Vulnerable Consumer Policy

  1. Purpose

The purpose of this policy is to ensure that Court Enforcement Specialists Limited conducts its business in a manner that safeguards vulnerable consumers and complies with applicable legislation, regulatory standards and professional guidance.

We are committed to ensuring that vulnerable individuals are treated fairly, with dignity and respect, and that our actions do not cause disproportionate distress or disadvantage.

  1. Definition of a Vulnerable Consumer

For the purposes of this policy, a vulnerable consumer is any individual whose personal circumstances, characteristics or situation mean that they may require additional support or consideration to ensure they are not disadvantaged during enforcement or debt recovery activity.

Vulnerability may be permanent, temporary, or situational and may not always be immediately apparent.

While vulnerability is not limited to specific categories, indicators may include (but are not limited to):

Advanced age
Physical disability or serious illness
Mental health conditions
Cognitive impairment or learning difficulties
Financial illiteracy
Recent bereavement
Pregnancy
Single parenthood
Unemployment
Limited literacy or difficulty understanding English
Any circumstance affecting the ability to make informed decisions

We recognise that individuals subject to enforcement action may experience heightened stress, which may increase vulnerability.

  1. Regulatory Framework

Court Enforcement Specialists Limited operates in accordance with:

The Tribunals, Courts and Enforcement Act 2007
The Taking Control of Goods Regulations 2013
The National Standards for Enforcement Agents

We are committed to ensuring enforcement activity is proportionate, ethical, and compliant with all regulatory expectations.

  1. Identification of Vulnerability

Vulnerability may be identified through:

Verbal disclosure
Behavioural indicators
Third-party information
Documentation provided
On-site observations

Employees and Enforcement Agents are trained to exercise appropriate discretion and professional judgment when assessing vulnerability.

If there is uncertainty, the matter will be referred to a supervisor or compliance manager for review before further action is taken.

  1. Conduct at Residential Premises

Employees and Enforcement Agents must:

Withdraw immediately if the only person present appears to be under 18 years of age.
Withdraw from making enquiries where only children who appear under 12 are present.
Act with sensitivity where a vulnerable person is present.
Avoid behaviour that could be perceived as intimidating, coercive or inappropriate.

Discretion must be exercised at all times to protect both the consumer and the employee from allegations of misconduct.

  1. Communication Safeguards

Where vulnerability is suspected or identified:

Additional time will be given for explanation and clarification.
Information will be communicated in clear, non-technical language.
Confirmation of understanding will be sought.
The consumer will be asked whether a third party (family member, adviser, support worker) should be present.
Where appropriate, communication may be paused pending third-party support.
Information on independent advice agencies (for example Citizens Advice or recognised debt advisory organisations) will be provided.

If an employee believes they are engaging with a vulnerable individual, they must escalate the matter to a supervisor. If immediate supervision is not available, the matter must be paused and a supervised follow-up arranged.

  1. Reasonable Adjustments

Where appropriate, we will:

Provide access to translation services where reasonably practicable.
Provide documentation in large print or alternative formats upon request.
Allow additional time for compliance.
Consider temporary suspension of enforcement activity where supported by evidence.
Refer matters back to the instructing creditor where necessary.

Any decision to suspend, amend or continue enforcement will be proportionate and documented.

  1. Enforcement Action Involving Vulnerable Persons

Where vulnerability is confirmed:

Enforcement activity may be adapted or suspended in accordance with regulatory guidance.
Cases may be referred back to the instructing creditor for further instruction.
Enforcement Agents will not proceed where doing so would be contrary to regulatory expectations or legal obligations.

All vulnerability assessments and decisions will be recorded on file.

  1. Financial Illiteracy

We recognise that some individuals may lack sufficient financial understanding to make informed decisions.

Where this is identified:

Explanations will be simplified.
Time will be allowed for consideration.
The individual will be encouraged to seek independent advice.

This does not automatically prevent enforcement action but may influence how engagement is conducted.

  1. Training and Oversight

All relevant staff and Enforcement Agents receive training in:

Identifying vulnerability
Appropriate communication techniques
Regulatory obligations
De-escalation and professional conduct

Supervisory oversight is maintained to ensure compliance with regulatory standards.

  1. Record Keeping

All vulnerability disclosures, indicators, adjustments, and decisions will be documented accurately and retained in accordance with data protection requirements.

  1. Commitment

Court Enforcement Specialists Limited is committed to:

Treating all individuals fairly and respectfully
Protecting vulnerable consumers from disproportionate harm
Ensuring enforcement action remains lawful, proportionate and ethical
Maintaining full compliance with applicable regulatory standards

 

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