Vulnerability Policy -

Introduction

We want to ensure that we treat all our customers fairly and with respect, including those in vulnerable situations.

This policy sets out our approach when dealing with consumer vulnerability issues, stating methods for identifying consumers who find themselves in a position of vulnerability, and the measures that may be implemented to provide additional support for such individuals.

Even though we are not regulated by the FCA, Our vulnerability policy is in line with FCA guidance, available at https://www.fca.org.uk/publications/finalised-guidance/guidance-firms-fairtreatment-vulnerable-customers (Guidance). All staff members are required to read this policy and Guidance in detail.

In addition, this policy will be distributed to all staff, each to be trained on the areas relevant to their role.

Definition of a vulnerable customer

The Financial Conduct Authority (FCA) outlines a vulnerable customer as ‘someone who, due to their personal circumstance, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care’.

While ‘vulnerability’ is often associated with visible frailty or observable distress, it is often not obvious and can impact individuals at any time, whether it is on a long-term or temporary basis. We believe that the fairtreatment of customers is central to our corporate culture.

Identifying a “vulnerable customer”

The risk of a customer becoming vulnerable is linked to four characteristics that have their own underlying drivers:

1. Health: health conditions or illnesses that affect the ability to carry out day-to-day tasks. This includes physical disabilities, severe or long-term illness, hearing or visual impairments, mental health challenges, and disabilities that result in low mental or cognitive issues.

2. Life events: major life events such as bereavement, job loss or relationship breakdown. Other examples include caring responsibilities, separation or divorce.

3. Resilience: low ability to withstand emotional or financial shocks such as low or inconsistent income, being in debt, low savings, lack of support from family or friends, and low emotional resilience – such as making impulsive financial decisions.

4. Capability: low knowledge of financial matters or low confidence in managing money (financial capability). Examples include low English language skills, and a lack of digital skills.

Likelihood of dealing with consumers that are in a vulnerable position or have characteristics of vulnerability

We expect to encounter a medium-high number of customers with characteristics of vulnerability, but will not target vulnerable customers. [Our target markets are individuals who want to sell their life term policy because it is financially beneficial to them relative to lapsing the policy.

We onlydeal with customers in vulnerable circumstances where we are aware oftheirneeds.

Characteristics of vulnerability in our target market and/or customer base

The vulnerable characteristics most likely to affect our target market or customer base are health, life events, financial resilience and/or capability. However, we understand that characteristics of vulnerability are complex and often overlap. For example, a life event like a relationship breakdown or bereavement may lead to further vulnerability such as mental illhealth or low resilience. This may be made worse if the consumer has low or limited capacity to manage their finances.

Customer 15-Minute Meeting

Customers may request a 15-minute introductory meeting as part of our process. During this meeting, staff should seek and encourage disclosure from customers about potential vulnerability or support needs, and ask for further information.

Some customers may choose to disclose their vulnerabilities directly, such as explaining that they are hard of hearing and therefore phone conversations are difficult. Others may state them indirectly. For example, they might say that they are struggling to read or understand information. Signals staff should look out for include the client:

- Asking unrelated questions
- Repeating themselves
- Appearing distressed
- Sounding flustered or having shortness of breath
- Answering yes to each question raised but not appearing to keep up with the conversation.
- Making statements such as “my partner recently died”, “my partner always dealt with these things for me” or “I have recently lost my job”.
- Mention of medication
- Signs that the client has not understood information that is being provided, or signs of confusion.

These could be some indicators of vulnerability, but this is not designed as an exhaustive list

Whether directly or indirectly disclosed, the client is unlikely to use the word “vulnerability” or understand that they may be classed as “vulnerable”. While we refer to customers as being vulnerable in the policy, staff should not use the term “vulnerable” in interactions with customers. Instead, staff should focus on what harm or disadvantage customers may be vulnerable to and how they can respond appropriately to enhance the client’s customer experience.

During the Meeting [and any other customerinteractions], staff should:

- ensure that customers do not feel rushed into making decisions and must ensure that complex terms and concepts are communicated clearly;
- considerany unusual aspects e.g., if someone else if accompanying a customer, in case there is potential for undue influence from that person;
- explain allmatters with no orlimited use of jargon;
- assess the client against this vulnerability policy; and
- establish whether the client’s stated needs and objectives align with their current circumstances.

Suitability Questionnaire

Prior to entering into any transaction, staff will send the customer a copy of our vulnerability questionnaire to complete. This is our second line stage of vulnerability determination which also addresses the reason for considering selling the policy.

A copy of our vulnerability questionnaire is available to customers on request.

Assessment and Management of Risk

Just because an individual is vulnerable does not automatically mean that they are unsuitable for the services we provide. As soon as we think we may be engaging with a vulnerable consumer, we will make a record of this and ensure that we adhere to this policy.

Generally, when speaking to the vulnerable customer, we will:

- Recognise and respond sensitively to a customer’s needs, including any requirements or preferences to communication (e.g., information in large print, Braille, providing text on coloured paper rather than white paper, etc);
- Provide additional opportunities for customers to ask questions about the information provided;
- Continuously seek confirmation that they have understood the information that has been provided;
- Ask if there is a preference fora third-party familymemberto be present;and
- Offer customers the opportunity to complete the transaction after a period of further consideration.

