Our approach to the FCA’s consumer duty and our support for vulnerable customers:

As an FCA authorised and regulated electronic money institution, the FCA’s “Consumer Duty” applies to products and services we offer to retail customers (including micro enterprises and small charities with an annual turnover of less than £1 million) and to the extent that we determine or have a material influence over consumer outcomes in the UK. The Duty requires us to act to deliver good outcomes for customers (including those in vulnerable circumstances) especially in relation: (i) products and services; (ii) price and value; (iii) consumer understanding; and (iv) consumer support. 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. Characteristics of vulnerability may result in consumers having additional or different needs and may limit their ability or willingness to make decisions and choices or to represent their own interests. These consumers may be at greater risk of harm, particularly if things go wrong. We, therefore, seek to provide our customers with a level of care that is appropriate given the characteristics of the customers themselves. We seek to embed the fair treatment of vulnerable customers in our policies and processes throughout the whole customer journey. The level of care that is appropriate for vulnerable consumers may be different from that for others and we seek to take particular care to ensure they are treated fairly. As part of our onboarding process, we seek to understand the characteristics of the vulnerability of retail customers and their needs. Where we recognise that an individual consumer has a specific need, we will inform our relevant customers about the options of help and support we offer to meet the needs of vulnerable consumers. We are also aware that all consumers are at risk of becoming vulnerable and may become more or less vulnerable, and so have an increased or reduced risk of harm throughout their lives. A heightened period of vulnerability can be short term, such as a hospital stay, or long-term, such as long-term unemployment affecting financial resilience. We have created an internal vulnerability policy that includes information on the likely vulnerabilities and needs in our target market, how vulnerable consumers may be more likely to be susceptible to behavioural biases, and how behavioural biases may present themselves so that we understand where there may be a risk of inappropriately exploiting these biases when engaging with relevant consumers. In short, we seek to ask ourselves what types of harm or disadvantage our customers may be vulnerable to, and how our own actions can increase or reduce the risk of harm. We train all our staff rigorously on this topic and seek to embed this into the culture of our firm. If you have any concerns or questions about how this applies to your relationship with us or would like to discuss any change in your circumstances with us, please contact us at [email protected] or contact your dedicated Client Manager.


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© 3S Money Club Limited 2019-2024. All rights reserved. 3S Money and 3s.money are trading names of 3S Money Club Limited. 3S Money Club Limited is authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011 for issuing of electronic money and the provision of payment services with FCA registration number 900918. 3S Money Club Limited is registered in England and Wales, Company Number 8574246, with its registered office address at 45 Folgate Street, London, E1 6GL, United Kingdom. 3S Money Club Limited is registered with The United Kingdom Information Commissioner's Office with ICO registration number ZA495485. 3S Money Club Limited (DIFC Branch) is regulated by the Dubai Financial Services Authority (DFSA) with DFSA reference number F007004, authorising it under Article 48 of the Regulatory Law 2004 to carry on the Financial Services comprised in Issuing Payment Instruments and Providing or Operating a Payment Account. 3S Money Club Limited (DIFC Branch) is registered in Dubai International Financial Centre, Licence Number CL5587, with its registered office address at Central Park Towers, office 20-54, DIFC, Dubai, UAE. 3S Money (Luxembourg) S.A. is authorised by the Commission de Surveillance du Secteur Financier (CSSF) under the law of 10 November 2009 on payment services for issuing, distribution and refund of electronic money with CSSF registration number W00000016. 3S Money (Luxembourg) S.A. is registered in Luxembourg, R.C.S number B245715, with its registered office address at 25C, Boulevard Royal, L- 2449, Luxembourg, Grand Duchy of Luxembourg