This policy is designed to ensure that the way we deliver our services has no detrimental impact upon vulnerable Customers. For the purposes of this policy, vulnerable Customers are Customers (existing and potential Customers) whose ability or circumstances require us to take extra precautions in the way that we sell and provide our services to ensure that they are not disadvantaged in any way. This policy outlines our approach to identifying and supporting vulnerable Customers in line with the Financial Conduct Authority (FCA) guidelines.

Vulnerable Customer Definition

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

We recognise that there are key categories of potential vulnerabilities. Whilst not all Customers represented in these categories may be vulnerable, we will consider a Customer’s individual circumstances where a potential vulnerability is identified. These categories may include, but are not restricted to:

• Customer with health issues, whether physical or mental illness, severe or long term.
  
  
• A sudden diagnosis of serious illness to the Customer or close family
  
  
• Personal circumstances of the Customer – factors such as financial difficulties, bereavement, caring responsibilities or redundancy.
  
  
• The Customers age particularly older and younger
  
  
• Low capacity e.g. poor literacy or numeracy skills
  
  
• Customers with communication difficulties (including learning difficulties and English not being their first language, dyslexia).

Wongs Code of Conduct incorporates treating all Customers fairly and with respect. Therefore, when Customers have vulnerable circumstances, we will ensure our sales process and excellence in Customer service provides a supportive experience.

Identifying a Vulnerable Customer

Wongs will ensure that all team members are trained to identify vulnerable Customers and to provide the additional level of assistance they may require in order to achieve a good outcome. However, it is not always easy to recognise these characteristics therefore we will look for common indicators of circumstances where additional support may be required; some examples are:

• Observing changes in behaviour, communication or circumstances for existing

• Listening for cues during interactions e.g. “can’t come into office”; “are there any stairs”.

• Communication difficulties e.g. Customers who are uncomfortable with email or computer or asking for help reading documents.

• Changes in Customer payments by stopping suddenly, late or missed

• Physical indications e.g. shortness of breath or signs of agitation, or mention of medication

• Customer understanding g. asking for repetition (a sign that the Customer is not retaining information), other signs that the Customer has not understood, or signs of confusion.

Supporting a Vulnerable Customer

When we think we may be engaging with a vulnerable Customer we will take appropriate steps to ensure they receive the support they need. This includes:

• Providing clear and simple information
  
  
• Provide additional opportunities for the Customer to ask questions about the information we have provided.
  
  
• Continuously seek confirmation from the Customer that they have understood the information provided.
  
  
• Ask the Customer if there is somebody who is able to assist If not, we will make arrangements to continue with their enquiry in the future.
  
  
• Offer the Customer the opportunity to complete the transaction after a period of further consideration.

If we are unable to help a Customer, we will endeavour to make sure that they understand what alternative options are available to them.

Staff Training and Awareness

All team members will receive regular training on how to identify and support vulnerable Customers. This training will cover:

• Understanding the FCA guidelines on vulnerable Customers

• Recognising the signs of vulnerability

• Effective communication techniques

• Providing appropriate support and solutions.

Monitoring and Evaluation

We will regularly monitor and evaluate our approach to ensure it remains effective and in line with FCA guidelines. This includes:

• Collecting and analysing data on vulnerable Customers

• Reviewing feedback from customers and team members

• Making necessary adjustments to our policies and procedures.

Continuous Improvement

We are committed to continuously improving our approach to supporting vulnerable Customers. We will stay informed about best practices and updates to FCA guidelines and incorporate these into our policy and training programs.