Vulnerable Customer Policy 

e movement (owned and operated by Kampyro ltd)



The purpose of this policy is to ensure that the operations of emovement electric bikes and other products do not have any negative impact upon vulnerable consumers. For the purposes of this policy, vulnerable consumers are customers and prospective customers whose ability or circumstances require us to take extra precautions in the way that we sell and provide our services to ensure that they are not disadvantaged in any way.

Vulnerability Groups

We acknowledge that there are specific customer segments that may be more susceptible to vulnerability. While it's important to note that not every customer within these segments will necessarily be vulnerable, we will carefully assess an individual's situation when signs of potential vulnerability are identified. These groups may encompass, but are not limited to:

  • Customers facing communication challenges, including those with learning difficulties, non-native English speakers, or dyslexia.
  • Customers experiencing a decline in physical or mental capabilities.
  • Customers dealing with various health issues, whether they are physical or mental, severe, or long-term in nature.
  • Customers who have received a sudden diagnosis of a serious illness, either personally or within their immediate family.
  • Customers facing personal challenges such as financial difficulties, bereavement, caregiving responsibilities, or redundancy.
  • Customers of varying ages, with a focus on both younger and older individuals. For example, younger individuals may be considered inexperienced, while older individuals may have limited technological proficiency.
  • Identifying a vulnerable consumer over the phone

When engaging with customers over the phone, it is often difficult to identify a vulnerable consumer because it is not possible to see many of the characteristics, such as body language and facial expressions, which may identify whether the prospective customer requires additional information and guidance to enable them to make an informed decision. For this reason, it is critically important to listen carefully to all customers and to identify people who may be classed as a vulnerable consumer.

Typical telephone characteristics include:

  • An inability to hear or understand what is being said
  • Repeated questions of a similar nature
  • Comments or answers which are inconsistent with the telephone discussion or which indicate they have not understood the information which has been provided.
  • Verbal confirmation that they dont understand or that they require the assistance of somebody else in making a decision.

What to do if we are engaging with a vulnerable consumer:

Just because somebody is vulnerable does not automatically mean that they are unsuitable for the products and services the we supplies. As soon as we think we may be engaging with a vulnerable consumer, we should immediately make a record of the same and ensure we adhere to this policy.

When speaking to the vulnerable consumer we:

  • Provide additional opportunities for the customer to ask questions about the information we have provided.
  • Continuously seek confirmation that they have understood the information that has been provided.
  • Ask if there is anybody with them who is able to assist them, and offer them the opportunity to have a family member or friend present during the conversation.
  • Offer them the opportunity to complete the transaction after a period of further consideration.
  • If for any reason we think the customer does not understand the service being offered to them, we will not proceed with the transaction and advise them that we will write to them with further information about the product or services they are seeking.

What is mental capacity?

Mental capacity is a person's ability to make a decision. Whether or not a person has the ability to understand, remember, and weigh-up relevant information will determine whether they can make a decision based on that information. The person will also need to be able to communicate their decision.

Mental capacity limitations may be permanent or temporary and may be related to various conditions, including but not limited to mental health conditions, dementia, learning disabilities, developmental disorders, neuro-disabilities or brain injuries, and the influence of alcohol or drugs.

Making decisions

Mental capacity is always defined in relation to a specific decision at a specific time. Consequently, when considering an application for a product or change in product factors, we take account of the customer's circumstances at the time at which the application or request is made. We take appropriate steps to identify whether or not the customer appears able to understand, remember, and weigh-up the information and explanations provided to them and, when having done so, make an informed decision. Mental capacity limitations can be either permanent or temporary (or be fluctuating over time). Consequently, the fact that a person may not have had the mental capacity to make a particular type of decision in the past does not necessarily mean that they currently do not have, or will never have, the capacity to make such a decision.

When offering purchase options to customers with mental capacity limitations, we provide information regarding their purchase that they can take away or have sent to them to enable them to research and consult with other parties to enable them to make an informed decision.

