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Vulnerable Customer Policy and Procedure

How do we identify Vulnerable Costumers?

The 4 common key drivers of customer vulnerability can be categorised as follows:

- Health. Conditions or illnesses that affect one's ability to complete day-to-day tasks, both mentally and physically. ...

- Life Events. Such as bereavement, job loss or relationship breakdown. ...

- Resilience. Low ability to withstand and manage financial or emotional shocks. ...

- Capability.

To identify and address the needs of vulnerable customers, our staff are trained to identify the signs that the person, or persons, they are talking too may not have the capacity to make an informed decision regarding the implications of the services/agreement that we are making, or presenting to them.

Current mental capacity legislation (Mental Capacity Act 2005 et al) declares that a person is deemed vulnerable, and thus unable to make a sound decision, if:

- they cannot understand information about the decision to be made,

- cannot retain that information in their mind,

- cannot use or weigh that information as part of the decision-making process, or

- cannot communicate their decision.

All our staff at Philip Paul Ltd aim to help and support our vulnerable customers by:

- Regularly completing training so they are able to engage with vulnerable customers appropriately.

- Observing and involving other members of staff who can provide additional help and support to vulnerable customers.

- Being patient and taking time to listen, and engage in appropriate conversation with the customer so that they fully understand.

- Sharing information with our Partners regarding the customer’s situation.

- Ensuring we spend the time to fully understand the customer’s needs.

- Allocating a familiar primary contact for the customer ensuring consistency and trust.

- Rewarding, recognising and praising good practice in relation to vulnerable customers.

- Simplifying language so it is clear and easy to understand and avoiding use of industry jargon.

What do we look for?

Our staff are trained to look for the signs that the person we are talking to may not have the capacity to make an informed decision regarding the implications of the services/agreement that we are presenting to them. In particular we look for the following signs:

- Do they ask us to speak more slowly?

- Do they understand what we are saying?

- Can they listen to the whole conversation without missing bits?

- Are they aware of what is being discussed?

- Are they asking unrelated questions?

- Do they sound flustered or out of breath when they answer the phone?

- Do they say 'yes' to a question that they have not understood?

- Do they keep repeating themselves?

- Do they suggest another family member deals with things for them?

- Do they say they have not understood previous correspondence or communication?

Communicating with Vulnerable Customers

When we communicate with vulnerable customers we ensure that we:

- Speak clearly to them.

- Set the expectations for the discussion in clear and simple terms.

- Demonstrate patience and ensure we do not rush them.

- Do not assume we know the customers’ needs.

- Keep the discussion on the relevant topic.

- Offer the customer a different method of communication as appropriate.

- Accept that customers can be forgetful.

- Double check the customer has heard what we have said.

- Check in case the customer does not have clear vision.

- Ask the customer if they need to speak to anyone before they make a decision.

- If a customer is not in a position to make a decision or does not have the capacity to do so, we try to find a family member, carer or someone with authority and with appropriate ID who can act on their behalf. We ensure that the authorised person knows exactly what is expected of them.

If a vulnerable customer is identified:

The matter must be referred to a senior colleague who will satisfy themselves that all the customer needs have been identified and appropriate measures are being taken to protect the customer.

Unaccompanied discussions around services or agreements will not be taken forward if it is identified that the customer requires their carer, family member or someone with authority and appropriate ID to be present/act on their behalf.

If you have any questions regarding our Vulnerable Customer Policy please get in touch via the contact details on our website.