Do You Have a Website Fair Treatment Policy?

What a Fair Treatment Policy Is and Why Your Website Needs One

A Fair Treatment Policy is a published statement of the fairness standards your business follows and the conduct you expect in return. SiteLaws.com developed the Fair Treatment Policy so that a business can inform clients, customers, visitors, vendors, consumers, and the public about how the business treats people, and you can read the SiteLaws Fair Treatment Policy as a working example. Where a privacy policy covers data and a terms page covers the contract, a Fair Treatment Policy covers behavior: honesty, respect, equal access, clear pricing, accessibility, and offers a method to give feedback.

The policy serves three practical purposes for you. First, the policy sets expectations for your team, so a new hire understands that abusive language toward a customer or a hidden fee in a quote violates a written standard. Second, the policy gives customers a path to raise a concern before they post a one star review or file a complaint with a state attorney general. Third, the policy creates a record you can point to if anyone ever alleges that you discriminated, misled, or retaliated. A written standard you actually follow is far stronger evidence than a verbal claim that you “treat everyone the same.”

You may wonder whether a small business with five employees needs this. Consider that consumer protection, civil rights, accessibility, and advertising laws already apply to you whether or not you write anything down. A Fair Treatment Policy does not add obligations you do not already have. Instead, the policy organizes those obligations into plain language, which makes compliance easier and shows customers that you take the rules seriously.

The Laws Behind Fair Treatment Policy Compliance

Your Fair Treatment Policy rests on real legal requirements, and knowing them helps you write commitments you can keep. Federal civil rights laws, including Title II of the Civil Rights Act of 1964, prohibit discrimination in public accommodations on the basis of race, color, religion, or national origin, and most states add protections for sex, age, disability, sexual orientation, and other characteristics. Fair treatment policy compliance starts with a nondiscrimination statement that reflects the law in your state.

Accessibility is the second pillar. The Americans with Disabilities Act requires public accommodations to be accessible to people with disabilities, and courts have applied that requirement to websites. The Department of Justice explains in guidance on web accessibility under the ADA that businesses open to the public must make sure their online content is accessible, and points to the Web Content Accessibility Guidelines as a recognized standard. The WCAG guidelines published by the W3C give you concrete criteria such as text alternatives for images, keyboard navigation, and sufficient color contrast.

Consumer protection law forms the third pillar. Section 5 of the FTC Act prohibits unfair or deceptive practices, and the FTC has used that authority against hidden fees, confusing cancellation flows, buried automatic renewal terms, and manipulative design. State laws such as California’s Automatic Renewal Law and the deceptive trade practices acts in most states add their own requirements. When your Fair Treatment Policy promises transparent pricing, clear renewal terms, and honest advertising, you are restating obligations these laws already impose.

Real Cases That Show Why Fair Treatment Matters

Abstract principles become concrete when you look at what has happened to businesses that treated people unfairly online. The cases below involve real U.S. companies and real consequences, and each maps directly to a section you will include in your own Fair Treatment Policy.

Robles v. Domino’s Pizza: Website Accessibility in Court

Guillermo Robles, who is blind, sued Domino’s Pizza in 2016 after he could not order from the company’s website and app using screen reader software. The Ninth Circuit Court of Appeals ruled in 2019 that the ADA applies to the website and app of a business with physical locations, and the U.S. Supreme Court declined to hear Domino’s appeal, leaving the ruling in place. The case later settled, and since then thousands of website accessibility lawsuits have been filed each year against businesses of every size, including single location restaurants and small online retailers.

The lesson for you is that accessibility belongs in your Fair Treatment Policy and in your website, not only in a legal footnote. A policy that invites users to report barriers and promises a good faith response gives you an early warning system before a demand letter arrives.

Epic Games: $245 Million in Refunds Over Manipulative Design

In December 2022, the FTC announced that Epic Games, the maker of Fortnite, would pay $245 million in consumer refunds to settle allegations that the company used confusing button layouts and other dark patterns to trick players, including children, into unwanted purchases and made cancellation and refund requests difficult. The FTC’s announcement described the refund order as the largest in an FTC administrative case at the time.

