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Vulnerable Customers Policy

Vulnerable Customers Policy & Procedures — COLABR8 Ltd

Effective Date: 1 January 2026

1. Introduction

At COLABR8 Ltd (“COLABR8”, “we”, “us”, “our”), we are committed to treating all customers with dignity, respect and fairness. This Vulnerable Customers Policy & Procedures sets out how we identify customers who may be experiencing vulnerability and how we tailor our approach to support them appropriately and sensitively.

This policy applies to all COLABR8 customers and to all employees, contractors and agents acting on our behalf.


2. What Is a Vulnerable Customer?

A “vulnerable customer” refers to someone who may, due to personal circumstances, be especially susceptible to harm or disadvantage when interacting with communications services providers like COLABR8. Vulnerability may be temporary, long-term or situational and can arise from a wide range of circumstances, including (but not limited to):

  • Physical disability or sensory loss
  • Mental health conditions or cognitive impairment
  • Age-related challenges
  • Low literacy or limited digital skills
  • Bereavement, serious illness or life changes
  • Financial hardship or debt issues
  • Other circumstances that may affect their ability to engage with us or make decisions confidently

Customers may not self-identify as “vulnerable,” but we consider their circumstances and needs to ensure fair treatment.


3. Our Approach

We aim to identify and assist customers in vulnerable circumstances in a way that respects their dignity and autonomy. Our approach includes:

a. Identification We encourage disclosure of needs and proactively train staff to recognise indicators that a customer may benefit from additional support. Examples include:

  • Difficulty understanding information provided
  • Repeated confusion or inability to complete standard processes
  • Requests for repeated explanation of terms
  • Third-party notification (e.g., carers or family members)

Staff are trained to respond sensitively and to ask questions in a respectful manner when appropriate.

b. Communication and Accessibility We offer clear, accessible communication in multiple formats where reasonably practicable, including:

  • Large print or easy-read versions of key documents
  • Telephone support tailored to individual needs
  • Extra time and patience during interactions
  • Use of preferred contact channels

c. Staff Training All customer-facing employees receive training on vulnerability awareness and the procedures for offering tailored support. Training covers:

  • Identifying possible indicators of vulnerability
  • Communicating clearly and patiently
  • Helping customers understand service options
  • Escalating complex cases to specialist teams

4. Tailored Support Procedures

Once vulnerability is identified, we take appropriate steps to support the customer, which may include:

  • Providing additional explanation of terms, billing or charges
  • Allowing more time for decisions or interactions
  • Offering flexible payment options or deferrals where appropriate
  • Signposting to free third-party support services (e.g., financial advice or advocacy groups)
  • Involving a trusted third party or advocate with the customer’s consent

We ensure that no customer is disadvantaged because of their circumstances and that they understand their rights, options and obligations.


5. Recording and Using Information

Where a customer consents, we may record relevant information to help ensure consistent and appropriate service in future interactions. Any such information is handled in accordance with our Privacy Policy and applicable data protection laws.

We only record data that is necessary to provide better service and support, and we protect it with appropriate safeguards. Customers are informed about how their data will be used and can withdraw consent at any time.


6. Continuous Review and Improvement

We regularly review and update this policy and our procedures to reflect:

  • Changes in regulatory guidance (e.g., Ofcom’s expectations for fair treatment of vulnerable customers)
  • Feedback from customers and staff
  • Best practice standards in customer service and accessibility

Our policy aims to ensure effective outcomes for customers with diverse needs.


7. Feedback and Complaints

We encourage customers to contact us if they feel this policy has not been applied appropriately or if they have suggestions for improvement. You can contact COLABR8 by email, post or phone:

Email: hello@colabr8.co.uk Address: COLABR8 Ltd, 280 St Vincent Street, Suite C, Second Floor, Glasgow, G2 5RL, United Kingdom

We aim to resolve concerns promptly and fairly.


8. Policy Governance

This policy applies to all COLABR8 staff and relevant contractors. Responsibility for oversight of the Vulnerable Customers Policy sits with our senior management, who ensure:

  • Regular review and updating of the policy
  • Adequate staff training and awareness
  • Compliance with UK regulatory requirements and best practice