Statements

We are 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 identifying, assessing and
dealing with all situations. Our policy content states out 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 identifying and support vulnerable
customers and to promote transparency and openness in all the business
practices and processes that we and our staff create and engage in. It also
defines the steps to be taken by all staff when dealing with a Vulnerable
Customer Situation. We and our 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/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 company, is treated
in a fair, reasonable and supportive manner.

Scope

This policy and procedure document relates to all staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the Company in the UK or overseas) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in
accordance with legal, regulatory, contractual and business expectations and
requirements.

Definition

The 2 main definitions of a vulnerable customers as used by the Company are:

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, learning difficulties, those with mental health issues suffering from bereavement, learning difficulties or the elderly. These customers may struggle to make a decision on whether the service or product you are providing is in their best interests. 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 cause them to added financial stress. 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."

Objectives

We are committed to providing the highest level of due diligence and ethical treatment
with regards to any customer or potential customer who is identified as being
vulnerable or being at risk from a vulnerable situation. To this end, we have developed the below objectives which are used to create our internal procedures for dealing with vulnerable customers.

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

Train staff 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

Research and take expert advice on specific vulnerabilities such as Mental Health and Debt so that our staff and procedures are adequately aligned aligned with the standards

Ensure that all materials, content and information is user-friendly, easy to understand and jargon free

Ensure that all systems and automated process are regularly audited for compliance

Ensure staff, product and information flexibility to provide a complete and ethical service to all customers, regarding of their situation

Ensure a consistent and structured approach across the organisation and our staff

Implement strict and robust policies and procedures for affordability assessments
and data protection

Have specialist teams and/or staff in place to deal with specific vulnerabilities and provide them with additional support, training and
evaluations

Debt and Mental Capacity

Mental health is one of the most common issues that can result in a customer being
vulnerable. We provide thorough staff training and support to identify and deal
with customers who have declared or meet the criteria for having mental health
problems.

We follow the Code of Practice relating to the collection of medical evidence about
mental health conditions and always aims to:

Take steps to establish whether the mental health problem affects the customers' ability to manage money or their debt

Work with the customer in a patient, clear and helpful manner to resolve the
debt problems and use workable solutions.

Provide reasonable periods of time for the customer to provide evidence of any
mental health condition and place accounts on hold during this period.

Prevent any interest and/or charges from being added to the account during the
consultation period.

Work with authorised 3rd parties to help the customer resolve their debt issues

Where we have identified that a customer is considered vulnerable, we always encourage
them to disclose any potential mental capacity limitation and actively look out
for indicators of a potential mental health capacity limitation. Any information collected regarding a mental health problem is kept secure and encrypted always and is only retained for as long as necessary under the DPA regulations.

When dealing with any potential mental capacity, we always ensure that:

Accounts are placed on hold and charges/interest are put on hold during any communications.

No further mental and or financial stress or burden is placed upon the customer

All collections staff with a responsibility for using medical evidence need to know how to read, interpret and make decisions on the basis of medical evidence

Customers are treated on a case by case basis according to their mental health issues and all effects are taken into consideration when processing an amount.

Procedures

We understand that the term 'Vulnerable Customer' applies to numerous and varied
situations and circumstances, therefore we have outlined the procedures in this
document for each Vulnerable Customer type as identified in our Vulnerable
Customer Policy. This procedure document contains specific vulnerable circumstances and the steps that we take to manage each situation, however we also have generic procedures as laid out of those with additional vulnerabilities.

Where a customer has been identified and/or declared as being vulnerable, the Company
always ensures that the below steps/processes are followed in ever instance:

Ensure that all staff are provided with the training and tools to identify, understand and deal with vulnerabilities and vulnerable customers

Email/telephone sales information and/or advice is followed up in writing containing the discussed content and any relevant terms & conditions and disclosure
information

With
regards to debt collection and/or debt management services, accounts will
be placed into a manual process (as oppose too automated), to ensure that
the customers' situation of properly handled

Ensure that staff on the front line are provided with additional vulnerable customer training and given appropriate lines of reporting should they
need to escalate a matter

Ensure
that ways to contact us are clearly visible on all communications and our
website and provide a choice of ways to communicate with us, include:

Post

Email

Face
to Face

Telephone

Online
Chat

Ensure
that all written materials are clear, to the point and jargon free

Ensure
that where applicable, the products/services that we offer are flexible
and made to suit the customers' needs and requirements

Offer
flexible outcomes on products/services as dictated by the customers'
situation and circumstances

Deal
with any authorised 3rd party in a helped and transparent manner

Ensure
that any sensitive and/or confidential information disclosed to us
regarding the customers' vulnerability is safe and secure and used. Stores
and destroyed in accordance with The Data Protection Act 1998

Ability to flag accounts where a vulnerable customer has been
identified so that other staff can see at a glace how the account is to be
handled in the future

Financial Difficulties

Prevention
Where possible, we aim to prevent an account from entering into arrears in the
first instance. Where previous arrears have occurred or the customers has
already notified us of a fiancial difficulty situation, the account is to be
flagged and monitored and close communication kept with the customer for a
specific period.

