Vulnerable Members Policy

Purpose

The FCA defines a Vulnerable Customer as: - “A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.”

The purpose of this policy is to identify and support vulnerable members. To promote transparency and openness in all business practices and processes that the Company and our staff create and engage in. It also defines the steps to be taken by all staff when dealing with a Vulnerable Member or associated situation.

The Company and its staff are committed to ensuring that all members are treated in a fair and consistent manner, but we also recognise that some circumstances require additional interactions and/or support to ensure that members are getting a product/service that is suitable and ethical.

Scope

This policy and procedure document relates to all staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the Company) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.

Definition

The two main definitions of a vulnerable members are:

1. Members who are unable, for whatever reason, to make an informed decision at the time of dealing with them – members falling into this category include those with language barriers, hearing difficulties, those with mental health issues, suffering from bereavement, learning difficulties or the elderly. These members may struggle to decide on whether the service or product you are providing is in their best interests.
2. Members whose welfare (financial, mental or physical) could be put at risk through choosing the service or product we offer – these members include anyone who is going to be put at detriment from taking up our offer/product/service. This includes financially (i.e. if taking out a loan or setting up a payment plan could cause them added financial stress).

FCA advises that four factors can act as drivers to actual or potential vulnerability. These factors (and the examples provided) are non-exhaustive, but are referenced in this policy as part of our approach to vulnerable member awareness and communication: -

• Health - examples can include physical disability, chronic illness, visual/audio impairments, mental health issues, impaired mental capacity
• Life Events - examples can include caring responsibilities, bereavement, income/job reduction/loss, relationship issues, non-standard requirements (i.e. ex-offenders, refugees) • Resilience - examples can include low/fluctuating income, debt, low/no savings, lack of support
• Capability - examples can include low knowledge/understanding/confidence in managing financial matters, poor literacy/numeracy skills, language barriers, learning impairments

Someone can find themselves in vulnerable circumstances at any time, FCA’s guidance and rules apply to firms who should be focusing on four main areas to achieve good outcomes for vulnerable members: -

• Understanding the needs of target market and/or member base.
• Making sure staff have the right skills and capability to recognise and respond to the needs of vulnerable members.
• Responding to customer needs throughout product design, flexible member service provision and communications.
• Monitoring and assessing whether they are meeting and responding to the needs of members with characteristics of vulnerability and make improvements where this is not happening.

Objective

The Company is committed to providing the highest level of due diligence and ethical treatment with regards to any member or potential member 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. The Company aims to: -

• Ensure members take a product which suits their needs and won’t put them in hardship in the future.
• Ensure that we have suitable, relevant and compliant tools, controls and measures in place to identify, handle and monitor vulnerable members.
• Train all staff on a rolling basis in the identification, communication and understanding of what vulnerabilities are and how to approach them.
• Ensure robust vulnerable member procedures are always in place and ensure continued relevance and compliance with regulations and guidelines.
• Research and take expert advice on specific vulnerabilities such as Mental Health and debt so that our staff and procedures are adequately aligned with the standards.
• Use ongoing assessment tests and evaluations for all staff to ensure understanding and knowledge of vulnerabilities.
• Use vulnerable member aids in place to help members with specific situations, including but not limited to: - Multiple contact options (email, phone, post, online, face to face)
• Ensure that all materials, content and information are user-friendly, easy to understand and jargon free.
• Ensure that all systems and automated processes are regularly audited for compliance.
• Ensure staff, product and information flexibility in providing a complete and ethical service to all members, regardless 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.

Understanding Vulnerabilities

The Company has identified and reviewed multiple factors that may pose harm or act as a barrier for vulnerable members using our products/services and have developed measures and controls to reduce or eliminate the impact of these. We have assessed the impact of vulnerability on the needs of our members by reviewing our target market and existing member base to identify the types of harm or disadvantage that are relevant to our industry and business. We also utilise internal data from previous interactions with vulnerable members to identify patterns in the types of people who are more susceptible to vulnerabilities based on the products/services that we provide.

We have reviewed and incorporated the FCA guidance on dealing with vulnerable members and have used their driving factors and potential harms to further develop our policy and measures in this area. We also utilise other papers and guidance on vulnerable members to accurately understand the drivers of vulnerability and the impact that being vulnerable can have on a person’s ability to engage in financial services. We recognise that vulnerable members are more likely to experience certain barriers or issues due to vulnerability and we continuously work hard to ensure that our products, services and advice is flexible, accessible and inclusive.

In accordance with the FCA guidance, we understand that the below potential harms can be a factor for many vulnerable members, and we pay specific attention to these areas when dealing with any member who has been identified as vulnerable or potentially vulnerable: -

• Financial exclusion
• Difficulty in accessing services
• Partial exclusion
• Disengagement with the market
• Scams
• Over-indebtedness
• Exposure to mis-selling
• Inability to manage a product or service
• Purchasing inappropriate products or services

Based on the above factors, we have been able to consider the impact to members and possible effects and outcomes of these potential harms. This has enabled us to consider the needs of vulnerable members and to develop effective controls, products and services aimed at making our company approachable, inclusive and accessible for all.

Delivering the outcome

The Company ensure that all staff are provided with the time, resources and support to learn, understand and implement our Vulnerable Member procedures and associated policy into their daily business practices. Senior Management are responsible for a top-down approach and in ensuring that all staff are included.

The CEO is the owner of this document and is responsible for keeping it up to date.