Vulnerable Customers Policy.

1.1 We Buy Any Home is a trading style of Webuyanyhome Ltd., a company registered in England and Wales with company number 08527463 and a registered office at: 2 Leman Street, London E19US (WBAH, the firm, us, we).

1.2 WBAH is in the business of purchasing and selling property in England and Wales and Scotland.

2.1 WBAH is committed to dealing honestly and fairly with all of its customers.

2.2 The purpose of this policy is to help ensure that WBAH treats Vulnerable Customers fairly.

2.3 Vulnerable Customers may be existing customers or prospective customers whose ability or circumstances require us to take extra precautions in the way interact with them to ensure that they are not disadvantaged and are treated fairly.

2.4 This policy sets out the firm’s approach to dealing with Vulnerable Customers. In particular its sets out:

1. How we define and identify Vulnerable Customers;
2. Principles for treating customers fairly;
3. How Vulnerable Customers should be treated once identified;
4. Specific considerations for categories of Vulnerable Customers WBAH regularly interacts with;
5. Accountability for this policy;
6. Management information in relation to Vulnerable Customers;
7. Monitoring and audit in relation to this policy;
8. Record keeping in relation to this policy; and
9. How staff can raise a concern in relation to the treatment of Vulnerable Customers.

2.5 This policy will be reviewed on at least an annual basis by the Responsible Officer, or more frequently if required, e.g. due to a change in legislation, due to a change in the firm’s business model or to address issues identified with the firm’s treatment of Vulnerable Customers.

2.6 This policy applies to all Staff who interact with customers on behalf of WBAH.

2.7 This policy has been based on guidance for financial institutions produced by the UK Financial Conduct Authority (FCA). WBAH is not subject to FCA regulation but wishes to apply a level of protection for its Vulnerable Customers.

The following defined terms are used in this policy:

MI: means management information.

Responsible Officer: means the member of the senior management team who is responsible for this policy as detailed in paragraph 9.3.

Staff: means WBAH’s employees, contractors and third parties that deal with its customers.

Vulnerable Customer: means someone who, due to their personal circumstances, is potentially or possibly especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care, examples of which are given at paragraph 4.2

4.1 It is important to identify Vulnerable Customers at the earliest opportunity in order to ensure they are treated appropriately.

4.2 Factors that may suggest a customer is a Vulnerable Customer include:

1. Health: health conditions or illnesses that affect the ability to carry out day to day tasks;
2. Life events: major life events such as bereavement, relationship breakdown, redundancy, serious illness of a close family member, becoming a carer;
3. Resilience: low ability to withstand financial or emotional shocks; and
4. Capability: low knowledge of financial matters, low confidence in managing money and communication difficulties (could be due to disability (hearing, sight, speech or mental capacity), dyslexia or ability to speak and understand English (e.g. it is not the customer’s first language)).

4.3 While the factors and example traits in paragraph 4.2 are quite broad it is not possible to cover every potential trait or characteristic that could indicate that a customer is vulnerable. WBAH and its Staff must be mindful of this in all interactions with customers in order to identify Vulnerable Customers.

4.4 WBAH buys properties from a range of customers, some of whom may have recently experienced life events that may indicate that they are, or have a likelihood of being, a Vulnerable Customer, e.g. the death of a relative whose property WBAH is attempting to buy from the estate.

4.5 It is therefore vital that all WBAH Staff are aware of this policy and how to treatnVulnerable Customers

4.6 It is important for all Staff to understand what the consequences of a customer being a Vulnerable Customer may be. Typical impacts of vulnerability that may be observable in interactions with customers include:

1. Heightened stress levels due to difficult personal circumstances;
2. Increasing time pressure, leaving less time for ‘personal admin’;
3. Increasing pre-occupation, e.g. ‘brain is elsewhere’, limiting ability to manage;
4. Processing power and ability decreases due to competing pressures, e.g. due to emotional distress from a bereavement;
5. Lack of perspective, especially when experiencing something for the first time, and therefore not fully understanding the broader implications, unable to make comparisons or to see the ‘bigger picture’; and
6. Changing attitudes towards taking risks – people often become more ‘reckless’ and/or careless at moments of stress.