Mental capacity limitations may also be partial. Under such circumstances, the person concerned is likely to be able to make certain decisions but not others. Decisions that may require the understanding, remembering, and weighing-up of relatively complex information are likely to be more challenging for many individuals with mental capacity limitations than more straightforward spending decisions.

Amongst the most common potential causes of mental capacity limitations are the following (this is a non-exhaustive list):

    • Mental health condition

    • Dementia

    • Learning disability

    • Developmental disorder

    • Neuro-disability/brain injury

    • Alcohol or drugs (including prescribed drugs) induced intoxication.

A customer may be understood to have or be suspected of having any of these (or other) conditions which are potential causes of mental capacity limitation (for example, a mental health condition). However, that does not necessarily mean that they do not have the mental capacity to make an informed decision. In some instances, it may constitute disability discrimination for the purposes of the Equality Act 2010 (EA) to decline a customer's application for a product on a presumption that he doesn't have the mental capacity to make a particular decision based solely on the knowledge that he has a condition of the type listed above.

Financial literacy

Mental capacity is not the same as financial literacy, but they may overlap in practice. We acknowledge that it can be challenging to differentiate between the two limitations, and we will apply this vulnerable consumer policy in both circumstances. We encourage customers to voluntarily disclose any health or well-being issues that may be relevant to their decision-making process to better facilitate informed services. If a customer provides information indicating they have a mental capacity limitation that might impact their ability to make an informed decision, this should trigger us to consider what reasonable steps might be taken to ensure the customer is treated fairly, and a positive outcome is achieved for the customer. Should our staff detect signs of vulnerability, we would signpost our customers to bodies that provide support such as; Samaritans and the Money Advice Bureau. emovement does NOT offer financial advice.

Training and Support

We are committed to providing comprehensive training to our staff to enable them to identify and treat vulnerable customers appropriately. Training includes making staff aware of the company's Vulnerable Customer Policy and its information, recognizing signs of vulnerability, tailoring communication approaches, and providing emotional support and guidance. We also offer practical and emotional support to frontline staff dealing with vulnerable consumers. Whenever staff feel they are unable to deal with or make a decision in relation to a vulnerable customer, they have the option to pass the enquiry on to higher management.

Review and Improvement

emovement actively reviews management information monthly by reviewing feedback and how we deliver finance, to ensure it is delivering good outcomes for vulnerable customers. If a vulnerable customer does not receive a good outcome, we will take appropriate actions, investigate the case, and implement necessary improvements immediately.

Additional Information

The FCA outlines Actions firms should take to treat vulnerable customers fairly: Guidance for firms on the fair treatment of vulnerable customers | FCA

The FCAs webinar to learn about our Vulnerability Guidance and the role you and your firm play in ensuring customers are treated fairly: Webinar: Consumer Vulnerability | FCA

FCA details their work on the fair treatment of vulnerable customers: FCA Fair Treatment of Vulnerable Customers

The FCA Principles for Businesses require firms to treat customers fairly, and we expect firms to exercise particular care with vulnerable consumers."

Customer Complaint Policy

e movement is committed to delivering top-notch service to all our customers. Should you encounter any issues, we want to hear about it promptly so we can address it effectively, maintain our high standards, and uphold our stellar reputation.

If you have a complaint, please reach out to us in writing via letter or email. We will promptly acknowledge receipt within 3 working days.

What happens next?

1. A dedicated member of our staff will thoroughly investigate the complaint.

2. We will engage with you to establish a mutually positive outcome.

3. If the matter persists after initial discussions, we will provide a detailed written reply within 21 days of receiving the complaint. This will include suggestions for resolving the issue.

4. If you remain dissatisfied, the Director will personally oversee a review of the decision and work with you to address your concerns.

If you are not satisfied with your recent experience with eMovement, you can raise a complaint by contacting our complaint team at or using our Contact Us page.

We aim to resolve your complaint as swiftly as possible. Our commitment is to provide you with our final response within 4 weeks, detailing our resolution. Should there be any delay beyond this timeframe, we will promptly inform you of the reason and provide an expected timeline for issuing our final response.