This document has been developed by AIMA Drain Cover to provide a comprehensive framework for managing direct marketing activities with a focus on ensuring fair and ethical interactions with all customers, particularly those who may be considered vulnerable. It also outlines the responsibilities of sales representatives working for or on behalf of AIMA Drain Cover to adhere to these standards.
While we do not intentionally target individuals with vulnerabilities, we acknowledge that some customers, particularly those in specific age groups (45+), or those experiencing financial challenges, may benefit from our services. As a result, it is crucial to implement safeguards that ensure transparency, fairness, and ethical marketing practices.
At AIMA Drain Cover, we recognize that vulnerability can take many forms. Vulnerable customers are defined as individuals who, due to their personal circumstances, may face challenges in making informed decisions or are at risk of harm. Examples include but are not limited to:
Difficulty in reading, writing, or managing finances.
Physical disabilities or long-term health conditions.
Mental health challenges or emotional distress.
Limited income or significant financial obligations.
Caregiving responsibilities, such as holding power of attorney.
Older individuals (particularly those over 80), who may face cognitive, physical, or sensory impairments.
Young individuals, who may lack sufficient life experience.
Life changes, such as job loss, bereavement, or divorce.
Non-native English speakers or those with limited language skills.
Unique circumstances, such as returning military personnel, recent immigrants, or individuals with a non-standard credit history.
Vulnerability is not static and can change depending on personal circumstances. Each interaction with a customer should be approached individually to assess their situation appropriately.
Under the Equality Act 2010, it is illegal to discriminate against individuals based on protected characteristics, including disabilities. Additionally, the Mental Capacity Act provides a framework to support individuals who may lack the ability to make informed decisions.
Our representatives must remain alert to signs of vulnerability and act in a manner that prioritizes the well-being of customers. This includes ensuring that services are explained clearly and that customers are not pressured into decisions they may not fully understand.
To ensure that all interactions align with this policy, AIMA Drain Cover provides in-depth training to all employees involved in direct marketing. The training focuses on:
Identifying potential signs of vulnerability.
Assessing the customer’s ability to benefit from our services.
Understanding complex and overlapping characteristics of vulnerability, such as emotional stress caused by life events.
Employees are prohibited from engaging in marketing activities until they have successfully completed this training. Training materials and practices are regularly updated based on feedback, industry standards, and internal assessments.
If a representative identifies signs of vulnerability, they should follow these steps:
Evaluate the Customer’s Needs: Determine whether the customer would genuinely benefit from our services.
Assess Affordability: Confirm that the service is financially viable for the customer.
Ensure Informed Decisions: Verify that the customer fully understands the terms and purpose of the service.
If any of these conditions are not met, the sale must not proceed. Further marketing to the customer may be discontinued based on the circumstances.
To uphold these standards, AIMA Drain Cover conducts regular quality assessments of customer interactions. This includes reviewing randomly selected interactions and investigating concerns raised through complaints or feedback. Any policy breaches are addressed through corrective measures, including re-training, formal warnings, or termination of employment if necessary.
If a breach of policy is identified after a sale, corrective actions may include:
Canceling the transaction.
Providing full or partial refunds.
Suspending payment collections.
Contacting the customer to determine the best course of action.
Decisions will be made on a case-by-case basis to ensure fairness and transparency.
While AIMA Drain Cover cannot share customer account details with third parties without proper authorization, we are committed to supporting customers who require assistance. For example, if a third party notifies us of a customer’s temporary inability to manage their account due to health or personal circumstances, we will make a note of this information to ensure appropriate measures are taken during future interactions.
In cases where a customer’s vulnerability has been identified, AIMA Drain Cover may exclude them from future marketing activities. Regular quality checks are conducted to ensure adherence to this policy, and each case is handled with sensitivity and care.
