Our Vulnerable Customer Policy has been designed to ensure that the way in which we conduct our business does not have a detrimental impact upon vulnerable customers. For the purposes of this policy, vulnerable customers are customers and prospective customers whose ability or circumstances require us to take extra precautions in the way that we sell and provide our services to ensure that they are not disadvantaged in any way.
What is a vulnerable customer?
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 firms like ourselves to treat all our customers fairly and when dealing with people with vulnerable circumstances to take account of such vulnerability to ensure that the way that we sell and provide our services does not cause them detriment.
Identifying a vulnerable customer
Our staff are trained to identify vulnerable customers and to provide the additional level of assistance they may require in order to achieve a good outcome. However, it is not always easy to recognise these characteristics. Therefore, if you believe you meet the criteria for a vulnerable customer, please read this statement and notify us as soon as possible of your particular needs. You are encouraged to do this when you first make contact with us.
As soon we think we may be engaging with a vulnerable customer, whether this is through our identification or you are approaching us, we will:
1. Immediately acknowledge this and ensure we adhere to this policy
2. Provide additional opportunities for you to ask questions about the information we have provided
3. Continuously seek confirmation that you have understood the information that has been provided
4. Ask if there is anybody with you who is able to assist. If not, and we believe this will be beneficial, we will make arrangements to continue with the subject at another time
5. Offer you the opportunity to complete the transaction after a period of further consideration
Vulnerability Groups
We recognise 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. These groups may include, but are not restricted to:
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
A 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 able
Assessment and Management of Risk
EnviroRides Ltd will not discriminate against customers in vulnerable circumstances by way of adjustment to fees or any refusal to assist purely on the grounds of the customer’s circumstance (unless that circumstance creates a situation which is likely to lead to detriment or a risk that removes the availability of any finance facility).
The following table illustrates mitigating actions for customers with mental capacity deficiencies (for the avoidance of confusion, “competent person” means an individual without the limitation presented by the customer.
| Capacity Issue | Risk | Mitigation |
|
Language |
Customer cannot fully understand important features of their agreement with EnviroRides Ltd, their recommendation or the consequences of that recommendation |
Customer to instruct a competent person to act as interpreter.
|
|
Other communication problem created by disability |
As above |
Customer to instruct a competent person to act as interpreter. Customer to nominate a reasonable communication medium suitable for their disability. Customer to instruct a competent person to communicate on their behalf. Legal agreement must be reached outside any period of incapacity. |
|
Mental incapacity (temporary) e.g. intoxication, mental illness |
As above plus the potential for reckless disregard for consequence |
Customer should be encouraged to seek independent professional advice. If legal agreement cannot be reached outside any incapacity, customer must provide “Power of Attorney” for a competent individual to act on their behalf. |
|
Mental incapacity (Permanent) |
As above, plus the possibility that any agreement might be unenforceable as a result of known incapacity. |
Customer must provide “Power of Attorney” to a competent individual to act on their behalf
|
Rights and Responsibilities
Responsibilities of EnviroRides Ltd
1. To ensure staff are aware of this policy and are adequately trained
2. To support individuals in relation to identified risk and vulnerability
3. To provide means of reporting any instance where they believe that a customer might be in a vulnerable circumstance.
Responsibilities of EnviroRides Ltd employees
1. To be familiar with this policy and procedures
2. To take appropriate action in line with the policies of EnviroRides Ltd
3. To report any instance where they believe that a customer might be in a vulnerable circumstance.