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Consumer duty


  • New UK FCA Consumer Duty rules effective 31 July 2023 aim to deliver good outcomes for retail customers.
  • Rules based on overarching principle of acting in customers’ interests.
  • Applies to new and existing products open to sale or renewal.

Key Principles


  • Act in good faith towards customers
  • Avoid foreseeable harm to customers.
  • Enable customers to pursue financial objectives.

Four Pillars of Success


Customer understanding: Products fit target market and match needs

Pricing and fair value: Customers pay fair prices.

Product and service governance: Products designed to meet customer needs.

Customer support: Good service and satisfaction

These principles and pillars of success are a central consideration for guiding how we interact with our customers and prospective customers. In particular, we do the following:

Consumer Understanding


We ensure that any communications with customers, whether written, visual, or verbal, is designed to support consumer understanding so they equip customers to make effective, informed decisions and carefully considers the audience they are designed for. Information we convey will always be suitably tailored and placed on appropriate channels to meet the needs of customers. The notifications will always be clear, fair, and not misleading, with content designed/delivered in a way that maximises customer engagement – clearly articulated and enabling our stakeholders to make effective decisions, and at suitable points throughout the lifecycle and, where relevant, let them assess their options. 

Customers in Vulnerable Circumstances


The FCA definition of vulnerability is that “A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”. 


We have policies and procedures in place to support customers in vulnerable circumstances:

  • We ensure that relevant colleagues receive training on recognising and supporting customers with characteristics of vulnerability. 
  • We have procedures and processes in place that allow customers to share and record support needs and share this information with us where appropriate.  



We have in place appropriate complaints reporting, processes and controls, based around the following themes: 


Customer Awareness: Customers will be made aware of how to complain about any product or service. 


Handling a Complaint: Including receiving a customer complaint, learning from complaints and quality assurance. 


Complaint Resolution: Including clarification of the complaint, assessing the merits of the complaint, the solution and dealing with complaints referred to the Financial Ombudsman Service.  

Security statement

Security is our top priority at Trust Payments and we strive to ensure that all data is kept secure at all times We keep all customer data safe with AES256 encryption, SSL Certificates, and a minimum of TLS1.2, between your website and our datacentres.

Our systems are scanned quarterly using the Qualys PCI Platform, an independent Qualified Security Assessor (QSA) and approved vendors – Omnicybersecurity (UK) & Forgenix (US) – to ensure compliance with the security requirements of the card schemes.

We follow a number of rigorous security procedures on a daily basis including, but not limited to, continuous monitoring of our perimeter, dark web monitoring, and internal checks to ensure that CIA triad is maintained at all times.