Caring for vulnerable customers

Our policy on dealing with vulnerable customers starts with one very simple, well known and ancient rule, the "golden rule". This rule has been written many different ways in many different contexts so we have written our own version.

"Please always treat your customers as you would wish to be treated yourself in their situation."

The FCA have suggested that approximately 50% of UK adults have some identifiable vulnerability in terms of their ability to engage with financial services. We ask that you treat our mutual customers kindly, fairly and with understanding at all times.

This document will go into depth on what constitutes a vulnerable person. You don’t need to know every word and paragraph but we ask that you familiarise yourselves and always act in accordance with it’s principles.

We define a vulnerable consumer 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.

We have identified 4 key drivers which may increase the risk of vulnerability. These are:‍

health – disabilities or illnesses that affect the ability to carry out day-to-day tasks

‍life events – major life events such as bereavement, job loss or relationship breakdown

‍resilience – low ability to withstand financial or emotional shocks

‍capability – low knowledge of financial matters or low confidence in managing money (financial capability) and low capability in other relevant areas such as literacy, or digital skills

If you become aware that a customer may have a vulnerability please treat that person with extra care. For example:

• If they are older please spend more time with them to explain your technical systems.
• If their understanding of English is limited please be patient with them in explaining the process in as understandable terms as possible.
• Do not promote finance to people who you don’t think will be able to read our marketing literature, application form or loan offers.
• It can be very difficult to ascertain a person’s financial standing. Often times wealth people will dress basically and people on low incomes can appear well. Common sense should be your guide.

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The following documents are required reading for Kandoo Merchants. They are the Financial Conduct Authority's most comprehensive documents regarding customer vulnerability.

FCA Occasional Paper No. 8 on Consumer Vulnerability

FCA Guidance for firms on the fair treatment of vulnerable customers

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Video from FCA

FCA article and source of video

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If you have any questions please contact us.