You are not Epic Games, but the same rules reach your checkout page. A pre checked add on, a “no thanks, I don’t want to save money” decline button, or a subscription that is easy to start and hard to cancel can all draw complaints and enforcement. Your Fair Treatment Policy should promise clear pricing, disclosed renewal terms, and a simple cancellation process, and your website should deliver on that promise.

Vonage: $100 Million for Cancellation Roadblocks

In November 2022, the FTC ordered Vonage to pay $100 million to customers after alleging that the company made cancellation nearly impossible by forcing customers to speak with a retention agent during limited hours, charging surprise early termination fees, and continuing to bill after customers had canceled. The order required Vonage to provide a simple cancellation mechanism.

For a small business, the equivalent failure is a membership, maintenance plan, or software subscription that customers cannot cancel without a phone call nobody answers. Fair treatment policy compliance means the exit is as clear as the entrance.

Fashion Nova: $4.2 Million for Hiding Negative Reviews

In January 2022, Fashion Nova paid $4.2 million to settle FTC allegations that the retailer suppressed hundreds of thousands of negative reviews on the Fashion Nova website while publishing positive ones. The FTC has since adopted a rule that makes review suppression and fake reviews subject to civil penalties. Honest communication with customers, including honest display of what those customers say, belongs squarely within a Fair Treatment Policy.

What to Include in Your Fair Treatment Policy

Now that you understand the purpose and the legal backdrop, you can build the policy section by section. The SiteLaws example runs eighteen numbered sections, and you do not need every one of them, but the structure below reflects the core of a complete website fair treatment policy. Write each section in plain language that a customer could read without a lawyer.

Open with an effective date, a last updated date, and a contact method, then state your commitment in one or two sentences. Define the scope by naming who the policy covers: website visitors, customers, prospective customers, people who contact support, vendors, contractors, advertisers, affiliates, and your own employees when acting for the business. Scope matters because a policy that applies only to “customers” leaves vendors and job applicants in a gray zone.

Next, state your fair treatment commitments and your nondiscrimination standard. Commit to honest communication, respectful treatment, fair access, transparent pricing, consistent application of your policies, reasonable protection of personal information, and compliance with consumer protection, civil rights, privacy, accessibility, and advertising laws. List the protected characteristics recognized under federal law and your state’s law. Then add an important balancing statement: fair treatment does not mean identical outcomes, and you may still decline or end service for legitimate reasons such as nonpayment, fraud, abuse, security threats, or breach of contract.

The middle of the policy covers day to day conduct. Include a respectful communications section that names what you will not tolerate, such as threats, harassment, slurs, deliberately deceptive statements, and retaliation. Add a fair pricing section that promises disclosure of the service, price, billing frequency, renewal terms, limitations, cancellation procedure, and refund rules before purchase. Add an accessibility section that states your commitment, invites reports of barriers, and promises a good faith review of accommodation requests. Add a privacy paragraph that points to your separate privacy policy and states that the privacy policy governs any conflict.

If you advertise other businesses, sell through affiliates, or feature vendors, include a section that sets expectations for those partners. The SiteLaws policy states that the company will not knowingly promote a vendor or advertiser that fails to follow the same fair treatment principles, and lists what partners must do: truthful claims, disclosed prices, honored refunds, reasonable privacy practices, and no predatory targeting. Pair that with a short section on sponsored content that discloses when you receive compensation and clarifies that featuring a product is not a guarantee or an endorsement of legal compliance.

Close with the accountability sections. Describe how someone can file a complaint, what information helps you investigate, and what outcomes are possible, from a clarification or refund to retraining staff or ending a vendor relationship. Add a no retaliation promise, an enforcement paragraph, and a limitations section that states the policy is not legal advice, does not create a contract or private right of action beyond nonwaivable rights, and does not guarantee third party conduct. Finish with a changes section and a contact section.

Website ABC: Always Be Compliant

SiteLaws.com coined the acronym WABC, which stands for “Website: Always Be Compliant,” to describe how you should treat every policy on your site, including this one. A Fair Treatment Policy that sits untouched for five years while your services, staff, and state laws change becomes a liability rather than a shield, because a court or regulator will hold you to the promises you published. The WABC approach turns your policy into a living practice in four steps.

Start by drafting your policy from a proven template rather than from scratch. Read the SiteLaws example, adapt each section to your business, and remove anything you cannot honestly commit to. If you do not run affiliate promotions, cut the vendor section rather than promising a vendor review process you will never perform. A shorter policy you follow beats a longer policy you ignore.

