Document Owner: Buckingham Leasing Limited

Purpose

This policy details how Buckingham Leasing will identify and manage vulnerable customers and ensure a
consistency of approach within the firm.

Buckingham Leasing is a finance broker specialising in helping customers to obtain finance on agricultural
purchases. We work with customers looking to purchase equipment on hire purchase or personal contract purchase
with companies selling assets. We help customers in choosing the right product for their personal circumstances
and budget. Most of our business is un-regulated with some regulated customers; once authorised by the FCA, we
will look to provide finance solutions to individuals, sole traders and small partnerships. The company also
offers a lender service to customers who fit the criteria detailed in section 6 of this document.

As a result, our target does not present specific vulnerability traits of:

• Physical disability or impairment (if not defined as a disability under the Equality Act 2010)
• Severe or long-term illness
• Mental health problems
• Change in circumstances (e.g. bereavement, divorce)
• Non-standard requirements or credit history

However, should we identify a vulnerable person, staff will raise this with our management team in line with
this policy. We can provide simple ideas and “point them in the right direction” if we recognise the person who
has made the initial contact shows signs of vulnerability.

According to the FCA’s definition, a vulnerable customer is someone who due to their personal circumstances is
especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. It
applies to the supply of products or services to retail customers who are natural customers, even if a firm does
not have a direct client relationship with the customer.

Buckingham Leasing embeds the fair treatment of vulnerable customers as part of our compliance culture
throughout the firm, not just on the frontline but also in areas such as product development. Our management
body is committed to create and maintain a culture that enables and supports staff to take responsibility for
reducing the potential for harm to vulnerable customers.

This policy has been written following FCA “Finalised Guidance 21/1 (FG21/1) – Guidance for firms on the fair
treatment of vulnerable customers” (February 2021) and considering the requirements established in the FCA’s
Principles for Businesses and the Consumer Duty.

Review of Policy

This policy will be reviewed regularly, at least once a year, and amended as considered necessary by Buckingham
Leasing’s Management Body in the event of changing circumstances or regulations.

Responsibilities

Management Body

Our directors are required to ensure that all employees are aware of the firm’s policy on identifying and dealing
with customers who may be vulnerable, be it on a temporary or a permanent basis. Buckingham Leasing will
provide training and support to assist employees in handling vulnerable customers.

Our culture is transparent and open; we actively encourage our staff to talk about any issues that they are
experiencing. Management has regular “catch-ups” with staff members to ensure there are no underlying concerns
when the staff member have been dealing with a vulnerable situation during their work. In addition, there is an
open-door policy and all staff know they can access our management team at any time.

Employee Responsibilities

On joining the firm, employees will complete a Vulnerable Customers online training to make themselves aware of
our firm’s approach to identifying and dealing with customers who may be vulnerable. They are also required to
read this policy to ensure they are aware of our internal procedures for dealing with vulnerable customers.

Where a customer has been identified as vulnerable, the employee will ensure that they follow the requirements
set out in this policy and manage the customer relationship accordingly.

Vulnerable Customers

The FCA’s definition of vulnerability refers to customers who, due to their personal circumstances, are
especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. Firms
should think about vulnerability as a spectrum of risk. All customers who are ‘natural customers’ are at risk of
becoming vulnerable and this risk is increased by characteristics of vulnerability related to four key drivers:

• Health – health conditions or illnesses that affect ability to carry out day-to-day tasks
• Life events – life events such as bereavement, job loss or relationship breakdown
• Resilience – low ability to withstand financial or emotional shocks
• Capability – low knowledge of financial matters or low confidence in managing money
  (financial capability). Low capability in other relevant areas such as literacy or digital skills.

Buckingham Leasing understands that vulnerability can be difficult to identify and that not all customers can be
managed in the same way. We have considered guidance provided by the FCA and have put in place internal
controls and processes to ensure the fair treatment of its customers and to ensure that vulnerable customers are
identified and supported.

Not all customers with characteristics of vulnerability will be vulnerable, but they may be more likely to have
additional or different needs which, if not met, could limit their ability to make decisions or to represent
their own interests.

