Vulnerable Consumer Policy For Direct Fireplaces

Aim:
The aim of this policy is to outline the practices and procedures for Direct Fireplaces staff to help prevent detriment to customers who find themselves in vulnerable circumstances.

This policy covers all staff who interact directly with customers.

Definition of Vulnerable:
The Financial Conduct Authority defines vulnerable consumers as:

"Someone who, due to their personal circumstances, is especially susceptible to detriment." The most significant detriment occurs when, "through the use of consumer credit, they get into unmanageable or problem debt."

Direct Fireplaces customers who may be considered vulnerable include:

·        Customers with mental capacity deficiencies

·        Customers who are underbanked or financially unsophisticated

·        Customers with low income

·        Customers already in financial distress

Identification of Vulnerable Customers:
·        Mental capacity deficiencies: The FCA provides clear guidance on the identification of mental capacity issues in its Handbook under CONC 2.10.8 Appended to this policy.

·        Underbanked or financially unsophisticated customers can be identified through interview and review of credit profile.  

·        Low-income customers can be identified through interview and review of credit profile.

·        Financial distress can be identified through interview and review of credit profile.

Risk Assessment and Management:
Direct Fireplaces will not discriminate against vulnerable customers through differential fees or refusal of service purely based on their circumstances unless those circumstances create a high risk of detriment or remove availability of services.

For customers with mental capacity deficiencies, Direct Fireplaces staff will take appropriate steps based on the customer's abilities, such as:

·        Involving a competent person to assist the customer

·        Explaining information in a clear, simple way

·        Checking for understanding frequently

·        Avoiding complex products or services

Direct Fireplaces will aim to treat all customers fairly based on their circumstances and needs. Staff will be trained to identify vulnerability and handle such cases with sensitivity and flexibility.