Notes

DISABILITY AND VULNERABILITY

- help disabled customers.

- Dementia affects almost 1 million people in the UK
- 3 million people in the UK are living with Cancer
- 318 people a day are declared bankrupt or insolvent
- 14.6 million UK residents have a disability, 70% of which have a hidden (invisible) disability, and this number is increasing year on year
- 1 in 6 adults experiences common mental health problems every week, and 23% of us suffer anxiety when dealing with service providers.


Equity and Equality
- We want to create a fairer future for everyone. Disabled and Vulnerable customer inclusion is a fundamental part of removing barriers for our customers and our people.


Summary
So, in summary, equality ensures everyone has access to the same opportunities, and equity means giving everyone what they need to have an equal opportunity for success.


Vulnerability Definition
- ​Our Regulators define a vulnerable customer, whether temporarily or permanently, as someone who, due to their circumstances, is especially susceptible to harm, particularly when a business is not acting with appropriate levels of care.
This might include:

• Physical or mental health problems

• Specific characteristics such as age or literacy skills

• Changes in personal circumstances such as bereavement, illness, job loss or changes in household income

• Struggling with an addiction which impacts their decision-making capability, or someone diagnosed with cancer and experiencing financial difficulties


Vulnerability Drivers
The fair treatment of disabled & vulnerable customers is not a tick-box exercise; it's about understanding:

- That some customers may be experiencing a permanent or temporary state of vulnerability.

- Someone who would not be considered to be in a vulnerable position but changes to their personal circumstances could, in turn, change that status.

Therefore, understanding the drivers contributing to a person's vulnerable state is essential, but it shouldn't be assumed that all customers displaying such characteristics are vulnerable. We must identify and support customers based on understanding their personal circumstances.


Disability Definition
- In UK law, the Equality Act 2010 defines disability as a physical or mental impairment that has a substantial and long-term adverse effect on a person's ability to carry out normal day-to-day activities.

In this context, long-term means lasting for at least 12 months up to a lifetime.


Getting it wrong

+ Customer Fairness
Providing a service to a lower standard, at a higher cost, or on other terms that are worse for people with disabilities.

+Unreasonably Difficult
Failing to change any policy, procedure or practice that makes it unreasonably difficult or impossible to use a service we provide. For example, insisting on speaking to a customer on the phone when you've already been made aware that they have a disability which prevents them from doing so, such as hearing loss or speech difference.

+Refusing
Refusing to provide a service made available to others.

+Creating Barriers
Creating barriers, by refusing to make reasonable adjustments for a customer with a disability.


Disability & Vulnerability
Our regulators mandate that we have appropriate policies and procedures to ensure that disabled and vulnerable customers are treated fairly and given the help, support and services they need.
Remember that vulnerability isn't a generic term we should use, but instead, consider the needs of disabled and vulnerable customers.


Summary
Well, that almost wraps things up for part two.

Together we've looked at the definitions of Disability and Vulnerability and what they mean for us at Virgin Media O2.

We also got to see some of the different teams we have in place to support our customers.
But let's be honest; it wouldn't be right if we didn't spend some time seeing what knowledge you've retained. So what are you waiting for?


Spending power of disabled people
Let's look at the cost of non-inclusive design on our business.

The "Purple Pound" refers to the spending power of disabled households in the UK. A disabled household is one in which at least one of the members has a disability.
In 2020 it was identified that the global spending power of people with disabilities and those around them is estimated to be a market the size of China.

The “Purple Pound” spend is approximately £274bn annually in the UK (and is expected to increase yearly).


Disabled customer buying habits
In June 2022, the Business Disability Forum published results from ground-breaking new research on disabled customers' buying habits.

The survey asked disabled people with a range of lived experiences, about their decision-making process and their experience after making a purchase.

The results are compelling and highlight that businesses must:
​-Demonstrate accessibility and inclusive design practices from the outset
-Provide great customer information and great customer service from the beginning of the buying process
-Equip customer-facing teams to allow them to go the extra mile in providing brilliant service


Our actions
The revenue opportunity in the Telecoms sector was estimated at £49 million per month in 2020, according to research by the We Are Purple organisation.
It's our responsibility to provide all customers with information in an accessible format to demonstrate inclusive design from the outset and throughout every stage of their customer journey. This approach enables disabled customers to make informed decisions about what they buy and why.
If we don't understand the needs of disabled and vulnerable customers and don't make reasonable adjustments when designing and delivering great customer interactions, we risk losing these valued customers from the outset.


