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Vulnerable Persons Policy

Introduction

At Citygate Leasing, we are committed to delivering good customer outcomes and ensuring our customers are treated in line with the FCA's rules on Consumer Duty. We understand that some individuals may experience circumstances that make them vulnerable, and we are dedicated to ensuring that these customers receive the support and consideration they need to make informed financial decisions. Our business conduct has been structured to align with Consumer Duty principles, ensuring that vulnerable customers receive clear, transparent and accessible information to make informed decisions. We aim to conduct our business in a way that does not harm or disadvantage vulnerable customers, which is in line with FCA guidelines.

Who Are Vulnerable Customers?

According to the Financial Conduct Authority (FCA), vulnerable customers are individuals who, due to their circumstances, are at greater risk of harm or disadvantage when engaging with financial services. Vulnerability can arise from a variety of factors, such as:

  • Age (older or younger individuals)
  • Disabilities (physical or mental)
  • Mental health conditions
  • Low income or financial difficulties
  • Significant life events (e.g., bereavement, illness, or job loss)
  • Limited English language skills
  • External pressures or coercion

It’s important to note that vulnerability can be temporary, permanent, or fluctuating and that not all individuals within these groups are automatically vulnerable.

Identifying Vulnerable Customers

Recognising vulnerability is vital to ensuring that customers receive appropriate support. Signs of vulnerability might include:

  • Difficulty understanding information or asking repeated questions.
  • Indicating a need for help or support from another person.
  • Displaying confusion or providing inconsistent answers.

Our team is trained to identify signs of vulnerability and take the necessary steps to provide tailored support. However, if you believe you require additional assistance, we encourage you to let us know by contacting us at leasingteam@citygate.co.uk or calling 0330 008 2244. You only need to inform us once unless your circumstances change.

Our Commitment to Supporting Vulnerable Customers

When we identify or are informed about a customer’s vulnerability, we will take steps to ensure their needs are met, including:

  • Adjusting our communication methods (e.g. providing written explanations or involving a trusted third party).
  • Allowing additional time for decision-making.
  • Offering clear and simple explanations to ensure understanding.
  • Ensuring the customer has access to relevant support or resources.

If we feel a customer cannot fully understand the product or service offered, we will pause the transaction and provide further information to support an informed decision.

Mental Capacity and Decision-Making

Mental capacity refers to a person’s ability to understand, process, and act upon information to decide. Some factors that may affect mental capacity include:

  • Mental health conditions
  • Dementia or cognitive decline
  • Learning disabilities
  • Brain injuries or neurological conditions
  • Intoxication (alcohol or drugs)

We will assess each situation carefully and adapt our processes where necessary to ensure fair treatment. If a customer indicates or we suspect they have limited mental capacity, this will not automatically disqualify them from accessing our services. Instead, we will work with them to identify reasonable adjustments and ensure they can make informed decisions.

Examples of Support We May Offer

  • Explaining products and services in simple, jargon-free language.
  • Providing additional opportunities to ask questions.
  • Suggesting the involvement of a trusted friend or family member during discussions.
  • Allowing a cooling-off period to give the customer time to reflect on their decision.

Organisations Offering Assistance

For further support, we encourage customers to contact the following organisations:

Our Pledge to Vulnerable Customers

We are committed to prioritising the needs of all our customers, especially those who may be vulnerable. By listening, adapting, and providing tailored support, we ensure that every customer is treated fairly and with dignity.

If you have any questions or need assistance, please don’t hesitate to contact us at leasingteam@citygate.co.uk or calling 0330 008 2244.