All Vehicle Contracts Limited may also be referred to herein as ‘We’ ‘Company’ ‘AVC’ ‘Us’ ‘Our’ and ‘All Vehicle Contracts’.
Customers and potential Customers may also be referred to herein as ’You’ and ‘Clients’.
Customer Risk Assessment
Risk Client Product Knowledge
Not understanding how experienced and knowledgeable Clients are in terms of financial products and services We offer, and if they have adequate assessment of affordability and clarity in their understanding of the contract.
AVC solution - how we will deal with this:
Having identified areas where We consider that problems may arise by each of the potential situations, we have set out and implemented controls to monitor our sales process, and gather feedback from our Clients and from ourselves, which will be considered at regular intervals our controls consist in providing adequate information, so clients can make an informed decision as follows.
With Initial contact quotation we provide a full and detailed (IDD) Initial-DisclosureDocument that provides links to Key information that relate to problem areas. We also insure that clients are provided with all the relevant key information on the products relevant to the clients quotation such as Personal Contract Hire and PCP Finance.
Misleading leasing promotions
The risks misleading leasing promotions could pose to consumers in our opinion are that the general low pricing in some instances are not in consumers best interests. The risk in our opinion is that the consumer can presume that the advertised price as the total price they pay without giving full consideration to the total affordability and there contractual obligations.
AVC solution - how we will deal with this:
AVC promote a clear and transparent method of offering vehicle promotions that are 'clear, fair and not misleading' and not miss lead consumers by price offering alone. For further information please view our Financial-Promotion Policy
The aim of this Policy is to outline the practice and procedures for staff who work for the Company to contribute to the prevention of detriment to Clients who find themselves in vulnerable circumstances. The Policy covers all staff areas of work when dealing directly with the Customer.
Definition of Vulnerable
We consider a vulnerable consumer to be someone who, due to their personal circumstances, is especially susceptible to detriment, with the most significant detriment occurring when “through the use of consumer credit [they may] get into unmanageable or problem debt.”
The nature of AVC’s business makes it unlikely that new Customers will be in vulnerable circumstances or that the nature of their circumstance may limit or remove the availability of facilities to the extent that the Company might be unable to accommodate their requirements.
However, we remain mindful of the potential for enquiry by such Clients and the potential for any change of circumstance in respect of existing Customers.
AVC Limited will not discriminate against Clients in vulnerable circumstances by way of adjustment to fees or any refusal to assist purely on the grounds of the Client’s circumstance (unless that circumstance creates a situation which is likely to lead to detriment or a risk that removes the availability of any finance or funding facility).
This section illustrates mitigation actions for Clients with mental capacity deficiencies (for the avoidance of confusion, “competent person” means an individual without the limitation presented by the Client):
o Solution: Client to instruct a competent person to act as interpreter.
o Solution: Client to nominate a reasonable communication medium suitable for their disability.
o Solution: Client to instruct a competent person to communicate on their behalf. Legal agreement must be reached outside of any period of incapacity. The Client should be encouraged to seek independent professional advice.
o Solution: Client must provide “Power of Attorney” for a competent individual to act on their behalf.
o Solution: Client must provide “Power of Attorney” to a competent individual to act on their behalf.
a. To ensure staff are aware of this policy and are adequately trained
b. To support individuals in relation to identified risk and vulnerability
c. To provide means of reporting any instance where they believe that a client might be in vulnerable circumstance.