Vulnerable Customer Policy
- Policy Statement
Friends Jewellers (Retail) Ltd is committed to the fair, transparent, and ethical treatment of all customers, including those who may be identified as vulnerable. We recognise that certain customers may experience circumstances that limit their ability to make fully informed decisions, and we are committed to ensuring that such individuals are treated with sensitivity, dignity, and integrity at all times.
- Purpose
The purpose of this policy is to:
- Establish a clear framework for the identification and fair treatment of vulnerable customers.
- Ensure that all business practices are aligned with principles of consumer protection, ethical retailing, and applicable regulatory requirements.
- Mitigate the risk of consumer detriment arising from the exploitation, misunderstanding, or undue influence of vulnerable customers.
- Scope
This policy applies to all employees, contractors, and representatives of [Your Business Name] engaged in sales, customer service, or related activities.
- Definition of a Vulnerable Customer
A vulnerable customer is defined as an individual who, due to personal circumstances, may be less able than a typical consumer to:
- Understand the information presented in the course of a sales transaction.
- Make an informed purchasing decision.
- Resist undue influence or pressure.
- Act in their own best interests.
Circumstances that may give rise to vulnerability include, but are not limited to:
- Age-related factors (e.g., elderly or very young customers).
- Mental or physical disability.
- Serious or long-term illness.
- Language or literacy barriers.
- Recent bereavement or emotional distress.
- Financial hardship.
- Dependence on third parties for decision-making.
- Principles of Conduct
All employees are required to uphold the following principles when engaging with vulnerable customers:
- Fairness and Transparency – All product and service information must be presented in a clear, accurate, and accessible manner.
- Respect and Dignity – Customers must be treated with patience, courtesy, and sensitivity at all times.
- No Undue Pressure – Staff must not engage in high-pressure sales tactics or exploitative behaviours.
- Informed Consent – Customers must be given adequate time and opportunity to consider their purchase before committing.
- Safeguarding – Where there are reasonable concerns that a customer is at risk of financial or other harm, staff must escalate the matter to management and, if appropriate, decline to proceed with the transaction.
- Staff Responsibilities
All employees must:
- Be vigilant in recognising indicators of vulnerability.
- Adapt communication and service delivery to meet the needs of the customer.
- Offer customers the opportunity to involve a family member, friend, or trusted representative in the decision-making process where appropriate.
- Document interactions with vulnerable customers where necessary to ensure transparency and accountability.
- Escalate concerns promptly to a manager or designated safeguarding officer.
- Training and Awareness
- All customer-facing staff will receive mandatory training on identifying and supporting vulnerable customers.
- Refresher training will be conducted on an annual basis, or as required.
- Training records will be maintained to demonstrate compliance.
- Record-Keeping
- Instances where a customer is identified as vulnerable, and any related decisions (including the refusal of a transaction), must be recorded in accordance with company procedures.
- Records will be retained securely and in line with data protection obligations.
- Monitoring and Review
- Compliance with this policy will be monitored by management through audits, customer feedback, and staff reporting.
- This policy will be formally reviewed on an annual basis, or sooner if required by regulatory changes or operational needs.
- Approval
This policy has been reviewed and approved by the Board of Directors of Friends Jewellers (Retail) Ltd and is effective from 1st January 2021