Treating Customers Fairly
How we make sure every customer is treated fairly at every stage, from first advert to final complaint.
OneCloud Pvt Ltd trading as FundingNearMe · Company no. 16991609 · ICO ZC130857 · Last updated 6 November 2026
1. Purpose and scope
OneCloud Pvt Ltd, trading as FundingNearMe, 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 and introducers acting for FundingNearMe.
Services covered: business finance introductions, including loans, merchant cash advance, invoice finance and asset finance, and information about government-backed schemes.
Customers covered: small and micro businesses. 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 our service:
| Area | Main standards |
|---|---|
| Business finance | FCA Principles and the Consumer Duty as they apply to the lenders we work with; FCA guidance on the fair treatment of vulnerable customers (FG21/1) |
| All services | Consumer protection from unfair trading rules (DMCC Act 2024), UK GDPR, CAP Code for advertising |
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
FundingNearMe commits to six outcomes, based on the FCA's Treating Customers Fairly outcomes.
| # | Outcome | What it means at FundingNearMe |
|---|---|---|
| 1 | Fairness is part of our culture | Directors set the tone; pay, targets and partner choice never reward outcomes that harm customers |
| 2 | Products fit the customer | We only promote funding that suits the needs of the customer group it is aimed at |
| 3 | Clear information | Customers get costs, terms, commission and risks in plain English before they commit |
| 4 | Suitable matches | Any introduction is based on the customer's actual needs and circumstances, recorded on file |
| 5 | Products perform as described | What we say a product does matches what the customer gets |
| 6 | No unreasonable barriers | Cancelling and complaining are easy; we do not use pressure or penalties to keep customers |
3. Roles and responsibilities
The Board owns customer outcomes; every member of staff is responsible for applying this procedure in their own work.
| Role | Responsibilities |
|---|---|
| Board of Directors | Approve this procedure; review fairness information quarterly; make sure incentives and partner choices support good outcomes |
| Compliance Lead | Maintain this procedure; approve marketing; run file checks; own the breach log; report to the Board |
| Complaints Manager | Log, investigate and resolve complaints; run root-cause analysis; signpost to the right ombudsman |
| Team Leaders | Coach and supervise advisers; listen to calls; act on file-check findings |
| Advisers and sales staff | Follow the journey steps in section 4; record needs and disclosures; flag vulnerability and concerns |
| Introducers and lenders | Meet the standards in their contract with us; report complaints to us within 2 working days |
4. Procedure across the customer journey
4.1 Marketing and promotions
- All adverts, web pages, FAQs, social posts and scripts are approved by the Compliance Lead before use and logged with the approval date.
- Finance promotions must be balanced: speed and "bad credit considered" messages sit alongside the fact that approval, rates and security depend on the lender.
- References to government-backed schemes must be checked as still open before publication and reviewed monthly.
- Testimonials must be genuine, from real customers, with written consent, and not edited to change their meaning. No fake or incentivised reviews.
- Statements such as "independent", "whole of market" or "impartial" are used only if true, and the number of lenders on our panel is kept current.
4.2 First contact and lead handling
- Introduce FundingNearMe, the adviser's name, the service and that the service is free with no obligation.
- Respect contact preferences and marketing consents; no cold calling to numbers on TPS/CTPS without consent.
- Check early for signs of vulnerability (section 6) and adapt.
- Never use pressure tactics: no false deadlines, "today only" offers or repeated calls after a customer says no.
4.3 Understanding needs
- Complete a fact-find before any introduction: business size, funding purpose, amount, trading history, turnover and affordability.
- Confirm who has authority to act for the business.
- Record the customer's priorities in their own words (cost, term, speed, flexibility).
4.4 Comparison and introduction
- Explain the scope of the search: which lenders were approached and that we do not search the whole market.
- Present options fairly and explain why any option fits the recorded needs.
- Make sure key terms are explained before sign-up: term, fees, APR or factor rate, security or personal guarantees, and early repayment terms.
- Never put forward a product mainly because it pays us more.
4.5 Commission and fee disclosure
- Before the customer agrees, tell them in writing how FundingNearMe is paid and who pays it.
- Disclose the nature of commission, and the amount where required or asked.
- Any fee charged directly to the customer is agreed in writing before work starts.
- Keep disclosures on file. Never describe the service as having "no commission" if a lender pays us.
4.6 After the introduction
- Confirm the introduction in writing and give a named contact.
- Track applications through to completion and tell the customer about any delay within 2 working days.
5. Business finance requirements
- 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.
- Do not act on regulated agreements, such as most borrowing of £25,000 or less by a sole trader or small partnership; tell the customer and signpost them instead.
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.
- Spot it: listen for cues such as confusion, stress, bereavement, illness, mentions of debt, a third party speaking for them, or difficulty with English.
- Ask and record: with consent, record what support is needed (not a diagnosis).
- Adapt: slow down, use plain English, offer written summaries, allow a trusted person to join, offer extra time to decide, or change channel.
- Check suitability twice: a Team Leader reviews any introduction for a customer flagged as vulnerable before it completes.
- Don't proceed if it isn't right: stop or pause if the customer cannot understand the commitment or it is not in their interest.
- Signpost: to free help where relevant, such as Business Debtline or Citizens Advice.
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. Where we are at fault we put the customer back where they should have been. Complaints about a finance product itself are handled by the lender under its own procedure. Full details are in our Complaints Policy.
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 files each month.
- Lenders and introducers are reviewed yearly for complaints and conduct.
- The Board reviews quarterly information on complaints, commission levels, file checks, vulnerable customer outcomes, delays and customer satisfaction.
- We keep fact-finds, disclosures, call recordings 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.