Treating Customers Fairly (TCF) and Vulnerable Customers Policy
Objective: To ensure (EHI) meets the customer’s needs and expectations at all times. To ensure that treating Customers Fairly (TCF) remains central to our conduct, and that we put the customers’ well-being at the heart of how we run our business.
To give out ongoing training that implements clear, effective policies and procedures for all of our staff. This will help our team to familiarise and more easily identify particularly vulnerable customers. More importantly this will help us to assist such customers with the respective due care.
Throughout all areas of interaction with potential and actual customers, we will always ensure, respectful, kind and fair treatment.
“The customer must be dealt with courteously at all times, and the customers’ interest and needs must be at the heart of how Eaton Home does business.” – Sakib Hameed, Managing Director
, is committed to meeting customer expectations of performance, quality, price, and delivery in all it does.
The six consumer outcomes for TCF (Treating Customers Fairly) are what Eaton Home should strive to achieve for its customers.
- Outcome 1 – Consumers can be confident that they are dealing with a business where the fair treatment of customers is central to our culture.
- Outcome 2 – Products/services marketed and sold are designed to meet the needs of identified consumer groups that are targeted accordingly.
- Outcome 3 – Consumers are provided with clear information and are kept appropriately informed, before, during and after the point of sale.
- Outcome 4 – Where consumers receive advice, the advice is suitable and takes account of their circumstances.
- Outcome 5 – Consumers are provided with products that perform as firms have led them to expect, and the associated service is of an acceptable standard. Their expectations have been fulfilled.
- Outcome 6 – Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint.
EHI aims to fully understand its customer’s requirements, and provide products/services to meet those needs.
EHI will attempt to answer customers’ questions and enquiries within the scope of its responsibilities. Where the question or enquiry requires more detailed information, we will refer the customer to the appropriate body or organisation. If we have the contact details for these bodies or organisations, we will communicate them to the customer within legal boundaries.
Policy for Dealing with Vulnerable Customers
Vulnerable Customers Policy (VCP) goes hand in hand with Treating Customers Fairly. TCF is about organisations being clear, transparent and open in handling customers. As such, vulnerable customers are identified and treated using a part of TCF. We believe that by having fair treatment at our heart, we should also embrace vulnerable customers. We do this by having measures, support, and training in place for our team.
EHI must take into account the needs of vulnerable consumers, e.g., those with additional needs including poor literacy and/or numeracy, mental health problems, or special access requirements. Where a customer may be vulnerable i.e., have mental/physical infirmity, or English may not be their first language, then we would request and allow that a trusted third party be present. Where a vulnerable person is identified by administration staff, this must be reported to the director. An appointed senior member of staff shall overtake the handling of the vulnerable customer. This includes the monitoring and documentation processes closely to ensure that only the highest level of TCF is maintained.
What Does “Vulnerable” Mean?
EHI have agreed a definition to provide a framework within which they can assess customers’ potential vulnerability. This definition is:
- “Customers who are unable, for whatever reason, to make an informed decision at the time of dealing with them”.
- “Customer whose welfare (financial, mental or physical) could be put at risk through choosing the service or product you offer”.
- “A customer is vulnerable if for reasons of age, health, disability or severe financial insecurity, they are unable to safeguard their personal welfare or the personal welfare of other members of the household”.
When a customer is defined as being vulnerable, it does not instantly prevent the service or product from being put forward. However, it does mean that additional probing is required. We must assess and ensure that what staff are offering is applicable, appropriate and needed by the customer. Some vulnerabilities such as being elderly or having suffered a bereavement may just mean spending more time with the customer. This could mean explaining the offer/suggestion in more detail or discussing it at a slower pace. Only in extreme circumstances would EHI suspend dealings with a vulnerable customer.
EHI are ultimately responsible for deciding whether a customer is vulnerable. For example, if we identify households in the following circumstances, then we will consider whether the customer is vulnerable, according to the definition above:
- A customer is caring for an elderly person in the household
- A customer is of Pensionable Age
- A member of the household is disabled or has a long-term medical condition (i.e., chronic illness) and is therefore unable to support themselves
- An informed third party, such as a carer, social worker, health visitor or physician has indicated that a member of the household may be vulnerable
- The age of any children living in the household
- A customer dependent on medical equipment that is operated by electricity. For example, a stair lift, electric wheelchair, defibrillator or dialysis machine
- A customer has had a recent bereavement
The Mental Health Act is applicable to dealing with vulnerable customers. Customers suffering from or experiencing mental health issues are defined as being vulnerable due to the symptoms that mental health issues can cause. These can include (but are not limited to), depression, stress, anxiety, confusion, suicidal thoughts or tendencies, self-harming, inability to understand or comprehend, and apathy.
Customers with Mental Health Issues (MHI)
The Mental Capacity Act 2005 sets out the legal framework concerning mental capacity. The Ministry of Justice has issued the Mental Capacity Act Code of Practice.
Mental capacity is a person’s ability to make a decision. It is reasonable to assume a customer has a sound mental capacity at the time the decision is made unless the firm knows anything prior, or should reasonably expect that the customer lacks capacity. Having limited mental capacity does not necessarily mean that the customer lacks the capacity to make a decision. The most common cause of mental capacity limitations are; mental health conditions; dementia, a learning difficulty/development disorder, a neurological disability, a brain injury, alcohol or drug abuse.
