Vulnerable Consumers Policy

Purpose

Cycle Solutions (Cycle to Work) Limited is committed to treating all customers fairly and to delivering good outcomes for customers, including those who may be experiencing vulnerable circumstances.

The purpose of this policy is to explain how we identify and respond to the needs of customers in vulnerable circumstances and how we seek to ensure that they receive fair treatment and outcomes that are as good as those experienced by other customers.

We recognise that vulnerability can affect anyone. It may be permanent, temporary, episodic or change over time. A customer's circumstances may also mean that they require additional support at one particular stage of their interaction with us but not at others.

We will seek to act with appropriate care, avoid foreseeable harm and provide support which reflects the individual needs of our customers.

What do we mean by a customer in vulnerable circumstances?

A customer in vulnerable circumstances is someone who, due to their personal circumstances, is especially susceptible to harm, particularly if a business does not act with appropriate levels of care.

Vulnerability can arise for many reasons and does not mean that a customer is unable to make their own decisions.

We recognise four broad drivers of vulnerability:

Health

This may include:

• physical disability or illness;

• mental health conditions;

• cognitive impairment;

• hearing or visual impairment;

• learning disabilities;

• neurodiversity; or

• other health conditions which affect how someone communicates with us, understands information or uses our services.

Life events

Significant life events can temporarily or permanently affect someone's circumstances. Examples may include:

• bereavement;

• relationship breakdown;

• redundancy or loss of income;

• becoming a carer;

• serious illness;

• domestic or financial abuse; or

• other major changes in personal circumstances.

Financial resilience

A customer may have limited ability to withstand financial difficulty or an unexpected financial shock.

This might include customers experiencing:

• low or unstable income;

• financial hardship;

• problem debt;

• changes in employment or household income; or

• other circumstances that affect their financial resilience.

Capability

Some customers may experience difficulties understanding, accessing or using financial products or services.

This may include:

• limited financial knowledge or confidence;

• literacy or numeracy difficulties;

• language or communication barriers;

• difficulty understanding complex information; or

• difficulties using online or digital services.

These examples are not exhaustive. Vulnerability will depend upon the individual customer and their circumstances.

Identifying customers who may require additional support

We recognise that customers may interact with Cycle Solutions in different ways, including through our website, telephone services, email, online communications, employers, retail partners and other customer service channels.

A customer may tell us directly that they require additional support, or our colleagues may identify circumstances which suggest that additional support would be helpful.

Indicators may include, for example:

• a customer telling us that they have difficulty understanding information;

• repeated questions or apparent difficulty retaining information;

• difficulty hearing, reading or communicating;

• difficulty completing an online process;

• asking for assistance from another person;

• disclosure of financial hardship or significant changes in personal circumstances;

• difficulty understanding the financial commitment associated with an agreement;

• a customer appearing distressed or confused; or

• a request for information or communication to be provided in a different way.

We will not make assumptions about a customer's abilities simply because they have a particular condition or characteristic.

Customers are encouraged to tell us if there is anything about their circumstances that affects how they communicate with us or use our services.

Providing this information is voluntary. We will use relevant information to help us provide appropriate support.

How we support customers

Just because someone is experiencing vulnerable circumstances does not mean that they are unable to use our products or services.

Our objective is to understand what support the customer may need and, where reasonable and appropriate, adapt the way we communicate with or assist them.

Depending on the circumstances, this may include:

• allowing additional time for the customer to consider information or make a decision;

• providing additional explanations or opportunities to ask questions;

• explaining information in a clearer or simpler way;

• providing information through an alternative communication channel or format where reasonably possible;

• following a telephone conversation with information in writing;

• breaking information or processes into smaller, more manageable stages;

• allowing a trusted family member, friend or other representative to assist the customer, subject to appropriate authority and security checks;

• providing reasonable adjustments for customers with disabilities;

• allowing the customer to pause an application or transaction and return to it later;

• avoiding asking customers to unnecessarily repeat sensitive information; or

• referring the customer to an appropriately trained colleague where additional support is required.

Where appropriate, we will take reasonable steps to check that customers understand material information rather than relying solely upon a customer confirming that they understand it.

If we believe that a customer does not sufficiently understand material information needed to make an informed decision, we may pause the process and provide further information or support before proceeding.

Salary sacrifice and financial circumstances

The Cycle to Work scheme normally involves an employee agreeing to a reduction in salary in exchange for the provision of a bicycle and/or cycling equipment.

We recognise that changes in personal or financial circumstances may affect a customer's ability to manage salary sacrifice deductions or other financial commitments.

If a customer tells us that they are experiencing financial difficulty, or indicates that a salary sacrifice commitment may cause them financial difficulty, we will seek to ensure that they understand the nature of the commitment and have an appropriate opportunity to consider whether proceeding is right for their circumstances.

Where appropriate, we may explain the options available under the relevant Cycle to Work scheme or refer the customer to their employer where a matter relates to payroll, salary sacrifice or their employment arrangements.

Cycle Solutions will not make assumptions about whether a customer should participate in a Cycle to Work scheme solely because they are experiencing financial vulnerability.

