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Vulnerable Customer Policy Statement

Fair treatment of customers is central to Clements core conduct. We put customers at the heart of everything that we do, focus on delivering good customer outcomes.

Clements Worldwide has a Vulnerable Customers policy which is designed to ensure that the way in which we conduct our business does not have a detrimental impact upon vulnerable customers.

For the purpose of this policy statement a Vulnerable Customer is someone who due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.

Any person can become vulnerable due to a sudden change in circumstances. There are many factors which act as drivers to actual or potential vulnerability such as;

• Health conditions or illness that affect the ability to carry out day to day tasks.
• Major life events such as bereavement or relationship breakdown.
• Resilience and/or low ability to withstand financial or emotional shocks.
• Low knowledge of financial matters or low confidence in managing money.

We aim to treat vulnerable customers fairly through the following measures: 

1. Ensuring a consistent approach across operations when dealing with vulnerable customers.
2. Providing clear information to customers before, during and after sales to help the customer’s understanding and ability to make effective, timely and properly informed decisions.
3. Ensure that we do not exploit customer’s behavioural biases, lack of knowledge or characteristics of vulnerability.
4. Ensuring that systems and processes are flexible allowing staff to manage situations with empathy.
5. Identifying and training staff on the factors that could establish someone as a vulnerable customer, such as risk factors which can include bereavement, illiteracy, illness, disability or other impairment.
6. Ensuring affordability questions are followed, as set-out by Close Premium Finance.
7. Ensuring our supervisors and management are available to help front-line staff identify a vulnerable customer and how to process this on the company’s internal systems.
8. Referring vulnerable customers to organisations that can offer specialist advice to the customer.

Identifying a Vulnerable Customer

Our staff are trained to identify vulnerable customers and to provide the additional level of assistance they may require in order to achieve a good outcome. However, it is not always easy to recognise these characteristics. Therefore, if you believe you meet the criteria for a vulnerable customer, please read this statement and notify us as soon as possible of your particular needs. You are encouraged to do this when you first contact us.

Our Principles When Engaging with a Vulnerable Customer

As soon we think we may be engaging with a vulnerable customer, whether this is through our identification or you are approaching us, we will:

• Immediately make a record of this and ensure we adhere to Clements’s policy.
• Provide additional opportunities for you to ask questions about the information we have provided.
• Continuously seek confirmation that you have understood the information that has been provided.
• Ask if there is anybody with you who is able to assist. If not, and we believe this will be beneficial, we will make arrangements to continue with the subject matter at another time.
• Offer you the opportunity to complete the transaction after a period of further consideration.
• Provide external help if required.

If we can’t help a customer, we will try and make sure that they understand what alternative options are available to them.

How To Contact Us

You can contact Clements for more information or to make us aware of your needs by calling one of our phone numbers listed blow or emailing compliance@clements.com or enquiries@clements.com.

Washington, DC

Clements & Co.

1220 L Street NW, Suite 1200
Washington, DC 20005

+1.202.872.0060

+1.800.872.0067 info@clements.com

London, UK

Clements Europe Limited*

1st Floor
67 Lombard St
London
EC3V 9LJ

+44(0) 33.0099.0104 europe@clements.com

Gibraltar

Unit 243.01
World Trade Center
6 Bayside Road
Gibraltar, GX11 1AA

+00350 57826000

+00350 54716000 europe@clements.com

Dublin, Ireland

Alexandra House
3 Ballsbridge Park
Ballsbridge, Dublin 4
Dublin, D04 C7H2, Ireland

International: +353 1 9645098

In Ireland: +1800 44 99 33 ireland@clements.com

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