Vulnerable Customer Policy

Need help right now? See Need extra help? for the ways we can adapt, or call us on 020 4569 1189. If you or someone else is in immediate danger, call 999.

1. Policy statement

OneCloud Pvt Ltd, trading as Serving Foxes, is committed to identifying customers who may be in vulnerable circumstances, adapting our service to meet their needs, and ensuring that no customer is disadvantaged or exploited because of those circumstances.

We introduce customers to providers of energy, finance, insurance, payment and home energy products. Many involve long-term contracts or regulated activity, and some are offered to households that qualify for grants because of low income or health conditions. Getting it wrong for a vulnerable customer can mean unaffordable debt, an unsuitable multi-year contract, or work on their home they did not fully understand. This policy exists to prevent that.

2. Scope

This policy covers every director, employee, contractor, installer and lead partner who speaks to customers or handles their data, across all channels: phone, WhatsApp, email, web forms, and home or site visits.

Business customers are covered. A sole trader, a small family business or a charity run by volunteers can be just as vulnerable as a household.

3. What we mean by vulnerability

A vulnerable customer is someone who, because of their personal circumstances, is especially likely to suffer harm, particularly when a firm does not take appropriate care. This follows the FCA's definition and Ofgem's approach. Vulnerability can be permanent, temporary or come and go, and anyone can become vulnerable. For a business customer, we look at the person we are dealing with and the business itself.

Vulnerability is about circumstances, not labels. A customer does not have to tell us, and we never demand proof before adapting our service.

4. Our commitments

Every customer who may be vulnerable will get outcomes as good as any other customer. We commit to:

1. Notice: train staff to recognise signs of vulnerability and to ask open, respectful questions.
2. Adapt: offer more time, other channels, plain-English and large-print documents, interpreters, and the involvement of a trusted person.
3. Never exploit: no pressure selling, no urgency tactics, no sale when we doubt the customer understands or can afford it. Commission never outweighs suitability.
4. Record with consent: note only what we need, with the customer's agreement, so they do not have to repeat themselves.
5. Refer: signpost free, independent help and, with consent, pass needs to suppliers, lenders and insurers.
6. Pause or stop: any member of staff may pause a sale, switch or installation if they are worried, without penalty.
7. Make complaints easy: accept complaints in any form and handle them with extra care.
8. Check it works: monitor outcomes for vulnerable customers and act on what we find.

5. Who is responsible

6. Our procedure

1. Spot it. At the start of every quote we ask: "Is there anything that would make it easier for us to help you, or anything about your circumstances we should know?" We do not diagnose or assume, and age alone does not make someone vulnerable.
2. Respond. We thank the customer, explain how we will use the information and that it stays confidential, ask for consent to record it, ask what would help, and signpost support if appropriate.
3. Record it. We record facts, not opinions. Health details are recorded only with explicit consent. If a customer refuses consent, we record only the adjustment needed (for example "prefers email, large print") and still make it.
4. Adapt. We slow down, offer a call back and a break before any decision, send a plain-English summary of costs, contract length, exit fees and cancellation rights, and wait for the customer to confirm. A trusted person can be involved with the customer's permission.
5. Decide whether to proceed. We stop or pause if the customer does not appear to understand, seems pressured by someone else, cannot afford the product, or may lack mental capacity for the decision. Only the Vulnerable Customer Lead can approve proceeding with a paused sale. We do not complete a sale on the same call where a serious vulnerability was first disclosed unless the customer clearly wants to and understands it.
6. Refer, follow up and review. With consent, we pass needs to the provider (for example the Priority Services Register for households), signpost free help, and review needs after 6 months or at renewal.

Urgent situations

• Immediate risk to life: we call 999.
• Distress without immediate danger: we offer Samaritans (116 123) and, with consent, a call back from the Lead.
• Suspected abuse, coercion or financial exploitation: we stop the sale and the Lead decides on a referral to the local authority safeguarding team or the police.
• Suspected scam targeting the customer: we stop, warn the customer, and report it to Action Fraud.

7. Extra safeguards by service

Business energy, telecoms and water

• We tell the customer, before they agree, that we are paid commission by the supplier and how much, always in the written quote.
• We explain contract length, fixed versus variable rates, standing charges, exit fees and auto-rollover in writing.
• We do not lock a struggling business into a long fixed contract it may not survive.
• If the customer mentions arrears, we tell them about the supplier's support and signpost Business Debtline.
• Verbal contracts on vulnerability-flagged accounts are listened back before submission.

Business finance

• We do not push a merchant cash advance or other high-cost product as a default for "bad credit" customers.
• Personal guarantees and security are flagged clearly and in writing.
• Where a director or sole trader is in financial difficulty, we signpost Business Debtline or a licensed insolvency practitioner before any new borrowing.
• We never advise a customer to hide information from a lender.

Business insurance

• We give extra help at claim time to customers in difficulty, and handle conversations about illness or death with care.

Solar, heat pumps, insulation and grant-funded work (households)

• We only describe a grant scheme as available after checking it is open and the customer is likely eligible.
• No cold-calling or doorstep selling to households that have not asked us to contact them. We respect "no cold callers" signs.
• Home visitors are named in advance, carry photo ID, offer to have a family member present, and leave if asked.
• We explain the 14-day cancellation right in writing. Work does not start in that period unless the customer asks in writing.
• We make clear what is free, what the customer pays, and any finance involved, and explain realistic savings with no exaggerated claims.

Payment solutions

• We explain contract term, minimum monthly charges, terminal rental and early termination fees in writing, and offer pay-as-you-go options where they fit.

8. Sales conduct, complaints, data and training

• Sales and marketing: no false urgency; marketing claims must be accurate and evidenced; commission and targets are reviewed yearly so no one is rewarded for sales that later cancel or cause complaints.
• Complaints: accepted in any form, including from a representative with consent. Complaints from vulnerable customers get priority handling by a senior handler.
• Data protection: information about health, disability or similar is special category data under UK GDPR. We record it only with explicit consent or a lawful exemption, restrict access, and share it only with consent or where the law allows. Customers can ask to see, correct or remove their information at any time.
• Training: all customer-facing staff and installers are trained before first contact and every 12 months. The Lead reports to directors quarterly on outcomes for vulnerable customers, and any gap triggers an action plan.

9. Free, independent support

Approved by the directors of OneCloud Pvt Ltd (trading as Serving Foxes) · Company No. 16991609 · ICO ZC130857 · Version 1.1 · 13 October 2026