Vulnerable Customers Policy

Our commitment

At Bathroom City, we believe every customer deserves to be treated with dignity, respect and fairness — regardless of their personal circumstances. We recognise that at any point in life, any one of us can experience circumstances that make us more vulnerable than usual. When that happens, the way a business treats you matters more than ever. This policy sets out how we identify, support and protect customers who may be vulnerable, and how we ensure that vulnerability never leads to a poorer outcome.

What we mean by vulnerability

A vulnerable customer is someone whose personal circumstances mean they may be at greater risk of harm, disadvantage or difficulty when engaging with our products, services or finance options. Vulnerability isn't a permanent label — it can be temporary, long-term, situational or fluctuating. A customer who is perfectly capable of making decisions today may find themselves in vulnerable circumstances tomorrow due to a change in health, finances or personal situation.

We take a broad view of what vulnerability looks like, because it doesn't always announce itself. Some customers will tell us they need additional support. Others may not realise they're in a vulnerable position, or may not feel comfortable disclosing it. Our responsibility is to be alert, to respond with care, and to adjust how we work to make sure the outcome is fair.

Circumstances that may indicate vulnerability

A customer may be considered vulnerable if they are affected by any of the following, whether individually or in combination:

Health — physical disability, chronic illness, severe or long-term medical conditions, sensory impairments such as hearing or sight loss, cognitive impairments, mental health conditions including anxiety, depression, dementia or conditions affecting memory and decision-making capacity.

Life events — bereavement, divorce or relationship breakdown, job loss or redundancy, retirement, caring responsibilities, domestic abuse, recent diagnosis of a serious illness, or any sudden change in personal circumstances that may affect emotional wellbeing or the ability to engage with financial decisions.

Financial circumstances — low income, irregular income, over-indebtedness, difficulty managing finances, reliance on benefits, financial abuse by a third party, or any situation where taking on additional financial commitments could cause hardship or distress.

Capability — low literacy or numeracy, limited English language proficiency, low financial literacy or limited experience with credit agreements, learning disabilities or difficulties, lack of internet access or digital confidence, or any factor that may affect the customer's ability to understand information, weigh up options and make informed decisions.

Age — older customers who may be more susceptible to confusion, pressure or exploitation, and younger customers who may have limited experience with significant purchases or financial commitments.

These factors are not exhaustive. Vulnerability is personal and context-dependent. Our team is trained to consider each customer as an individual rather than applying a checklist.

How we identify vulnerability

We don't expect customers to disclose their circumstances to us, and we never require them to. Instead, we train our team to be observant, empathetic and responsive to signs that a customer may need additional support. These signs may include:

Difficulty understanding product information, pricing or finance terms after they've been explained. Repeated requests for the same information to be clarified. Signs of confusion, distress, anxiety or agitation during a conversation. A third party who appears to be controlling the customer's decisions or finances. Statements that suggest financial hardship, health difficulties or difficult personal circumstances. Difficulty communicating by the method being used — for example, struggling with a phone conversation or finding written information hard to follow. Requests that seem inconsistent with the customer's stated needs or circumstances. Hesitation or uncertainty about committing to a purchase or finance agreement that seems disproportionate to their situation.

Our team is trained not to make assumptions. A sign of potential vulnerability is a reason to pay closer attention and offer support — not a reason to refuse service or make judgements about the customer's capacity.

How we support vulnerable customers

When we identify or are made aware that a customer may be in vulnerable circumstances, we take practical steps to ensure they receive a fair outcome. These include:

Communication — we adapt how we communicate to suit the customer's needs. This may mean speaking more slowly and clearly, avoiding jargon, providing written summaries of conversations, offering information in larger print or alternative formats, allowing more time for the customer to read and process information, or following up a phone conversation with a written confirmation of what was discussed and agreed.

Decision-making — we give vulnerable customers additional time and space to make decisions without pressure. We never rush a vulnerable customer into a purchase or a finance agreement. If we believe a customer needs more time to consider their options, we encourage them to take it — even if that means pausing the sale and continuing on another day. We explain options clearly, outline the alternatives, and make sure the customer understands what they're agreeing to before proceeding.

Third-party involvement — if a customer wishes to involve a trusted friend, family member, carer or advocate in their conversations with us, we welcome and facilitate that. We will always confirm with the customer that they're happy for the third party to be involved and that the third party is acting in the customer's interests. We will never share personal or financial information with a third party without the customer's explicit consent.

