Vulnerable Customer Policy

VULNERABLE CUSTOMER POLICY & PROCEDURE

Coche Conexion Ltd trading as Car Connection and One EV

1. Statement

Coche Conexion Ltd is fully committed to identifying, assessing and managing vulnerable customers in accordance with our internal governance framework, policies and procedures, and in line with the rules, principles and guidance issued by the Financial Conduct Authority (FCA).

We are committed to ensuring that all customers, including those identified as vulnerable, are treated fairly, consistently, respectfully and with appropriate levels of care, in line with the FCA's expectations and the principles of Consumer Duty.

The Company has implemented robust identification, assessment, escalation and management controls within this policy to ensure that vulnerable customer situations are handled consistently, proportionately and appropriately, and that all staff are trained, confident and supported in responding to such circumstances.

2. Purpose

The purpose of this Vulnerable Customer Policy & Procedure is to:

  • Identify and support customers who may be vulnerable
  • Promote transparency, fairness and good customer outcomes
  • Embed vulnerability awareness across all business practices and processes
  • Ensure compliance with FCA requirements, Consumer Duty and relevant legislation

This policy defines the steps to be taken by all staff when dealing with a vulnerable customer situation and ensures that customers receive products and services that are suitable, ethical, appropriate and in their best interests, taking account of individual circumstances.

3. Scope

This policy applies to all employees, contractors and representatives of Coche Conexion Ltd and covers all stages of the customer journey, including but not limited to:

  • Marketing and advertising
  • Sales and point of sale interactions
  • Credit broking and finance introductions
  • Complaints handling
  • After-sales and post-contract support

The policy has been designed to ensure ongoing compliance with legal, regulatory, contractual and business requirements and forms part of the Company's wider governance and risk management framework.

3.1 Definition of a Vulnerable Customer

a) Customers unable to make an informed decision

A vulnerable customer may be someone who, due to personal circumstances, is unable to make a fully informed decision at the time of dealing with the Company. This may include, but is not limited to, customers with:

  • Language barriers
  • Hearing or visual impairments
  • Mental health conditions
  • Learning difficulties
  • Cognitive impairments
  • Age-related vulnerabilities
  • Customers experiencing bereavement or emotional distress

Such customers may experience difficulty understanding information, assessing risk or determining whether a product or service is suitable for their needs.

b) Customers whose welfare may be at risk

This includes customers whose financial, mental or physical wellbeing may be adversely affected by engaging with the Company's products or services, including circumstances where taking credit could lead to financial hardship or distress.

FCA Definition

The Financial Conduct Authority defines a vulnerable customer 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.”

The FCA identifies four key drivers of vulnerability:

  • Health - physical disability, chronic illness, mental health conditions, impaired capacity
  • Life Events - bereavement, caring responsibilities, job loss, relationship breakdown, refugees or ex-offenders
  • Resilience - low or unstable income, over-indebtedness, lack of savings or support networks
  • Capability - low financial literacy, language barriers, learning difficulties

4. The Consumer Duty

Vulnerable customer awareness is fundamental to treating customers fairly and achieving good outcomes.

In accordance with Consumer Duty (PRIN 2A), Coche Conexion Ltd has assessed the nature, scale and characteristics of vulnerability within its target market and business activities.

Customer interests are considered throughout the entire customer journey, including product and service design, marketing, sales, contractual terms, after-sales support and post-contract communications.

Where vulnerability is identified, the Company takes reasonable and proportionate steps to mitigate the risk of harm and support positive customer outcomes.

4.1 Equality Act 2010

The Company recognises its obligations under the Equality Act 2010 and is committed to ensuring that customers with protected characteristics are not disadvantaged.

Policies, processes and controls are designed to ensure that such customers receive fair treatment, reasonable adjustments where appropriate and access to suitable support.

5. Objectives

The Company aims to:

  • Maintain effective and compliant vulnerable customer controls
  • Identify and respond appropriately to vulnerability indicators
  • Provide ongoing staff training and guidance
  • Ensure communications are clear, accessible and jargon-free
  • Monitor outcomes to ensure customers are not disadvantaged
  • Continuously review and improve processes where required

6. Controls and Measures

6.1 Vulnerable Awareness Review

The Company regularly reviews its customer base, target market and processes to identify potential risks or barriers for vulnerable customers.

Where vulnerability is identified, appropriate steps are taken to adjust communication, pace, support or escalation to ensure fair outcomes.

6.2 Signposting

Where appropriate, customers may be signposted to internal or external support organisations, including:

  • National Debtline - https://www.nationaldebtline.org
  • Samaritans - https://www.samaritans.org
  • StepChange - https://www.stepchange.org
  • Alzheimer's Society - https://www.alzheimers.org.uk
  • RNIB - https://www.rnib.org.uk
  • RNID (Action on Hearing Loss) - https://www.rnid.org.uk

6.3 Communications

The Company recognises that effective communication is essential to achieving good outcomes for vulnerable customers.

Multiple communication channels are available and no customer will be forced to use a single method where this may cause distress or disadvantage.

Communication methods include, but are not limited to:

  • Website
  • Email
  • Telephone
  • SMS / WhatsApp
  • Marketing materials
  • Complaints handling processes
  • Point of sale documentation
  • Contracts and agreements
  • After-sales and post-contract communications

All information is presented in a clear, accessible and understandable format, allowing customers sufficient time to consider decisions.

7. Responsibilities & Governance

Coche Conexion Ltd ensures that all staff are provided with sufficient training, resources and time to understand and implement this policy effectively.

Senior Management is responsible for ensuring a top-down culture of compliance, fairness and accountability.

Conor O'Shaughnessy, Director, holds overall responsibility for oversight of Vulnerable Customer arrangements, including:

  • Policy ownership and review
  • Monitoring and assurance
  • Gap analysis and remedial actions
  • Ongoing governance and reporting

An appropriate audit trail and record-keeping framework is maintained to evidence compliance, decision-making and continuous improvement.

Commitment

Coche Conexion Ltd recognises that vulnerability can affect any customer at any time.

We are committed to ensuring that our products, services and interactions are fair, inclusive, flexible and accessible, and that all customers are treated with dignity, respect and care at all times.