It is estimated that one in six British adults has a mental health problem. Some customers who fall into financial difficulties may have mental health issues either as a result of being in a financial hardship, or it may cause their financial hardship as their ability to function may be disrupted for either a short period or permanently.
Mental Health Policy
It is our policy to ensure that we treat customers who have mental capacity limitations with respect and consideration. Therefore, in our dealings with such customers, we will endeavour to adhere to the following practices:
- Not to discriminate against the individual
- Not to inappropriately deny a service or product
- Assist the customer to make an informed decision
- Ensure the finance proposition is responsible and is based on a reasonable assessment of affordability and in the best interests of the customer
- Make a reasonable assessment of the customer’s ability to understand and retain the information
- Allow the customer sufficient time to make a decision
Staff will be trained to recognise and encourage a customer to disclose a mental health issue. In all instances where a disclosure is made, the customer’s consent to record this information on our systems is obtained, and the customer will be advised of how this information will be used. Customers will be requested to provide medical evidence if necessary.
In the event that a customer does make a disclosure, staff MUST:
- Inform the Managing Director and request consent to record the information
- Provide a Data Protection Statement
Ask appropriate questions:
- Does your mental health affect your financial situation? If yes, can you send in proof of this from your doctor or other medical professional?
- Does it affect your ability to deal or communicate with us or other third parties?
- How would you prefer us to contact you – (in writing or by phone or by email?)
- Does anyone help you manage your finances such as a family member – If yes; do you want us to deal with this person on your behalf? Consent must be noted on the system
Dealing with Vulnerable Customers and What to Do
Dealing with vulnerable customers, learning about what makes someone vulnerable, and how to deal with arising situations is everyone’s responsibility at EHI. This is irrespective of someone’s job title or rank.
For example, if a customer has agreed to the products/service that we are offering but has displayed signs of being hard of hearing through the conversation, then in order to ensure their vulnerability has been noted and addressed, we send everything discussed in writing to the customer. Only then may we sign them up after the customer has had time to read through everything.
Recapping and reiterating everything in writing is a must with all vulnerable customers. This then gives them the opportunity to have a friend, relative, carer or advisor help them whilst providing extra time to digest the information and make an informed decision.
We instruct all our staff with the following pieces of advice when dealing with vulnerable people:
- Be Patient – take your time with the customer and do not rush
- Be Flexible – some vulnerable situations can be helped or overcome by being flexible and altering both your approach and service
- Be Empathetic – put yourself in the customers’ shoes and show them that you have listened and understood what they have said
- Reiterate – always repeat information and reiterate outcomes or consequences prior to getting agreement;
- Explain – avoid unnecessary jargon
At EHI, we use the BRUCE guide as a checking tool to ensure that we have asked the correct questions, and given the appropriate response to support the customers vulnerability. BRUCE stands for:
- Behaviour and talk – staff should monitor a customer’s behaviour and talk for indications of difficulties with:
- Remembering – is the customer exhibiting any problems with their memory or recall?
- Understanding – does the customer grasp/understand the information given to them?
- Communicating – can the customer share and communicate their thoughts, questions, decisions about what they want to do?
- Evaluating – can the customer weigh up the different options open to them?
Managing Directors Objective Statement
I Sakib Hameed am committed to ensuring that the principles of treating customers fairly (TCF) is applied in all areas of its business activities and running.
In adopting the TCF principle, EHI recognises that fair treatment of its customers is about adding value to the service we offer by aiming to:
- Protect the interests of its customers at each stage of the product life cycle, from promotion right through to after sales service
- Meet as best it can the unique needs of each customer by offering a transparent, efficient and professional service, and constantly reviewing its service to identify areas for improvement
We will ensure this practically by;
- Ensuring that promotional material is clear, compliant, jargon free and appropriately targeted
- Ensuring that sales staff (both on and off-site) have thorough training on all products they advise on or sell, understand who they are suitable for, and are encouraged to challenge where they spot inconsistencies, ambiguities or potential unfairness in the product literature or product features
- Ensuring we only approach customers at an appropriate time of day
- Operating sales remuneration systems which assure fairness to the customer as well as customer satisfaction, rather than only rewarding sales volumes
- Finding ways to encourage non-sales staff to implement TCF in their daily business activities
- Keeping detailed records of customer instructions, risks, the advice/offers given before, during and after a sale. This ensures fair treatment, and can deal with any complaints that may arise swiftly and fairly
- Stating the services EHI in relation to the financial services
- Encouraging after sales contact with clients where appropriate to correct or improve on the service already offered
- Ensuring that customer complaints are assessed fairly, promptly and impartially, and in line with FCA deadlines and rules
- Encouraging staff to recommend improvements to service following customer complaints – and monitoring the outcome
- Ensuring that staff are kept up to date with relevant training in relation to competence, data protection and other matters directly affecting the quality of service offered to customers
- Offering regular training in the principle of TCF at all levels of the business
- Regularly monitoring and reporting on all of the above TCF activities as part of the company’s monthly statistics/MI, in order to assess TCF performance across the business and recommend changes where appropriate.
- Ensuring that TCF values, which are set and communicated by Senior Management, are supported by all staff and understood in the same way
Policy review date March 2021