Customers may not want the label ‘vulnerable’ applied to them. While we refer to customers as being vulnerable
throughout this policy, Buckingham Leasing, as suggested by the FCA, does not use this label in its interactions
with customers. Instead, we focus on what harm or disadvantage customers may be vulnerable to and how it can
respond appropriately.

Types of Vulnerability

Our clients are UK based, companies or private individuals looking to purchase a product on hire purchase or
personal contract purchase with companies offering finance products or taking out a financial loan for an asset.

We appreciate 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.

• Many people in vulnerable situations would not diagnose themselves as ‘vulnerable’
• Buckingham Leasing recognises that everyone is at risk of becoming vulnerable at some point in their lives

To enable us to identify potential vulnerability and prioritise our efforts, we assess the type of vulnerability
being presented and work to provide appropriate solutions. Employees will work with our management team to
identify the client vulnerability and assess the most appropriate way forward for the client, taking account their
individual vulnerability.

Examples of Vulnerability Characteristics

Buckingham Leasing recognises that potential or actual vulnerability is not limited to just mental health or
age-related limitations and ensures that staff are aware of the wide ranging characteristics that could indicate
vulnerability in a customer. Examples include:

• Low literacy, numeracy and financial capability skills
• Physical disability or impairment (if not defined as a disability under the Equality Act 2010)
• Severe or long-term illness
• Mental health problems
• Low income and/or debt
• Caring responsibilities (including operating a power of attorney)
• Being ‘older’ (e.g. over 80; may be associated with cognitive/dexterity impairment, sensory impairments, onset of ill-health, or not being comfortable with new technology)
• Being young (associated with less experience)
• Change in circumstances (e.g. job loss, bereavement, divorce)
• Lack of English language skills
• Non-standard requirements or credit history (e.g. armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants)

Buckingham Leasing will take account of an individual’s characteristics and assess whether our products and/or
services are presented in a way that meets the specific needs of that customer.

Vulnerability is not limited to a person’s characteristics. It could be their circumstances or a situation that is
making them vulnerable, rather than any mental or physical condition.

Impact of Change in Circumstances

A change in personal circumstances can cause a consumer to fall into a vulnerable situation – more so if the
consumer already has one or more risk characteristics.

People are particularly at risk in their interaction with financial services when they experience a change in
circumstances that often leads to a financial shock. Examples include:

• A change of job leading to different working patterns, making communication more difficult
• A change in relationship status
• An unwell child or other relative
• Moving house
• Retirement (leading to change in daily patterns and routines)
• Physical or mental health issues

Impact of Change in Income

A financial shock could be an unexpected large expense or a loss of income. A drop in income, or income
volatility, can cause problems due to the ongoing commitment presented by many financial products. A reduction
in ability to meet these financial commitments can cause both immediate and longer-term problems.

Examples of income vulnerabilities can include:

• Zero hours contracts (leading to fluctuating income)
• Redundancy
• Retirement (leading to drop in income)
• Statutory sick pay
• Maternity/Paternity/Parental leave (note, this can affect the partner as well as the person taking leave)
• Being under duress or control by others

In these conditions, the impact of a problem or difficult interaction can be magnified, and vulnerability to
unscrupulous practices is increased, creating a vicious circle. The individual’s practical ability to seek redress
may also be diminished.

Signs of Vulnerability

Buckingham Leasing’s staff are reminded to be on the lookout for the following signs that may be indicative of vulnerability:

• Payments stopping suddenly
• Late or missed payments
• Unsettled transactions
• Willingness to accept losses in order to withdraw capital
• Repeated requests for actions already carried out or responses already given
• Frequently asking staff to repeat themselves
• Transactions that do not appear to make sense

Other triggers during interaction may include phrases such as:

• I can’t pay
• I’m having trouble paying
• I can’t read my statement/invoice
• I can’t understand the letter you sent me
• I can’t hear you very well
• I can’t hold on all day
• My son/daughter/wife/husband deals with these things for me

