Vulnerable Customers Policy

Statement

We are committed to identifying, assessing and managing vulnerable customers in accordance with our own defined objectives and policy, as well as any regulations and guidelines set out by our regulators. We aim to treat all customers, who we define as being vulnerable, in a fair, clear and respectful manner. We have implemented several identification and assessment tools within the procedure section of this document, aimed to identifying, assessing and dealing with all situations. Our policy content states out intent and obligations with regards to handling customers with vulnerabilities and includes external guidance in our procedures and information as provided by the Money Advice Liaison Group (MALG).

Purpose

The Purpose of this policy and procedure document is to be identifying and support vulnerable customers and to promote transparency and openness in all the business practices and processes that we and our staff create and engage in. It also defines the steps to be taken by all staff when dealing with a Vulnerable Customer Situation. We and our staff are committed to ensuring that all customers are treated in a fair and consistent manner, but also understand that some circumstances require additional interactions and/or steps to ensure that the customer is getting a product/service that is suitable and ethical. Our staff are provided with training on what makes a customer vulnerable and how to identify, assess and deal with any vulnerability. We are committed to ensuring that any customer who has a relationship with company, is treated in a fair, reasonable and supportive manner.

Definition

The 2 main definitions of a vulnerable customers as used by the Company are:

1. Customers who are unable, for whatever reason, to make an informed decision at the time of dealing with them – customers falling into this category include those with language barriers, learning difficulties, those with mental health issues suffering from bereavement, learning difficulties or the elderly. These customers may struggle to decide on whether the service or product you are providing is in their best interests.

2. Customers whose welfare (financial, mental or physical) could be put at risk through choosing the service or product you offer – these customers include anyone who is going to be put at detriment from taking up your offer. This could be financially if taking out a loan or setting up a payment plan cause them to add financial stress.

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.’

Objectives

We are committed to providing the highest level of due diligence and ethical treatment with regards to any customer or potential customer who is identified as being vulnerable or being at risk from a vulnerable situation. To this end, we have developed the below objectives which are used to create our internal procedures for dealing with vulnerable customers. We aim to:-

• Ensure that we have the suitable, relevant and compliant tools, controls and measures in place to identify, handle and monitor vulnerable customers
• Train staff in the identification, communication and understanding of what vulnerabilities are and how to approach them
•  Have robust vulnerable customer procedures in place at all times and ensure their continued relevance and compliance with the regulations and guidelines
•  Ensure that all materials, content and information is user-friendly, easy to understand and jargon free
•  Ensure that all systems and automated process are regularly audited for compliance
•  Ensure staff, product and information flexibility to provide a complete and ethical service to all customers, regarding of their situation
•  Ensure a consistent and structured approach across the organisation and our staff
•  Implement strict and robust policies and procedures for affordability assessments and data protection

Procedures

We understand that the term ‘Vulnerable Customer’ applies to numerous and varied situations and circumstances, therefore we have outlined the procedures in this document for each Vulnerable Customer type as identified in our Vulnerable Customer Policy. This procedure document contains specific vulnerable circumstances and the steps that we take to manage each situation, however we also have generic procedures as laid out of those with additional vulnerabilities. Where a customer has been identified and/or declared as being vulnerable, the Company always ensures that the below steps/processes are followed in every instance:-

• Ensure that all staff are provided with the training and tools to identify, understand and deal with vulnerabilities and vulnerable customers
• Ensure that ways to contact us are clearly visible on all communications via our website.
• Ensure that all written materials are clear, to the point and jargon free
• Ensure that where applicable, the products/services that we offer are flexible and made to suit the customers’ needs and requirements
• Offer flexible outcomes on products/services as dictated by the customers’ situation and circumstances
• Ensure that any sensitive and/or confidential information disclosed to us regarding the customers’ vulnerability is safe and secure and used. Stores and destroyed in accordance with The Data Protection Act 1998.

Financial Difficulties

Prevention Where possible, we aim to prevent an account from entering into arrears in the first instance. Where previous arrears have occurred or the customers has already notified us of a financial difficulty situation, the account is to be flagged and monitored and close communication kept with the customer for a specific period. Offering options such as missing a payment and making a double payment the next month or accepting lower instalments for a set period and then increasing the payments to make up the shortfall can often prevent an arrears situation from developing. Ongoing Monitoring We assess all accounts and credit agreements on an annual basis to identify if any customer has developed financial difficulties during their contract period. This ongoing monitoring includes:-

Contacting any customer who has missed or delayed one or more payments and completing and affordability assessment and new credit check Flagging accounts where a customer has made one or more late payment (even if all payments are up-to-date) and monitoring that account on a monthly basis. Where more than 3 payments are made after the due date, the customer is contacted to discuss the reasons for late payments and the due date is either changed (i.e. if the customer’s pay day has been moved) or an affordability assessment is completed. We therefore do not exclude a customer from using/purchasing our products/services on the basis that they have been identified as vulnerable. We do however, follow the below procedures to ensure a fair, consistent and ethical approach. Any information collected regarding a mental health problem is kept secure at all times and is only retained for as long as necessary under the DPA regulations. When dealing with any potential mental capacity case, we always ensure that:-

• No further mental and or financial stress or burden is placed upon the customer
• Customers are treated on a case by case basis according to their mental health issues and all effects are taken into consideration when processing and account
• All information discussed via telephone/email with a vulnerable customer are followed up in writing afterwards and full disclosure is provided in the content
• Customers are provided with clear, transparent and jargon-free information so that they can make an informed decision on wanting/needing the product/service we provide

Product Governance

The design and distribution of new products will take into account the requirements of vulnerable customers and this will include collecting relevant management information to monitor the company’s performances in treating vulnerable customers in accordance with the requirements set out in this policy.

Signed: A Wilby

Director A. Wilby

Date May 2022