4.7 All of these factors can impact the ability of Vulnerable Customers to understand information presented to them and to make sensible decisions in relation to the information given.

4.8 All interactions with customers are important in identifying Vulnerable Customers. WBAH’s processes help ensure certain information is collected that may indicate if a customer is a Vulnerable Customer, but it is vital that all Staff that interact with
customers, regardless of how (e.g. person to person, by phone, electronically (e.g. website, app, email, etc.)), are aware of WBAH’s policy and how to identify actual, or potentially, Vulnerable Customers.

4.9 If any member of Staff identifies that a customer is, or may be, a Vulnerable Customer they should notify the Responsible Officer.

5.1 WBAH and its Staff should apply the following principles in order to help ensure the fair treatment of all customers, including Vulnerable customers:

1. Skill, care and diligence:
   1. WBAH must conduct its business with due skill, care and diligence;
2. Management and control:
   1. WBAH must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems;
3. Customers’ interests:
   1. WBAH must pay due regard to the interests of its customers and treat them fairly; and
4. Communications with customers:
   1. WBAH must pay due regard to the information needs of its customers and communicate information to them in a way which is clear, fair and not misleading.

5.2 WBAH and its staff should also consider the following customer outcomes that it aims to achieve for all its customers including Vulnerable Customers:

1. Outcome 1: Customers can be confident they are dealing with a firm where the fair treatment of customers is central to the corporate culture.
2. Outcome 2: Customers are provided with clear information and are kept appropriately informed during a purchase.
3. Outcome 3: Customers do not face unreasonable barriers to submit a claim or make a complaint.

5.3 WBAH and its Staff should apply these principles (detailed in paragraph 5.1) and seek to achieve these outcomes (detailed in paragraph 5.2) for all customers and must ensure they apply them appropriately for Vulnerable Customers.

6.1 Any products and services that WBAH provides must be designed in a way that takes account of the needs of its customers including the requirements set out in this policy in respect of Vulnerable Customers.

6.2 WBAH must design all information it provides to customers to be clear, fair and not misleading to the customer.

6.3 WBAH must ensure that its processes for dealing with customers do not introduce any barriers.

6.4 All customers, whether they are vulnerable or not, receive legal advice before selling a property to WBAH.

7.1 If a customer has been identified as a Vulnerable Customer, WBAH and its Staff must immediately make a record of this and apply as many of the following measures as is appropriate for the customer concerned:

1. Provide a choice of ways in which to communicate depending on the circumstances of the customer, e.g. telephone, face to face conversation, text phone, large print, braille, sign-language, translator or such other method that may be appropriate in the circumstances;
2. Provide additional opportunities for the customer to ask questions about the information we have provided;
3. Seek confirmation that the customer has understood the information that has been provided;
4. Make it possible for family, friends or carers to help the customer if requested or appropriate in the circumstances;
5. Be flexible when making appointments in respect of location, times of day, duration and facilities available.

7.2 If at any time during interaction with a Vulnerable Customer it is apparent that they have not understood or their behaviour suggests that they are acting in a way that is out of character, or reckless, the customer should be given further time to consider whether or not to proceed and the matter should be escalated to the Responsible Officer who will determine what, if any, further action is required, and whether or not to proceed with the transaction.

8.1 WBAH has dealt with the following types of Vulnerable Customers:

1. Vulnerable Customers who have recently experienced a bereavement:
   1. WBAH has purchased property following the death of an individual;
   2. In such circumstances the estate of the deceased may often seek a quick sale in order to distribute assets;
   3. Clear information and warnings should be given to the customer that WBAH purchases properties below market value. Where appropriate additional, or repeat, information and warnings should be given;
   4. If appropriate additional time should be given for the Vulnerable Customer to consider and agree to sell the property; and
   5. In all cases the customer must acknowledge and consent to the purchase at a below market value;
2. Vulnerable Customers who lack capacity:
   1. WBAH must ensure that such customers have appropriate support from family, friends or carers in making the decision to sell property to WBAH;
   2. WBAH must provide additional opportunities for the customer to ask questions about the information provided;
   3. WBAH should repeatedly seek confirmation that the customer has understood the information that has been provided; and
   4. WBAH should offer the customer the opportunity to complete the transaction after a period of further consideration.