Staff are also reminded to be on the lookout for:

• Shortness of breath or signs of agitation
• Asking for repetition (may indicate difficulty retaining information or difficulty hearing)
• Signs the consumer has not understood or signs of confusion
• Mention of medication
• Repeated unrelated questions
• They keep repeating themselves
• They say “Yes” in a manner that suggests they did not listen to or understand the question
• Unwilling to discuss the situation
• A customer who does not recognise they are vulnerable

Examples of harm and disadvantage that the Firm should be alert to

The FCA has explored some of the behavioural and personal consequences of vulnerability for consumers and
shared this in its Occasional Paper 8 – Consumer Vulnerability. These include:

• Heightened stress levels due to difficult, or different, personal circumstances
• Increasing time pressures due to additional responsibilities
• Increasing pre-occupation (“brain is elsewhere”) limiting their ability to manage
• Processing power and ability decreasing due to competing pressures (e.g. side effects or emotional toll of receiving medical treatment)
• Lack of perspective when experiencing something for the first time (not fully understanding broader implications; unable to make comparisons or see the “bigger picture”)
• Changing attitudes towards taking risks; people may become more “reckless” and/or careless when under stress

These consequences may affect the way vulnerable consumers engage with providers and may negatively impact
their decision-making.

Summary

Vulnerability involves the interplay between individual circumstances, situations and market factors. These can include:

• A consumer’s state of mind can have a major impact on behaviour and decisions
• A change in circumstances, and multi-layered risk factors, are flags for potential vulnerability
• The number of people involved is large and rising — prioritisation is vital to achieve a realistic approach

To address the needs of vulnerable customers correctly, it is important to be able to identify them. In many
cases, more than one characteristic is present which increases the consumer’s vulnerability.

Buckingham Leasing’s staff need to be alert to the signs that the person they are dealing with may not have the
capacity, at that moment in time, to make an informed decision about the implications of the arrangements that
they are undertaking. This is managed by ensuring that staff are encouraged to listen, identify needs, and
adjust their approach accordingly.

Dealing with Vulnerabilities

Policies and Procedures

Buckingham Leasing recognises that a good vulnerability strategy will benefit all customers, and this policy
informs the Firm’s approach to dealing with potentially vulnerable customers. Where it is necessary to interact
with customers, procedures have considered how vulnerability can be identified and managed.

Products and Services

When firms design products and services that do not anticipate or consider the needs of vulnerable consumers in
their target market and customer base, there is a risk that these consumers can suffer harm as their needs may
not be met from the start. Products and services can have inherent features that could be harmful to some
vulnerable consumers. Note that this applies to the supply of products or services to retail customers who are
natural customers, even if Buckingham Leasing does not have a direct client relationship with the customer.

Buckingham Leasing’s products and services have been designed in an inclusive way to respond better to the
needs of those in vulnerable circumstances. An inclusive strategy has been embedded that aims to make services
available, usable and accessible to all regardless of personal circumstances.

Communications have been designed in a manner that is clear, fair and not misleading and when informed of
specific communication vulnerabilities (i.e. large print), we will make reasonable adjustments to ensure that
those customers’ needs can be managed.

Where our products and services are offered through agents, we will ensure that all firms in the chain treat
customer fairly, irrespective of whether they have a direct relationship with the consumer.

At all times, Buckingham Leasing will ensure products are clearly explained and understood by the consumer.

Customer Service Systems

In implementing systems (e.g. telephone systems, Client/Customer Relationship Management (CRM) systems etc.),
Buckingham Leasing has considered the potential impact on vulnerable customers.

Our systems are set up to enable staff to record vulnerability / suspected vulnerability.

7.0 Credit Brokers

Whilst there are no specific rules for credit brokers regarding vulnerable customers, due to the relationship
with lenders with whom Buckingham Leasing has a relationship, it is good practice to be aware of how the lenders
are expected to treat customers who may be vulnerable. Following the introduction of the Consumer Duty in 2023
Buckingham Leasing have emphasised to all staff the need to be ever more vigilant in assessing customers for any
sort of vulnerability.

