Understanding Vulnerability Cosmo Graham and Linda Lennard, Centre for Consumers and Essential Services (CCES)

Reality of vulnerability Utility legislation took “group” approach CCES argued that this approach outdated Too rigid, under and over inclusive Ofgem first regulator to revise approach Consumer vulnerability strategy 2013 Since taken up by Financial Conduct Authority (2015) and other regulators Also trade associations Ofgem now looking to develop enforceable principles

Understanding vulnerability – who is at risk? Nearly all of us Constellation of risk factors Short term or fluctuating Or long-lasting and cumulative `Vulnerable consumers’ aren’t a separate group

Some numbers 10.8 million in poverty in 2014 in UK ~ 4 million in persistent poverty 11 million disabled people in Britain 6.5 million carers in UK Hidden issues: literacy or numeracy difficulties Multi-dimensional: many are dealing with multiple risk factors Poverty statistics from ONS: https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/incomeandwealth/articles/persistentpovertyintheukandeu/2014 assuming 64.1 million population

Thinking about vulnerability Changes in circumstances: stuff happens Multiple risk factors Not just about personal situations: the role of markets and companies Barriers to complaining

Key challenges for Ombudsman Accessibility! Training staff – active listening Getting the whole organisation on-board Reviewing, learning and improving Good networks – including people at risk of being marginalised Sharing insights and lessons Be prepared to influence and intervene to change company behaviour – using all available routes

Inclusive service Design for all rather than special schemes Consistent with Equality Act obligations Organisational commitment Openness, planning and scrutiny Organisational learning

Contact details Centre for Consumers and Essential Services, Leicester Law School, University of Leicester LE1 7RH United Kingdom Tel: 44 (0)116 252 2363 E-mail: cosmo.graham@Leicester.ac.uk Web: http://www2.le.ac.uk/departments/law/research/cces