1. SUMMIT INSURANCE SERVICES LIMITED'S APPROACH TO CONSUMER VULNERABILITY

4. FCA Research Shows -

5. OUR POLICY SIS believe that in order to ensure a consistent approach is applied throughout its operations it is critical to have a high level policy on consumer vulnerability in place. SIS Must –  Be clear and easy to understand, both in policy terms, and all communication with consumers.  Select the most suitable way to communicate with each consumer and tailor our responses accordingly.  Treat all consumers as individuals and take in to account their own needs and circumstances.  Be flexible whenever possible, and adapt our approach to the customers situation within the policy limits.  Listen and take note of the customers concerns, be sympathetic and try to resolve the issue, if this is not possible always refer it to someone more senior.

6. SIS Are Committed To Providing The Following – Our policy on consumer vulnerability will be simple and straightforward. Our staff will be empowered to use discretion and a flexible attitude towards consumer needs as far as possible. We will communicate effectively internally and with our partners to avoid customers repeating instructions or complaints to multiple people. We will avoid automated services and customers will always speak to fully trained members of staff within the UK. Policy wording and literature that is always clear fair and not misleading. That jargon and complicated terms will be avoided wherever possible. Our product will not be inflexible, and will not be designed solely for a standardised perfect customer. We will tailor our prices to ensure that they are affordable for people even in non standard situations.

7. Key Risk Factors That We Need To Be Aware Of -  Low literacy, numeracy and financial capability skills  Physical or mental disability  Low income families  Lack of English language skills This is not an exhaustive list, but are the areas of vulnerability that we are most likely to come across. Vulnerability can come in a range of guises, and can be temporary, sporadic or permanent in nature. It is a fluid state that needs a flexible, tailored response from firms.

8. Vulnerability Statistics:  More than 8.9 million people are deaf or hard of hearing (RNID, 2010).  About 2 million people in the UK have significant sight loss (RNIB, 2008).  One in seven adults has literacy skills that are expected of a child aged 11 or below (Department for Business, Innovation and Skills, 2012).  Just under half of UK adults have a numeracy attainment age of 11 or below (Department for Business, Innovation and Skills, 2012).  1.5 million people have some form of learning disability. (Foundation for People with Learning Disabilities).  Six and a half million people in the UK have significant caring responsibilities. According to the Carers UK project this will reach 9 million by 2037. One in eight adults care, unpaid, for family and friends (Carers UK, 2014).