Buckingham Leasing will obtain copies of any vulnerable customer guidelines or policies that the lenders use as
some of them may have different requirements. Buckingham Leasing will ensure that staff follow those guidelines
and remind all staff that if they become aware at any time before or during a discussion that the customer may be
vulnerable, the discussion must be concluded, and advice sought from senior management.

It may be necessary to decide for a trusted third party to assist the customer. Additionally, Buckingham Leasing’s
Vulnerability policy is assessed annually by the lenders when reassessing partnership working with them. A log has
been maintained for vulnerable customers from 2025.

Affordability checks involve income verification including a review of 3 months bank statements, last 2 years Tax
Calculations, salary payments, proof of income, expenditure, existing commitments, credit file (e.g. Experian Report).

Systems, particularly automation of systems (where a customer has no opportunity to speak to a real person) are
recognised as making it difficult to realise that customers may be vulnerable.

Buckingham Leasing recognises that lack of co-ordination between departments can lead to customers repeating
themselves (this can be particularly distressing if someone is dealing with a bereavement). However, we ensure
information is readily available through our internal systems.

We have ensured that where there is no direct contact with customers, that staff are aware of other signs of
vulnerability and are aware of how to take the appropriate actions.

Staff dealing directly with customers are aware that call script is provided as guidance to key discussion points
and are not intended to be applied to the exclusion of potentially vulnerable customers. Any concerns about
managing a vulnerable customer should be brought to the attention of management who will arrange for the
appropriate support.

We speak directly to all our customers through the application process. Staff are trained in how to manage
records, particularly sensitive personal information, in a manner that allows colleagues to understand the
individual’s vulnerability.

7.1 Communications

Buckingham Leasing appreciates failure to communicate with vulnerable customer in ways they can understand may
result in an increased risk of harm. Customers may not be able to understand the information they are sent or
may struggle to communicate their needs to the firm.

Buckingham Leasing will ensure communications throughout the life cycle of a product or service are clear and
provided to vulnerable customers in a way that they can understand, this includes:

• Marketing
• Point of sale
• Post-contractual information
• Information about changes to the product or service
• Complaints processes

Buckingham Leasing will consider the needs of vulnerable customers in their target market and customer base
when designing communications.

7.2 Training

Staff, from senior management through to frontline and relevant back-office staff, can influence outcomes for
vulnerable consumers. We ensure that all relevant staff have the appropriate skills and capability, as well as
support from appropriate systems and processes, to understand and consider the needs of vulnerable consumers in
their work.

All relevant staff should understand how their role can affect vulnerable consumers and the potential needs from
their target market’s vulnerabilities and what this may mean in practice for their role.

We ensure that staff have the skills and capabilities to recognise vulnerability and respond appropriately to individual consumers’ needs, so they deliver good outcomes. Our staff should be capable of recognising and responding to needs:

• Where the customer has told the firm about a need
• Where there are clear indicators of vulnerability; or
• Where there is relevant information noted on the customer’s file that indicates an additional need or vulnerability

Staff should take steps to encourage disclosure where they see clear indicators of vulnerability but are not
expected to go further than this to proactively identify vulnerability.

Buckingham Leasing provides training to its staff on identifying and managing the relationships with vulnerable
customers. All customer facing staff are expected to undertake refresher training at least annually.

Ongoing training includes advice regarding how to:

• Understand vulnerabilities
• Successfully identify vulnerable customers: verbal indications, communication difficulties; changes in behaviour post customer communication; observe for pre-occupation and signs of ‘not listening’; signs of physical distress; difficulty in completing forms
• Build trust
• Be vigilant when dealing with customers
• Encourage sharing of information in an unhurried way
• Avoiding jargon
• Analyse vulnerable data to improve strategic decision making

7.3 Specific Requirements: Credit Brokers

Buckingham Leasing will obtain copies of any vulnerable customer guidelines or policies that the lenders use as
some of them may have different requirements. We will ensure that staff follow those guidelines and remind all
staff that if they become aware at any time before or during a discussion that the customer may be vulnerable,
the discussion must be concluded and advice sought from senior management. It may be necessary to plan for a
trusted third party to assist the customer.

