Vulnerable Customer Policy
The Financial Conduct Authority (FCA) requires all firms within financial services to recognise and understand the impact that life events, health, resilience, and financial capability may have on their customer’s needs.
Arighi Bianchi is committed to ensuring that all customers, including vulnerable customers are treated fairly and have equal access to Arighi Bianchi products and services.
To this end, we have implemented a Vulnerable Customer policy within our business. The purpose of this Policy is to set out our expectations when dealing with vulnerable customers throughout the end-to-end product lifecycle.
Our staff receive training to ensure we can identify vulnerable customers and to provide the additional level of support they may require to meet their needs and achieve a good outcome. However, we acknowledge that vulnerability can take various forms, and is specific to each individual customer.
Therefore, if you believe you meet the criteria for a vulnerable customer, please notify us of your particular needs so that we can provide the necessary support. To register as a vulnerable customer, please contact us in one of the following ways: Phone : 01625 613333 (Lines are open Monday – Friday 9.30 am – 5.30 pm) Email : enquiry@arighibianchi.co.uk or In Writing to Arighi Bianchi, The Silk Road, Macclesfield, Cheshire, SK10 1LH
Arighi Bianchi Vulnerable Customer Policy
Contents
1.Introduction
2.Definition of vulnerable customer
3.Applicable Regulation and Legislation
4.Arighi Bianchi’s approach to vulnerable customers
4.1 Expectation of Arighi Bianchi colleagues
4.2 Third Party Relationships
4.3 Delegated Authority
4.4 Claims and Customer Relations
5.0 Pricing
6.0 Controls and Adherence
7.0 Management Information
8.0 Monitoring and oversight
9.Training
- Introduction
Arighi Bianchi is committed to ensuring that all customers, including vulnerable customers are treated fairly and have equal access to Arighi Bianchi’s products and services.
Arighi Bianchi (including all outsourced/delegated activities) must operate appropriate processes that consider the circumstances of individuals (and small medium enterprises) and be able to identify whether they are vulnerable or susceptible to detriment (whether permanently or temporarily) and tailor the way in which we communicate and deal with them to take account of the vulnerability.
If you feel that you may be in a position of vulnerability, please contact Arighi Bianchi on 01625 613333 and our team will be able to help you further.
Objectives of this policy
The main objective of this policy is to set out Arighi Bianchi’s approach when dealing with vulnerable customers throughout the end-to-end product lifecycle to ensure that we deliver fair customer outcomes.
The Policy also aims to achieve the following:
- To define what types of vulnerability and susceptibility there are
- To outline how Arighi Bianchi approach identification, recording, and management of vulnerable customers.
- Definition of vulnerable customer
The FCA’s definition of vulnerable customers; “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 considers that the following factors act as drivers to actual or potential vulnerability:
- Health – health conditions or illnesses that affect the ability to carry out day to day tasks, both permanently and on a temporary basis
- Life events – major life events such as bereavement or relationship breakdown
- Resilience – low ability to withstand financial or emotional shocks
- Capability – low knowledge of financial matters or low confidence in managing money An individual may suffer from one or more of these types of vulnerability at the same time which may make them especially susceptible to harm.
- Applicable Regulation and Legislation
Vulnerability is a key priority for the FCA, and it expects firms to exercise extra care when customers may be vulnerable because where vulnerable customers are not treated fairly, there circumstances often mean they face an increased risk of harm. The FCA expects firms to have policies and procedures in place to deal with customers who may be at greater risk and to take account the potential negative impact to vulnerable customers in product availability, product design, distribution channels and post sales servicing of Arighi Bianchi’s products and services. One of the FCA’s operational objectives is to secure an appropriate degree of protection for customers and the FCA would be more likely to intervene where they identify actual, or potential, harm for vulnerable customers. In meeting this objective, the FCA must have regard to the general principle that customers should take responsibility for their choices and decisions. However, there can be factors that may limit the ability of vulnerable customers to take on this responsibility. This risk is further supported by the recent introduction of the ‘customer best interest rule’ which requires Firms to act in the best interests of its customers, considering the capabilities of the customer, their current and future needs and appropriate support required to prevent any potential or actual vulnerability being perpetuated or worsened by the colleagues’ actions, inaction or Arighi Bianchi process.
The FCA also has regard to the general principle that financial services firms should be expected to provide customers with a level of care that is appropriate, having regard, amongst other things, to the capabilities of the customers in question. The level of care that is appropriate for vulnerable customers may therefore be different from what is required for other customers. The FCA will take action against firms that do not afford appropriate processes and procedures for vulnerable customers, and whether intentional or not.
The FCA’s Principles for Businesses underpins the fair treatment of vulnerable customers:
- Principle 2: Skill, care and diligence - Arighi Bianchi commit to conduct its business with due skill, care and diligence.
- Principle 3: Management and control - Arighi Bianchi commit to take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems.
- Principle 6: Customers’ interests - Arighi Bianchi commit to understand the needs of vulnerable customers to pay due regard to their interests and treat them fairly.
- Principle 7: Communications with clients - Arighi Bianchi commit to pay due regard to the information needs of its clients and communicate information to them in a way which is clear, fair and not misleading.
- Principle 9: Customers: relationships of trust – Arighi Bianchi commit to take reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is entitled to rely upon its judgement.
This Policy acts in accordance with the Equality Act 2010, which provides it is illegal to discriminate and strengthens protection for specific protected characteristics. This means when a customer who has a disability is identified through Arighi Bianchi’s operational processes or service, reasonable steps must be taken to ensure they are treated equally, fairly and with respect.