Offering
options such as missing a payment and making a double payment the next month or
accepting lower instalments for a set period and then increasing the payments
to make up the shortfall can often prevent an arrears situation from
developing.

Assessment

Affordability
Assessment We use assessment questions to assess the customer's affordability.

Ongoing
Monitoring We assess all accounts and credit agreements on an annual basis to
identify if any customer has developed financial difficulties during their
contract period. This ongoing monitoring includes:

Contacting
any customer who has missed or delayed one or more payments and completing
and affordability assessment and new credit check

Flagging accounts where a customer has made one or more late
payment (even if all payments are up-to-date) and monitoring that account
on a monthly basis. Where more than 3 payments are made after the due
date, the customer is contacted to discuss the reasons for late payments
and the due date is either changed (i.e. if the customer's pay day has
been moved) or an affordability assessment is completed.

Mental Health Issues

Despite a
customer being identified as having mental health issues (including stress,
depression, anxiety or other diagnosed condition), the Company understands that
financial/credit products and services are still required (e.g. car insurance,
debt collection activities, home insurance etc).

We
therefore do not exclude a customer from using/purchasing our products/services
on the basis that they have been identified as vulnerable. We do however,
follow the below procedures to ensure a fair, consistent and ethical approach.

Any
information collected regarding a mental health problem is kept secure and
encrypted at all times and is only retained for as long as necessary under the
DPA regulations. When dealing with any potential mental capacity case, we
always ensure that:

No
further mental and or financial stress or burden is placed upon the
customer

Customers
are treated on a case by case basis according to their mental health
issues and all effects are taken into consideration when processing and
account

All
information discussed via telephone/email with a vulnerable customer are
followed up in writing afterwards and full disclosure is provided in the
content

Customers
are provided with clear, transparent and jargon-free information so that
they can make an informed decision on wanting/needing the product/service
we provide

Work with any authorised 3rd party in providing the customer with
the best service/product as suitable to them, their needs and their
situation

Elderly and General Vulnerabilities (Including Bereavement)

We
understand that elderly customers and those with circumstantial vulnerabilities
may still need the products/service that we offer, however, we aim to give more
time, consideration and options to this group of vulnerabilities due to their
possible inability to process information as quickly as others may. With this
in mind, where possible and/or applicable, we always ensure that:

We
speak with an authorised 3rd party to liaise with the customer and ensure
that the details of the product/service are being correctly relayed

Provide
all discussions and product information in writing prior to the customer
receiving any contractual agreement

During
phone calls, reiterate all important and the details of any financial
implications from taking out the product/service

Allow
time for the customer to read, understand and gain 3rd party assistance
with any documentation and/or contractual agreements

Clearly
explain the benefits AND disadvantages of the products/services and any
implications that may be associated with missed payments or breaches in
contract

Where
possible, provide extra time for the customer to cancel the contract after
the agreement has been signed

Increase the time limit for returning any products purchased online

Young/Inexperienced

It is not
common to see young people as vulnerable, however we are committed to ensuring
that any person who may have difficulties understanding the products/services
that we offer, are provided with extra support.

Where we
offer any products and/pr services that can be utilised by young and/or
inexperienced people, we ensure, as with all customers that:

All
sales calls are followed up in writing and any relevant disclosures are
provided ahead of any contractual agreement being provided The benefits
and consequences of any product/service are fully explained along with any
legal implications for having the products and missing payments

Additional time is provided between the sales call, written follow
up and contractual agreement to allow the customer time to communicate
with a 3rd party and understand and content of the product/service offered

Audits and Monitoring

We carry
out regular internal audits and gap analysis monitoring in all business
practices and procedures to ensure that our Vulnerable Customers ethos and
objectives are being met.

Regular reviews of the audit results are held with senior management and
an ongoing record of gaps, actions and improvements is maintained. Vulnerable
Customer compliance as well as providing gap analysis reporting used for M1 and
regulator evidence.

Training and Staff Support

We are committed to ongoing professional development and 1:1 training
sessions and workshops around the ideas and ethos of Vulnerable Customers and
to ensure feedback is given at all times.