Vulnerable customer policy

Definition of vulnerable customers:

a. Elderly individuals.
b. Customers with disabilities, including physical, sensory, cognitive, or mental health impairments.
c. Customers experiencing financial hardship or debt-related difficulties.
d. Customers with limited English proficiency or communication barriers.
e. Individuals identified as vulnerable by a recognized authority or social service agency.

Identification and training:
a. All employees will undergo regular training to recognize signs of vulnerability and understand the
appropriate actions to take.
b. Frontline staff will be trained to proactively identify vulnerable customers through attentive
observation and active listening.
c. Managers and supervisors will receive additional training to handle complex cases and provide
necessary support.

Communication and accessibility:
a. Provide clear and accessible communication channels, including easy-to-understand language and
alternative formats (such as large print or braille).
b. Offer translation or interpretation services for customers with limited English proficiency.
c. Ensure physical facilities are accessible to customers with mobility impairments.

Support and assistance:
a. Designate a specific team or individual responsible for handling vulnerable customer inquiries and
providing personalised support.
b. Offer flexible appointment scheduling and extended time for vulnerable customers to discuss
their needs or make decisions.
c. Provide assistance with form filling, document submission, or navigating online platforms if
required.
d. Establish referral partnerships with external organisations or agencies to connect vulnerable
customers with additional support services.

Data protection and confidentiality:
a. Ensure that all personal information shared by vulnerable customers is handled in accordance
with data protection regulations and treated with strict confidentiality.
b. Obtain explicit consent from customers before sharing their information with external agencies or
organisations, unless legally required or in the customer's best interest.

Complaints and feedback:
a. Provide clear information to vulnerable customers on how to make complaints or provide
feedback, including multiple channels (such as phone, email, or in-person).
b. Designate a dedicated contact person to handle complaints related to vulnerable customers
promptly and sensitively.
c. Regularly review and analyse complaints to identify areas for improvement in the vulnerable
customer support process.

Staff training and awareness:
a. Conduct regular training sessions to raise awareness among employees about vulnerability issues,
empathy, and understanding.
b. Provide ongoing support and resources to employees to ensure they can effectively implement
the vulnerable customer policy.
c. Foster a culture of respect, inclusivity, and non-discrimination throughout the organization.