department for both our employees and our clients. We make training engaging and clear based on each employee's needs and we encourage our employees to take relevant exams to improve their abilities and skills for the own benefit and that of our clients'. Where training is mandatory, such as on money laundering and data protection, we make it interesting and fun but still compulsory. Our TUQ score drives the reward package of all our employees from senior directors to the most junior administrator. Base salaries are set at competitive levels. This together with the possibility of share options after 12 months employment combine to promote a culture and behaviour where caring for clients leads to long term client relationships.

We will always seek to meet our clients' needs by creating new solutions, services and products where appropriate.

Darwin is the very epitome of innovation and our core value of "Challenge Everything - Deliver Excellence" tells you all you need to know about how we operate. We are at the cutting edge with our Intelligent Reward™ methodology and our software and we continue to drive forward, employing some of the most insightful, pioneering and experienced reward consultants globally.

We make our marketing collateral and all communications, as clear and free of jargon as possible for all our clients.

We are totally committed to jargon busting and to ensuring that our clients fully understand the services and products that we deliver. All our services are transparently laid out in our clear and simple client contracts.

We will take any corrective action to protect the interests of our clients as quickly as possible and behave in an impartial and reasonable manner. We will treat all forms of client feedback, including complaints, as opportunities to improve our clients' experience with us.

From time to time, despite our best endeavours, things may go wrong. If they do, we will act quickly, impartially and with tenacity to resolve the issue. We always learn from feedback and use the experiences we share to deliver even better next time. All of our employees are fully aware of how to escalate client issues and the speed, openness and decisiveness with which we act is always in the clients' best interests.


Darwin helps organisations achieve their benefits, people, and wider business goals by increasing engagement, streamlining administration, controlling cost and reducing risk. And your employees are able to access and engage with their benefits wherever they are in the world.


Find out more