Vulnerable Customer Policy

INTRODUCTION

This policy sets out how we identify and support vulnerable customers using automated systems combined with staff oversight in accordance with FCA regulations and consumer protection standards, and should be considered alongside our Treating Customers Fairly Policy

What is a vulnerable customer?

The Financial Conduct Authority (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.”

This could include those with:

  • Age-related vulnerability - elderly customers or young adults with limited financial experience
  • Health conditions - physical or mental health issues that affect financial decision-making
  • Life circumstances - bereavement, redundancy, relationship breakdown, or other significant life events
  • Financial difficulty - customers in arrears, debt, or financial hardship
  • Cognitive impairment - learning difficulties, dementia, or other conditions affecting understanding
  • Language barriers - customers with limited English proficiency
  • Low financial literacy - customers with minimal understanding of financial products or services
  • Isolation - customers with limited social networks or support systems
  • Dependency - customers reliant on others for financial decisions or care
How we identify and treat vulnerable customers

All customers are automatically assessed for vulnerability when they apply for finance via Phoenix. Our automated system checks for various vulnerability indicators, and if a customer is flagged as being potentially vulnerable, Our normal application process will be paused whilst our team contact the customer to further assess and assist them as appropriate, before their application is even passed to the lender.

However, it is not always possible to recognise these characteristics. Therefore, if you believe you may fit the criteria for a vulnerable customer, please read this policy and notify us immediately of your particular needs.

Steps we take if we believe a consumer may be vulnerable:
If we believe a consumer may be vulnerable, we will:
  • flag their account in our system to alert all staff and pass this information to prospective lenders where applicable
  • assess their circumstances to understand their needs
  • provide clear, simple communications and offer tailored assistance as appropriate
  • maintain a record of the vulnerability flag, support offered, and any changes to their circumstances.
  • record that we are satisfied that the consumer completely understood everything that was discussed.
Throughout this process, we will treat the customer with dignity and respect and ensure all information is communicated in a way they can understand.

Policy Review

Our Compliance team will monitor and assess our ongoing compliance with the principles of this policy and will review the policy immediately if there are significant changes to our business, if we receive feedback from vulnerable customers, or if we identify any issues with how the policy is being followed.



Date: 23-09-2024: Ver 1