Vulnerable Consumer Policy

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Document Purpose

The purpose of this document is to clearly outline the Drain Swift Ltd policy on direct marketing activities to vulnerable customers and what procedures and conduct we expect from the sales representatives working for or on behalf of Drain Swift Ltd.

Although Drain Swift Ltd will never actively target vulnerable customers, with customers of a 45+ age bracket and low socioeconomic demographics most likely to benefit from our service, we must assume that our sales representatives will inadvertently promote our services to customers with vulnerabilities. Therefore, we need to have adequate control in place to avoid detriment to vulnerable customers from direct marketing activities.

Definition

Drain Swift Ltd define a vulnerable customer as the following: ‘Any person whether a customer of Drain Swift Ltd or not, who, due to their personal circumstances, is especially susceptible to detriment.’ The following, describes key areas of vulnerability but is not an exhaustive list:

Low literacy, numeracy and financial capability skills
Physical disability
severe or long-term illness
Mental health problems
Low income and/or debt
Caring responsibilities (including operating a power of attorney)
Being ‘older’ for example over the age of 80, although this is not absolute (may be associated with
cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill-health,
not being comfortable with new technology)
Being young (associated with less experience)
Change in circumstances (e.g. job loss, bereavement, divorce)
Lack of English language skills
Non-standard requirements or credit history (e.g. armed forces personnel returning from abroad, exoffenders; care-home leavers, recent immigrants)

As vulnerability can be transient it’s important to judge every interaction with the customer on its own merit
and not assume that not previously detecting vulnerability means the customer is not vulnerable. As a
business we have to be very cautious when dealing with potentially vulnerable customers.

Under the Equality Act 2010, it is illegal to discriminate. When we provide services over the phone we must
not discriminate against, harass or victimise people because of a ‘protected characteristic’ which includes
disability. Hence, it is reasonable to make adjustments to provide a service in a different way or in some
circumstances not to offer our services to those who are unable to make an informed decision.

The Mental Capacity Act puts a framework in place to protect people who are unable to make their own
decisions.

As a result we also need to be alert to the signs that a person we are talking to may not have the capacity, at
that moment in time and/or is vulnerable, or for various reasons may have difficulties to understand that
we promote our product, with the motivation to sell. This is not a diagnosis of a condition but an extension
of staff’s listening skills.

Training

To help our workforce adhere to this policy, we will offer full and suitable training on detecting signs of vulnerability, scoping the nature and extent of vulnerability and whether to continue offering our products and services. We ensure that our workforce understand that characteristics of vulnerability are likely to be complex and overlapping. For example, a life event like a relationship breakdown or bereavement may lead to further vulnerability such as mental ill-health. This may be made worse if the consumer has low or limited
capability to engage with financial services or to manage their finances. Therefore, no one must conduct direct marketing activities until they have received and understood the training.

The training will be reviewed and improved based on insight from QA feedback, industry/non-industry learnings and feedback from customer services.

What an Drain Swift Ltd representative does if they detect signs of vulnerability

As some vulnerable customer groups may benefit the most from our service. Therefore, it is not our policy to
immediately terminate the interaction once vulnerability is detected (unless it is an evident lack of mental
capacity). However, we expect our representatives to identify the signs of vulnerability, attempt to scope the
nature of the vulnerability and act according to our training and policy.

If signs of vulnerability are detected, we must ask ourselves the following questions.
- Will the customer benefit from our product?
- Is the product affordable for the customer?
- Did the customer make/was the customer able to make an informed decision to buy the product?
If the answer is ‘no’ to any of these questions, then continuation of the sale would be against Heating4life
policy and the customer may be excluded from further marketing activities permanently.

Quality Assessment

All sales representatives will be subject to QA activity to ensure our policy is being adhered to. QA will be completed on a selection of random customer interactions and upon request of any complaints or third party concerns. Any claim that the policy may have been breached will be progressed and the interaction will be investigated. All policy breaches detected will be subject to feedback to the representative and further action, which includes but not limited to re-training, verbal or written warning or dismissal.

Detection of a post-sale vulnerable policy breach

If there is a detection of a vulnerable customer policy breach post sale either by QA, feedback from Customer Services or via a valid third party complaint, Drain Swift Ltd will take action to correct the breach. The action will either be to cancel the transaction, full or partially refund any money paid, suspension of payment collection or contact the customer to establish what the best course of action is to be. This must be done on a case-by-case basis. Where necessary the customer may then need to be excluded permanently from further marketing activities, however, this should also be addressed on a case-by-case basis.

Third Party Complaints

Due to regulation and legislation we cannot disclose information about a customer’s account to a third party without authorisation or an arrangement such as a Power of Attorney or third-party mandate. However, if a customer needs assistance in making a call, and the nominated person has the security information they need to conduct a transaction, they should be enabled to carry out the call on the customer’s behalf.

In addition, if a third party contacts Heating4life to let them know that a customer cannot manage their financial affairs for a while, because of, for example, a deteriorating health condition or a sudden crisis, Drain Swift Ltd will make a note of the circumstances so that appropriate action can be taken when Drain Swift Ltd contact the customer.

Exclusions

Where known, Drain Swift Ltd may exclude vulnerable customers from direct marketing activities. QA work
will be used to establish if the policy of excluding detected vulnerable customers is being adhered to.