Slide 1
    Vulnerable Customer Policy

    Introduction

    The FCA requires organisations to treat all our customers fairly and when dealing with people with vulnerable circumstances to take account of such vulnerability to ensure that the way we sell and provide our services does not cause them detriment.

    The purpose of this policy is to outline how Cosi Living UK supports and protects vulnerable customers in compliance with the Financial Conduct Authority (FCA) guidelines. This policy ensures that our practices uphold the highest standards of fairness and accessibility for all customers, particularly those in vulnerable situations.

    Scope

    This policy applies to employees, contractors, apprentices, consultants, officers, interns, volunteers, job applicants, temporary, agency, casual workers and any other person, representatives or bodies involved with the organisation who interact with customers in any capacity or otherwise operate in a capacity where they can be reasonably aware of information that indicates a customer is vulnerable or particularly vulnerable.

    This policy provides a documented framework to promote a consistent fair treatment of customers who are vulnerable or particularly vulnerable.

    If you are an employee, this policy does not form part of your contract of employment. We reserve the right to amend it at any time.

    What Is A Vulnerable Customer?

    The FCA defines a vulnerable consumer 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’.

    Vulnerability may arise from, but is not limited to:

    • Age (e.g., elderly customers)
    • Disability (e.g., physical, sensory, or cognitive impairments)
    • Illness (e.g., chronic health conditions)
    • Mental health issues (e.g., anxiety, depression)
    • Financial hardship
    • Language barriers or low literacy levels
    • Recent bereavement or significant life changes

    FCA Requirements

    In accordance with FCA guidelines, Cosi Living UK is committed to:

    • Treating Customers Fairly: Ensuring that vulnerable customers are not disadvantaged and receive appropriate support and fair treatment at all stages of their interaction with us.
    • Identifying Vulnerability: Implementing processes to identify customers who may be vulnerable and understanding their specific needs.
    • Providing Appropriate Support: Offering tailored solutions and support mechanisms that address the individual needs of vulnerable customers.
    • Clear Communication: Communicating information in a clear and understandable manner, making adjustments where necessary to accommodate the needs of vulnerable customers.
    • Accessibility: Ensuring that our services and information are accessible to all customers, including those with disabilities or those who may require alternative formats.
    • Training: Providing regular training to employees to ensure they understand FCA requirements and are equipped to support vulnerable customers effectively.
    • Monitoring and Review: Continuously monitoring our practices to ensure they are in line with FCA requirements and reviewing this policy regularly to incorporate any regulatory updates or changes.

    1. Identifying Vulnerable Customers

    We must assess a number of factors when considering if a customer is vulnerable, and the support they may require, including whether the vulnerability is either a permanent or 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 FCA (finalised guidance FG21/1 Guidance for firms on the fair treatment of vulnerable customers) identifies four key drivers of vulnerability as follows:

    Health

    • Physical disability
    • Severe or long term illness
    • Hearing or visual impairment
    • Mental health condition or disability
    • Addiction
    • Low mental capacity or cognitive impairment

    Life Events

    • Retirement
    • Bereavement
    • Income shock
    • Relationship breakdown
    • Caring responsibilities
    • Domestic abuse (including economic control) Other circumstances that affect people’s experience of financial services (e.g. leaving care, migration or seeking asylum, human trafficking or modern slavery, convictions, etc)

    Resilience

    • Inadequate (outgoings exceed income) or erratic income
    • Over-indebtedness
    • Low savings
    • Low emotional resilience

    Capability

    • Low knowledge or confidence in managing finances
    • Poor literacy or numeracy skills
    • Poor English language skills
    • Poor or non-existent digital skills
    • Learning difficulties
    • No or low access to help or support

    Identification of vulnerable customers must be individual, responsive and aimed at removing barriers to accessing our products and services.

    Cosi Living UK staff should be attentive to signs of vulnerability during interactions with customers. Indicators may include but are not limited to:

    • Difficulty in understanding or following instructions
    • Hesitation or confusion during discussions
    • Explicit statements of difficulty or need for extra assistance
    • Behavioural changes or emotional distress

    2. Treating Customers Fairly

    Cosi Living UK strives to achieve the 6 outcomes detailed by the FCA in relation to treating customers fairly. These outcomes can be found here.

    When a vulnerable customer is identified, employees should take steps to ensure they receive appropriate support. These will vary from customer to customer and Cosi Living’s staff should be aware and open to adopting alternative steps when required. Some steps may include but are not limited to:

    Empathetic Communication

    • Active Listening: Engage in active listening to fully understand the customer’s needs and concerns. Avoid interrupting and show empathy through verbal and non-verbal cues.
    • Clear and Simple Language: Use plain language and avoid jargon or technical terms that may be confusing. Break down complex information into smaller, manageable parts.
    • Patience and Reassurance: Allow extra time for the customer to process information and ask questions. Reassure them that their needs and concerns are being taken seriously.