We will ensure all customers (including those displaying signs of potential vulnerability) are fully aware of our
scope of service and remuneration structure. During initial discussion our terms of business is provided which
confirms this including detail of any commission arrangements in place. This is further supported by our
commission disclosure which is signed by customers prior to entering into a credit agreement.

Where a vulnerable customer may be experiencing mental health difficulties, the Firm has obtained guidance from
the Money Advice Liaison Group (MALG) Guidelines called “Good Practice Awareness Guidelines for Consumers with
Mental Health Problems and Debt”.

In the appendix below, we have also listed details of further organisations/charities who may be able to assist
vulnerable clients dependant on their vulnerabilities.

7.4 Specific Requirements: Lender

7.4.1 Credit Worthiness

All lenders are required to make sure that any regulated credit agreement that they provide to a customer is
affordable. We conduct a credit worthiness assessment which means gathering information such as the amount of
credit that they want, the customer’s financial position, their credit history and whether they have experienced
any financial difficulties before, any future financial commitments and whether they may have any kind of mental
capacity issues that could affect their understanding of the credit agreement.

In the event that a mental capacity issue has been identified, our staff will ensure that they (or a
representative) understand the terms of the loan and that it is affordable prior to proceeding.

7.5.1 Debt Recovery

There may be occasions when a customer is having difficulties in making their repayments.

Where a vulnerable customer may be experiencing mental health difficulties, Buckingham Leasing has obtained
guidance from the Money Advice Liaison Group (MALG) Guidelines called “Good Practice Awareness Guidelines for
Consumers with Mental Health Problems and Debt”.

Customers who have mental health difficulties are provided with additional protections under FCA rules when they
fall behind on repayments. Buckingham Leasing will cease recovery action immediately after being advised that a
customer lacks the mental capacity to make decisions about the management of their debt or lacks the ability to
engage in any conversations about the recovery of the debt.

Where a customer has someone helping them, like a relative, then provided the customer has given permission or
an active power of attorney is in place, we are allowed to speak to them to help clear the debt.

7.6.1 Data Accuracy

Buckingham Leasing will maintain accurate records that document a customer’s needs and if they have any special
requirements. This will assist staff in understanding what steps they may need to take to get the best outcome
for the customer and the firm.

Staff who believe that a customer could be vulnerable will consider how they can record the details in a way
that is sensitive and helpful. A customer has the right to access their records, so staff are advised to be
sensitive in how they record the information.

7.7.1 Breathing Space and Signposting

Vulnerable customers who are experiencing financial difficulties are entitled to the additional support provided
to them in line with our firm’s Arrears Policy.

8.0 Monitoring and Evaluation

Buckingham Leasing monitor the actions it is taking to ensure we treat vulnerable customers fairly and the
outcomes vulnerable customers experience in comparison to other customers. We do this with reference to all of
the aspects of our customer relationships and have regard to delivering good customer outcomes.

Monitoring in this way will allow Buckingham Leasing to determine whether we are achieving good outcomes for
vulnerable customers and understand which activities and processes work well, and which ones needs to be
adapted to improve the outcomes for vulnerable consumers.

As part of our ongoing due diligence, Buckingham Leasing will review the lenders Vulnerable Customers policies.
Any subsequent changes notified to us by the lender will be immediately communicated to our staff.

8.1 Quality Assurance

Lack of effective quality assurance on services and products along the customer journey may result in Buckingham
Leasing failing to spot where the needs of vulnerable customers are not being met and what needs to be changed
as a result.

