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Vulnerable Customers Policy

1. Purpose and Regulatory Framework

This policy outlines how Deal Drive Motors identifies and supports vulnerable customers in accordance with the Financial Conduct Authority (FCA) requirements, including:

  • FCA Principles for Businesses - Principle 12 (Consumer Duty)
  • PRIN 2A - Consumer Duty (Cross-cutting Rules and Four Outcomes)
  • CONC (Consumer Credit Sourcebook)
  • FCA Guidance FG21/1 - Guidance for firms on the fair treatment of vulnerable customers

Deal Drive Motors is committed to delivering good outcomes for retail customers and ensuring that vulnerable customers are not disadvantaged or exposed to harm throughout the sales and finance process.

2. Definition of a Vulnerable Customer

In line with FCA guidance, a vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly where a firm is not acting with appropriate levels of care.

Vulnerability may arise from one or more of the following drivers:

  • Health - physical or mental health conditions
  • Life events - bereavement, relationship breakdown, job loss
  • Resilience - low financial resilience or over-indebtedness
  • Capability - low financial literacy, learning difficulties, language barriers

3. Our Commitment Under Consumer Duty

Deal Drive Motors will act to deliver good customer outcomes by:

  • Acting in good faith toward customers
  • Avoiding foreseeable harm
  • Enabling and supporting customers to pursue their financial objectives

We ensure our products and services are designed, distributed, and communicated in a way that meets the needs of our target market, including customers in vulnerable circumstances.

4. Identifying Vulnerability

All customer-facing staff are trained to recognise indicators of vulnerability, including:

  • Difficulty understanding information
  • Signs of confusion, distress, or anxiety
  • Disclosure of financial hardship
  • Health-related disclosures affecting decision-making

Staff will record relevant information sensitively and in compliance with data protection legislation.

5. Supporting Vulnerable Customers

Where vulnerability is identified, we will, where appropriate:

  • Allow additional time for explanation and decision-making
  • Use clear, plain, and non-technical language
  • Avoid pressure selling or inappropriate upselling
  • Provide written documentation for later review
  • Permit a trusted third party to be present
  • Consider alternative communication methods where necessary

6. Staff Training and Competence

All relevant staff receive initial and annual refresher training covering:

  • FCA Consumer Duty requirements
  • Identification of vulnerability
  • Appropriate communication techniques
  • Record keeping and data protection obligations

7. Monitoring, Governance and Review

Senior Management is responsible for oversight of this policy. We will:

  • Monitor customer outcomes and complaints data
  • Review sales and finance processes for fair treatment
  • Update this policy in line with regulatory developments
  • Conduct an annual formal review

8. Contact Details

Deal Drive Motors
Roadside Retail Park
Skippers Lane
Middlesbrough
TS6 6UU