Vulnerable Customer Policy

The purpose of this policy is to ensure that the operations of Senior Response Ltd do not have any negative impact upon vulnerable customers.

For the purposes of this policy vulnerable customers 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 to ensure that they are not disadvantaged in any way.

What is a vulnerable customer?

The Financial Conduct Authority (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 expects firms like ourselves to treat customers fairly when we are dealing with people with vulnerable circumstances.

Identifying a vulnerable customer

As an organisation, we are trained to identify vulnerable customers so we can take extra steps to assist outside of our standard procedures. However, it is not always possible to recognise these characteristics. Therefore, if you believe you your customer or prospective customer fits the criteria for a vulnerable customer, please read this policy and notify your line manager immediately to raise your particular concerns.

Vulnerability groups

We recognise that certain groups of customers may be vulnerable. Whilst not all customers in these groups may be vulnerable, we will consider a customer’s individual circumstances where a potential vulnerability is identified. These groups may include, but are not restricted to:
• Customers with communication difficulties (including learning difficulties and English not being their first language, dyslexia)
• A customer with a reduction in physical or mental capacity
• Customer with health issues – illness, whether physical or mental illness, severe or long term
• A sudden diagnosis of serious illness to the customer or close family member
• Personal circumstances of the customer – factors such as financial difficulties, bereavement, caring responsibilities or redundancy
• The customers age particularly older and younger people. For example, a younger person may be considered inexperienced and the older person may be less technologically able

Our key principles when engaging with a vulnerable customer

As soon we think we may be engaging with a vulnerable customer, whether this is through our identification or a concern you have raised, we will:
• Immediately make a record of this and ensure we adhere to this policy
• Provide additional opportunities for the customer to ask questions about the information we have provided
• Continuously seek confirmation that the customer has understood the information that has been provided
• Ask if there is anybody available there to help or assist the customer. If not, and we believe this will be beneficial, we will make arrangements to continue with the call at another time
• Offer the opportunity to complete the transaction after a period of further consideration.

If we cannot help a customer, we will try and make sure that they understand what alternative options are available to them.

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