Statement
Crawfords Electronics Limited is committed to identifying, assessing and managing vulnerable customers in accordance with our own defined objectives and policy, as well as any regulations and guidelines set out by our regulators. We aim to treat all customers, who we define as being vulnerable, in a fair, clear, and respectful manner.
We have implemented several identification and assessment tools within the procedure section of this document, aimed to identify, assess, and deal with all Vulnerable Customer situations and to consistently ensure that our staff are aware of and knowledgeable about Vulnerable Customers, including how to handle certain situations. Our policy content states our intent and obligations with regards to handling customers with vulnerabilities and includes external guidance in our procedures and information as provided by the Money Advice Liaison Group (MALG).
Purpose
The purpose of this policy and procedure document is to identify and support vulnerable customers and to promote transparency and openness in all the business practices and processes that our staff create and engage in. It also defines the steps to be taken by all staff when dealing with a Vulnerable Customer situation.
Crawfords Electronics Limited and its staff are committed to ensuring that all customers are treated in a fair and consistent manner, but also understand that some circumstances require additional interactions and/or steps to ensure that the customer is getting a product and service that is suitable and ethical.
Our staff are provided with training on what makes a customer vulnerable and how to identify, assess and deal with any vulnerability. We are committed to ensuring that any customer who has a relationship with our company, is treated in a fair, reasonable, and in a supportive manner.
Scope
This policy and procedure document relates to all staff within the organisation and has been created to ensure that staff deal with customers in accordance with legal, regulatory, contractual and business expectations and requirements.
3.1 Definition
The 2 main definitions of vulnerable customers are:
a. Customers who are unable, for whatever reason, to make an informed decision at the time of dealing with them – customers falling into this category include those with language barriers, hearing difficulties, those with mental health issues, suffering from bereavement, learning difficulties or the elderly. These customers may struggle to decide on whether the service or product you are providing is in their best interests.
b. Customers whose welfare (financial, mental or physical) could be put at risk through choosing the service or product you offer – these customers include anyone who is going to be put at detriment from taking up your offer. This could be financially if taking out a loan or setting up a payment plan causes them to add financial stresses.
The FCA defines a Vulnerable Customer as: -
“Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”
The FCA notes four factors that can act as drivers to actual or potential vulnerability. These factors (and the examples provided) are non-exhaustive, but are referenced in this policy as part of our approach to vulnerable customer awareness and communication: -
- Health - examples can include physical disability, chronic illness, visual/auditory impairments, mental health issues, impaired mental capacity
- Life Events - examples can include caring responsibilities, bereavement, income/job reduction/loss, relationship issues, non-standard requirements (i.e. ex-offenders, refugees)
- Resilience - examples can include low/fluctuating income, debt, low/no savings, lack of support
- Capability - examples can include low knowledge/understanding/
confidence in managing financial matters, poor literacy/numeracy skills, language barriers, learning impairments
In February 2021, the FCA published further guidance for treating vulnerable customers fairly in their FG21/1 Guidance for Firms on the Fair Treatment of Vulnerable Customers. The regulator noted that protecting vulnerable customers was still one of their key focus areas and the additional guidance aimed to ensure that firms are treating vulnerable customers fairly. Through driving improvements in the way firms treat vulnerable consumers, the FCA wants to bring about a practical shift in the actions and behaviour of regulated firms.
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 service
- Monitoring and assessing whether they are meeting and responding to the needs of customers with characteristics of vulnerability and making improvements where this is not happening.
The Consumer Duty
Vulnerable Customer awareness goes hand in hand with treating customers fairly and ensuring adequate consumer protections. In accordance with the Consumer Duty, Crawfords Electronics Limited has carried out an assessment of the nature and scale of characteristics of vulnerability that exist in our sector and within the target market we operate in.
