Our Vulnerable Customer Policy:
Definition of what a Vulnerable Customer is.
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”.
Our duty, as a retailer and as the first point of contact with the customer, is to recognise the signs of vulnerability before submitting a finance application.
How staff can identify who are the Vulnerable Customers
Vulnerability can take many different forms and is not always obvious. Some customers will tell you if they have a problem or additional requirements, but others may be more reluctant to do so, because they fear that if they admit to a problem this may affect their chances of obtaining finance. If you believe that a customer might be vulnerable, or feels like they are being pressured, or that something is not quite right, then you should ask them more questions in line with our vulnerable customer policy and alert the manager and finance company if we’re concerned.
We will identify vulnerable customers through a variety of means including Talking to our customers and Staff Training.
There are many different types of vulnerability, and this is not a definitive list.
- Customer has difficulty in understanding basic numeracy.
- Customer is unable to read, or if English is not their first language.
- Customer has a mental health issue.
- Customer mentions having been diagnosed with a serious illness.
- Customer repeatedly asks the same questions despite adequate explanations having been provided to them.
- Also, Financial Difficulty, Bereavement, Abuse, Physical Impairments, Mental Health Concerns, Language Barriers are taken into account.
What initial and ongoing training that staff receive around Vulnerable Customers
All staff will have access to FCA guidance.
https://www.fca.org.uk/publication/finalised-guidance/fg21-1.pdf
All staff are trained on customer vulnerability best practice plus ongoing training for all staff.
How a Vulnerable Customer is treated by the retailer.
When we identify a vulnerable customer, we will take steps to understand their individual needs and provide additional levels of support and assistance.
- Providing clear and easy to understand information.
- Giving extra time to make decisions.
- Offering them extra support services
- Seek confirmation that they understand information provided.
- Work with others including family or friends to provide support.
How do we monitor our Performance?
- We will review our policies and procedures regularly.