VRM Swansea (Vehicle Registration Marketing Ltd) Vulnerable Customer Policy

Policy Statement

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 in a fair, clear and respectful manner and ensure information provided is clear and concise and free from jargon.

Purpose

The purpose of this policy is to ensure that the operations of VRM Swansea (Vehicle Registration Marketing) Ltd do not negatively impact vulnerable customers. For the purposes of this policy, vulnerable customers are customers whose ability or circumstances require us to take extra precautions in the way that we sell our products and services.

Definition of Vulnerable Customers

The main definitions of a vulnerable customer as used by VRM Swansea (Vehicle Registration Marketing) Ltd are:

• Customers with communication difficulties (including learning difficulties, hearing difficulties, Dyslexia, and English not being their first language)
• A customer with a reduction in physical or mental capacity (permanent or temporary), sudden diagnosis of serious illness to the customer or close family member
• Personal circumstances of the customer – factors such as financial difficulties, bereavement, caring responsibilities or redundancy
• The customers age, particularly older and younger people. For example, a younger person may be considered inexperienced, and the older person may be less technologically confident

This list is not exhaustive.

Signs we look for from the customer:

• Does the customer ask us to speak up or speak slower?
• Does the customer understand what we are saying, or do they miss important bits?
• Does the customer appear confused about what is being offered and ask any unrelated questions?
• Does the customer take a long time to answer questions or say that someone else deals with these things for them?
• Does the customer have a language barrier?
• Does the customer say they don’t understand a previous phone conversation, or recent written correspondence?

Engagement with Vulnerable Customers

If a member of our team believes we are engaging with a vulnerable customer, whether this is through our identification, or advice from the customer, we will:

• Immediately make a record of this and ensure we adhere to this policy
• Provide additional opportunities for the customer to ask questions about the information we have provided. Show patience and repeat information where appropriate.
• Continuously seek confirmation that the customer has understood the information that has been provided
• Follow up in writing after phone calls and ensure full disclosure is provided in the content
• Offer to communicate via alternative means to allow customers to interpret and understand information
• Offer to speak with an authorised 3rd party to liaise with the customer and ensure that the details of the product/service are being correctly relayed
• Offer the customer the opportunity to complete the transaction after a period of further consideration
• Ensure the customer is not overextending if we are aware they are on a low income

If we can’t assist a customer, we will try and make sure that they understand what alternative options may be available to them.

Training & Staff Support

We are committed to ongoing professional development and will ensure that all staff are provided with the time, resources and support to learn, understand and implement the Vulnerable Customers procedures and associated policy into their business practices.

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