Hubpy Customer Exit Policy

v2022.1

Principles

Treating Customers Fairly

Prior to an exit decision

Customer Engagement Following an Exit Decision

Principles

The risk team must assess all existing and prospective customers on a proportionate, objective and non-discriminatory basis.

When carrying out an assessment, the risk team will take account of the laws and regulations in the jurisdictions in which they operate, including those that have extraterritorial reach. The risk team will also take account of policies that often conform to the highest common denominator of the jurisdictions in which they operate to ensure the legal and regulatory protection of their staff and that global legal and regulatory obligations are met.

When the risk team concludes that we cannot offer, or continue with, the provision of a service to a customer, the communications it has with the customer should be sensitive and easy to understand.

These principles set out the approach that the risk team should adopt when communicating a decision to a customer that we cannot offer, or continue with, the provision of our service.

The risk team must balance these important offerings with occasions where we cannot offer, or continue with, our services to a customer.

These occasions may arise for different reasons, for example, the customer’s geographical presence, the customer’s money laundering risk or the customer’s terrorist financing risk. There are also broader Risk Considerations such as those driven by strategic business decisions, increased capital requirements, customer viability and overall cost. A reason or consideration may appear in combination with others, or by ourselves.

If the risk team concludes that we are not in a position to assist a customer, the team must communicate that we cannot offer, or continue with, the provision of a service so far as is feasible and permissible. In every case, our team must treat the customer fairly and communicate in plain language.

If the risk team is considering whether we should not offer, or continue with, the provision of a service to a customer, the team should discuss the matter with the customer, so far as is feasible and permissible, and where necessary secure additional information or funding from the customer. The team should encourage, so far as is feasible and appropriate, the customer to provide any additional information or funding as quickly as is possible to allay its concerns.

There will, however, be situations where it may not be appropriate or permissible for the team to engage in a dialogue to explain their reasoning. Such situations may include:

If the risk team concludes that we should not offer, or continue with, the provision of a service to a customer, the team should:

ensure its decisions that affect the customer have been reviewed, so far as is appropriate, by a person with sufficient authority before they are communicated to the customer;
ensure its decisions take account of financial inclusion considerations and the sensitivities of the customer, for example, customer vulnerability;
tailor its communications with the customer, including setting out its reasoning clearly, so far as is feasible and permissible;
ensure its communications with the customer reflect any specified requirements or preferences, for example, due to a disability or other vulnerable circumstances;
endeavour to identify for the customer, so far as is feasible and appropriate, alternative ways for them to access services;
endeavour to provide an appropriate period of time for the customer to make alternative arrangements, and where possible, reflect the time period needed by the customer;
identify for the customer the way in which representations, or an appeal, can be made against a final decision, including representations to us in the first instance and subsequently an appeal to an external person; and
take informed and proportionate, objective and non-discriminatory decisions that affect the customer, recording the decisions in writing.