The purpose of this policy is to ensure that the operations of the business do not have any negative impact upon vulnerable consumers.
For the purposes of this policy vulnerable consumers are customers and prospective customers whose ability or circumstances require us to take extra precautions in the way that we sell and provide our services in order to ensure that they are not disadvantaged in any way.
Identifying a vulnerable consumer
The appropriate use of discretion is core to how we will approach any given situation and will use our experience to handle members of the public with due care and consideration.
The exercise of appropriate discretion is needed, not only to protect the debtor, but also the employee who has been trained to avoid taking action which could lead to accusations of inappropriate behaviour.
Our employees must withdraw from communication if the only person present is, or appears to be, under the age of 18; they will ask when the customer will be home if appropriate. Our employees will also withdraw from making enquiries at any address if the only persons present are children who appear to be under the age of 12.
Wherever possible, SHCE Limited’s employees will have arrangements in place for accessing translation services when these are needed, and will provide upon request information in large print or in Braille for consumers with impaired sight.
Although not exhaustive, SHCE Limited recognises that the following groups may be potentially vulnerable and will modify our procedures accordingly to accommodate the needs of such persons:
- Who are considered to be financial illiterate *;
- The elderly
- People with a disability
- The seriously ill
- The recently bereaved
- Single parent families
- Pregnant women
- Unemployed people
- Those who have obvious difficulty in understanding, speaking or reading English
- People who suffer from mental health issues
*In this context, it should be noted that the FCA considers that all debtors hold a certain degree of vulnerability due to their current financial situation. It may be found, upon sensitive enquiry, that they may not have the ability to understand and consider properly the information that has been given, and thus cannot make what might be considered to be an informed decision. This is considered to be financial illiteracy and thus to render a person vulnerable: Financial illiteracy is defined by the FCA as “an individual having inadequate knowledge, or financial education rendering a customer unable to, or feeling insufficiently empowered to, manage his finances, engage confidently with Firms, and make informed financial decisions.
If employees think they may be speaking to a vulnerable consumer they should immediately request that a supervisor listens to the call. If the supervisor is unavailable the employee should arrange to call the debtor back and the supervisor should be listening and interacting when the call back is made.
When the employee speaks to the vulnerable consumer they should:
- Provide additional opportunities for the customer to ask questions about the information provided
- Provide information as to sources of advice and information available to the customer or in the customer's locality, such as consumer advice groups, Citizens Advice Bureau, debt counselling organisations (this information is also provided in the documents sent to customers)
- Continuously seek confirmation that they have understood the information that has been provided
- Ask if there is anybody with them who is able to listen to the call
- Offer them the opportunity to complete the transaction by post rather than over the phone