Vulnerable Persons Policy

What is a Vulnerable Persons Policy?

This policy outlines how V4B Ltd will recognize that customers using our services may be vulnerable and/or in financial difficulty.

Who is classed as a Vulnerable Person?

Vulnerable persons could include (this is not an exhaustive list):-

1. Low literacy, numeracy and financial capability skills
2. Physical disability
3. Severe or long-term illness
4. Mental health problems
5. Low income and/or debt
6. Caring responsibilities (including operating a power of attorney)
7. Being ‘older / old’ for example over 80, although this is not absolute (may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill-health, not being comfortable with new technology)
8. Being young (associated with less experience)
9. Non-standard requirements or credit history (e.g. armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants)

How do we identify a Vulnerable Persons?

Our staff receive regular training to ask our customers questions and to actively listen to responses. A customer may reveal information that suggests that they could be vulnerable (self-identification) or we may recognise certain behaviours which could indicate that a customer is potentially vulnerable.

How do we support Vulnerable Persons?

The FCA believe consumers in vulnerable circumstances need to trust that they will experience the following outcomes when they approach financial services providers: -

• Transparent Products: We provide clear financial products free from hidden "surprises" or complex terms that only surface during a crisis.
• Inclusive Communication: We offer a wide range of contact methods—from web chat and video relay to braille and interpreting services—tailored to your specific needs and schedule.
• Individual Treatment: We treat you as a person, not a data point. We reject "computer says no" mentalities and outdated automated assumptions.
• Tailored Responses: If your circumstances change suddenly, we provide a flexible, bespoke response rather than a rigid, one-size-fits-all approach.
• Empathetic Experts: You will speak with trained staff who take the time to listen, allow for natural conversation, and can refer you to specialists when needed.
• Empowered Decision Makers: When necessary, we refer you to staff with the authority to exercise discretion and offer creative, flexible financial solutions.
• Flexible Outcomes: We go beyond basic forbearance. We offer alternative payment methods, assistance with Power of Attorney, and specialised formats for all documentation.
• Encouraged Disclosure: We foster a safe environment for you to share your needs, ensuring that any information disclosed is used collaboratively to achieve positive outcomes.
• "Tell Us Once" Policy: We record your needs accurately across our systems so you never have to repeat your story to different departments.
• Proactive Support: If we notice signs of financial difficulty or suspicious activity (indicating potential fraud or abuse), we reach out to you directly.
• Support for Carers: We listen to and record the concerns of those in a caring capacity, even when privacy laws limit the information we can share back.
• Consistency in Bereavement: We provide consistent, respectful advice and treatment for those navigating bereavement or managing third-party mandates.

What do V4B Ltd do if we suspect a customer may be in vulnerable circumstances?

We do follow this process to ensure every interaction results in fair treatment and positive outcomes.

Step 1: Identifying Potential Vulnerability
Our staff take active responsibility for spotting signs of vulnerability. This occurs through direct disclosure or via observations during our day-to-day interactions.

How we identify indicators:
Difficulty understanding information or answering questions.
Visible signs of confusion, distress, or anxiety.
Mentions of illness, bereavement, financial hardship, or caring duties.
Memory lapses or difficulty communicating.
Repeated requests for the same explanation.
Unusual behavior or signs of third-party pressure.

Our standard of engagement:
We remain patient, professional, and empathetic at all times.
We allow the customer all the time they need to speak.
We avoid making assumptions or judgments.
We ask open, sensitive questions and actively listen to clarify understanding.

Step 2: Assessing Immediate Support Needs
Once we identify a potential vulnerability, we immediately assess what specific support is required to help the customer navigate our process.

Our active support measures:
We ask the customer for their preferred communication method.
We explain all details using simple, non-technical language.
We provide extra time for the customer to review documents or ask questions.
We confirm understanding before moving to the next stage.
We check if a trusted third party or carer should be involved.
We refrain from applying pressure or rushing decisions.

Note: If a customer is not yet comfortable, we pause the process until they are ready to proceed.

Step 3: Recording Vulnerability Information
When vulnerability is disclosed or identified, we accurately record the details within the customer file and our CRM system after obtaining express permission from the customer to the information we will record.

What we record:
The nature of vulnerability (if disclosed).
Specific support requirements or agreed adjustments.

Preferred communication channels.
Actions taken by staff members.
Whether escalation or lender notification is necessary.

All data is recorded sensitively, factually, and in strict accordance with data protection requirements.

Step 4: Tailoring the Customer Journey
We adapt our approach throughout the entire relationship to ensure the customer is never at a disadvantage.

Our tailored actions:
Providing information in alternative formats.
Allocating additional contact time for meetings or calls.
Breaking complex information into smaller, manageable sections.
Conducting follow-up calls to ensure the customer remains clear on all points.

Signposting customers to external support organizations when relevant.
Ensuring every recommended product is suitable and affordable for their specific situation.

Step 5: Escalation Process
We escalate cases to a Manager or the Compliance Team in specific circumstances to ensure the highest level of protection.

Triggers for escalation:
The customer appears unable to make an informed decision.
There are concerns regarding mental capacity.
The customer is experiencing significant financial difficulty.
There are concerns regarding safeguarding, fraud, or coercion.
A complaint is raised that relates to the customer’s vulnerability.

The Role of Management & Compliance:

They review the case to determine the best path forward.
They liaise with lenders to ensure they are aware of the situation.
They approve exceptional handling or bespoke arrangements.
They guarantee that the customer receives the necessary support to achieve a fair outcome.

Vulnerable Customers Policy (V4B) rev 2026-05
Created by Christine Roberts
Version 4