Finance applications — when a vulnerable customer is considering a finance option, we take extra care to ensure they fully understand the total cost, the repayment amounts and frequency, the interest rate, the length of the agreement, and the consequences of missing payments. If we have any reason to believe that a finance agreement could cause the customer financial harm or distress, we will not proceed with the application. We will never encourage a vulnerable customer to take on credit that is beyond their means or that they do not fully understand.

Signposting — where a customer's circumstances suggest they may benefit from independent advice or support beyond what we can provide, we signpost them to appropriate services. This may include debt advice organisations such as StepChange or Citizens Advice, mental health support services, Age UK for older customers, or other relevant charities and support organisations. We provide this information sensitively and without judgement.

Alternative contact methods — we offer flexible ways for customers to communicate with us. If a customer finds phone calls difficult, we can correspond by email. If written communication is challenging, we can arrange a phone call or an in-person conversation at our showroom. If a customer needs someone to visit them or requires a home consultation, we will do our best to accommodate that where possible.

Our responsibilities around finance

As a business that offers finance through FCA-authorised partners, we have a particular responsibility to ensure that vulnerable customers are protected when considering credit. We take the following steps:

We assess each finance interaction individually and consider whether the customer appears to understand the terms being presented. We explain finance agreements in plain language, avoiding technical jargon, and confirm the customer's understanding by asking them to explain the key terms back to us where appropriate. We do not incentivise staff to push finance products on customers who may not be suitable. We flag any concerns about a customer's vulnerability to our finance partners so that additional affordability checks or safeguards can be applied. We ensure that vulnerable customers are aware of their right to cancel a finance agreement within the 14-day cooling-off period and that they understand how to exercise that right. If a customer contacts us after entering a finance agreement and indicates they are struggling with repayments or experiencing financial difficulty, we direct them to the finance provider and to independent debt advice services.

Staff training

Every member of the Bathroom City team receives training on identifying and supporting vulnerable customers as part of their induction and through regular refresher sessions. Training covers recognising the signs of vulnerability across different circumstances, communicating effectively and sensitively with vulnerable customers, understanding the additional protections that apply when offering finance to vulnerable customers, knowing when and how to escalate a concern about a customer's vulnerability to a manager, and being aware of external support services to signpost customers to.

We foster a culture where staff feel confident raising concerns about a customer's vulnerability without hesitation. No member of staff will ever be penalised for pausing a sale, declining to proceed with a finance application, or taking additional time with a customer because they believe vulnerability may be a factor.

Recording and monitoring

Where a customer discloses vulnerability or where our team identifies signs of vulnerability, we record this sensitively and securely in line with our data protection obligations under UK GDPR. Records are kept only for the purpose of ensuring the customer receives appropriate support in future interactions with us and are never shared with third parties without the customer's consent.

We monitor our handling of vulnerable customer interactions through regular review of recorded cases and outcomes, analysis of complaints data to identify any patterns involving vulnerable customers, feedback from staff on the challenges they encounter and the support they need, and senior management oversight of vulnerable customer cases and policy compliance.

Complaints from vulnerable customers

If a vulnerable customer raises a complaint, we apply the same principles of additional care, patience and flexibility that we apply throughout their experience with us. We ensure complaints from vulnerable customers are prioritised and handled with sensitivity. We adapt our complaints process to suit the customer's communication needs. We provide clear updates throughout the complaints process. We escalate to senior management where the complaint involves a vulnerable customer and a potentially harmful outcome. If the customer remains unsatisfied, we provide clear information about external options including the relevant ombudsman and alternative dispute resolution services.

Telling us about your circumstances

You don't have to tell us anything about your personal circumstances — our team is trained to respond to the signs of vulnerability whether or not you disclose them. But if you'd like to let us know about anything that might affect how we communicate with you, how much time you need to make decisions, or any additional support that would help, we welcome that and we'll treat the information with complete confidentiality and respect.

You can tell us in whatever way feels most comfortable:

By phone: 0121 753 0700 By email: customerservice@bathbiz.net In person: 15 Seeleys Road, Tyseley, Birmingham, West Midlands, B11 2LQ

You can also ask a trusted friend, family member or carer to contact us on your behalf — we'll just need to confirm with you that you're happy for us to speak with them.

Ongoing review

This policy is reviewed regularly by our senior leadership team. We update it in response to changes in regulation, guidance from the FCA, feedback from customers and staff, and any trends identified through our complaints and monitoring processes. Fair treatment of vulnerable customers is not a static obligation — it evolves as our understanding of vulnerability deepens and as our customers' circumstances change. We are committed to continuous improvement in how we identify, support and protect the customers who need it most.

Last reviewed: June 2026