Vulnerable Customer Policy

1. Our Commitment

UK Energy Management Group Ltd ("UKEM") is committed to treating every customer fairly. Some customers may be in circumstances that make them more likely to suffer harm if we do not take extra care. This policy explains how we identify those customers and how we adapt the way we deal with them during the sales and finance process.

This policy reflects the Financial Conduct Authority's guidance on the fair treatment of vulnerable customers (FG21/1) and applies to everyone who contacts us about our products, finance arranged through us, or both.

2. Who We Consider Vulnerable

Anyone can find themselves in vulnerable circumstances at some point in their lives. We follow the FCA's four drivers of vulnerability:

• Health: physical disability, severe or long-term illness, hearing or sight impairment, mental health conditions, or low mental capacity.
• Life events: bereavement, relationship breakdown, job loss, becoming a carer, or other major changes.
• Resilience: low or unstable income, debt, or limited ability to absorb a financial shock.
• Capability: low knowledge or confidence with financial matters, low literacy or numeracy, poor English, or being a first-time buyer of an unfamiliar product.

A customer may show one of these factors, several at once, or none of them but still need extra support. We do not require a customer to label themselves as vulnerable to receive it.

3. How We Identify Vulnerability

Our staff are trained to listen for signs that a customer may need extra help. These can include things the customer tells us directly, signs of difficulty understanding information, requests to repeat or rephrase information, hesitation around finance or affordability, or third parties stepping in to help with the conversation.

If a customer tells us about a vulnerability, or we identify one during a call or appointment, we record it on the customer's file so that everyone who deals with the customer afterwards is aware, with the customer's consent.

4. How We Respond

Where a customer is in a vulnerable circumstance, we will adapt our approach. Depending on the situation, this may include:

• Allowing extra time to consider information and decisions, with no pressure to commit.
• Offering to talk things through with a family member, carer, friend, or other trusted third party (with the customer's consent).
• Providing information in larger print, plain English, or by another method that suits the customer.
• Pausing or postponing the sales process if a customer is distressed, unwell, or otherwise unable to engage fully.
• Declining to proceed with finance, or with a sale, if we are not satisfied that the product or finance is suitable for the customer's circumstances.
• Signposting to independent guidance (for example, MoneyHelper, Citizens Advice, or the customer's lender) where appropriate.

5. Pressure-Free Selling

Our staff and any third parties acting on our behalf are not permitted to use high-pressure sales techniques. A customer can ask for a quote, take time to think, and walk away at any point before contracts are signed without any consequence.

Where finance is involved, affordability and suitability checks are carried out by the lender. We will not encourage a customer to take finance that they have indicated may be difficult for them.

6. Training and Review

All customer-facing staff receive training on identifying and supporting vulnerable customers as part of induction and at regular intervals afterwards. We review this policy at least once a year, and sooner if our products, processes, or applicable guidance change.

7. Contact

If you would like to tell us about a vulnerability, ask for information in a different format, or raise a concern about how we have treated you, please contact our customer care team:

• Telephone: 0800 222 9494
• Email: customercare@ukem.co.uk
• Post: Customer Care, UK Energy Management Group Ltd, 6 Crown Road, Quay West Business Village, Sunderland, SR5 2AL

If you are not satisfied with how we have responded, you can use our Complaints Procedure.