Vulnerable Customer Policy

VULNERABLE CUSTOMER POLICY

Reviewed 22.12.2022

A vulnerable consumer 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)

The Policy also aims to achieve the following:

• To define what types of vulnerability and susceptibility there are
• To outline how Trade Furniture Ltd approach identification, recording, and management of vulnerable customers

The FCA’s definition of vulnerable customers; “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”

Examples of risk factors for vulnerability

• Life events – major life events such as bereavement or relationship breakdown
• Resilience – low ability to withstand financial or emotional shocks
• Capability – low knowledge of financial matters or low confidence in managing money
• Health – health conditions or illnesses that affect the ability to carry out day to day tasks, both permanently and on a temporary basis

• Mental health problems
• Being ‘older old’ for example over 80, although this is not absolute (may be 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)
• Lack of English language skills

Impact of change in circumstances and income

A change in personal circumstances can cause a consumer to fall into a vulnerable situation – even more so if the consumer already has one or more risk factors.

People are particularly at risk in their interaction with financial services when they experience a change in circumstances that often leads to a financial shock.

This shock could be an unexpected large expense or a loss of income. A drop in income, or income volatility, can cause particular problems due to the ongoing commitment presented by many financial products. A reduction in ability to meet these financial commitments can cause both immediate and longer-term problems.

In some instances, vulnerability and the associated stress can have an effect on people’s emotional state, cognitive ability, and ability to function. This may include feeling stressed and anxious, feeling unable to cope, too upset to talk, finding it difficult to concentrate, think clearly, assimilate information, and make decisions, and finding it difficult to deal with new or unfamiliar tasks.

Types of vulnerability

Vulnerability can come in a range of guises, and can be temporary, sporadic or permanent in nature.

• Many people in vulnerable situations would not diagnose themselves as ‘vulnerable’
• The clear message is that we can all become vulnerable
• Vulnerability involves the interplay between individual circumstances, situations and market factors
• A consumer’s state of mind can have a major impact on behaviour and decisions
• A change in circumstances, and multi-layered risk factors, are particular flags for potential vulnerability

Vulnerability is not just to do with the situation of the consumer. It can be caused or exacerbated by the actions of a company. Many people are trying to cope with difficult situations and limited resources, energy and time. Stress can affect state of mind and can create a spiral of stress and difficulty, resulting in detriment. Our company has a dedicated sales team available 7 days a week, contact forms and live chat facility in order to reduce stress levels and provide support with a human being who is trained to answer all queries and escalate issues where required. The phone lines do not require use of a touch pad or ask questions prior to connecting to a member of the sales team and we have very quick response times for phones, live chat, contact forms and e-mails which all enable a vulnerable individual to easily connect with us and seek support.

In order to address the needs of vulnerable customers correctly, it is important to be able to identify them. In many cases, more than one risk factor is present which increases the consumer's vulnerability.

Our sales team need to be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make an informed decision about the implications of the agreements that they are being asked to make. This is not a diagnosis of a condition; it is just an extension of staff's existing skill of listening, identifying needs, and adjusting their approach accordingly.

Training and feedback

Our approach to vulnerability includes internal training, call monitoring and e-mail monitoring, as most orders are made via the Ecommerce platform most customers place orders without contact from our sales team which avoids the element of coercion by an individual. The website has a FAQ section and lots of information to inform customers of our policies and their rights as well as clear information on costs and charges at every stage of checkout. Performance assessment includes managers listening to a sample of calls and assessing e-mails to see how potentially vulnerable people are handled. Any member of staff (including drivers at the time of delivery) that has dealt with a potentially vulnerable customer would flag this up to management level for the situation to be evaluated and appropriate action taken if required. As Trade Furniture Company is not a financial Institution nor an essential service provider and we sell non-essential products the likelihood of dealing with vulnerable customers is much lower than other organisations however all staff are trained to deal with an array of difficult situations and offer a high level of service at all times and escalate where required which in itself promotes the culture of caring for others and being aware of vulnerability.