Vulnerable Customers Policy

Vulnerable Customers Policy

This policy outlines our commitment to treating all customers fairly, with particular care and consideration given to those who may be in vulnerable circumstances. We aim to ensure that our products and services are accessible to everyone, and that vulnerable customers are not disadvantaged in any way. We are committed to equipping our staff with the necessary skills to effectively identify and respond to the needs of customers in vulnerable circumstances.

Definition of Vulnerability

A vulnerable customer is 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 can be caused by a range of factors, including:

• Physical Vulnerabilities & Health: Physical or mental health conditions, illness, disability. Customers may have mobility impairments, disabilities, or health conditions that could affect their ability to operate an off-road vehicle or understand product or finance information.
• Financial Vulnerabilities/Resilience: Low income, financial difficulties, low financial capability. Customers might be on low incomes, have limited financial literacy, or be experiencing financial hardship, making them susceptible to unsuitable financing options or pressure selling.
• Age-related Vulnerabilities: Older customers might be more susceptible to cognitive decline, have difficulty with technology, the credit application process, complex paperwork, or be more trusting of salespeople.
• Life Events: Bereavement, job loss, relationship breakdown.
• Capability: Limited understanding of financial matters, language barriers, learning difficulties.

Vulnerabilities can impact a customer’s understanding, decision-making, or communication with us. These customers may be more vulnerable to exploitation or making unsuitable products or financial decisions.

Identifying Vulnerable Customers

We recognise that vulnerability is not always obvious. We will actively seek to identify vulnerable customers through:

1. Direct Disclosure: We encourage customers to self-identify if they feel they may be vulnerable.
2. Communication Patterns: We are attentive to signs of difficulty understanding information, anxiety, or stress during interactions.
3. Life Events: We always try to note significant life changes that may trigger vulnerability.
4. Staff Training: We train and equip our staff with the knowledge and skills to identify and support vulnerable customers.

Internal Communication and Escalation Procedures:

• Clear internal procedures are in place for staff to escalate concerns about vulnerable customers to managers. This ensures that all customer requirements are handled appropriately and that vulnerable customers receive the necessary support.
• Record Keeping and Monitoring:
• We maintain records of all interactions with vulnerable customers, including support provided or referrals made. These records are regularly reviewed to monitor the effectiveness of our processes and identify areas for improvement.
• This helps us personalise our service and ensure vulnerable customers receive the information and support they need to make informed decisions.
• Our systems and processes are designed to support the delivery of good outcomes for all customers, including those in vulnerable circumstances, in line with the FCA’s Consumer Duty.
• We regularly review our systems and processes to ensure they are effective in meeting the Consumer Duty’s requirements and delivering good outcomes for our customers.

Supporting Vulnerable Customers

We recognise that our customer base may include individuals with specific vulnerabilities such as those identified above. We are committed to understanding these vulnerabilities and taking proactive steps to ensure these customers are treated fairly and appropriately.

When dealing with vulnerable customers, we will:

• Be patient and empathetic: Take the time to understand their individual needs and concerns.
• Communicate Clearly: Use plain language, avoid jargon, and offer alternative communication formats (e.g., large print, read out) if needed.
• Offer Flexibility: Provide additional time and support for decision-making and explore flexible options such as payment methods and alternative payment plans.
• Avoid Pressure: We never use assertive sales tactics (with any customer) and ensure all decisions are made freely and with full understanding.
• Refer to Specialist Support: If necessary, signpost customers to external organisations that can offer additional help and guidance.
• Delivery Process: We have adapted our delivery process to better support vulnerable customers. Flexible delivery options are available to accommodate customers with limited availability, mobility or transport. Our delivery staff are trained to provide clear explanations and demonstrations of vehicle features, ensuring customers with cognitive impairments or learning difficulties fully understand how to operate their system safely and efficiently.
• Customer Service: We have adapted our customer to better meet the needs of vulnerable customers. Dedicated customer service staff are trained to handle inquiries from vulnerable customers with patience and sensitivity. Multiple communication channels are available (e.g., phone, online, email, chat and in-person) to cater to customers with different communication preferences or needs.
• Ongoing Support: We provide ongoing support to vulnerable customers throughout their ownership of the product. This may include
  • Regular check-ins with vulnerable customers to ensure they are satisfied with their purchase and to address any concerns.
  • Proactive reminders about servicing and maintenance, recognising that some vulnerable customers may need additional support with vehicle upkeep.
  • Accessible and easy-to-understand resources (including online tutorials, FAQs) to help customers with ongoing questions or issues.

Staff Training

We are committed to providing ongoing training to our staff on how to identify and support vulnerable customers. We regularly monitor our practices and make improvements where necessary to ensure this policy is effective and up to date with current regulatory guidance.

Confidentiality

All information disclosed by customers regarding their vulnerability will be treated with the utmost confidentiality and sensitivity, in accordance with applicable data protection laws.

Review & Updates

This policy will be reviewed annually to ensure it remains relevant and effective in protecting the interests of vulnerable customers.

 

Last updated: 3^rd October 2025