Vulnerable Persons Policy

Vulnerable Customer Policy

1. Policy Aim

The aim of this policy is to outline how StovesAreUs identifies and supports customers who may be vulnerable, in order to prevent detriment and ensure fair treatment at all times. We are committed to recognising vulnerability, responding appropriately, and providing a flexible, sensitive service where required.

2. Scope

This policy applies to all StovesAreUs employees who interact with customers, whether through sales, finance, support, or complaints handling. It covers both regulated activities (e.g. consumer credit) and general customer service.

3. Definition of Vulnerability

The Financial Conduct Authority (FCA) defines a vulnerable customer as:

“Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.”

Vulnerability may be temporary, situational or permanent, and does not always arise from a medical condition or disability.

Common categories include:

• Health: physical illness, mental health difficulties, cognitive impairment
• Life events: bereavement, unemployment, relationship breakdown
• Financial resilience: low income, debt problems, inability to absorb financial shocks
• Capability: literacy or language barriers, digital exclusion, lack of experience with financial products

4. Identifying Vulnerable Customers

We recognise that customers may not always disclose vulnerability directly. Staff are trained to look for verbal, behavioural and contextual indicators, including:

• Confusion, distress, or forgetfulness
• Difficulty understanding or retaining information
• Repeated questions or inconsistent statements
• Signs of hardship or stress (e.g. mentions of illness, recent life changes)
• Requests for help from a third party

In regulated contexts, additional insight may be gathered from credit profile reviews or conversations about affordability.

5. Supporting Vulnerable Customers

Where vulnerability is identified or disclosed, staff will take appropriate action based on the customer’s needs. This may include:

• Using plain, jargon-free language
• Allowing extra time to explain options
• Providing written follow-up summaries
• Offering alternative communication formats (e.g. email instead of phone)
• Involving a trusted third party or advocate, with the customer’s consent
• Adjusting product recommendations or delaying decisions where appropriate

Staff will avoid high-pressure tactics and will check frequently for understanding.

6. Fair Treatment and Risk Management

StovesAreUs does not discriminate against vulnerable customers. We will not charge additional fees or deny access to products based solely on a person’s vulnerability.

However, where a customer’s circumstances present a significant risk of harm, particularly in relation to consumer credit or financial hardship, we may:

• Recommend simpler or lower-risk products
• Decline to proceed with a credit agreement if it is not in the customer's best interest
• Refer the customer to an appropriate third-party support organisation

7. Staff Training and Support

All relevant staff receive regular training to:

• Understand the types and causes of vulnerability
• Recognise signs and cues during customer interactions
• Respond with empathy and professionalism
• Escalate complex cases for internal review or further support

Supervisors are available to advise on difficult or sensitive cases.