Please note that the above list is non-exhaustive. We have also set out the following steps for vulnerabilities we view as most likely for our target market:

Risk Identified	Mitigation of Risk
Hearing or visual impairment – or where understanding due to age of the client is slower than usual	An additional meeting or communication would be offered using different formats or channels e.g. use of telephone conversation where possible, or invite family members (or interpreters) to participate in the meeting. Where additional participants are invited, care must be taken for potential undue influence. We would adapt our meeting style and methods of communication in a way that would support the consumer’s understanding. We would also continuously seek confirmation that the customer has understood the information that has been provided at every stage.
Over-indebtedness or erratic income	We would reiterate the need for the customer to seek legal and financial advice, if possible. We may consider involving a third party, and where appropriate, make a referral or recommendation to an appropriate specialist organisation or debt charity.
That all premiums on the Policy are, and at all times not been paid in full and on time, or are not paid up to date	We are of the view that our services are not suitable.
Relationship breakdown, bereavement, heightened stress and anxiety	We recognise that this is likely to be emotionally challenging for the consumer. We would adapt our services accordingly, e.g. adjust our service by offering more time, additional meetings where appropriate, e.g. where the client is not focused on the discussion, and/or invite a third party to support the client. Where additional participants are invited, care must be taken for potential undue influence.
Terminal Illness	We are of the view that our services are not suitable. ‘Terminal Illness’ means having a definite diagnosis by an Attending Consultant of an illness that satisfies both of the following: the illness either has no known cure or has progressed to a point where it cannot be cured; and in the opinion of the Attending Consultant, the illness is expected to lead to death within 12 months. An ‘Attending Consultant’ means a surgeon, anaesthetist or physician who is legally entitled to practice medicine or surgery. They must have attended a recognised medical school and be recognised by the relevant authorities in the country in which any treatment takes place as having a specialism in a particular field.
Incapacitated	We are of the view that our services are not suitable. ‘Incapacitated’ means totally incapable of carrying out your normal occupation by reason of an illness or injury, necessitating medical or surgical treatment and are not carrying out any other occupation or are in gainful employment.

Where a vulnerability has been identified, staff are required to make a general note on the customer’s file to describe the customer’s needs. This general note helps minimise the number of times a customer may inform us of their vulnerability. However, staff are prohibited from recording any of the following data: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data (e.g., details of a terminal illness, etc), sex life and/or sexual orientation.

Staff training and awareness

All staff are required to undertake the ‘Good Outcomes for Vulnerable Customers Course’ provided by Skillcast, available at https://www.skillcast.com/good-outcomes-vulnerablecustomers-course. Our CEO completed this training with a pass-certificate during his first attempt.

Training on topics covered by this policy must be completed by staff every six months, including soft-skills to navigate difficult conversations. We are of the view that open conversations can also lead to consumers self-disclosing other vulnerabilities that may have been missed out by more formulaic questioning.

Vulnerability awareness will form part of staff members ongoing training and competency requirements.

How we will review outcomes

We understand that we need to monitor for trends and understand how vulnerable characteristics may change over time in relation to our target market and customer base.

Our [Customer Support Team]3 will keep a record of any customer feedback received on the whole customer journey to highlight areas where (i) staff performance has led to poor outcomes for vulnerable customers; (ii) customer service processes are not meeting vulnerable customer needs; (iii) we have not fully understood vulnerable customers’ needs; and (iv) our services unintentionally caused harm to vulnerable customers. We aim to learn from experience and improve our support to customers.

This policy will be reviewed on an annual basis following the above quality assurance process.

Third party resources

We can provide links to charities and/or associations which may be able to offer additional support and/or services, such as the Citizens Advice, Department for Work and Pensions, Victim Support, etc.

Referrals

Some vulnerable consumers may be in difficult or crisis situations and it is not appropriate for us to resolve them. Where there is immediate or serious risk to the health or life of the consumer or their family members, we will consider it appropriate or necessary to inform the relevant authorities.

Transparency in our process

Our process is transparent, and we aim to make customers aware of the risks involved in undertaking this transaction across several stages of a customer’s journey. We also take the following steps that complement this vulnerability policy and aim to make our overall customer engagement process more fair and transparent:

1. Withdrawal Option: The customer is able to withdraw from the process at any time prior to entering into an agreement with us.
2. Cooling Off Period: We offer customers a 14-day cooling off period after signing the agreement to change their mind. This is subject to no claims in the period.
3. No financial/health questions upon quote: We do not ask the customer any financial or health questions to determine their quote. Our quotes are based on the experience of the general term insurance insured population, and we do not ask any questions that will give us any indication of their financial/health vulnerability at the quote stage.
4. Refund in case of early claim: In case of any death within 30 days of policy transfer date, we willreturn 25%of the life insurance proceedsback to the owner/estate of the policy.
5. Transparency: One of our core principles as business is to be fully transparent in our dealings with our stakeholders. Customers are the most important stakeholder and at each stage of the journey our staff will be trained to adhere to this core principle.
6. Better Outcomes: At each stage of the process, we aim to ensure that the customer is getting a better outcome relative to the course of action they were originally taking. If at any stage of the process we feel that it is not the case, then we have the discretion to not enter into the relevant transaction.

We do not impose post-sale barriers imposed to change our services, switch provider, submit a claim or make a complaint.