Consumer understanding

We aim to provide customers with information that enables them to make informed decisions.

Where a customer appears to require additional support, we may adapt our communication to help them understand important information.

This might involve:

• slowing down a conversation;

• using straightforward language;

• explaining information in smaller sections;

• giving the customer additional time;

• inviting questions;

• repeating or rephrasing information where appropriate; or

• asking the customer to explain their understanding of important information in their own words where this is appropriate.

Our objective is to support customers to make their own informed decisions wherever possible.

Mental capacity and decision-making

Mental capacity refers to a person's ability to make a particular decision at a particular time.

A person's ability to make a decision may be affected where an impairment or disturbance in the functioning of their mind or brain prevents them from understanding, retaining, using or weighing relevant information or communicating their decision.

Mental capacity is decision-specific and time-specific.

A person may therefore be able to make some decisions but not others, and their ability to make a decision may change over time.

Possible causes of limitations in mental capacity can include, amongst other things:

• mental health conditions;

• dementia;

• learning disabilities;

• developmental conditions;

• neurological conditions or brain injury; and

• intoxication or the effects of medication.

The fact that a customer has, or appears to have, one of these conditions does not mean that they lack capacity to make a particular decision.

We will not automatically refuse access to our products or services because a customer has a health condition, disability or other characteristic which may be associated with limitations in mental capacity.

Instead, we will consider whether reasonable steps can be taken to support the customer to understand the relevant information and make their own informed decision.

Where we reasonably believe that a customer is unable to understand the material information necessary to make a particular decision, we will not proceed with that decision or transaction until appropriate steps have been taken.

Financial capability and mental capacity

Mental capacity is different from financial knowledge or financial literacy.

A customer may have full mental capacity but find financial information difficult to understand or lack confidence when dealing with financial matters.

Where this occurs, we will seek to provide appropriate support and clearer information rather than attempting to determine whether a customer's difficulty arises from financial capability or mental capacity unless it is necessary to do so.

Recording information about customer needs

Where appropriate, we may record information about a customer's support needs so that we can provide appropriate and consistent assistance.

We will seek to record only information that is relevant and necessary for this purpose.

Where possible, we will focus on recording the support or adjustment that the customer requires rather than unnecessary details about a medical condition or other personal circumstances.

For example, it may be more appropriate for us to record that a customer:

• requires information in writing;

• would benefit from additional time;

• requires assistance using online services; or

• has authorised another person to assist them.

Information relating to vulnerability will be handled in accordance with applicable data protection legislation and our Privacy Policy.

Customers can tell us if their circumstances or support needs change.

Third-party assistance

Customers may wish to have a family member, friend, carer or other trusted person assist them when communicating with us.

We will seek to accommodate this where appropriate, but we may need to obtain the customer's authority and complete relevant identification or security checks before discussing personal information with another person.

Where formal legal authority exists, such as a registered power of attorney, we will deal with the authorised representative in accordance with the scope of that authority.

Our colleagues

Customer-facing colleagues receive appropriate guidance and training to help them:

• recognise indicators that a customer may require additional support;

• communicate sensitively with customers experiencing vulnerable circumstances;

• understand the support and reasonable adjustments available;

• recognise potential difficulties with consumer understanding;

• know when and how to escalate a matter; and

• handle information concerning vulnerability appropriately.

Where a colleague is unsure how best to support a customer, or believes that applying our normal processes may result in an unfair or poor outcome, they should refer the matter to an appropriately authorised colleague or manager.

Our partners and distribution arrangements

Customers may interact with other organisations when accessing the Cycle to Work scheme, including their employer and participating cycle retailers.

Where appropriate, we seek to ensure that organisations involved in delivering aspects of our service understand the importance of treating customers in vulnerable circumstances fairly.

Where a partner identifies a concern which requires support from Cycle Solutions, we encourage the matter to be referred to us so that we can consider what assistance may be appropriate.

Monitoring customer outcomes

We regularly consider whether our products, services and customer support arrangements are delivering appropriate outcomes for customers, including customers experiencing vulnerable circumstances.

This may include considering relevant information such as:

• customer feedback;

• complaints;

• customer service interactions;

• requests for additional support or reasonable adjustments;

• application or transaction outcomes; and

• other relevant management information.

Where we identify evidence that customers in vulnerable circumstances may be experiencing poorer outcomes, we will consider the reasons for this and take appropriate action.

Our commitment

Cycle Solutions is committed to creating an environment in which customers feel comfortable telling us when they need additional support.

We will:

• treat customers with dignity and respect;

• listen to the individual needs of customers;

• avoid making assumptions based on a person's circumstances;

• provide reasonable and appropriate support;

• seek to make our services accessible;

• protect information customers share with us; and

• seek to deliver good outcomes for all of our customers.

If there is anything about your circumstances which affects how you communicate with us or use our services, please tell us.

We will work with you to understand what support may help.

Contact us

Customers who require additional support can contact our Customer Services team through the contact methods shown on our website.

Policy owner: Cycle Solutions (Cycle to Work) Limited
Approved by: Board of Directors
Effective date: August 2026
Review frequency: At least annually and following any material regulatory or operational change