Vulnerable Customer Policy

In order to adequately service all of our customers, Apex Jewellers Ltd t/a Shining Diamonds makes every effort to qualify our customers to fully understand their wants and needs as well as identify any signs of customer vulnerability. We are aware that there are many risk factors that impact the level of vulnerability in our customers which include, but are not limited to, loss of loved ones/bereavement, illiteracy or language barriers, e.g. someone who's first language is not English, illness, disability, job loss and other impairments which increase the customer vulnerability.

All of our customer facing staff are trained to be alert to any potential signs that our customer is a vulnerable person and to have sympathy for their needs. This is gauged primarily through our qualification process. The qualification process allows us to ascertain what the customer needs from Apex Jewellers Ltd t/a Shining Diamonds, but also allows us to get to know them on a personal level, and therefore have a better ability to determine any signs of vulnerability. The FCA define customer vulnerability as:

"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." Here at Apex Jewellers Ltd t/a Shining Diamonds as part of our qualification and customer service processes we aim to identify vulnerable consumers and aim to help and support them by the following: -

• Sharing any information and potential vulnerabilities with our trusted strategic partners, i.e. finance companies/warranty companies. This is done with the customers' express consent.
• Offering our customers an appropriate amount of time to consider our offer, so that they may best make an informed decision.
• Where a vulnerability is identified, suggest that the customer may want to seek the advice of an independent trusted third party i.e. a friend or family member.
• Involve management level staff in the sales process to ensure that Apex Jewellers Ltd t/a Shining Diamonds make adequate attempts to identify vulnerability.
• Continuous training of customer facing staff to keep a continued awareness of the importance of identifying customer vulnerability.
• Communicate as clearly as possible, with all information put to the customer in a good time.

What signs do we look for to determine vulnerability?

• Is it clear the customer fully understands the offering and service we're providing?
• Can the customer summarize our offer showing adequate understanding?
• Does the customer ask that we repeat ourselves regularly?
• When they say they have not understood previous correspondence or communication.

Process followed when dealing with a vulnerable customer

• Speak clearly to the customer, in a jargon free and meaningful way.
• Clearly signpost our sales process so that the customer knows what to expect when dealing with Apex Jewellers Ltd t/a Shining Diamonds. Proper signposting/ agenda setting will help prevent any surprises in the sales process.
• Be patient and allow the customer adequate time to consider their options.
• Clearly define everything we do, making no assumptions that a customer has understood or not understood something important.
• Suggest that the information we've discussed in person is summarized in a follow up email or telephone conversation
• Set out clear timescales for delivery of goods/services.
• Ask the customer if they would like to run things past a trusted friend or family member before proceeding.
• Log information regarding vulnerability so that we can continue to offer the level of service our customer expects and requires. This is done with the explicit consent of our customers and in accordance with data protection / GDPR regulations.

What do we do when Vulnerable Customers are identified?

• Refer the matter to a member of the management team, so that they can also determine and satisfy themselves that the customers' needs have been central to the sales process.
• Any potential vulnerability will be stored in our system and that information will be shared with our strategic partners as early in the process as possible i.e. finance companies at proposal stage (V12 Retail Finance) and our warranty partners. This will be done with the customers explicit consent. This process will continue where potential vulnerabilities are identified through the duration of the agreement.
• A customer's situation can change at any time, so we need to ensure this is escalated to a senior colleague if this is identified.