    Personalised Assistance

    • Tailored Solutions: Customise solutions based on the specific needs of the customer. This might include providing detailed product information, alternative product options, or adjustments to the sales process.
    • One-on-One Consultations: Offer personalised consultations to help the customer make informed decisions. This may involve face-to-face meetings, phone calls, or virtual consultations.
    • Home Visits: If appropriate, arrange for a representative to visit the customer’s home to provide personalised advice and support, particularly if mobility is an issue.

    Alternative Formats

    • Accessible Information: Provide information in various formats such as large print, Braille, or audio recordings to accommodate different needs. Ensure that digital information is accessible and compatible with assistive technologies.
    • Language Support: Offer translation services or provide information in different languages to assist customers with limited English proficiency. Use clear and simple language in translations to avoid misunderstandings.

    Accessibility Adjustments

    • Physical Access: Ensure that your physical locations are accessible to customers with disabilities. This includes providing ramps, elevators, and accessible restrooms.
    • Digital Accessibility: Ensure that your website and online services comply with web accessibility standards (e.g., WCAG) to accommodate customers with visual or other impairments. Provide alternative ways to access online information if needed.

    Financial Support and Advice

    • Payment Flexibility: Offer flexible payment options or arrangements for customers experiencing financial hardship. This could include extended payment terms or interest-free periods.
    • Financial Advice: Provide information about financial assistance programs or connect customers with financial advisors if they need help managing their budgets or making financial decisions.

    Emotional and Psychological Support

    • Supportive Environment: Create a supportive and non-judgmental environment where customers feel comfortable discussing their needs and concerns.
    • Referral to Support Services: If a customer requires emotional or psychological support beyond what your company can provide, refer them to appropriate support services or organisations.

    Follow-Up and Feedback

    • Ongoing Support: After the initial assistance, follow up with the customer to ensure that their needs have been met and to address any additional concerns they may have.
    • Feedback Mechanism: Encourage customers to provide feedback on the support they received. Use this feedback to make continuous improvements to your services and support practices.

    Escalation Procedures

    • Complex Cases: For cases that require more specialised support, escalate the issue to a senior team member or dedicated support specialist.
    • Complaints Handling: Ensure that there is a clear process for handling complaints from vulnerable customers and address these complaints promptly and effectively.

    The overriding principle is that good outcomes are achieved throughout the customer journey, and any vulnerability related barriers are removed to allow access to 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.

    Third Party Representatives

    We recognise that some vulnerable consumers need additional support in making decisions or rely on others to make some decisions on their behalf. This may be because their ability to manage their money or represent their own interests is permanently or temporarily impaired (for example, due to dementia or mental health conditions). Cosi Living UK will strive to provide straightforward options to enable legitimate and legal delegated access or support, while maintaining robust safeguards to reduce the risk of abuse.

    If a staff member has doubts about a consumer’s ability to understand a product or service, suspects they do not have capacity to make decisions or that they are acting as a result of fraud or coercion, they should assess whether they should allow the consumer to proceed. Staff should be able to recognise when it is appropriate to seek additional support, such as escalating a case to the next level, seeking additional help from specialist teams or referring a consumer to third party support. This may even be appropriate in circumstances where formal third-party access mechanisms are not set up.

    3. Training & Awareness

    All employees will receive training on recognising and assisting vulnerable customers. Training will include:

    • Understanding different types of vulnerability
    • Effective communication techniques
    • FCA requirements and regulatory standards
    • Procedures for escalating complex cases
    • Legal and ethical considerations

    4. Failure to Comply

    Failure to comply with the provisions of this policy will endanger employees and customers. This is not acceptable and therefore any breach of policy will lead to disciplinary action up to and including dismissal.

    5. Confidentiality

    Cosi Living UK will treat all information regarding a customer’s vulnerability with the utmost confidentiality and always in accordance with the data protection regulations in force at the time.

    6. Review and Improvement

    This policy will be reviewed annually to ensure its effectiveness, relevance, and compliance with FCA requirements. Feedback from customers and employees will be considered to make necessary improvements.

    7. Contact Information

    For further assistance or to report a concern, customers can contact: Amol Khullar

    Dedicated Vulnerable Customer Support: Amol Khullar

    Complaints and Feedback: Amol Khullar 01753 517527

    8. Approval

    This policy has been approved by Amol Khullar and is effective as of 01/09/2024