Business Benefits
Now we've explored why it's so important for our business let's look at how your role affects the fair treatment of disabled and vulnerable customers.
All staff, not just those who communicate with our customers daily, are responsible for the fair and appropriate treatment of disabled and vulnerable customers.

We all need to understand how our roles can positively impact the customer experience.


Accessibility and Inclusive Design framework
We have an Accessibility & Inclusive Design framework which incorporates global accessibility standards.

Our framework enables us to address barriers for our people and customers by encouraging everyone to use the guidance and principles on all projects with accessibility & equity in mind.
For guidance on how to remove barriers for our disabled &/or vulnerable customers or to discuss how Accessibility & Inclusive Design can be adopted as part of existing ways or working, there are contact links at the end of the module.


Why inclusive design is important
If you work in departments where you design products, services, or technology for people (internal or external), you should take the needs of disabled and vulnerable people into account as part of the design process.
It is critical that our products, customer service systems and operational teams are able to meet everyone's needs.


Everyone can ensure the fair treatment of disabled and vulnerable customers

+ Launching a product or service with accessibility features included from the outset ensures it's available to a wider audience.

+Adding an adjustment to a customer account so we can tailor our support without them having to tell us each time they contact us.

+Ensuring that products and services are available in multiple channels so customers can choose a channel which works for them and caters for their needs.


Likely barriers that our customers may face
We previously mentioned barriers; barriers can be anything that prevents a customer from getting the most out of our products and services, such as our contact options, the format of the information we send to customers, the accessibility of our stores or the usability of our products.



Talking more about barriers
+Most of our customers will only ever need to tell us about their situation if they face barriers when using our products and services.
+A higher number of our customers will have a disability or be in a vulnerable situation than we know about.
+If a customer tells us about any barriers they face when using our products and services, we can put reasonable adjustments in place. With consent, we can also make a note on their account, so they don't need to tell us each time they contact us.
+It's all about having a good conversation with our customers and being equitable.




An Introduction to FCA Compliance

- This topic introduces several aspects of Financial Conduct Authority (FCA) compliance including the roles of the FCA, our regulated products and our compliance training.

When you've completed this topic, you should be able to:
- List three reasons why compliance is important to O2
- Outline the role of the FCA with respect to our regulated financial products
- Briefly explain the purpose of the Consumer Credit Act 1974
- Describe how the FCA protects our customers


Why is Doing the Right Thing important to O2?
Do you know why doing the right thing is important to O2? Take a look at this video, where our Director of Compliance, Paul Asare-Archer, answers this question and explains how this module will help you to meet your compliance responsibilities.


What does the FCA do?

1. The FCA regulates our O2 Refresh and Mobile Phone Insurance propositions
Our regulated activities include providing customers with credit agreements and insurance.

The FCA can also withdraw our authorisation if we do not comply with the relevant requirements. This means that we wouldn't be able to continue to offer credit and or insurance to our customers.

2. The FCA ensures that we protect our customers
One of the key things that the FCA requires is that we treat our customers fairly.

Treating customers fairly includes:
Providing them with information that is clear, fair and doesn't mislead
Offering products in a fair and honest way
At O2, our corporate values put the customer at the heart of everything we do, clearly embracing the spirit of treating all customers fairly.



The FCA and regulated financial activities

Credit agreements
The FCA and credit agreements
We cannot legally offer goods and services to our customers on credit unless we have been regulated to do so by the FCA. Telefónica UK is regulated by the FCA to provide credit to our customers (Firm Reference Number: 718822).

What does this regulation affect in O2?
The FCA regulates the way that we enable our customers to buy their devices through O2 Refresh credit agreements.

Franchise stores and third parties (such as Capita) that offer O2 Refresh need to hold their own authorisation so that they can offer credit agreements on our behalf.


Insurance
The FCA and insurance
We cannot legally offer, advise or recommend on insurance products unless we have been regulated by the FCA.

What does this regulation affect in O2?
The FCA regulates the way that we enable our customers to protect their devices with O2 Insure.

