Vulnerable Consumers Policy

Purpose The purpose of this policy is to ensure that the operations of the Harwoods Group do not result in poor outcomes for Customers in vulnerable circumstances.

For the purposes of this policy vulnerable consumers are customers and prospective customers whose ability or circumstances require us to take extra diligence or care in the way that we sell and provide our services in order to ensure that they are not disadvantaged in any way.

Identifying a vulnerable consumer When engaging with customers over the phone it is often difficult to identify a potentially vulnerable consumer because it is not possible to see many of the characteristics, such as body language and facial expressions, which may identify whether the prospective customer requires additional information, guidance or support to enable them to make an informed decision. For this reason, it is critically important to listen carefully to all customers and to identify people who may be classed as a vulnerable consumer.

Typical characteristics include: • An inability to hear or understand what is being said • Repeated questions of a similar nature • Comments or answers which are inconsistent with the telephone discussion or which indicate they have not understood the information which has been provided. • Verbal confirmation that they do not understand or that they require the assistance of somebody else in making a decision. • Difficulty in understanding the documentation provided to the customer. • Shortness of breath or signs of agitation • Mention of medication • Mention of payment difficulties or contacting a debt advisor

When assisting with signing up consumers we regularly engage with customers face to face. When doing this the same characteristics are likely to be evident but body language and facial expressions may also assist in identifying the vulnerability.

What to do if we are engaging with a vulnerable consumer Just because somebody is vulnerable does not automatically mean that they are unsuitable for the products and services we as a firm supply. As soon we think we may be engaging with a vulnerable consumer we should ensure we adhere to this policy.

When speaking to the potentially vulnerable consumer we: • Provide additional opportunities for the customer to ask questions about the information we have provided. • Continuously seek confirmation that they have understood the information that has been provided. • Ask if there is anybody with them who is able to assist them and offer them the opportunity to have a family member or friend present during the conversation. • Offer them the opportunity to complete the transaction after a period of further consideration. • Inform a line manager and ask for assistance • Inform any relevant 3rd party If for any reason we think the customer does not understand the service which is being offered to them, we will not proceed with the transaction and advise them that we will write to them with further information about the product or services they are seeking.

What are characteristics of vulnerability? We recognise that customers may be vulnerable or potentially vulnerable for a number of reasons. The following summarises the characteristics associated with 4 drivers of vulnerability: • Health: • Physical disability • Severe or long-term illness • Hearing or visual impairment • Mental health condition or disability • Addiction • Low mental capacity or cognitive disability • Life events: • Retirement • Bereavement • Income shock • Relationship Breakdown • Domestic abuse (including economic control) • Caring responsibilities • Other circumstances that affect people’s experience of financial services (e.g. leaving care, migration, seeking asylum, human trafficking, modern slavery, convictions) • Resilience: • Inadequate or erratic income • Over-indebtedness • Low savings • Low emotional resilience • Capability: • Low knowledge or confidence in managing finances • Poor literacy or numeracy skills • Poor English language skills • Poor or non-existent digital skills • Learning difficulties • No or low access to help or support If for any reason you believe that a customer does not understand the situation in hand or instruction being provided or perhaps you consider that customer to be under duress, you must not proceed with activity, particularly regarding sales activity, until further assistance is sought.

Simply experiencing one or more of the circumstances above does not mean that the customer is vulnerable. It is important not to make assumptions as you may offend a customer. Just because a person is identified as vulnerable does not automatically mean that they are incapable of following a requested action or instruction through.

Vulnerable customer data is regularly reviewed, monitored, and highlighted within the Compliance Review Meetings. Vulnerability Identified After an Event If you retrospectively believe a customer is vulnerable in any way, appropriate steps should be taken to support the customer as much as possible. Consideration as to the required action will be made on a case-by-case basis, each case should be referred to