Vulnerable Customer Policy

Purpose of this policy

The purpose of this policy is to ensure that the operations of Heston Automotive Ltd do not have any negative impact upon vulnerable customers.

For the purposes of this policy, vulnerable customers are customers and prospective customers whose ability or circumstances require us to take extra precautions in the way that we conduct business and provide our services, to ensure that they are not disadvantaged in any way.

What is a vulnerable customer?

The Financial Conduct Authority (FCA) defines a vulnerable customer as "someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care."

The FCA expects firms like ourselves to treat customers fairly when we are dealing with people with vulnerable circumstances.

Identifying a vulnerable customer

Our staff are trained to identify vulnerable customers so we can take extra steps to assist outside of our standard procedures. However, it is not always possible to recognise these characteristics. Therefore, if you believe you may fit the criteria for a vulnerable customer, please read this policy and notify us immediately of your particular needs.

Signs we look out for include:

• Do they ask us to speak up or speak more slowly?
• Do they understand what we are saying, or do they miss important bits?
• Do they appear confused about what is being offered?
• Do they ask any unrelated questions?
• Do they keep wandering off the point in the discussion and talk about irrelevant things or things that do not make sense?
• Do they keep repeating themselves?
• Do they take a long time to answer questions, or say that someone else deals with these things for them?
• Do they have a language barrier?
• Do they say they do not understand their statements, a previous phone conversation or recent written correspondence?

Vulnerability groups

We recognise that certain groups of customers may be vulnerable. Whilst not all customers in these groups may be vulnerable, we will consider a customer's individual circumstances where a potential vulnerability is identified. These groups may include, but are not restricted to:

• Customers with communication difficulties (including learning difficulties, English not being their first language, and dyslexia)
• A customer with a reduction in physical or mental capacity
• Customers with health issues, whether physical or mental, severe or long term
• A sudden diagnosis of serious illness to the customer or a close family member
• Personal circumstances such as financial difficulties, bereavement, caring responsibilities, or redundancy
• The customer's age, particularly older and younger people. For example, a younger person may be considered inexperienced and an older person may be less technologically able

Steps we take if we believe a customer may be vulnerable

• We speak slowly, clearly and explain fully
• We are patient and empathise where appropriate
• We do not rush, as it may sometimes take the customer time to get relevant information together such as account details
• We keep on the subject under discussion
• We do not make assumptions about a customer's needs
• We clarify understanding at every point and always ask if there is anything else they would like us to explain
• We ask the customer to explain to us what they understand the agreement to be
• We offer alternative types of communication: phone, post, email, in person
• We do not assume that the person we are dealing with is sighted, as they may be unable to read or understand serial numbers or account numbers
• We do not assume that the person we are talking to can hear everything we say, as they may have a hearing impairment
• We always remember that the person we are speaking to may sometimes be forgetful or overly trusting
• We understand that some people may be lonely and welcome the opportunity just to talk to someone
• We give the customer time to explain their circumstances fully and do not interrupt or appear impatient
• We also listen for what is not being said, for example lack of questions about price, lack of commitment, timing of responses, or extended silences
• We always ask if there is a better time to discuss matters, as some people may perform better at different times of the day
• We ask if there is anyone else they may need to talk to before making the decision

Staff training and identification tools

All customer-facing staff complete vulnerability awareness training as part of induction, with refresher training at least annually. Training covers how to identify indicators of vulnerability at the point of sale, including the signs listed above, and how to adapt the sales conversation accordingly.

Staff are trained to use the TEXAS drill when a potential vulnerability is identified during a call or in-person conversation:

• Thank the customer for sharing
• Explain what will happen to the information they share
• eXpect that they may not wish to disclose further detail
• Ask an open question to understand support needs
• Signpost or support the customer appropriately, including onward referral where required

Where a member of staff is unable to resolve a customer's needs directly, cases are escalated to the Compliance Manager (Eesa Nasim), who determines whether the case should be escalated further to the relevant lender or finance partner.

A record of vulnerability training completed by each member of staff is maintained and reviewed by management as part of the firm's Training and Competency Scheme.

Prior to forming the contract

• We ensure that “yes” is a real agreement, not just a giving in
• We ensure that the customer demonstrates that they understand the decision they need to make, why they need to make it, and the consequences of making, or not making, that decision
• We ask if they need to discuss the matter with anyone else, or if they would like us to explain anything else, or if there is anything else we can do to help
• We are always prepared to repeat anything to clarify understanding
• We do not assume that they fully understand all the implications of the agreement, and we explicitly and clearly confirm all the important points
• We ensure that the customer is not flustered, agitated or in an emotional state when they make a decision
• We suggest that they talk it through with someone else and offer to contact them when they have had a chance to talk with a third party. If appropriate, we suggest that a third person could be present

After the contract

• If we identify communication needs, we store that information so future communication is handled appropriately
• We record that we are satisfied that the customer completely understood everything that was discussed
• We allow customers to make a personal declaration about their capabilities or communication needs and store this information
• Any records that are held are with the full knowledge and consent of the customer and are deleted when the relationship no longer exists, in accordance with the Data Protection Act 2018

If specialist advice is needed

If we identify a person who may be in need of specialist advice which we are unable to offer, we will signpost to the Debt and Mental Health Evidence Form (DMHEF) where appropriate. We will refer to, or seek guidance from, an appropriate organisation such as:

• Samaritans, Carers Trust, Citizens Advice
• Age UK, Alzheimer's Society, Mind
• StepChange, Money Advice Trust, MALG
• Macmillan Cancer Support

Sources of guidance we refer to include the Equality Act 2010, the Mental Capacity Act 2005, CONC 7.9 and CONC 1.10 (mental capacity), FCA Guidance FG21/1 on the fair treatment of vulnerable customers, and MALG guidance on treating vulnerable consumers fairly.

Contact us

To discuss this policy in more detail or to register yourself as a vulnerable customer, please contact us:

• Email: eesa@hestonautomotive.com
• Phone: 020 8564 8030
• In writing: Heston Automotive Ltd, Unit 1 Vinyl Place, Dawley Road, Hayes, Middlesex, UB3 1DA