Then align your website with your words. If the policy promises transparent pricing, check your checkout for hidden fees, pre checked boxes, and renewal terms buried in fine print. If the policy promises accessibility, run an accessibility scan, fix missing image descriptions and low contrast text, and make sure your contact form works with a keyboard. If the policy promises a complaint process, create the email address or form you named and assign a person to answer within a stated number of business days.

Next, train your team and your partners. Walk every employee who talks to customers through the respectful communication and nondiscrimination sections, and give vendors and affiliates a copy of the standards they must meet. A short signed acknowledgment from staff and partners costs nothing and shows good faith if a dispute ever arises.

Finally, review the policy on a schedule. Put a calendar reminder every six months to check the effective date, confirm your contact details still work, update protected characteristics if your state’s law changed, and read through any complaints you received to see whether the process worked. Update the “Last Updated” date whenever you make a change, and keep prior versions in a folder so you can show what the policy said on any given date.

How to Publish and Link Your Fair Treatment Policy

Placement affects whether anyone reads the policy and whether the policy protects you. Add a link in your website footer next to your privacy policy, terms and conditions, and accessibility statement, because footer links are where customers, plugins, and attorneys look first. Link to the policy from your contact page and from any complaint or support form, and consider referencing the policy in your vendor and affiliate agreements so partners are bound by the standards contractually.

Keep the page design simple. Use real headings for each section so screen readers and search engines can parse the structure, avoid embedding the policy in an image or a PDF only, and make sure the text meets contrast and font size standards. A Fair Treatment Policy page that fails accessibility standards undermines the accessibility promise inside the policy.

Key Takeaways

A Fair Treatment Policy is a public statement of how your business treats visitors, customers, vendors, advertisers, and the public, and SiteLaws.com created the format so any business can publish one. The policy restates obligations you already carry under civil rights, ADA accessibility, consumer protection, and advertising law, and cases such as Robles v. Domino’s, Epic Games, Vonage, and Fashion Nova show what happens when businesses ignore those obligations. A complete policy covers scope, commitments, nondiscrimination, respectful communication, fair pricing, privacy, accessibility, vendor standards, sponsored content, complaints, no retaliation, enforcement, limitations, and changes. Follow the WABC approach, “Website: Always Be Compliant,” by drafting from a proven example, aligning your site with your promises, training your team, and reviewing the policy twice a year.

Frequently Asked Questions

Is a Fair Treatment Policy legally required?

No federal law requires you to publish a Fair Treatment Policy by that name. The laws behind the policy, including civil rights, ADA, and consumer protection statutes, do apply to your business, and the policy helps you organize and demonstrate compliance with them.

How is a Fair Treatment Policy different from terms and conditions?

Terms and conditions form the contract between you and the user and focus on legal rights, liability, and dispute resolution. A Fair Treatment Policy focuses on conduct and standards, such as respect, nondiscrimination, honest pricing, accessibility, and complaint handling, and usually states that the policy does not create additional contractual rights.

Can a Fair Treatment Policy be used against you?

Any published promise can be cited in a dispute, which is why you should only include commitments you actually follow and should include a limitations section. In practice, a policy you honor reduces your exposure by showing good faith, documented standards, and a working complaint process.

Do you need a lawyer to write a website fair treatment policy?

You can draft the policy yourself from the SiteLaws example and adapt each section to your business. A brief review by an attorney familiar with your state’s consumer protection and civil rights laws is a sensible final step, especially for the nondiscrimination and limitations sections.

How often should you update the policy?

Review the policy at least twice a year and whenever you add a service, change pricing or renewal terms, begin advertising other businesses, or learn of a change in state or federal law. Update the “Last Updated” date with every change.

Conclusion

A Fair Treatment Policy costs you an afternoon to write and a few hours a year to maintain, and in exchange you get a public, written standard that guides your team, reassures your customers, and documents your good faith if anyone ever questions how you treat people. The laws behind the policy already bind you, so the only question is whether you want your compliance to be visible and organized or invisible and improvised. Use the SiteLaws example as your starting point, keep only the promises you can honor, and treat the policy as part of your reputation rather than a formality.

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