O2 Insure is a financial product that's regulated by the FCA, so when we offer it to our customers, we need to ensure that we offer it correctly by following FCA rules.



The FCA and the Consumer Credit Act

The Consumer Credit Act (1974) is the main piece of legislation that regulates consumer credit in the UK. It governs how we, as a credit provider, must treat our customers.

The legislation covers:
+ The information we give customers before they sign up for credit
+ The checks we need to make on customers applying for credit
+ The information we include in our credit agreements
+ The way that we advertise the credit we offer to our customers.
+ The procedures we need to follow if customers want to cancel their credit agreement, or make an early settlement, or if they fail to meet their payments

The Consumer Credit Act requirements are outlined in the FCA's Consumer Credit Sourcebook (CONC) which regulated credit providers like us must adhere to.


What are our compliance obligations?

Meeting our obligations with compliance training

FCA rules state that before an individual can offer regulated products, they must be appropriately trained and qualified to do so.

Therefore, O2 advisors (Store, Voice and Webchat) who provide customers with information about our regulated credit and insurance products need to be able to follow the correct O2 policies and processes at each stage of the customer journey to ensure that we're:
Complying with FCA rules
Treating our customers fairly
This involves induction training and ongoing quality assurance to ensure staff competence. It begins with the training you are doing right now and continues throughout your career as regulations, products and services change.



End of topic summary

Why is doing the right thing important to O2?
- Doing the right thing helps O2 to:
- Treat our customers fairly, giving them a great service from a business they can trust
- Meet the expectations of our regulators
- Protect our reputation
- Build a brand people can trust

The FCA
The FCA authorises and supervises our regulated financial activities and ensures that we protect consumers.


The FCA and regulated financial products
We are regulated by the FCA to provide credit agreements and insurance to our customers. Credit agreements and insurance are both regulated financial products.


The FCA and the Consumer Credit Act
The Consumer Credit Act (1974) is enforced by the FCA. It's the main piece of legislation that regulates consumer credit in the UK and governs how we, as a credit provider, must treat our customers.


The FCA and protecting consumers
One of the key things that the FCA require is that we treat our customers fairly. For example, providing them with clear and fair information about our products and services and offering them in a fair and honest way.


Our FCA compliance training
O2 advisors (Store, Voice and Webchat) who provide customers with information about our regulated credit and insurance products need to be able to follow the correct O2 policies and processes at each stage of the customer journey.



Credit agreements and the Consumer Credit Act (1974)

Our obligations under the Consumer Credit Act 1974

If you're an O2 Store, Voice or Webchat advisor, it's essential that you follow all the relevant O2 processes when providing customers with information about credit for O2 Refresh.

These processes are designed to ensure that we comply with the FCA consumer credit rules and include how we need to:
- Carry out checks on the customer
- Provide the customer with information about how our credit agreements work
- Sign up the customer
- Support the customer after sign-up


Carrying out checks on our customers
In order to comply with the Consumer Credit Act 1974, we need to carry out certain checks to ensure that our customers are eligible to sign up for an O2 Refresh credit agreement.

There are two essential checks that we must complete before a customer can sign up.

Identity check
Before a new O2 customer can sign up for credit, we must check their identity to verify that they are who they say they are. This helps to protect us from financial crime and ensures that the customer is eligible for the offer.


Credit check
We also need to check that the customer can afford to take out the Device Plan and meet the monthly repayments.
For new customers, we need to follow the standard credit check and affordability process
For upgrading O2 Refresh customers, we don't need to carry out a credit check as one will have been completed previously. However, depending on how long the customer has been with us and their payment history, the system may prompt you to run an additional check to ensure that the customer can afford to take the credit.


What information must we provide customers considering credit?


Providing customers with information about how our credit agreements work
After a customer has passed the ID and credit/affordability check, we next need to provide them with important information about how our FCA regulated credit agreements work. Under FCA rules we have to provide customers with this information before they sign up, to ensure they can make an informed decision about the credit agreement and whether it is right for them.

We provide customers with two key documents.

The Pre-Contract Credit Information (PCCI)
When you provide your customer with a summary of their O2 Refresh or O2 Business Essentials Device Plan, you must explain the following that's included in the PCCI.

