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Vulnerable Customer Policy

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Vulnerable Customers Consideration

The Financial Conduct Authority 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.'

We recognise that some of our own customers may be considered vulnerable. Vulnerability may take many forms and could be temporary, sporadic or permanent. Vulnerability needs to be recognised in order that we can provide a flexible, tailored response that meets the vulnerable customer's needs and reduces the risk of detriment to them. Examples of personal circumstances that may indicate permanent vulnerability are old age, disabilities such as dementia or deafness, and poor literacy or numeracy skills. Temporary vulnerability may occur due to stress brought on by unemployment, adverse physical or mental health or traumatic events. All customers have the potential to be vulnerable from time to time, or to become permanently vulnerable due to changing personal circumstances.

We also recognise that vulnerability is not just to do with the customer's circumstances. It can be caused or exacerbated by our own actions and processes. For example, poorly designed sales or call-handling systems may cause additional stress to an already stressed customer and increase the risk of detriment to that customer.

We see dealing with vulnerable customers appropriately as a key aspect of treating customers fairly.

In order to minimise the risk of detriment to vulnerable customers we will:

  • Keep how we are performing in dealing with vulnerable customers under regular review, identifying any barriers which may be preventing us from performing better.
  • Ensure that all interfaces with customers are as inclusive as possible and that customers always have a range of communication options.
  • Consider the impact of all business decisions on vulnerable customer groups.
  • Consider vulnerable customer groups when designing or updating business processes.
  • Train staff who deal with customers by telephone to have appropriate conversations with customers about their circumstances, to have awareness of various aspects of vulnerability, and to be able to recognise and deal appropriately with a vulnerable customer. This will include awareness of procedures for referral to specialists within the firm and to external sources of help, if applicable.
  • Ensure that call-handling staff are not prevented by 'scripts' or other procedural requirements from developing a conversation or put under undue pressure to finish a call quickly.
  • Develop our customer record systems to ensure that, when it is established that a customer may be vulnerable, the circumstances indicating vulnerability are clearly recorded and appropriately flagged so that all staff that subsequently deal with the customer are aware of these circumstances.
  • Ensure that relevant senior staff are trained and empowered (where possible and appropriate) to use their judgement to make appropriate decisions, and that vulnerable customers are consistently referred to such staff when it is appropriate to do so.
  • Give positive recognition to staff who deal with potentially vulnerable customers well.
  • Provide appropriate training and support for any staff who, due to their role, regularly deal with vulnerable customers.