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Cycle Solutions (Cycle to Work) Limited is committed to treating all customers fairly and to delivering good outcomes for customers, including those who may be experiencing vulnerable circumstances.
The purpose of this policy is to explain how we identify and respond to the needs of customers in vulnerable circumstances and how we seek to ensure that they receive fair treatment and outcomes that are as good as those experienced by other customers.
We recognise that vulnerability can affect anyone. It may be permanent, temporary, episodic or change over time. A customer's circumstances may also mean that they require additional support at one particular stage of their interaction with us but not at others.
We will seek to act with appropriate care, avoid foreseeable harm and provide support which reflects the individual needs of our customers.
A customer in vulnerable circumstances is someone who, due to their personal circumstances, is especially susceptible to harm, particularly if a business does not act with appropriate levels of care.
Vulnerability can arise for many reasons and does not mean that a customer is unable to make their own decisions.
We recognise four broad drivers of vulnerability:
This may include:
Significant life events can temporarily or permanently affect someone's circumstances. Examples may include:
A customer may have limited ability to withstand financial difficulty or an unexpected financial shock.
This might include customers experiencing:
Some customers may experience difficulties understanding, accessing or using financial products or services.
These examples are not exhaustive. Vulnerability will depend upon the individual customer and their circumstances.
We recognise that customers may interact with Cycle Solutions in different ways, including through our website, telephone services, email, online communications, employers, retail partners and other customer service channels.
A customer may tell us directly that they require additional support, or our colleagues may identify circumstances which suggest that additional support would be helpful.
Indicators may include, for example:
We will not make assumptions about a customer's abilities simply because they have a particular condition or characteristic.
Customers are encouraged to tell us if there is anything about their circumstances that affects how they communicate with us or use our services.
Providing this information is voluntary. We will use relevant information to help us provide appropriate support.
Just because someone is experiencing vulnerable circumstances does not mean that they are unable to use our products or services.
Our objective is to understand what support the customer may need and, where reasonable and appropriate, adapt the way we communicate with or assist them.
Depending on the circumstances, this may include:
Where appropriate, we will take reasonable steps to check that customers understand material information rather than relying solely upon a customer confirming that they understand it.
If we believe that a customer does not sufficiently understand material information needed to make an informed decision, we may pause the process and provide further information or support before proceeding.
The Cycle to Work scheme normally involves an employee agreeing to a reduction in salary in exchange for the provision of a bicycle and/or cycling equipment.
We recognise that changes in personal or financial circumstances may affect a customer's ability to manage salary sacrifice deductions or other financial commitments.
If a customer tells us that they are experiencing financial difficulty, or indicates that a salary sacrifice commitment may cause them financial difficulty, we will seek to ensure that they understand the nature of the commitment and have an appropriate opportunity to consider whether proceeding is right for their circumstances.
Where appropriate, we may explain the options available under the relevant Cycle to Work scheme or refer the customer to their employer where a matter relates to payroll, salary sacrifice or their employment arrangements.
Cycle Solutions will not make assumptions about whether a customer should participate in a Cycle to Work scheme solely because they are experiencing financial vulnerability.
We aim to provide customers with information that enables them to make informed decisions.
Where a customer appears to require additional support, we may adapt our communication to help them understand important information.
This might involve:
Our objective is to support customers to make their own informed decisions wherever possible.
Mental capacity refers to a person's ability to make a particular decision at a particular time.
A person's ability to make a decision may be affected where an impairment or disturbance in the functioning of their mind or brain prevents them from understanding, retaining, using or weighing relevant information or communicating their decision.
Mental capacity is decision-specific and time-specific.
A person may therefore be able to make some decisions but not others, and their ability to make a decision may change over time.
Possible causes of limitations in mental capacity can include, amongst other things:
The fact that a customer has, or appears to have, one of these conditions does not mean that they lack capacity to make a particular decision.
We will not automatically refuse access to our products or services because a customer has a health condition, disability or other characteristic which may be associated with limitations in mental capacity.
Instead, we will consider whether reasonable steps can be taken to support the customer to understand the relevant information and make their own informed decision.
Where we reasonably believe that a customer is unable to understand the material information necessary to make a particular decision, we will not proceed with that decision or transaction until appropriate steps have been taken.
Mental capacity is different from financial knowledge or financial literacy.
A customer may have full mental capacity but find financial information difficult to understand or lack confidence when dealing with financial matters.
Where this occurs, we will seek to provide appropriate support and clearer information rather than attempting to determine whether a customer's difficulty arises from financial capability or mental capacity unless it is necessary to do so.
Where appropriate, we may record information about a customer's support needs so that we can provide appropriate and consistent assistance.
We will seek to record only information that is relevant and necessary for this purpose.
Where possible, we will focus on recording the support or adjustment that the customer requires rather than unnecessary details about a medical condition or other personal circumstances.
For example, it may be more appropriate for us to record that a customer:
Information relating to vulnerability will be handled in accordance with applicable data protection legislation and our Privacy Policy.
Customers can tell us if their circumstances or support needs change.
Customers may wish to have a family member, friend, carer or other trusted person assist them when communicating with us.
We will seek to accommodate this where appropriate, but we may need to obtain the customer's authority and complete relevant identification or security checks before discussing personal information with another person.
Where formal legal authority exists, such as a registered power of attorney, we will deal with the authorised representative in accordance with the scope of that authority.
Customer-facing colleagues receive appropriate guidance and training to help them:
Where a colleague is unsure how best to support a customer, or believes that applying our normal processes may result in an unfair or poor outcome, they should refer the matter to an appropriately authorised colleague or manager.
Customers may interact with other organisations when accessing the Cycle to Work scheme, including their employer and participating cycle retailers.
Where appropriate, we seek to ensure that organisations involved in delivering aspects of our service understand the importance of treating customers in vulnerable circumstances fairly.
Where a partner identifies a concern which requires support from Cycle Solutions, we encourage the matter to be referred to us so that we can consider what assistance may be appropriate.
We regularly consider whether our products, services and customer support arrangements are delivering appropriate outcomes for customers, including customers experiencing vulnerable circumstances.
This may include considering relevant information such as:
Where we identify evidence that customers in vulnerable circumstances may be experiencing poorer outcomes, we will consider the reasons for this and take appropriate action.
Cycle Solutions is committed to creating an environment in which customers feel comfortable telling us when they need additional support.
We will:
If there is anything about your circumstances which affects how you communicate with us or use our services, please tell us.
We will work with you to understand what support may help.
Customers who require additional support can contact our Customer Services team through the contact methods shown on our website.
Policy owner: Cycle Solutions (Cycle to Work) Limited
Approved by: Board of Directors
Effective date: August 2026
Review frequency: At least annually and following any material regulatory or operational change
