Treating Customers Fairly (TCF) Policy

I. Introduction

OSO money is the trading name of CGI Foreign Exchange (Pty) Ltd (“OSO money”, “we”, “us” or “our”), an authorised financial services provider (FSP No. 26368) regulated by the Financial Sector Conduct Authority (FSCA).

Treating Customers Fairly (TCF) is an outcomes-based regulatory approach that requires financial services providers to deliver specific, clearly set out fairness outcomes for their customers. This policy explains how OSO money embeds TCF in its culture, governance and day-to-day operations across its Treasury Outsourced Company (TOC) model.

II. Scope

This policy applies to all directors, key individuals, representatives, employees and contractors of OSO money, and to every stage of the client relationship: marketing, onboarding, pricing, execution, settlement, servicing, complaints and termination. It also governs how we select and oversee the banking partners and service providers that support our Services.

III. The Six TCF Outcomes

Outcome 1: Fair treatment is central to our culture

• Senior management owns TCF and sets the tone from the top.
• TCF considerations form part of product design, business decisions, performance management and staff training.
• Staff are not incentivised in a way that rewards volume at the expense of fair client outcomes.

Outcome 2: Services are designed for the clients they are offered to

• Our Services are designed for businesses, institutions and individuals with genuine cross-border payment and foreign exchange needs.
• Onboarding and risk-profiling help ensure that the Services offered are appropriate to each client’s profile, activity and jurisdiction.
• We do not market or offer Services to clients for whom they are clearly unsuitable.

Outcome 3: Clients receive clear information before, during and after each transaction

• We distinguish clearly between platform services provided by OSO money and regulated banking, safeguarding and settlement provided by our banking partners, including the Authorised Dealer.
• Exchange rates, fees and spreads are disclosed before a client commits to a transaction.
• Marketing material is fair, balanced and not misleading, and includes appropriate risk warnings.
• Clients receive confirmations and records of their transactions.

Outcome 4: Any guidance given is appropriate

OSO money provides intermediary services and does not provide personal financial advice. Where our staff give general information about currencies, payment routes or settlement timing, it is factual, balanced and takes account of what we know about the client’s circumstances. Clients are encouraged to seek independent advice where appropriate.

Outcome 5: Services perform as clients have been led to expect

• We monitor execution quality, settlement times and service levels, including those of our banking partners and service providers.
• Service failures are investigated, root causes are addressed and affected clients are kept informed.
• Pricing is applied consistently with what was disclosed and agreed.

Outcome 6: No unreasonable post-sale barriers

• Clients can raise queries, lodge complaints or end their relationship with us without unreasonable barriers or penalties.
• Complaints are handled promptly and fairly in line with our Complaints Policy, including the right to escalate to the relevant Ombud.
• Client funds are returned promptly on termination, subject to applicable legal and regulatory requirements.

IV. Oversight of Banking Partners and Service Providers

Because banking, safeguarding and settlement are provided by authorised institutions under our TOC model, we assess partners before appointment and monitor their performance on an ongoing basis. Where a partner’s conduct or performance could result in unfair client outcomes, we escalate the matter and take appropriate action.

V. Vulnerable Clients

We take additional care where a client may be vulnerable, for example because of language barriers, limited familiarity with foreign exchange, or financial or personal difficulty. Staff are trained to identify such situations and to adapt communication and support accordingly.

VI. Governance and Monitoring

• The key individual is responsible for the implementation of this policy.
• TCF performance is measured using management information such as complaints data, client feedback, execution and settlement metrics, and onboarding outcomes.
• Findings are reported to senior management and the compliance function, and corrective action is tracked to completion.
• All staff receive TCF training on appointment and refresher training at least annually.

VII. Review

This policy is reviewed at least annually, and sooner if there are material changes to our Services, operating model or regulatory requirements.

VIII. Contact

Questions about this policy can be sent to [email protected].