Vulnerable Customers

Policy Statement

Raw Power York Ltd is committed to ensuring the fair treatment and protection of all customers but particularly those who may have difficulty understanding or making informed decisions due to varies factors including health, life events, resilience, or capability. This Policy outlines how we will identify, assess and support vulnerable customers and, in turn ensure we are able to deliver- “good customer outcomes”.

 

A “good customer outcome” is a wide definition and does not just relate to the avoidance of financial detriment, it includes instances which cause or

could cause distress and/or inconvenience. A ‘good customer outcome’ also helps to support customers in being able to achieve their financial objectives.

 

Applicable Regulations and Legislation

This policy and approach has been developed in line with Consumer and Regulatory demands. Treatment of vulnerable customers is covered within FCA principles in the Finalised Guidance for Fair Treatment of Vulnerable Customers.

 

We have also reflected on our legal obligations with regard to:

• The Equality Act (2010) – no discrimination and making reasonable adjustments.

• General Data Protection Regulation – processing special category data under the Data Privacy Policy.

 

What constitutes a vulnerable customer?

Our definition is:

Customers who, due to age, health, mental capacity, financial situation, or other personal circumstances, may find it harder to understand, communicate, or make decisions about products and services we offer.

 

The FCA definition of a vulnerable customer is:

Customers who, due to their personal circumstances, are especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.

 

We acknowledge that life can present obstacles and challenges that may inhibit customers financial decisions with regard to buying a car. The FCA advised that because anyone can find themselves in vulnerable circumstances at any time, their

guidance and rules apply to most firms who should be focusing on four main areas to achieve good outcomes for vulnerable customers:

• Understanding the needs of their target market and/or customer base.

• Making sure staff have the right skills and capability to recognise and respond to the needs of vulnerable customers.

• Responding to customer needs throughout the whole process, flexible customer service provision and communications.

• Monitoring and assessing whether they are meeting and responding to the needs of customers with characteristics of vulnerability and make improvements where this is not happening.

 

How will we identify vulnerabilities in our customers?

Customers may be identified through direct disclosures, behavioural cues, or circumstances such as disability, illness, or recent traumatic events.  Customers are encouraged to disclose any vulnerabilities voluntarily however staff will be trained to recognise the signs of vulnerability.

 

Risk factors that can help to identify a vulnerable customer include illness, disability, illiteracy, bereavement and other impairments as indicated above. The customer may have indicated a vulnerability in correspondence or one or more of the following indicators may become apparent during a telephone conversation or meeting within the business. key indicators that often highlight a risk factor include:

a) Can the customer hear everything you are saying, and do they understand what you are saying? Do they ask you to slow down or to speak louder? Are you sure they have heard and understood all the relevant details? Do they ask you to clarify any details or advise they do not understand terminology being used?

b) Does the customer stay on topic and hold a conversation that is coherent, or do they appear distracted or confused? Do the customers responses remain relevant and are their questions typical for the discussion being had?

c) Does the customer take an unusually long amount of time to answer a question that suggests they are struggling to process the information provided to them?

d) Does the customer indicate they may have a disability or impairment based on their voice, pronunciation, breathing, hearing or ability to understand the conversation? Are they coherent and fluent in the language being used?

 

 We understand that our customers may not recognise themselves as vulnerable or that they may not appreciate the terminology been used. All communications will be dealt with empathy, respect and consideration.

 

 

For the full policy please get in touch.