Vulnerable Customer Policy

1. Purpose

The Purpose of the Policy.

The purpose of the Vulnerable Customer Policy is to set out our approach to identifying and interacting with vulnerable customers to ensure we deliver “fair customer outcomes”. A “fair 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 inconvenience. The purpose of this policy document is to define what constitutes a vulnerable customer.

Applicable Regulations and Legislation

The Lucy Pittaway Limited approach to the treatment of vulnerable customers evolves in line with consumer and Regulatory demands.

In addition, the Policy reflects Lucy Pittaway Limited’s legal obligations:

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

• General Data Protection Regulation – processing special category data.

Requirements of the Policy

To deliver fair outcomes to our customers we must consider the circumstances of each individual and in our dealings with them tailor our approach, removing any barriers that restrict the customer achieving a resolution and accessing our products and services.

Lucy Pittaway Limited has no appetite for customer conduct failure. Our Conduct Risk Appetite states that “We will build trust and deliver fair outcomes by understanding our customers’ needs and vulnerabilities by meeting them appropriately.”

2. Scope

The Vulnerable Customer Policy applies to all brands within the Lucy Pittaway Limited. This policy relates to the treatment of vulnerable customers.

3. Definitions

Lucy Pittaway Limited vulnerable customer definition: A vulnerable customer is someone who due to their current personal circumstances may be susceptible to detriment and therefore may require us to engage with them in a different way to meet their individual needs.

Colleague: Lucy Pittaway Limited colleagues (permanent and temporary) and colleagues delivering services to the Lucy Pittaway Limited as employees of third parties.

Customer Facing Colleague is a colleague that will as part of their day-to-day routine, interact with customers through any channel.

First Point of Contact (FPOC): is the colleague/department, including 3rd parties and outsourced service providers, that is the first point of direct business interaction with customers identifying complaints.

Non-customer facing areas is a department or team where colleagues will not typically engage with customers as part of their daily routine. They will predominately, but not exclusively, be in the Fulfilment or Office areas of the business.

4. Policy Statements

Vulnerable Customers

The categorisation of a customer as “vulnerable” must consider a combination of factors including whether the vulnerability is either a permanent or a temporary situation for an individual. The basis of whether a customer is vulnerable, or not, must be assessed on a case-by-case basis and this assessment must consider the key factors which may make them susceptible to unfair customer outcomes.

The following are types of circumstances and characteristics may suggest vulnerability, but these are not exhaustive, and the identification of vulnerable customers must be individual, responsive, and aimed at removing barriers to accessing our products and services.

Age

Mental Health

Low Income Levels

Addictions such as gambling, drinking or drugs

Medical/Health Condition

Financial Hardship

Language Barriers

Mental Capacity Limitations

Life Changing Event

Victims of Financial Crime

Environmental Impacts i.e. floods, subsidence.

Identification

Customers may be recognised as potentially vulnerable through self-identification or through indicators the organisation has identified. All colleagues have a responsibility to remove barriers for customers and should consider this overarching policy when interacting with any customer or potential customer to highlight and identify potential vulnerabilities.

Customers must be able to contact us through any of our communication channels and by any reasonable means, which may include asking a third-party representative to act on their behalf, to notify us of vulnerable circumstances without any barrier.

A non-customer facing colleague that identifies a potential vulnerable customer must communicate the details to the Management Team immediately, where exploration of circumstances will be completed by Management Team in liaison with the non-customer facing colleague if required.

Treatment

Due to the diversity of the factors that can contribute to the level of customer vulnerability (see table 1) there will not be one approach that can be adopted to fit each circumstance. The over-riding principle that must be adhered to by colleagues in their dealings with vulnerable customers is that fair outcomes are achieved throughout the customer journey, and any barriers are removed to access our products and services. It is therefore essential that colleagues take a flexible approach as our failures can lead customers to suffer financial and non-financial impacts.

Colleagues must consider vulnerable customer needs in all interactions; alternative communication methods, such as Braille or Large Print, will be accommodated where possible to remove access barriers.

Processes and procedures will be tailored to enable the identification and treatment of vulnerable customers specific to the nature of the product or services offered and our interactions with customers across the whole customer journey.

Colleagues must offer those customers who have been identified as vulnerable, regular reviews at intervals appropriate to their circumstances to establish whether their classification and treatment continues to be appropriate.

Colleagues must escalate individual cases where vulnerable customers are at risk of an unfair outcome with situations that fall out of existing policy / procedure to the Customer Solutions team for review. The Vulnerable Customer Panel may sit to determine the most suitable outcome for the customer.

Colleagues must seek to provide additional support to enable customers to make informed decisions and maintain access to products and services.

Colleagues must treat all authorised third-party representatives in the same way as the customer to ensure there are no barriers for the customer.

Products and Channels

All products and channels including written, face to face, phone and online digital channel will be periodically reviewed based on an appropriate risk rating to ensure vulnerable customer considerations, this will be managed by the Management Team

Controls and Adherence

The Vulnerable Customer Policy and accompanying guidance will be clearly signposted on the company network and HR software and accessible by all colleagues.

Lucy Pittaway Limited recording of sensitive personal data meets General Data Protection Regulation (GDPR) requirements, regarding each vulnerable customer record and additional support measures. Records can be maintained for a minimum of 10 years.

5. Implementation and Monitoring

Implementation

All Lucy Pittaway Limited colleagues are required to read the policy upon joining the company.

Policy updates will be communicated via email and via our HR Software and any other appropriate mechanisms to cascade to colleagues will be agreed.