Vulnerable Customers Policy

Why have a vulnerable customers policy?

We recognise that customers can experience vulnerability at any time and can find themselves in situations that make them vulnerable. If people are vulnerable, they are less able than other people to cope with and recover from stresses and pressures or make suitable decisions. 

It is important that vulnerable or potentially vulnerable customers get the support that they need – as they may not be able to represent their own interests and there is a higher possibility of them suffering harm. We want to ensure our customers feel comfortable telling us about their vulnerability and feel confident that they will be treated with sensitivity, respect and compassion. 

Purpose

We are committed to providing appropriate support to vulnerable and potentially vulnerable customers. 

This Policy aims to:

·      Outline the roles and responsibilities in relation to vulnerability;

·      Ensure that potentially vulnerable customers are treated with care and get the support that they need;

·      Help our people better understand what constitutes a potentially vulnerable customer; 

·      Enable staff to proactively identify potentially vulnerable customers;

·      Provide some practical guidance on the steps to follow in dealing with vulnerable customers and mitigate potential customer vulnerability;

·      Ensure training is provided to all staff in dealing with vulnerable customers;

·      Provide feedback to the business to ensure processes are designed appropriately. 

This policy and associated processes are designed to be flexible and respond to each customer’s needs on a case-by-case basis. 

Scope 

Who must comply with this Policy?

This Policy applies to Zenith Financial Group and its people (including permanent staff and contractors).  

This Policy is particularly important for our advisers and administration teams, who may deal with vulnerable or potentially vulnerable customers everyday. 

Defining vulnerability 

Who is a vulnerable customer? 

‘A vulnerable customer is someone who due to their personal circumstances, whether temporary or permanent, requires extra care, support or protection to ensure they are not disadvantaged in any way.’

We have aligned our definition with our company values of ‘doing the right thing and putting our customers at the heart of our business.’ We understand that vulnerability is fluid and subjective. At times, some customers may be more vulnerable than others due to their personal circumstances and be at higher risk of: 

·      Misunderstanding information;

·      Choosing products which are not suited;

·      Experiencing disadvantage or negative outcomes;

·      Miscommunication. 

It is important to us that when a customer is experiencing vulnerability that they are treated with respect and fairness and that we continually find opportunities to improve our customer experience and support. It’s about developing trust with our customers. 

Identifying Vulnerability 

How do we identify a vulnerable customer?

As explained by the Human Rights Commission in their Best practice guidelines for the prioritisation of vulnerable customers vulnerability can at times be difficult to attribute. We acknowledge, as set out in the guidelines, that:

1.     The same factors can impact people differently, meaning that situations which negatively impact some people may not negatively impact others, and vice versa;

2.     People can be exposed to multiple factors of vulnerability at the same time;

3.     Vulnerability is not something that is fixed. It changes over time and depending on people’s circumstances, means that people can move in and out of vulnerability and between different kinds of vulnerability.  

It is important that our people can identify vulnerable customers (both existing and potential).

Dealing with Customer Vulnerability

How we should behave when dealing with customer vulnerability?

When people identify a vulnerable or potentially vulnerable customer, delivering an appropriate level of service, care and support is primary. It doesn’t mean that the products and services we are providing are unsuitable, or that our role is to solve a person’s underlying problem, but that we need to apply extra care and attention based on the customer’s needs. Dealing with vulnerability or mitigating vulnerability is not a one size fits all policy. We have identified several ways we help our customers through times of vulnerability. 

·      By treating all customers as individuals and with respect:

o  Being flexible where appropriate

o  Allow friends or family to help them (with the customer’s consent and where appropriate)

·      By listening to understand the customers, using appropriate language and empathy:

o   Refer back to any notes on files/systems for prompts

o  Maintain respect at all times

o  Maintain realistic outcomes

o  Don’t be condescending 

o  Don’t assume they know what you’re talking about 

o  Use every day plain language and avoid using insurance jargon

o  Being patient

o  Being friendly but don’t get personal

o  Actively listen

o  Politely ask plenty of questions to make sure you understand 

o  Being empathetic

o  Encouraging questions

o  Help them maintain focus

o  Give them time and space to explain their situation and do not create a time pressured situation

o  Asking what they want out of the situation 

o  Seeking reassurance that they have understood any information provided

·      Having several communication options available and limiting barriers to service:

o  Telephone, post, email, face-to-face, website, Facebook, through financial advisers

o  Suggest involving support persons where appropriate

·      By ensuring communication and information is clear, accessible and easy to understand:

o  Clear and plain communication 

o  Easy to read forms and guidance documents

o  Easy access to certain information (contact information, payment information, fees, complaints processes and services, what disclosure means)

o  Having information available to the customer that helps them understand insurance, our products and services, including any changes that may affect them

o  Follow up on communication(s) ensuring that they received it, read it and understand it

o  Providing details about external support services