Vulnerable Customer Policy

We have a Vulnerable Customer Policy which is designed to ensure the way in which we act and conduct business ensures that vulnerable customers can access all our goods and services without prejudice or hindrance. Vulnerable customers are defined as those whose ability or circumstances require us to take additional steps and precautions in the way we sell and provide our services to ensure they are not disadvantaged.

Who are considered vulnerable customers? Examples may be:

a. Elderly individuals.
b. Customers with disabilities, including physical, sensory, cognitive, or mental health impairments.
c. Customers experiencing financial hardship or debt-related difficulties.
d. Customers with limited English proficiency or communication barriers.
e. Individuals identified as vulnerable by a recognized authority or social service agency.

If a vulnerable customer is identified we commit to:

• Provide extra opportunities for you to ask questions or seek further confirmation about the transaction or service we provide.
• We will continuously seek confirmation that you have understood the information, especially in cases of customer finance application, for example.
• If you feel it would help, you can ask for someone to assist you, such as a family member or friend. We may also suggest this option.
• We will always offer additional opportunities to complete a transaction after further consideration.
• If for some reason we are unable to help, we commit to taking extra steps beyond our standard sale process to try to seek alternatives or point customers to where they can best seek a solution.

Identification and training:
a. All employees will undergo regular training to recognize signs of vulnerability and understand the
appropriate actions to take.
b. Frontline staff will be trained to proactively identify vulnerable customers through attentive observation and active listening.
c. Managers and supervisors will receive additional training to handle complex cases and provide necessary support.

Communication and accessibility:
a. Provide clear and accessible communication channels, including easy-to-understand language and
alternative formats (such as large print or braille).
b. Offer translation or interpretation services for customers with limited English proficiency.
c. Ensure physical facilities are accessible to customers with mobility impairments.

Support and assistance:
a. Designate a specific team or individual responsible for handling vulnerable customer inquiries and
providing personalized support.
b. Offer flexible appointment scheduling and extended time for vulnerable customers to discuss their needs or make decisions.
c. Provide assistance with form filling, document submission, or navigating online platforms if required.
d. Establish referral partnerships with external organizations or agencies to connect vulnerable customers with additional support services.

Data protection and confidentiality:
a. Ensure that all personal information shared by vulnerable customers is handled in accordance with data protection regulations and treated with strict confidentiality.
b. Obtain explicit consent from customers before sharing their information with external agencies or organizations, unless legally required or in the customer's best interest.

Complaints and feedback:
a. Provide clear information to vulnerable customers on how to make complaints or provide feedback, including multiple channels (such as phone, email, or in-person).
b. Designate a dedicated contact person to handle complaints related to vulnerable customers promptly and sensitively.
c. Regularly review and analyse complaints to identify areas for improvement in the vulnerable customer support process.

Staff training and awareness:
a. Conduct regular training sessions to raise awareness among employees about vulnerability issues, empathy, and understanding.
b. Provide ongoing support and resources to employees to ensure they can effectively implement the vulnerable customer policy.
c. Foster a culture of respect, inclusivity, and non-discrimination throughout the organization.