Purpose of Vulnerable Customer Policy
As inclusivity is one of the core values of Andertons Music Co, it is important that all customers are treated fairly and certain groups are not disadvantaged in any way. For the purposes of this policy vulnerable customers are customers whose ability or circumstances require us to take extra care in the way that we help them to buy and finance their musical purchases to ensure they are not disadvantaged in any way.
Definition of Vulnerable Customers
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 us, as a licenced consumer credit intermediary firm, to treat customers fairly when dealing with people with vulnerable circumstances.
Type of Vulnerable Customers
We recognise that vulnerability can take various forms and 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. The following are types of possible circumstances and characteristics which may suggest vulnerability:
- 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 (including dementia, mental disorder, cancer etc)
- A sudden diagnosis of serious illness to the customer or close family member
- Personal circumstances of the customer – factors such as severe financial difficulties, bereavement, caring responsibilities, job loss or relationship breakdown, addiction
- Customer’s capability e.g. low literacy or numeracy skills, low knowledge or financial matters
- We also recognise that there is a spectrum of risk and all customers may be at risk of becoming vulnerable at various times in their life.
Engaging with a Vulnerable Customer
Our sales staff are trained to identify vulnerable customers as part of their interactions with customer, so that we can take extra steps to assist when advising customers on their proposed purchase and how this is to be financed. As such, sales staff are expected to be able to confidently and competently effectively listen, identify the customers’ needs and adjust their approach accordingly.
However, it is acknowledged that it is not always possible to recognise these characteristics. Our staff are not expected to go further than this to pro-actively identify any vulnerability.
If we suspect a customer may be vulnerable, staff will:
- 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
- Offer the customer the opportunity to complete the transaction after a period of further consideration
- Ask if there is anybody with the customer who may be able to help in decision-making
- Discuss with the customer how best to meet their needs. It may be that the customer would benefit from taking more time to consider whether they are able to fully understand the commitment.
Specifically with regard to our actions as a credit intermediary we will ask for the customer’s explicit consent before passing on any information to the consumer credit company. This also applies to covering specific communication requirements e.g. large font, braille, email-only communication.
This Policy acts in accordance with the Equality Act 2010 and the requirements of General Data Protection Regulation.