9.1 Ultimately the board of WBAH is accountable for this policy and how the firm treats Vulnerable Customers.

9.2 The board delegates the day to day responsibility for this policy to the Responsible Officer.

9.3 The following senior manager is nominated as the firm’s Responsible Officer:

1. Name: Matthew Gerrish
2. Email: matt@webuyanyhome.com
3. Telephone: +44 (0) 203 789 2401
4. Address: 50 St. Mary Axe, London EC3A 8FR

9.4 The Responsible Officer is responsible for:

1. Creating and maintaining this policy, including conducting an annual review of it;
2. Ensuring this policy is applied by and complied with by WBAH and all of its Staff;
3. Monitoring this policy;
4. Developing and delivering training on this policy to all Staff; and
5. Ensuring WBAH keep appropriate records in relation to this policy.

9.5 All Staff must comply with this policy and provide the Responsible Officer any 
assistance that may be necessary to give effect to this policy.

10.1 The Responsible Officer is responsible for:

1. Creating and maintaining training for Staff in relation to this policy;
2. Delivering the training to Staff; and
3. Ensuring Staff understand the training.

10.2 All new staff will receive training on this policy within 14 days of joining WBAH.

10.3 All Staff must receive refresher training on this policy on at least an annual basis and/or when there is a need for additional training, e.g. due to a change in legislation, due to an issue the firm has experienced or due to a significant regulatory change.

11.1 It is important to collect information that will allow WBAH to monitor how effectively this policy is being applied.

11.2 The Responsible Officer must ensure that management information (MI) about Vulnerable Customers is recorded and reported to the board.

11.3 The MI collected should include:

1. Numbers of Vulnerable Customers identified;
2. The nature of the vulnerability, or vulnerabilities, associated with each Vulnerable Customer;
3. What measures were taken to ensure that each Vulnerable Customer was treated fairly and in accordance with this policy;
4. Whether or not each Vulnerable Customer sold their property to WBAH;
5. Complaints information:
   1. Whether or not a Vulnerable Customer, or their representative,
      made a complaint to WBAH;
   2. The nature of the complaint made;
   3. Whether or not the complaint has been resolved;
   4. How long it took to resolve the complaint;
   5. What was done to resolve the complaint including any changes policy and procedure.

11.4 The Responsible Officer is responsible for:

1. Compiling and reviewing MI on a weekly basis;
2. Identifying, escalating and resolving any issues identified by reviewing MI;
3. Compiling and delivering quarterly MI reports to the board;
4. Completing any actions that the board decide are needed in respect of WBAH’s treatment of Vulnerable Customers.

11.5 The board of WBAH must review MI relating to Vulnerable Customers on at least a quarterly basis and determine if WBAH needs to take any action to ensure the fair treatment of Vulnerable Customers.

12.1 The Responsible Officer is responsible for monitoring the firm’s compliance with this
policy.

12.2 The Responsible Officer must, on at least an annual basis:

1. Set out the firm’s plans to monitor compliance with this policy including whether or not an audit (whether internal or external) should be conducted;
2. Carry out monitoring of the policy in accordance with any such plan developed;
3. Report to the board / senior management on the findings of the monitoring;
4. Determine if any changes are needed to policy and procedures, getting the board to agree the changes needed, and implementing any such changes in a timely manner.

13.1 The firm should keep records of:

1. The different versions of this policy as apply from time to time;
2. Records of customers identified as Vulnerable Customers including relevant MI;
3. Evidence of any monitoring or audits of this policy that have been conducted; and
4. Any reports, complaints or findings in relation to Vulnerable Customers.

14.1 If you become aware of an issue relating to Vulnerable Customers that you do not think the firm is aware of you should raise it with the Responsible Officer or member of the board.

15.1 The following table details the versions of this document including an overview of the reasons for any changes made.