Vulnerable Customers Policy

1. What is a Vulnerable Customer?
A vulnerable customer is someone who, due to their circumstances, is particularly susceptible to
detriment, especially when a company does not act with appropriate levels of care. This definition is
based on guidelines from Ofgem.

1.1 Identifying a Vulnerable Customer: Examples of Risk Factors
The following non-exhaustive list outlines factors that may categorize a customer as vulnerable:
• Low literacy, numeracy, and financial capability skills
• Physical disabilities
• Severe or long-term illnesses
• Mental health issues
• Low income and/or debt
• Caring responsibilities (including operating a power of attorney)
• Advanced age (e.g., over 80, which may be associated with cognitive or dexterity
impairments, sensory impairments like hearing or sight, onset of ill-health, or discomfort
with new technology)
• Youth (associated with less experience)
• Changes 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, ex-offenders, care-home leavers, recent immigrants)
1.2 Impact of Change in Circumstances and Income
A change in personal circumstances can lead a consumer into a vulnerable situation, particularly if
they already have one or more risk factors. Financial shocks, such as unexpected large expenses or
income loss, can exacerbate vulnerability. This can impact their emotional state, cognitive ability,
and functionality, increasing stress, anxiety, and the risk of falling victim to unscrupulous practices.

1.3 Vulnerability Affects Us All
Everyone can face times of stress and difficulty that compromise their ability to cope. Changes such
as job loss, bereavement, or serious illness can make interactions with financial services
challenging. Vulnerability can be caused by long-term conditions or short-term circumstances and
can fluctuate over time. Financial services should be designed to ease these challenges, but
sometimes they inadvertently make them worse.
1.4 Types of Vulnerability
Vulnerability can be temporary, sporadic, or permanent. It requires a flexible, tailored response.
Many people do not consider themselves vulnerable, but circumstances can change that status. It is
crucial to recognize potential vulnerability through a risk factor approach to prioritize and address
these needs effectively.

How We Treat Vulnerable Customers

2. Choice of Communication Methods
We offer multiple communication methods to ensure that our customers can reach us in ways that
are inclusive, flexible, clear, and easy to understand, meeting their specific needs. We adhere to
Ofgem’s requirements for accessible communication to support vulnerable customers effectively.

2.1 Treating People as Individuals
We recognize the unique circumstances of each individual and tailor our responses accordingly. Our
staff are trained to listen carefully, avoid judgment, and ensure they fully understand the
customer’s message before taking action. We diligently record information to prevent customers
from having to repeat themselves and to refresh our understanding before further interactions. We
also work openly and transparently with a customer’s representative or carer, providing all legally
permissible help and information.

2.2 Training and Feedback
We are committed to continually improving our approach to dealing with vulnerable customers. We
promote a culture of empathy and understanding, recognizing that frontline staff may not have
extensive experience with vulnerable individuals. Staff are trained to spot warning signs or triggers
and refer customers to specialists when needed. We avoid rigid scripts and encourage flexible
conversations to address customers’ difficulties effectively.
We aim to remove the fear of discussing sensitive issues by providing clear guidance and
accompanying agents on client calls when necessary.

3. Vulnerable Customers and Our Business Model
We acknowledge that some customers may be categorized as vulnerable due to financial profiles or
mental and/or physical impairments. We ensure that:
• Any financial product offered is appropriate, suitable, and affordable given the customer’s
circumstances.
• The customer fully understands their obligations.
• Our staff are trained to identify and appropriately address vulnerability, treating all
customers with respect and clear communication.
• We assess each customer’s understanding and offer individualized support.
• Customers are given ample time to consider financial products.
• We recommend seeking free independent advice when appropriate.

This policy ensures that we meet our obligations to treat all customers fairly, provide well-designed
products and services, and respond flexibly to individual circumstances, promoting overall
consumer satisfaction and protection. We are committed to complying with Ofgem’s standards for
supporting vulnerable customers, ensuring our practices align with regulatory expectations, and
contribute to a fair and inclusive energy market.