1. Contact Details: customers may be more familiar with the O2 name, so you should tell them that the creditor is Telefónica UK, trading as O2.
Outsource providers like Capita, or Franchisees, are listed on the PCCI as 'credit intermediaries' because they are acting as a 'broker' of credit between us and the customer. Explain this to the customer if they ask.

2. Key features of the credit product:
- The total amount of credit
- The number and frequency of installments
- The total amount they'll pay (not on the PCCI but includes upfront payment)
- The fact that it's 0% interest
- The duration of the credit agreement
- Their right to cancel within 14 days


The Key Information Sheet
The second document that you should read through with the customer before they sign up for credit is the Key Information Sheet. This document provides customers with important information about the Device Plan and:
- Their right to change their mind about having a credit agreement
- Their right to change their mind about the device
- What happens if they miss a payment
- What could happen if they are in breach of any of their obligations


Providing customers with information about how our credit agreements work

Price changes
You must explain to customers that:
1. Their Airtime Plan will be adjusted each year on the customer's April bill by the Retail Price Index (RPI) in the preceding February. This can mean a small increase to their monthly Airtime payment each year, but this will depend on the RPI rate. We'll let them know before we do it.
2. Their Device Plan payments are not subject to any price change during the contract term and remain at 0% interest.


Providing customers with the right information before they sign up

We provide the customer with this important pre-sign-up information in different ways depending on whether they are in a store, on the phone, in a webchat with us or using our website.

In-store
If a customer comes into one of our stores, wanting to apply for O2 Refresh, the advisor will talk them through the PCCI and the Key Information Sheet face-to-face.

The advisor can also provide the customer with a paper or electronic version of the documents if they want to read them later, before they make a decision.

If the customer has any questions, the advisor will be able to answer them face-to-face.

Voice
If a customer phones in, the advisor will talk them through all the essential information and provide them with links to the PCCI and the Key Information Sheet so that they can access the information themselves before they sign up.

If the customer has any questions, the advisor will be able to answer them on the phone or direct the customer to an O2 Store so that they can discuss the details and sign up for credit face-to-face.


Webchat
If a customer makes contact via a webchat, the advisor will provide them with a summary of the essential information from the PCCI and the Key Information Sheet. They will also provide them with a link so that they can access the full details before they sign up.

If a customer has any questions, the advisor will be able to answer them during the webchat.


Website
If a customer applies for O2 Refresh via our website, they will view all of the all the essential information through the portal on our website.

If they need to speak to someone, they can visit one of our Stores, call us, or use our webchat facility.


Is the customer ready to sign up in store?

When you have talked the customer through the PCCI and the Key Information Sheet, they should have the information that they need to help them to decide whether to sign up. But, are they ready?

To determine whether the customer is ready, there are three key questions you need to consider.


1. Does the customer understand?
If you think a customer doesn't understand the information, you should take the time to go through the information with them again and answer any questions they may have.

2. Is the customer unable to make a decision?
If there are signs that the customer still doesn't understand, or seems unable to make a decision you should:
- Suggest that they take the information away with them so that they can make a decision at a later date; or
- Ask if they'd like us to talk to someone else (for example a family member or carer) who may be able to help explain it to them.

3. Do you think the customer is competent?
Remember, that we need to act responsibly when providing consumer credit.

Acting responsibly includes ensuring that a person is competent to take out such an agreement.

If you think that a customer isn't competent, you should not let them sign up for credit.


How do we support customers before and after signing up?




Eric is the eligible customer as he is a UK resident, aged 18, and signing up for insurance at the same time as a purchase direct from O2.

You can 'not' offer O2 Insure to:
Customers who purchase from somewhere other than O2.
Customers who had purchased their device more than 28 days ago.
Customers who are not UK residents.
Customers who are aged under 18.



If a customer discovers their phone has been stolen, they need to:
Contact O2 Customer Services as soon as possible, so that we can bar the phone
Report the incident to us within 14 days, unless there are extenuating circumstances
Provide us with the Crime Reference Number within 14 days


We must conduct Customer due diligence to find out who the customer is and check that they aren't using a stolen identity.

Politically Exposed Persons (PEPs) screening checks if the customer is potentially susceptible to corruption.

Sanctions screening is required if the customer is subject to restrictions and/or potentially susceptible to corruption.