Arighi Bianchi also acts in accordance with the requirements of General Data Protection Regulation (GDPR). In practice, this means that Arighi Bianchi colleagues are required to obtain explicit consent from the customer regarding the recording of information, including both medical data (the vulnerability) and the duration of any vulnerability, for example, whether the vulnerability is thought to be temporary or permanent. Colleagues are expected to ensure the recording of a vulnerability is accurate and reflective of the customers most recent circumstances.
Arighi Bianchi colleagues can record the interventions or adjustments requested by a customer rather than the vulnerability itself, in these instances, Arighi Bianchi colleagues are still required to obtain the customer’s consent before making a record.
- Arighi Bianchi’s approach to vulnerable customers
Arighi Bianchi has different approaches to ensuring that vulnerable customers are identified and handled appropriately and this section details Arighi Bianchi’s approach to identifying vulnerable customers and the processes and controls that it has in place to protect customers throughout the lifecycle of their policy.
- Expectation of Arighi Bianchi colleagues
The FCA expects firms to be able to spot a vulnerable customer when they provide personal details during a call or in customer correspondence, and to respond appropriately to this information. Relevant Arighi Bianchi colleagues receive training for communicating with vulnerable customers to ensure they are empowered and trusted to be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make a decision or provide the correct information. As such, relevant Arighi Bianchi colleagues are expected to be able to confidently and competently effectively listen, identify the customers’ needs and adjust their approach accordingly.
It is acknowledged that vulnerability can take various forms. The following are types of possible circumstances and characteristics which may suggest vulnerability. This is not an exhaustive list and is used as guidance only. The identification of vulnerable customers must be individual, proactive, and aimed at removing barriers to accessing our products and services, to result in both a good and fair customer outcome.
- Low literacy and/or numeracy ability
- Communication challenges
- Physical disability, visual impairment, hearing impairment health or illness that affects the carrying out of day-to-day tasks
- Dementia/mental capacity limitations
- Domestic abuse including economic control low income and/or debt, including outgoings exceeding income and erratic income
- Medical / Health condition No, or low access to help and support Addictions (Gambling, drinks, drugs)
- Advanced age (this can be associated with the onset of ill health, a deterioration in hearing and/or sight, a weakening in cognitive ability or reduced dexterity or not being comfortable with new technology)
- Inability or lack of confidence using technology Environmental (such as floods, subsidence or any other matter relating to a claim or complaint)
In order to act in accordance with the requirements of this Policy, Arighi Bianchi colleagues are expected to:
- Be alert and ensure to listen to what the customer advising, look out for triggers or clues to vulnerability
- Take time to understand the reasons behind any difficulties the customer may be facing, such as job loss, illness, divorce, or learning difficulties as this will help colleagues to understand what the best option or outcome for the customer is
- Set expectations clearly – whether this be over the duration of the call, the process, or the service, it is useful to set expectations at the earliest possible stage
- Apply discretion or adapt the existing process where appropriate
- Speak very clearly and if required slow down and be patient and empathetic, be prepared to repeat or allow time for the person to make notes or agree to confirm in writing
- Clarify understanding at trigger points by asking questions such as ‘is there anything else you would like me to repeat or explain?’
- Ensure there are no barriers to the appropriate and fair treatment of a customer, including barriers to support throughout the product lifecycle.
- Where vulnerability is identified, this will be recorded accurately, sensitively and regularly reviewed for relevance.
- Third Party Relationships
Company Managers are tasked with assessing the internal and external processes and procedures needed within their area of responsibility to ensure they meet the objectives of this Policy when engaging with customers or when overseeing third party outsourced activity.
4.3 Delegated Authority
Company Managers are responsible for the initial (as part of due diligence) and ongoing oversight of vulnerable customer controls in place, ensuring their processes and procedures operate effectively and continue to meet the objectives of this Policy.
4.4 Claims and Customer Relations
Once claims and complaints are referred into Arighi Bianchi, Company Managers are responsible for ensuring that the processes and procedures that operate within their areas meet the objectives of this Policy. The responsibility for ongoing oversight of claims and complaints activities also falls to the respective Company Manager to ensure that vulnerable customers are treated fairly throughout the end-to-end claims and complaints journeys.
- Pricing
Where goods are offered for sale to consumers they must have their price clearly indicated and be inclusive of VAT; our pricing approach makes consideration of vulnerable customers, particularly those with protected characteristics, such as disability, captured under the Equality Act 2010.
- Controls and Adherence
The Vulnerable Customer Policy will be clearly signposted on the intranet and accessible by all colleagues.
When reviewing a complaint or when assessing whether a breach of this policy and associated procedures has occurred, all colleagues must also consider whether a regulatory breach (including breach of a Conduct Rule) has occurred. All suspected regulatory breaches must be reported to the Store Manager.
Arighi Bianchi’s Company Managers are individually responsible for the processes and procedures regarding vulnerable customers in their respective business area.
Arighi Bianchi’s recording of sensitive personal data meets General Data Protection Regulation (GDPR) requirements, regarding each vulnerable customer record and additional support measures. Customer policy records can be maintained for a minimum of 7 years in accordance with the Data Classification and Data Retention Policy.
Company Managers provide regular and accurate reporting to the Store Manager.
- Management Information
Company Managers are responsible for the design and production of accurate and timely MI, relevant to the activities conducted within their Business Unit or within their oversight responsibilities. Company Managers hold the responsibility for identifying, setting risk tolerances, and reporting on Key Performance Indicators (KPIs), associated with managing vulnerable customers in a fair manner. Where risk tolerances (appetites) are breached, escalation to a Director is required.
- Monitoring and oversight
Arighi Bianchi assesses vulnerability through regular oversight and monitoring.
- Training
Arighi Bianchi provides mandatory e-learning training for colleagues which all colleagues must complete and pass each year. Arighi Bianchi colleagues performing roles within the Customer Service Team are required to undertake further detailed training in respect of vulnerable customers.
