TREATING CUSTOMERS FAIRLY

Soul Leads must pay due regard to the interests of their customers and treat them fairly by ensuring that:

• Customers feel confident that they are dealing with Soul Leads where the fair treatment of customers is central to its culture.
• Products and services marketed and sold are designed to meet the needs of customers.
• Customers are provided with clear information and are kept appropriately informed before, during and after point of sale.
• Where customers receive advice, the advice is suitable and takes account of their circumstances.
• Customers are provided with products and associated services that perform and are of the standard as Soul Leads have led them to expect.
• Customers do not face unreasonable post-sales barriers imposed by Soul Leads to change a plan, redeem or cancel a plan or make a complaint.

Vulnerable customers are those who, due to their personal circumstances, are especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.

Soul Leads has a written policy that sets out how they will identify and treat vulnerable customers.

Soul Leads takes the necessary steps to identify vulnerable customers or customers in vulnerable situations. This will include ensuring all employees, agents or representative operating on the Soul Leads’s behalf, all members of staff will be trained in line with Soul Leads’s vulnerable customer policy. The consideration of funeral arrangements can, obviously, often arise at very difficult times. Soul Leads will be sensitive to this and take account of any other further factors that might affect decisions to take out a plan or choose a funeral.

Soul Leads will make the necessary effort and time to ensure that vulnerable customers understand all aspects of signing a contract for a funeral plan. Where appropriate, Soul Leads will suggest the involvement of a trusted friend or relative.

Soul Leads are prohibited from generating sales enquires or new orders from the creation, obtaining, distribution, maintenance or use of lists of specific customers that are susceptible to responding to cold calling approaches (sucker lists).

Where Soul Leads undertakes a home visit for the sale of a funeral plan, the representative must leave immediately if requested to do so or if it becomes apparent that the customer is not interested in the goods or services the business is selling.

Customers must be provided with a written cancellation notice. This notice must inform customers of their right to cancel within 30 days or more of the date the customer received such notice without any cancellation or other fee being applied. This condition applies irrespective of the way the plan was sold.

COMPLAINTS AND DISPUTES

Customers who are dissatisfied with the service provided by Soul Leads should, in the first place, contact that Soul Leads who must acknowledge receipt of the complaint to the customer in writing within 7 working days of receiving a complaint.

Customers should contact charlotte@soulleads.co.uk to write their complaint.

If Soul Leads cannot resolve a complaint to the customer’s satisfaction, the customer should contact the FPA who provides an independent conciliation and arbitration service.

VULNERABLE CUSTOMERS

A vulnerable customer as:

Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care. 

The FCA analysed the answers customers gave to their Financial Lives Survey 2017 to understand how many display one or more of the indicators below and could be considered as potentially vulnerable.^[1]

1. Health – health conditions or illnesses that affect ability to carry out day-to-day tasks. 5% of UK adults say their ability to carry out day-to-day tasks is reduced a lot by health conditions or illness.
2. Resilience – low ability to withstand financial or emotional shocks. 30% of UK adults have been identified as having low financial resilience.
3. Life Events – major life events such as bereavement or relationship breakdown. 19% of consumers say a major life event has happened to them or their partner in the last 12 months.
4. Capability – low knowledge of financial matters or low confidence in managing money. 17% of UK adults have low financial capability.

Given these sort of indicators examples of risk factors for vulnerability that Soul Leads should consider in relation to the funeral plan market include:

• being ‘older old’ for example over 80, although this is not absolute (may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill-health, not being comfortable with new technology)
• change in circumstances (e.g. bereavement, divorce)
• severe or long-term illness
• low literacy, numeracy and financial capability skills
• physical disability
• mental health problems
• low income and/or debt
• caring responsibilities (including operating a power of attorney)
• lack of English language skills