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The term "vulnerable customer" does not seek to label individuals negatively. It recognizes that vulnerability is a multifaceted and fluid concept. Vulnerability arises from various personal, situational, or market-based circumstances that hinder an individual's ability to access products and services and may expose them to potential harm or disadvantage.

Common conditions or characteristics that may indicate vulnerability include, but are not limited to:

• Chronic illness
• Elderly age
• Unemployment
• Financial distress
• Non-native English speakers
• Hearing or speech impairments
• Intellectual impairments

It is important to note that vulnerability does not necessarily imply a lack of competence or comprehension.

Our staff can identify vulnerable customers by following the CARE protocol:

C - Comprehend: Assess whether the customer can follow the conversation and understand the information being presented.

A - Assess: Determine if the customer can evaluate information and make informed decisions.

R - Retain: Check if the customer can retain and remember information, as well as recall it at a later time.

E - Evaluate: Evaluate whether the customer can effectively communicate their decisions and engage in a two-way conversation.

Additionally, staff may identify signs of vulnerability when:

• Customers appear distressed, agitated, or flustered.
• Customers frequently repeat themselves.
• Customers become easily confused.
• Customers struggle to articulate their queries clearly.
• Customers answer affirmatively to questions that may not be appropriate.
• Customers require extended time to respond to questions.
• Customers request repeated phrases or question repetitions.
• Customers experience difficulty speaking clearly or without syntax errors.
• Customers mention that others used to assist them with such matters.

It is crucial to recognize that signs of vulnerability may not solely stem from physical or intellectual disabilities, as personal trauma or grief can also impact communication.

When communicating with customers known or suspected to be vulnerable or distressed, our staff follows these best practices:

• Practice Empathy: Approach all interactions with empathy and sensitivity to the customer's feelings and experiences.
• Set Expectations: Clearly communicate the purpose and duration of the call or interaction, as well as the information required.
• Inquire About Preferences: Ask customers about their communication preferences, such as the need for interpreters or assistance from caregivers or relatives.
• Active Listening: Dedicate time to actively listen to the customer, avoiding interruptions, and seeking clarification when necessary.
• Clear Communication: Speak clearly and concisely without patronizing or oversimplifying the conversation.
• Validate Emotions: Acknowledge and validate the customer's feelings without reacting negatively.
• Avoid Transfers: Whenever possible, ensure that the same customer service representative handles the entire interaction to minimize frustration and anxiety.
• Ensure Emotional State: Before asking questions requiring consent or decision-making, ensure that the customer is emotionally prepared for the discussion.

When corresponding with vulnerable customers via email, adhere to these guidelines:

• Clarity: Maintain clear and simple communication. If a customer's email appears confused or unsure, consider initiating a phone call for greater clarity.
• Recognizing Vulnerability: Look for indications of vulnerability in their writing style, decision-making, mentions of assistance, expressions of confusion, or repetitive information.

By following these practices, we aim to provide a supportive and respectful customer experience for all, recognizing that vulnerability can manifest in various forms and situations.