Vulnerable Consumers Policy

1. Purpose

ProMediate (UK) Limited is committed to ensuring that all consumers can participate effectively in our Alternative Dispute Resolution (ADR) procedures regardless of age, disability, illness, language, financial circumstances, bereavement, mental capacity, digital exclusion or any other factor that may make them vulnerable.

This Policy explains how ProMediate identifies vulnerability, the assistance that may be available and the steps taken to ensure consumers are able to participate fairly throughout the ADR process.

2. Our Commitment

We recognise that vulnerability may be temporary, permanent or situational. Consumers may become vulnerable because of:

Our ADR process is designed to be flexible so that consumers are not disadvantaged because of vulnerability.

3. Identifying Vulnerability

Consumers are encouraged to tell us if they require any assistance. Vulnerability may also become apparent through:

• correspondence;
• telephone conversations;
• information provided by representatives;
• supporting documents;
• observations made by ADR Officials.

4. Reasonable Adjustments

Where appropriate, ProMediate may offer reasonable adjustments including:

• Additional time to submit information;
• Flexible timescales;
• Telephone rather than online communication;
• Online rather than face-to-face communication;
• Documents in accessible formats;
• Large print documents;
• Simplified explanations of the ADR process;
• Additional breaks during meetings;
• Allowing a representative, family member or support worker to assist;
• Other reasonable adjustments appropriate to the individual's needs.

Each request will be considered individually.

Further detail is set out in our Reasonable Adjustments Policy.

5. Communication

ADR Officials will communicate clearly, respectfully and without unnecessary legal or technical language wherever possible.

Consumers may request communication by:

• email;
• telephone;
• post; or
• other reasonable methods where appropriate.

6. Representatives and Support Persons

Consumers may appoint:

• a solicitor;
• a family member;
• a friend;
• a support worker; or
• another authorised representative

to assist them throughout the ADR process.

The ADR Official may communicate directly with that representative where appropriate and authorised.

7. Fairness and Independence

Reasonable adjustments are intended to ensure equal participation.

They do not affect the independence or impartiality of the ADR Official, nor do they alter the requirement to consider each dispute fairly and objectively.

8. Confidentiality

Information concerning vulnerability will be treated confidentially and processed in accordance with ProMediate's Privacy Policy and Data Retention Policy.

Such information will only be shared where necessary to administer the ADR process or where required by law.

9. Signposting

Where a consumer appears to require assistance beyond the ADR process, ProMediate may signpost them to appropriate organisations or sources of independent advice.

Such signposting does not constitute legal advice or endorsement of any organisation.

10. Training

ADR Officials and staff receive appropriate guidance regarding:

• recognising vulnerability;
• communicating effectively;
• equality and diversity;
• reasonable adjustments; and
• safeguarding awareness.

11. Responsibilities

All ADR Officials and staff are responsible for implementing this Policy.

The Directors are responsible for monitoring compliance and reviewing the effectiveness of the Policy.

12. Review

This Policy will be reviewed annually or sooner if required by changes in legislation, regulatory guidance or operational experience.

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