Vulnerable Customers Policy
1. Introduction
1.1 What is a vulnerable customer?
A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care (FCA definition).
1.2 Identifying a vulnerable client
Examples of risk factors for vulnerability include, but are not limited to:
Low literacy, numeracy, and financial capability skills
Physical disability
Severe or long-term illness
Mental health problems
Low income and/or debt
Caring responsibilities (including operating a power of attorney)
Being over 80 years old (associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill health, not being comfortable with new technology)
Being young (associated with less experience)
Change in circumstances (e.g., job loss, bereavement, divorce)
Lack of English language skills
Non-standard requirements or credit history (e.g., armed forces personnel returning from abroad, ex-offenders, care-home leavers, recent immigrants)
1.3 Impact of change in circumstances and income
A change in personal circumstances can cause a consumer to fall into a vulnerable situation, especially if they already have one or more risk factors. Such changes can lead to financial shocks, including unexpected large expenses or a loss of income. This can affect their ability to meet financial commitments and cause immediate and long-term problems. Vulnerability can also affect emotional state, cognitive ability, and functionality, leading to increased stress and difficulty in managing financial matters.
1.4 Vulnerability affects us all
We, or our family and friends, can all face times of stress and difficulty, when our abilities to cope may be compromised. Vulnerability can be long-term, short-term, sudden, or gradual. Most of us will experience some form of vulnerability at some point. Financial services should be designed to alleviate stress rather than exacerbate it.
1.5 Types of vulnerability
Vulnerability can be temporary, sporadic, or permanent, requiring a flexible, tailored response. Many people in vulnerable situations do not diagnose themselves as ‘vulnerable.’ To identify potential vulnerability, we use a risk factor approach.
Summary
Vulnerability involves the interplay between individual circumstances, situations, and market factors.
A consumer’s state of mind can significantly impact behavior and decisions.
Change in circumstances and multi-layered risk factors are particular flags for potential vulnerability.
Vulnerability can be caused or exacerbated by the actions or processes of firms.
The impact of vulnerability is significant, and people may be trying to cope with difficult situations and limited resources, energy, and time.
Training staff to listen and understand, equipping them with flexible options, and providing access to specialists can help address vulnerable customers' needs.
2. How We Treat Vulnerable Customers
2.1 Choice of ways of communicating
We offer multiple ways of communication to ensure flexibility, clarity, and ease of understanding, meeting customer needs inclusively.
2.2 Treating people as individuals
We recognize each individual’s unique circumstances and tailor our responses accordingly. We aim to:
Listen carefully without judgment.
LEnsure the customer's message is clearly understood before taking any action.
Record information properly to avoid repetition in future contacts.
Deal openly and transparently with a vulnerable person’s representative or carer.
Proactively contact customers in financial difficulty to offer sympathetic assistance and resolution, and signpost to free sources of advice as necessary.
2.3 Training and feedback
We are committed to:
Promoting a culture of empathy and understanding towards vulnerability.
Training staff to recognize and respond to signs of vulnerability.
Allowing staff the flexibility to engage in meaningful conversations rather than rigidly scripted responses.
Removing fear around discussing difficult topics, providing clear guidance on responding, and accompanying agents on client calls if needed.
3. Vulnerable Customers and Our Business Model
We recognize that some customers may be vulnerable due to financial profile or mental and/or physical impairments. We ensure:
Financial products offered are appropriate, suitable, and affordable given the customer’s circumstances.
The customer fully understands the nature of the obligation.
Staff are trained to identify and appropriately deal with vulnerable customers, treating all with respect and clear, friendly communication.
Staff are trained to discuss vulnerabilities with clients and assess their personal circumstances.
Clients are given ample time to consider the financial product requested.
When appropriate, we recommend that customers seek free independent advice.
FleetEV Limited is committed to designing products and processes that cater to the broad range of real consumer experiences, ensuring inclusivity and better performance for all customers. If you have any questions or feedback about our Vulnerable Customers Policy, please contact us at compliance@fleetev.com
