Vulnerability Policy

The Financial Conduct Authority (FCA), who are the UK’s financial conduct regulator have defined vulnerability as “A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.”. 

In practice, this can arise from a wide variety of different factors, some of which are detailed below: 

 

• limited literacy, numeracy and financial capability or skills 

• physical disability 

• mental health issues 

• severe and/or long-term illness 

• low income and/or debt 

• the natural ageing process causing impairment of cognitive functions, sensory impairments such as of hearing or sight, onset of ill-health, and simply not being comfortable with using new technology 

• changes in personal circumstances, such as redundancy or divorce 

• major life events, for example a bereavement 

• limited English language skills 

 

What is also important to recognise as a financial services provider is that customer vulnerability can either be permanent and stable or it can be fluid and fluctuate.   Therefore, if we begin working with a customer and we have deemed there not to be any vulnerability factors, that does not mean that they cannot become relevant at a later point in the customer journey.  Equally, where a customer has disclosed information to us which would be deemed as a vulnerability factor, then depending on the nature of the disclosure, we should also bear in mind that this can change in the future too. 

 

The jsp credit management Approach 

The purpose of this policy is to provide a standard, to which each and every employee of jsp credit management is expected to work with vulnerable customers.  This policy includes any external stakeholders that may interact with any of Zhuī Lóng Zhài’s customers, such as partners, contractors or sub-contractors.  jsp credit management's approach to everything it does is underpinned by its core values.  These are: 

 

• Open-Minded  

• Honesty  

• Ambition  

• Humility  

• Diversity 

 

Every single one of these core values inform the way that we should approach customer vulnerability.  Our view of the way these core values inform out our approach to customer vulnerability is detailed below. 

 

Open-Minded 

jsp credit management does not make assumptions about people.  Our approach should be open-minded to any circumstance or factor that might challenge unconscious bias about who people are and how they should behave.  Our role in our industry is not to judge people for the choices they make, and this approach should result in a positively curious approach by all staff when dealing with customers to learn about their circumstances.   

 

However, as a registered Data Controller, jsp credit management is legally obliged to ensure that is compliant with Data Protection Act 2018 and UK GDPR regulations.  This means that we understand that customers have a fundamental right to privacy and that they have a right to control over their own identity.  Therefore, our enquiries must be handled delicately and sensitively without being forceful in our approach to capturing the information we need from our customers to apply this policy. 

 

Honesty 

We must understand that as a financial services provider we are duty bound to put in place measures, processes and training to be able to identify and appropriately manage a customer who might be deemed as vulnerable.  A part of this includes an understanding that a customer who has been deemed as vulnerable should be given an even greater level of attention and forbearance to pay for their debts.   

 

Therefore, as a company it is critical that we do not allow other commercial goals to interfere with or take precedence over this regulatory requirement at any time.  Our approach should be one which makes consideration of customer vulnerability a priority in everything that we do.  This requires a level of honesty internally in the way we prioritise our approach to work, and it also requires no compromise on honesty with customers who should be offered our fullest support where appropriate. 

 

Ambition 

As a company, we should aspire to do our best for our customers who find themselves in a position of vulnerability for whatever reason.  All staff should take the view that our obligations to comply with this policy extend far beyond a regulatory requirement to do so.  We also have an opportunity to make a huge difference to customers who may be presenting issues of vulnerability to help them return to a position of a financial stability and security if we ensure our approach is compliant with this policy.   

 

jsp credit management understands that viewing and assuming customers are average can be counter-productive to our commitment to customer vulnerability.  Much in the same way that we as a business do not want to be average.  Our ambition as a company is to become a leader in the credit management industry in the way that we approach customer vulnerability and with each staff member working in alignment with this policy within a company that is underpinned by psychological values, we are well positioned to do that. 

 

Humility 

As a financial services provider that operates in the credit management industry, it would be poor judgement of us not to recognise that power imbalances exist between the various parties that we will usually interact with in our day-to-day work.  Laws, legislations, regulations, codes of conduct all exist which affect what we can and cannot do but also serve as mechanisms through which power imbalances can be struck.  It is our duty to ensure that these imbalances are not abused irresponsibly. 

 

Every staff member that works for jsp credit management is introduced to our core values as a business during their induction.  Humility to us is more than a set of beliefs or a feeling that everybody should be given equal opportunity to achieve financial stability and security again regardless of their circumstances.  It needs to be reflected in our actions too and further along in this policy some practical requirements will be offered that all staff are expected to abide by in to ensure this is respected and the risks of causing harm to our customers is minimised. 

 

Diversity 

It is well grounded in psychological theory that as human beings it is inherent within us to gravitate towards other people with whom we feel that we share an aspect of our identity with.  This aspect of identity could be our sexual identity, biological gender, race, nationality, socioeconomic status, social status, disability or ability, sexual orientation, or even hobbies and interests.  This can have the problematic effect of viewing people that does not belong to the same group as you less favourably. 

 

When we interact with customers that might be viewed as people who do not belong to a group that you have chosen to identify yourself with it is essential that this does not result in them being treated less favourably in any way.  We should remain vigilante at all times of the potential for, sometimes even unconsciously, treating somebody less favourably because of issues of diversity.  If you have concerns about your ability to comply with this then you are encouraged to discuss this with your supervisor. 

 

Practical Steps We Take When Dealing With Vulnerable Customers 

 

1: Listen to them – really listen to learn their real situation. The phone will work better than any other medium so use it if you can. 

 

2: Be timely – we need to keep our customers informed but don’t overload them. Find times that suit them for a catch up rather than bombard them with emails. 

 

3: Suspend process-driven responses – if you’re able, avoid letting the usual dunning runs or automated messaging go out. It will only add to their stress. 

 

4: Instil confidence that resolution is possible – Use positive language and work collaboratively to find solutions. 

 

5: Be creative – Finding new solutions to unprecedented situations will require new ways of working. Now’s the time for the ultimate blue-sky thinking. 

 

6: Signpost to others – We don’t have all the answers straight away and that’s ok. Build a network of colleagues and organisations who you can refer the customer to if you need to. 

 

7: Let technology help – self-service orders and automated payment processes can alleviate pressure. If you and your customer are working from home there may be teething troubles, so be prepared for this. 

 

8: Simplify – rapid changes call for constant shifts in approach. Try to keep any new processes as simple as possible for the customer to understand and apply. 

 

9: Keep it personal – your customer is receiving an influx of generic communications. We need to be different. In all communications, show your personality, share your concerns, appeal to their heart. 

 

10: Be kind – in this time of stress and uncertainty, it will go a long way. 

 

 

Further Advice 

Our systems have been designed so they can prompt disclosures of vulnerability from our customers.  Our online debt collection instruction webform specifically asks this question from our clients so we should be mindful of this information when new cases to you to work on.  We also invite our customers to discuss ways we can support them in our first letter to them.  However, the absence of disclosures through these measures does not mean we can safely conclude that vulnerability factors do not exist and we should remain open-minded to that possibility throughout the customer journey. 

 

Our vulnerability policy is critical to jsp credit management’s ability to operate in the industry that we do operate in.  Therefore, any deviations from this policy by any of our staff when interacting with our customers will be investigated and treated extremely seriously.  If any employee, partner, contractor or sub-contractor is found to have willfully ignored this vulnerability policy in their conduct for the company then this will lead to disciplinary action, up to dismissal for gross misconduct or termination of our contract with them with immediate effect.