Vulnerable Customers

A vulnerable customer is someone whose decision-making and engagement with financial services might be impacted negatively as a result of their personal circumstances.  Vulnerable customers might be more likely to experience detrimental outcomes, which in the event they materialize, are likely to be greater than for other (non-vulnerable) customers.

There are many reasons why a person might feel vulnerable during their lifetime.  Some of the characteristics that might contribute to a customers vulnerability are as follows:

Health physical or mental disabilities or illnesses that affect the ability to carry out day-to-day tasks;

Life events major life events such as bereavement, job loss, or relationship breakdown;

Resilience low ability to withstand financial or emotional shocks; and

Capability low knowledge of financial matters or low confidence in managing money (financial capability) and low capability in other relevant areas such as literacy, or digital skills.

Vulnerability characteristics can potentially have a number of detrimental impacts on an TBanque customer.  Some examples are listed below:

1. Lack of technological ability and experience due to older age, leading to a reduced ability to operate TBanques investment platform.
2. Lack of mental capacity leading to erroneous trading decisions, in particular in relation to higher risk products.
3. Certain characteristics or events which may lead to reckless or emotionally-driven investment decisions, such as:

• A sudden diagnosis of serious illness to either the customer or a close family member.
• Financial hardship.
• Addiction-related health conditions, such as gambling addiction or compulsive behaviors.
• Mental health disorders include depression, heightened levels of anxiety, and suicidal thoughts.

If you believe you might be impacted by any characteristics of vulnerability, it is important that you notify us as soon as possible.  Vulnerability is most often not easily visible and we rely on our customers being open and making us aware of such situations.  Should you wish to notify us about your situation, or if you believe that you are a vulnerable customer, please let us know by opening a ticket via the Customer Service Center. Once you have opened a Customer Service request, please wait until the request is addressed and refrain from opening multiple tickets for the same issue. Opening multiple tickets for the same request delays our teams response times.

TBanque has well-defined policies and procedures for addressing customer vulnerability.  No two vulnerability cases are the same and TBanque takes a tailored approach based on the individual characteristics of each vulnerability case.  Generally, TBanque operates in line with the following principles:

1. TBanque works on the general principle that it will take appropriate steps to consider the circumstances of any individual who is particularly vulnerable or susceptible to the detriment and therefore needs adjustments to the way in which the Firm communicates and supports them.
2. TBanque recognizes that vulnerability is a state, not a trait, that there is a sliding scale of vulnerability, and that people are different, meaning that some customers will become vulnerable in circumstances where others may not.
3. TBanque believes that the welfare of any vulnerable person is paramount; those who are vulnerable without exception have the right to protection from abuse regardless of gender, ethnicity, disability, sexuality or religious beliefs.
4. TBanque works on the basis that every individual is different and is subject to different circumstances. This means that as far as possible, the Firm will treat individuals in a way that is appropriate to their needs, where possible tailoring its approach.

When responding to vulnerability, TBanque will consider the various aspects of a customers situation and may take steps to monitor and support users, ultimately to assess what level of detriment their vulnerability poses to their future TBanque experience.

Ultimately, if we cannot ensure fair treatment of customers that are considered vulnerable, we may not enter into a relationship with you. In addition, where a customers vulnerability is not immediately apparent/visible, information that is subsequently disclosed by a customer may lead to the exiting of a relationship. It is important to emphasize that some vulnerabilities are more visible to us than others (age, for example) and we are not obligated to proactively seek out and consider vulnerabilities that are less visible.

Vulnerable customers may seek external support from the following organizations:

• Vulnerable customers that are suicidal or in a state of depression or heightened anxiety should contact the Samaritans
• MoneyHelper (formerly known as the Money Advice Service);
• Citizens Advice Service
• Mental Health Foundation
• MIND
• National Debt Helpline
• Step Change
• Alzheimers Society
• The Royal National Institute of Blind People (RNIB)
• Action on Hearing Loss (RNID)