VULNERABLE CUSTOMER POLICY - OVERVIEW

The purpose of this policy is to ensure that Giomani Designs Limited is treating vulnerable customers fairly. We are committed to identifying, assessing and managing vulnerable customers in accordance with our own defined objectives and policy, as well as any regulations and guidelines set out by our regulators. We aim to treat all customers, whom we define as being vulnerable, in a fair, clear and respectful manner.

Our promise is to treat all our customers fairly, and when dealing with people with any vulnerability, we will take account of such vulnerability to ensure that the way that we sell and provide our services does not cause them detriment. 

VULNERABLE CUSTOMER - DEFINITION

The FCA defines a vulnerable consumer as ‘someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care’.

VULNERABLE CUSTOMER - SPECTRUM

For the purposes of this policy, vulnerable customers are existing and prospective customers whose ability or circumstances require us to take extra precautions in the way that we sell and provide our services to ensure that they are not disadvantaged in any way. This can include:

• Customers with any form of disability
• A customer with personal circumstances i.e. financial difficulties, redundancy, bereavement, serious illness
• A customer with any illness, either physical or mental illness
• A customer’s age - in particular older and younger people
• Customers with communication difficulties (including speech impediments or language barriers)
• A customer with a reduction in physical or mental capacity

IDENTIFICATION

Due to our business model and very limited interaction with the customer directly, our teams will try to identify vulnerable customers when we interact with them directly to allow us to take extra steps to assist outside of our standard procedures. This will include asking questions, looking for indicators and providing customers multiple opportunities to declare any vulnerabilities.

However, it is not always possible to recognise these characteristics. Therefore, we urge customers to make us aware if they feel that they may fit the criteria for a vulnerable customer. This may or may not include any of the above. Therefore, if you believe you may fit the criteria for a vulnerable customer, please read this policy and notify us immediately of your needs.

Our teams have access to FCA guidance (https://www.fca.org.uk/publication/finalised-guidance/fg21-1.pdf). We also ask everyone to read the guidance provided identifying vulnerable customers and how best to treat them. 

MAKING ADJUSTMENTS TO OUR SERVICES

Where possible, we will adjust the services that we offer and commit to taking extra steps beyond our normal sales process to try and seek alternatives or point customers to where they can best seek a solution. This adjustment is based on the personal situation of each customer. As soon we think we may be engaging with a vulnerable customer, either by identifying ourselves or a customer has told us, we will endeavour to offer some of the following solutions:

We will try and provide larger-scale print information, read-aloud options for crucial information.

We will controlled outbound contact times, including visitation by our delivery teams.

We provide extra opportunities for you to ask questions or seek further confirmation about the transaction or service we are providing. 

We will continuously seek confirmation that you have understood the information, especially in cases of customer finance applications for example.  If we or you feel it necessary, we may ask if there is anybody with you who can assist you, such as a family member or friend.  

The main rule is that we won't rush. We will always offer extra opportunities to complete a transaction after further consideration and as much time as you need.

This is in reference to the furniture products we provide; as we do not directly offer financial products, the finance provider, V12, will also provide additional adjustments to the finance service.