VULNERABLE CUSTOMERS POLICY

The Vulnerable Customer Policy aims to identify customers whose decision-making ability may be limited by personal circumstances. We provide a structured framework to avoid financial exploitation and ensure informed consent for all financial, payment, and investment services.

Vulnerable customers are individuals whose ability to protect their own interests is impaired by factors such as:

• Health restrictions (physical, mental, or cognitive).
• Life events (death of a relative, loss of employment, displacement).
• Low financial resilience or lack of digital literacy.
• Addictions or coercion by third parties.

The Board of SCANDIC FINANCE GROUP LIMITED is responsible for integrating vulnerable customer protection into core compliance and risk management. This involves appointing responsible officers, providing staff training, and ensuring regular policy reviews.

We identify vulnerability through self-disclosure or observable signs (confusion, emotional overload, or signs of pressure). Handling involves simplifying communication, allowing additional reflection periods, and avoiding high-risk or complex products.

For our staff, the process involves:

1. Initial Assessment: Support teams identify markers of vulnerability.
2. Communication Adjustment: Using clear language and offering written summaries.
3. Escalation: Referring sensitive cases to Compliance and Risk Management.
4. Risk Analysis: Reviewing transactions for potential exploitation or abuse.