Complying with the Consumer Duty requirements mean us going above and beyond considering generic customer vulnerabilities that are person or situation specific and also reviewing and monitoring vulnerabilities and characteristics that apply because of our target market. We have developed policies, controls and tools to comply with the Consumer Duty and specifically the requirements contained in PRIN 2A. Customer interests are considered from product/service design through to after-sales care and everywhere in between.
Crawfords Electronics Limited aligns with the guidance for firms on the fair treatment of vulnerable consumers and aims to improve outcomes for customers in vulnerable circumstances. We are committed to ensuring that good outcomes are attainable for all customers, regardless of circumstance, situation or vulnerabilities.
4.1 The Equality Act 2010
In its aim to ensure adequate and fair customer protections, the Consumer Duty requires that the needs of customers in vulnerable circumstances and customers with protected characteristics under the Equality Act 2010 are considered. This includes developing and implementing policies, controls and tools that meet the needs of customers with protected characteristics, as defined by The Equality Act 2010.
The Company is aware that certain groups of customers may have, or be more likely to have, characteristics of vulnerability. These groups can often share a protected characteristic which could result in vulnerable circumstances. We continuously monitor the outcomes of all customers and review the associated management information on a regular basis.
Where there is a pattern or any evidence that customers that share a protected characteristic are more susceptible to experiencing harm from our products or services, we carry out an assessment and ensure that we are complying with both the Equality Act 2010 and the Consumer Duty.
Objectives
We aim to: -
- Ensure that we have the suitable, relevant and compliant tools, controls and measures in place to identify, handle and monitor vulnerable customers.
- Have structured induction training workshops and support tools to explain and guide in the vulnerable customer requirements.
- Train all staff on a rolling basis in the identification, communication and understanding of what vulnerabilities are and how to approach them.
- Have robust vulnerable customer procedures in place at all times and ensure their continued relevance and compliance with the regulations and guidelines.
- Use ongoing assessment tests and evaluations for all staff to ensure understanding and knowledge of vulnerabilities.
- Ensure that all materials, content and information are user-friendly, easy to understand and jargon free.
- Ensure that all systems and automated processes are regularly audited for compliance.
Controls and Measures
6.1 Vulnerable Awareness Review
Crawfords Electronics Limited has identified and reviewed multiple factors that may pose harm or act as a barrier for vulnerable customers using our services and have developed measures and controls to reduce or eliminate the impact of these.
We have assessed the impact of vulnerability on the needs of our customers by reviewing our target market and existing customer base to identify the types of harm or disadvantage that are relevant to our industry and business activities.
We have reviewed and incorporated the FCA guidance on dealing with vulnerable customers and have used their accurate understanding of the drivers of vulnerability and the impact that being vulnerable can have on a person’s ability to engage in consumer credit.
We recognise that vulnerable customers are more likely to experience certain barriers or issues because of their vulnerability and we continuously work hard to ensure that our products, services and advice are flexible, accessible and inclusive.
In accordance with the FCA guidance, we understand that the below potential harms can be a factor for many vulnerable customers, and we pay specific attention to these areas when dealing with any customer who has been identified as vulnerable or potentially vulnerable: -
6.2 Employee Awareness & Training
We recognise that its employees are often the first contact a vulnerable customer will have and their understanding and ability to handle such situations is essential to achieving good outcomes.
We recognise that a consumer may find it difficult to make an informed decision about their available options for a variety of reasons. The risk factors that contribute to consumer vulnerability in financial services include:
- low literacy, numeracy and financial capability skills
- physical disability
- severe or long-term illness
- mental health problems including common mental disorders (CMD)
- low income and/or debt
- caring responsibilities (including operating a power of attorney)
- 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)
- 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).
Living with a disability, illness or diagnosis does not in itself make someone vulnerable. In the context of financial services, it is the person’s situation and barriers to accessing such services that may make them vulnerable. Equally a person may be vulnerable without any disability, illness or diagnosis, for example if they are recently bereaved or frail.
