Vulnerable Customers

It is imperative that all our customers receive suitable, affordable and sustainable information. With this in mind, we must ensure that the information given is received and understood by our customers.

Important: It is crucial that at every point of a customer journey, we identify customers that may be particularly vulnerable and use our operating procedures to ensure they receive a consistent approach which takes account of their particular circumstances and meets their particular needs.

Initial Training

All Swift staff complete a unit within initial training on vulnerable customers and particularly vulnerable customers. A workbook is completed and a test taken; incorrectly answered questions are fed back into regular training.

Regular Training

As part of ongoing personal development, cases and customers that have been signposted as particularly vulnerable will be reviewed in order to assess the service we provide to such customers and how this may be optimised.

Further training follows to implement any necessary changes following such review and assessment.

Identifying High-Risk Customers

We aim to deal with identification at the earliest possible opportunity, particularly identifying vulnerable/mental capacity limitations. This is assessed where possible in the first telephone contact with the customer.

Customers that have been identified as a particularly vulnerable customer shall be signposted to Senior Financial Managers who’ve had the relevant training to ensure the needs of the customer are met.

There is an ongoing review of all customers. If at any stage beyond first contact, a customer is identified as particularly vulnerable; action taken on behalf of that customer to review any guidance given and action to date has been appropriate and fully understood by the customer.

Specialist Training for Employees

The compliance team at Swift monitor particularly vulnerable customers and will recommend where it is considered appropriate; that a selection of specialised Senior Financial Managers become designated to deal with all customers who are identified as particularly classification of “Particularly Vulnerable”

The business has identified that individuals within the following groups may be classified as particularly vulnerable:

• People with long term sickness, serious illness or frailty.
• People with learning difficulties or mental health problems.
• People with physical disability.
• People with communication difficulties.
• People with a history of alcohol or drug misuse.
• People subject to recent bereavement.
• Victims of domestic violence.
• The elderly.
• Pregnant women and recent parents.