Vulnerable Customer Policy
1. Policy statement
We are committed to identifying, assessing and managing vulnerable customers in accordance with our own objectives and policy, as well as any regulations and guidelines set out by our regulators.
Implemented are several identification and assessment tools within the procedure section of this document, aimed at identifying, assessing and dealing with all Vulnerable Customer situations and to consistently ensure that our staff are aware of, and knowledgeable about Vulnerable Customers, including how to handle all situations.
2. Regulatory References
PRIN 2.1.1, FG21/1 Guidance for firms on the fair treatment of vulnerable customers
3. Purpose
We are committed to ensuring that all of our customers are treated fairly and we meet all of their needs to the best of our ability.
We appreciate that sometimes our customers may be vulnerable as a result of a physical or mental health condition suffered by themselves or a family member, age, illiteracy, or if their first language is not English.
This means that we may have to treat vulnerable customers according to their individual circumstances. In order to do so we endeavour to recruit staff with suitable experience in sales and customer service, and give them the necessary training to enable them to identify the signs of vulnerability and how to proceed with that customer.
We ensure that our staff have the necessary training, knowledge, understanding and support in order to be able to identify the potential signs of a vulnerable customer in their dealings with them, and then tailor their approach accordingly.
4. Scope and definition
Vulnerability is an extremely subjective area, however our staff are trained to lookout for potential signs, such as, a lack of understanding, communication issues and unusual or erratic behaviour.
The FCA defines a Vulnerable Customer as: –
“Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”
The majority of our sales communication with customers is face to face and, in some instances, over the phone, which does make it easier for our staff to be able to identify both short term causes of vulnerability, such as short-term illnesses or a bereavement, as well as long-term causes, such as mental illness or a disability.
There are several risk factors that contribute to consumer vulnerability so these should be considered whenever dealing with an existing or potential customer.
The nature and scale of characteristics of vulnerability that exist in our customer base are:
- Communication difficulties – struggling with hearing or sight.
- Advanced age – unfamiliar with finance or finance applications.
- Low income combined with high value purchases.
- A change in circumstances – e.g. bereavement, divorce
- Physical disability
- Severe or long-term illness
These characteristics may affect the customers’ ability to make an informed decisions on what is best for them and knowingly enter into contract/ credit agreements.
5. Processes and procedures
If a member of staff believes that a customer could potentially be vulnerable then they will ask non-intrusive questions in order to understand the customer’s circumstances, allowing them to identify if the customer is in fact vulnerable and how our approach will need to be tailored for that customer.
Any information gathered will be processed in line with GDPR and the Data Protection Act 2018. Where necessary, explicit consent will be obtained from a customer to enable us to process the details of their vulnerability accordingly. Customers will also be fully informed of how we will process this information.
We will always:
- Ask for a customer’s explicit consent in order to record, store or process the details of their vulnerability, where it is necessary and appropriate to do so
- Clearly explain to the customer why we need to record, store or process the details of their vulnerability
- Clearly explain to the customer who the details of their vulnerability will be shared with
To assist with consent, we train staff to use the TEXAS model:
To allow us to tailor the needs of the customer we have adopted IDEA to allow us to manage more in-depth conversation:
Typically, we would only look to process the details of a customer’s vulnerability where we may need to tailor our approach during our communications with them, or when we are entering their home for the purposes of a sales consultation or installation. We would therefore only share the details of the vulnerability with the relevant staff and representatives.
All customer facing staff are provided with the training and tools to identify, understand and deal with vulnerabilities and vulnerable customers, this training is delivered on commencement of employment and is refreshed annually.
The various methods for customers to contact us are clearly visible on all communications and our website and provide a choice of ways to communicate with us,
- Post
- Face to Face
- Telephone
All our verbal communications or written material is clear, to the point and jargon free.
Where applicable, we try our best to ensure the products/services that we offer are flexible and made to suit the customers’ needs and requirements and where possible deal with the customer’s authorised third-party in a helpful and transparent manner.
The majority of sales consultations are done in person in one of our stores or on occasions on one of our show stands. We also deal with sales enquiries submitted by telephone, email, our website or our manufacturers website. We never cold call customers on the telephone or go door to door, and only speak to customers who visit our stores or enquire about our products. Once a customer has made a sales enquiry then the sales person will follow up with a telephone call or in writing (depending on the customer’s preferred method of communication) to summarise the details provided during the sales consultation and to check if the customer has any questions.
We ensure that all of our customers do not make a purchase with us or enter into a credit agreement with one of our lender partners without fully understanding what they are entering in to.
When presenting finance options to our customers we do so using our electronic choice of funding software (eCOF) which describes the products clearly and displays the breakdown of each product to the customer. A copy of the bespoke choice of funding is the emailed directly to the customer. Sales representatives also talk through this with customers and explain verbally the information which has been emailed to them.
If we believe that the customer is not fully aware of what they are entering in to then we will:
· Not continue with the sale of any products or services.
· Not continue with any application for credit to fund a purchase.
· Ask if a friend or family member is available to assist the customer, or we will arrange a follow-up appointment when a friend or family member is available.
· Provide the customer with all relevant information in a clear, fair and not misleading manner, allowing them to make an informed decision.
· Not refuse to deal with an individual due to their vulnerability. Instead we will work with them to ensure they are treated fairly.
· Not label different demographics or individuals as vulnerable without understanding their situation. We accept that no two people are the same and each individual should be handled on a case-by-case basis.
· We may tailor or communication to meet the customer’s needs, for example, increasing the font size on our written communications.
· Where appropriate, we may also signpost customers to agencies such as Citizens Advice or Age Concern UK to seek further guidance and support.
· Should we be made aware via a third party that a customer has passed away we will act with empathy and respect. We will then decide on the best way for all parties involved how to move forward.
6. Monitoring and reviews
The company conducts Quality Assurance (QA) checks with vulnerable customers to track the customer outcome. The QA checks may be completed with the customer over the phone or via email depending on the customers needs and their preferred method of communication. The results of any vulnerable customer QA checks are presented at the monthly department heads meeting where any feedback or trends are reviewed, and if necessary appropriate follow up action is determined.
7. Financial Product Design
When it comes to product design, the financial products will be available to all customers and when making changes to any financial products, we will ensure this is in line with customer needs.
When creating or amending any informative or promotional material, we will ensure that we that the needs of our vulnerable customers are considered.
8. Responsibilities
The Company ensure that all staff are provided with the time, resources and support to learn, understand and implement the Vulnerable Customers procedures and associated policy into their business practices. Senior Management are responsible for a top-down approach and in ensuring that all staff are included.
All staff are provided with the training and tools to identify, understand, and deal with vulnerabilities and vulnerable customers, this training is delivered on commencement of employment and is refreshed annually.
We understand that at times, employees may experience situations with vulnerable customers which affect them emotionally, for example if they have suffered from a similar experience with a family member or themselves. In these scenarios, we will offer support to the individual and make considerations with regards to their exposure to such situations moving forward.
9. Policy Reviews
This policy, along with any supporting documents, will be reviewed at least once a year and amended as required to ensure it remains up to date with any regulatory or internal business changes.
Last reviewed on 17/07/24 by James Hallett, Director