Based on the above factors, we have been able to consider the impact to customers and possible effects and outcomes of these potential harms. This has enabled us to consider the needs of vulnerable customers and to develop effective controls, products and services aimed at making our company approachable, inclusive and accessible.
6.2.1 Training
We ensure that all staff are provided with the training and tools to identify, understand, and deal with vulnerabilities and vulnerable customers.
Our training programme is provided to all new, temporary and existing staff, reminding and updating them on the requirements, guidelines and company ethos of managing Vulnerable Customers.
We recognise that informing, training and assessing front line staff and those with dedicated vulnerable customer roles is essential in removing barriers and reducing potential harm. We work hard to ensure that our staff have adequate and effective skills and knowledge to help vulnerable customers and to ensure that the right and relevant product, service or advice is provided every time
Training is provided through eLearning assessment. Training involves the identification of vulnerable customers as above and correct procedure as outlined below.
6.2.2. Communication Channels
6.2.2 Procedure
Signs we look out for when identifying vulnerability in customers:
- Do they ask you to speak up or speak more slowly?
- Do they understand what you are saying, or do they miss important bits?
- Do they appear confused about what is being offered?
- Do they ask any unrelated questions?
- Do they keep wandering off the point in the discussion and talk about irrelevant things or things that don’t make sense?
- Do they keep repeating themselves?
- Do they take a long time to answer questions or say that someone else deals with these things for them?
- Do they have a language barrier?
- Do they say they don’t understand their bank statements, a previous phone conversation or recent written correspondence?
Where a customer has been identified and/or declared as being vulnerable, Crawfords Electronics Limited follows the steps below
- We speak slowly, clearly and explain fully
- We are patient and empathise where appropriate
- We don’t rush as it may sometimes take the customer time to get relevant information together such as account details
- We keep on the subject under discussion
- We do not make assumptions about a customer’s needs
- We clarify understanding at every point and always ask if there is anything else they would like us to explain
- We ask the consumer to explain to us what they understand the agreement to be
- We offer alternative types of communication – phone, post, email, in person
- We do not make assumptions that the person we are dealing with is sighted as they may be unable to read or understand serial numbers or account numbers
- We do not make assumptions that the customer we are talking to can hear everything we say as they may have a hearing impairment
- We always remember that the customer we are speaking to may sometimes be forgetful or overly trusting and believe that a sales representative is always acting in their best interest
- We understand that some customers may be lonely and welcome the opportunity just to talk to someone
- We give the customer time to explain their circumstances fully and don’t interrupt or appear impatient
- We also listen for what is NOT being said, for example, lack of questions about price, lack of commitment, timing of responses, extended silences
- We always ask if there is a better time to discuss matters as some customers may perform better at different times of the day
- We ask if there is anyone else the customer may need to talk to before making the decision
We also use the TEXAS Model outlined by many advocates of vulnerable customers, including MALG and the FCA. This model enables us to train our employees in effective handling of disclosures of vulnerabilities. It helps employees to identify, assess and support vulnerable customers.
The steps of the model include: -
- Thanking the customer for their disclosure.
- Explaining how their disclosed information will be used.
- EXplicit consent or carry out checks to ascertain if the customer objects to data processing (depending on the basis on which the data will be processed).
- Asking the customer questions to find out key information to understand the situation better.
- Signpost to internal support, or to external services with specialised expertise (where appropriate)
Prior to moving ahead with the sale:
- We ensure that the consumer demonstrates that they understand the decision they need to make, why they need to make it and that they understand the consequences of making, or not making that decision.
- We ask if they need to discuss the matter with anyone else, or if they would like us to explain anything else, or if there anything else we can do further to help
- We are always prepared to repeat anything to clarify understanding
- We do not assume that the customer fully understands all the implications of the agreement and explicitly and clearly confirm all the key features
- We suggest that they talk it through with someone else and offer to re-contact them. If appropriate we suggest that a third person could be present