Buckingham Leasing will implement quality assurance processes throughout the whole customer journey to highlight areas where:

• They do not fully understand vulnerable customers’ needs
• The performance of staff has led to poor outcomes for vulnerable customers
• Products or services unintentionally cause harm to vulnerable customers
• Customer service processes are not meeting vulnerable customers’ needs

Buckingham Leasing will consider the following aspects of the firm customer relationship in its monitoring of the quality of the processes associated with vulnerable customers:

• Decision making: are products/services meeting the needs of customers when providing information and support to make decisions?
• Engagement throughout the customer journey: are customer service and communications meeting the needs of vulnerable customers?
• Disclosing changes in circumstance/needs: are vulnerable customers supported and encouraged to share information?
• Suitable products: are customers able to access product features that are suitable and meet their changing needs?

Some examples of how Buckingham Leasing can put this into practice are:

• Looking at complaints data (and ensuring it is easy for vulnerable consumers to make complaints through multiple channels)
• Using feedback not sent directly to the firm, including online reviews and social media complaints
• Testing experiences of vulnerable customers through mystery shopping, auditing, focus groups and deep dives
• Using insights from organisations with understanding of ‘lived experience’ (consumer bodies, charities, third sector), including published insights
• Allowing staff to feedback honestly when processes for vulnerable consumers could be improved
• Reviewing whether processes and policies are effective in the fair treatment of vulnerable customers

8.2 Management Information

Under Principle 12, Buckingham Leasing will have management information (MI) or measures in place to test quality
of customer outcomes.

Buckingham Leasing is committed to producing MI that captures outcomes for identified vulnerable customers and
making sure this is discussed regularly at an appropriate level and escalated and acted on where necessary.
Types of MI we will collect include:

• Business persistence: analysis of customer retention records (e.g. claims and cancellation rates and why customers leave)
• Distribution of legacy products / pricing and fees and charges: review whether customers with characteristics of vulnerability are more likely to incur fees/charges or receive less favourable rates
• Behavioural insights: interactions and drop-off rates; use of different channels including digital; testing of financial promotions
• Additional support: contact rates with vulnerability teams, referrals to and feedback from specialist services
• Training and competence records: staff training records, including remedial actions where knowledge/actions were below expectations
• File reviews: reviewing customer files and monitoring calls to check for errors and assess if customers were treated fairly
• Customer feedback: formal and informal feedback including complaints and social media
• Numbers of complaints: trends involving vulnerable customers compared to other customers
• Complaint root cause analysis: investigating complaints fully to understand causes, not just symptoms
• Compliance reports: review compliance reports to check standards are met for treating customers fairly

9.0 Breaches of Vulnerable Customers Policy

Any breaches of the Vulnerable Customer Policy will be recorded on our breach log in conjunction with our
Regulatory Breach procedure.

Appendix 1: Who to contact for information, support and advice

Appendix 2

In line with Buckingham Leasing’s commitment to identifying and meeting the needs of any customers with
vulnerabilities, an updated communication practice has now been implemented. When discussing finance with a
customer, brokers now read the following statement to encourage transparency and highlight support available:

Alongside the above, Buckingham Leasing has updated its website with information for vulnerable customers,
including signposting to further support.

Website copy (as provided)

Your wellbeing and vulnerability when accessing financial products

Buckingham Leasing recognizes that ongoing issues and life events can occur that make decisions around finances,
or repayment difficult. In line with the Financial Conduct Authority’s (FCA) guidance, we are committed to
supporting customers in making the best financial decisions for themselves.

Vulnerabilities that may affect decisions and ability around financial issues are broad, but may include:

• Your health — both physical and mental
• Life events — for example relationship changes or bereavement
• Resilience — including financial or emotional strength
• Capacity — for example lack of confidence or knowledge in financial business or terminology used, difficulty
  reading the standard style of our documentation

If you have any special circumstances or need, even if these occur after you have made a commitment to a
product or service, please do not hesitate to inform us and let us know what extra support may help. Any
information you share with us will be treated in the strictest confidence and we will do our best to support
your needs. We can provide further information by phone or face to face as appropriate. We can also provide
written information in a variety of formats if needed.

Please see the link to The Money Charity website. Signposting from The Money Charity – this page lists several
agencies who may be able to help with advice around issues that may lead to temporary or ongoing financial
vulnerability.