Customer Treatment and Consumer Duty Statement 

Last reviewed: April 2024 


Sturgeon Ventures LLP (the “Firm”) is committed to the fair treatment of all its customers. The Firm believes that customer treatment is more than just having a statement; it is about instilling the right culture and values throughout the business from executive decision-making, through the teams and across all areas of the business. This statement sets out frameworks and regulations that the Firm operates under in meeting its objectives in this area. 

Principles of business 

Sturgeon Ventures LLP is Authorised and regulated by the Financial Conduct Authority (FCA) (Registration Number 452811) and is therefore required to meet the FCA’s 12 Principles of business. These are broad and cover a range of areas,  including ensuring customers are treated fairly (PRIN 6), communicating effectively with clients in a way that is clear, fair, and not misleading (PRIN7), and acting to deliver good outcomes for retail customers (PRIN12). The principles of business are built into the Firm’s processes to ensure that the customer journey is at the heart of our firm and activities. 

These FCA 12 Principles of business are available to all staff within the Compliance Manual which is maintained by Compliance and is required reading for all regulated individuals within the Firm. 

Treating Customers Fairly (TCF) 

The Firm has a TCF Policy. The TCF Policy sets out the Firm’s expectations to all staff to ensure we treat our customers fairly. The Firm strives to achieve the following outcomes in respect of TCF: 

  • Fair treatment of customers is central to our corporate culture;

  • Customers are provided with fair, clear, and not misleading information and kept informed appropriately before, during and after the point of engagement; and

  • Services are performed as customers have been led to expect.

These objectives also align with the 6 TCF outcomes set out by the FCA, which regulated firms should follow. 

The outcomes are considered during the Firm’s Product Governance process as well as during decision making. 

Consumer Duty

The FCA’s Consumer Duty was fully embedded by the Firm ahead of the 31 July 2023 deadline. Consumer Duty is ultimately about delivering good outcomes for retail customers through delivery of products and services. This means that customers will get communications they can understand and services that meet their needs and offer fair value, and will get the customer support they need, when they need it. 

The duty is embedded into the Firm’s processes which are continually evolving where improvements can be applied. 

Vulnerable Customers 

Ensuring that customers in vulnerable circumstances are treated not only fairly, but with empathy and sensitivity to their circumstances is important to the Firm. Therefore, the FCA definition of a Vulnerable Customer is applied, being as follows: 

“Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.” 

The Firm’s services and communications take into account considerations of potential Vulnerable Customers in line with our Vulnerable Customers Policy. Staff in customer facing roles, if they are aware of Vulnerable Customers, will ensure to communicate appropriately so that these customers have a considerate outcome and their journeys are appropriately managed for them. 

Communicating with Customers 

The Firm believes communicating with customers in a clear and transparent way is critical so they can fully understand the services available to them. The Firm has teams who work collaboratively to prepare and review communications with customers. Where possible, the Firm will avoid the use of jargon and abbreviations and will keep to plain English. 

The Compliance Manual and Client Communications & Financial Promotions Policy set out how staff are expected to communicate with customers. 


Whilst the Firm aims to provide excellent customer service, we understand that occasionally we may get this wrong and our customers will need to complain. This is a critical time for us as although a customer has felt the need to complain, this is also our opportunity to put things right for them. 

The Firm investigates all complaints fairly and promptly as per our Complaints Policy. 

Associated Policies & Materials

Further information on frameworks and regulations can be found in the following policies and materials which have been developed by and are available to customers of the Firm: 

  • Client Communications & Financial Promotions Policy;

  • Complaints Policy.

  • Compliance Manual (including PRIN, TCF and Vulnerable Customers); and➢ Vulnerable Customers Policy. 


Version control: April 2024