Vulnerable Customer Policy

Ensuring Fair Treatment and Support for Vulnerable Customers

Chelsea Home & Leisure Ltd is authorized to provide services under the Financial Conduct Authority (FRN 971441)

1. Purpose and Scope

At Chelsea Home & Leisure Ltd, we are committed to maintaining a fair and inclusive approach in all our interactions, with a particular focus on vulnerable customers. This policy outlines our commitment to identifying, assisting, and providing tailored services to ensure that vulnerable customers receive the support they need.

2. Definition of Vulnerability

For the purposes of this policy, we define a vulnerable customer in alignment with the Financial Conduct Authority (FCA): “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

3. Identification of Vulnerable Customers

3.1 Training and Awareness

Our staff undergo comprehensive training to recognize indicators of vulnerability and are equipped to provide additional assistance as needed.

3.2 Customer Self-Disclosure

Recognizing the challenge of identifying vulnerability solely through external indicators, we encourage individuals who believe they meet the vulnerability criteria to disclose this information during their initial contact with us.

4. Engagement and Assistance

4.1 Immediate Acknowledgment

Upon identifying a potential vulnerable customer, Chelsea Home & Leisure Ltd will promptly acknowledge the situation, ensuring adherence to this policy.

4.2 Additional Opportunities for Questions

We are committed to providing extra opportunities for vulnerable customers to seek clarification on any information provided to them.

4.3 Continuous Confirmation

Chelsea Home & Leisure Ltd will consistently seek confirmation from vulnerable customers to ensure their understanding of the information presented.

4.4 Assistance Availability

In cases where a vulnerable customer may benefit from assistance, we will inquire about the presence of someone who can help. If no one is available, and if beneficial, arrangements will be made for continued interaction at a later time.

4.5 Transaction Flexibility

Recognizing the importance of careful consideration, Chelsea Home & Leisure Ltd will offer vulnerable customers the option to complete transactions after a period of further contemplation.

5. Identification of Vulnerability Groups

We acknowledge that certain groups of customers may be more susceptible to vulnerability. While not an exhaustive list, these groups may include:

• Customers with communication difficulties
• Those with a reduction in physical or mental capacity
• Individuals facing health issues
• Those with sudden diagnoses of serious illness
• Customers with significant personal circumstances such as financial difficulties, bereavement, caring responsibilities, or redundancy
• Customers of varying ages, considering both younger individuals and older individuals with potential technological limitations.

6. Assessment and Management of Risk

Chelsea Home & Leisure Ltd commits to not discriminating against vulnerable customers. Adjustments to fees or any refusal to assist will not be based solely on a customer’s circumstance, unless it poses a risk that removes the availability of any finance facility.

Mitigating Measures for Customers with Mental Capacity Challenges

Capacity Challenge	Potential Risk	Mitigation Strategies
Language Barriers	Customer may struggle to comprehend crucial aspects of their agreement with Chelsea Home & Leisure Ltd, the provided recommendations, or the resulting consequences.	– Customers are encouraged to designate a competent person to act as an interpreter. – They should choose a suitable communication medium for their disability. – In cases of incapacity, legal agreements must be established outside of that period, with the assistance of a competent person.
Communication Issues Stemming from Disability	Similar to language barriers	– Customers are advised to appoint a competent person to serve as an interpreter. – Selection of a communication medium tailored to the specific disability is recommended. – When necessary, a competent person can act as a communicator on behalf of the customer, ensuring legal agreements are reached during periods of capacity.
Temporary Mental Incapacity (e.g., intoxication, mental illness)	Elevated risk of reckless disregard for consequences	– Customers are urged to seek independent professional advice. – In cases where legal agreements cannot be established during periods of incapacity, customers must provide a “Power of Attorney” for a competent individual to represent them.
Permanent Mental Incapacity	In addition to the above, the possibility of unenforceable agreements due to known incapacity	– Customers must provide a “Power of Attorney” designating a competent individual to act on their behalf, addressing the potential challenges arising from permanent mental incapacity.

These tailored mitigation measures are implemented to address distinct risks associated with various mental capacity challenges. They underscore the importance of ensuring that customers facing language barriers, communication difficulties, temporary or permanent mental incapacity receive adequate support, and any legal agreements are reached with due consideration and safeguards.

7. Rights and Responsibilities

At Chelsea Home & Leisure Ltd, we recognize the importance of clearly defined rights and responsibilities to uphold the principles of fair treatment, especially when dealing with vulnerable customers. This section outlines the specific responsibilities of Chelsea Home & Leisure Ltd as an organization, as well as the corresponding obligations of our employees.

7.1 Responsibilities of Chelsea Home & Leisure Ltd

7.1.1 Ensure staff awareness and provide adequate training on this policy.

Chelsea Home & Leisure Ltd is committed to maintaining a workforce that is well-informed and sensitive to the needs of vulnerable customers. To fulfill this commitment:

• Continuous training programs will be implemented to keep our staff abreast of the nuances of this Vulnerable Customer Policy.
• Training sessions will cover the identification of vulnerability indicators, appropriate responses, and the overarching goal of fair treatment.

7.1.2 Support individuals in relation to identified risks and vulnerabilities.

To support vulnerable customers effectively:

• We will implement measures to provide additional assistance and accommodations based on identified risks and vulnerabilities.
• Tailored support mechanisms will be established to address the unique needs of individual customers.

7.1.3 Provide means for reporting any instance where a customer might be in a vulnerable circumstance.

To foster a proactive approach and ensure accountability:

• Chelsea Home & Leisure Ltd will establish accessible channels for reporting instances where staff members identify or suspect a customer may be in a vulnerable circumstance.
• Reporting mechanisms will be designed to encourage transparency and timely response to potential vulnerabilities.

7.2 Responsibilities of Chelsea Home & Leisure Ltd Employees

7.2.1 Be familiar with this policy and associated procedures.

Chelsea Home & Leisure Ltd employees play a crucial role in the successful implementation of the Vulnerable Customer Policy. Therefore:

• All employees are expected to thoroughly familiarize themselves with this policy and the associated procedures.
• Regular updates and reminders will be provided to ensure ongoing awareness and compliance.

7.2.2 Take appropriate action following Chelsea Home & Leisure Ltd policies.

To ensure consistent and effective responses:

• Employees are expected to adhere to Chelsea Home & Leisure Ltd policies when interacting with customers.
• Clear guidelines will be provided to help employees understand and apply the principles outlined in this policy in their day-to-day activities.

7.2.3 Report any instance where they believe a customer might be in a vulnerable circumstance.

Encouraging a culture of vigilance and responsibility:

• Employees are empowered to report instances where they believe a customer may be in a vulnerable circumstance.
• Reporting procedures will prioritize confidentiality and prompt attention to potential vulnerabilities.

8. Alternative Options

In circumstances where Chelsea Home & Leisure Ltd may be unable to provide direct assistance:

• Every effort will be made to communicate and ensure that vulnerable customers understand alternative options available to them.

• This may involve providing information on external support services, guiding customers to relevant resources, or facilitating connections with appropriate agencies to address their specific needs.