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.