1. Scope

The scope of this Vulnerable Customer Policy for AB Money is to ensure that vulnerable customers are identified and supported appropriately in line with FCA and industry guidance. The policy applies to all AB Money employees, including those in the finance and operations team, KYC team, compliance team, MLRO, and senior management. The policy covers the responsibilities of each department, escalation procedures, AB Money's operating model and risk mitigation, data privacy and retention policies, vulnerable customer logs, and risk mitigation control measures. By implementing this policy, AB Money aims to provide a high level of support to vulnerable customers, mitigate risks associated with vulnerable customers, and comply with all relevant regulations and legislation.

2. Introduction

AB Money is committed to ensuring that vulnerable customers are identified and supported in line with the FCA and industry guidance. This policy sets out the procedures to be followed by AB Money employees and the measures put in place to mitigate risks associated with vulnerable customers.

3. Definition of Vulnerable Customers

Vulnerable customers are defined as individuals who are more susceptible to harm than the average consumer when accessing financial services due to their personal circumstances, including but not limited to:

• Age
• Physical disability
• Mental health conditions
• Learning disabilities
• Long-term illness or health conditions
• Bereavement
• Financial difficulty

4. Employees Responsibility

All AB Money employees have a responsibility to identify and support vulnerable customers.

The following departments have specific responsibilities:

Finance and Operation Team:

• Identify any customers who may be experiencing financial difficulties and provide them with appropriate support, such as payment plans or debt management advice.
• Ensure that all communication with customers is clear, understandable, and in line with the customer's needs and circumstances.
• Provide vulnerable customers with the necessary support to manage their finances and access financial services.

KYC Team:

• Ensure that all customers' identities are verified in accordance with AB Money's procedures.
• Identify any customers who may be vulnerable due to their personal circumstances and provide them with appropriate support, such as access to specialist services or guidance.

Compliance Team:

• Ensure that AB Money complies with all relevant regulations and legislation relating to vulnerable customers.
• Monitor AB Money's performance in supporting vulnerable customers and identify areas for improvement.
• Provide training and support to employees on identifying and supporting vulnerable customers.

MLRO:

• Ensure that appropriate measures are in place to prevent money laundering and financial crime relating to vulnerable customers.
• Monitor AB Money's performance in supporting vulnerable customers and identify areas for improvement.
• Provide training and support to employees on identifying and supporting vulnerable customers.

Senior Management:

• Ensure that AB Money is committed to supporting vulnerable customers and that policies and procedures are in place to ensure that this happens.
• Provide the necessary resources to support employees in identifying and supporting vulnerable customers.
• Monitor AB Money's performance in supporting vulnerable customers and identify areas for improvement.

5. Escalation to AB Money Compliance Team and MLRO

If an AB Money employee identifies a vulnerable customer, they should escalate this to the Compliance team and the MLRO within the firm. The Compliance team and the MLRO will then assess the situation and determine the appropriate course of action.

6. AB Money Operating Model and Risk Mitigation

AB Money has a risk-based approach to identifying and supporting vulnerable customers. We have a system in place to monitor customer transactions and identify any unusual activity that may indicate a customer is vulnerable. We also have measures in place to ensure that employees are aware of the risks associated with vulnerable customers and how to mitigate them.

7. Data Privacy and Retention Policy

AB Money takes data privacy seriously and has strict policies in place to protect customer data. We only collect and retain data that is necessary for the provision of our services, and we ensure that it is stored securely and in accordance with data protection legislation.

8. Vulnerable Customer Logs

AB Money maintains vulnerable customer logs to record any interactions with vulnerable customers and the support provided. This information is used to monitor our performance in supporting vulnerable customers and to identify areas for improvement.

The logs must include:

• The customer's name and contact details
• The reason the customer has been identified as vulnerable
• Details of any support provided to the customer, including referrals to specialist services
• Any additional measures taken to ensure the customer is protected, such as increased security checks

Vulnerable customer logs must be kept up to date and securely stored in accordance with AB Money's data retention policy.

9. Risk Mitigation Control

AB Money has measures in place to mitigate the risks associated with vulnerable customers, including:

• Providing employees with training and support on identifying and supporting vulnerable customers
• Conducting regular reviews of our policies and procedures to ensure they are up to date and effective
• Monitoring our performance in supporting vulnerable customers and identifying areas for improvement
• Ensuring that vulnerable customer logs are kept up to date and securely stored
• Providing vulnerable customers with appropriate support, such as access to specialist services or guidance

10. Customer Duty Road Map

A1) Customer base in the UK

Our services and products are designed for customers and corporate clients residing in the UK.

A2) Information sources from advertising channels below

Implements marketing source and channel to UK markets with accurate product and services information underlying of permission with the regulator (FCA). There are multiple marketing sources reachable to the market with different method below.

Apps (ABFX) Engage with ABFX application for comprehensive information and registration.

Word of Mouth

Consider recommendations and experiences shared by other customers.

Website:

Explore our official website for detailed offers and updates.

Social media

Facebook and IG are stay informed through our social media channels

Line application:

Stay connected and receive updates through our Line application channels.

Email:

Receive direct communications and updates via email.

A3) Acknowledged and understand the information.

Providing comprehensive information on the website is crucial for transparency and ensuring that customers have access to all the details they need. It fosters a sense of trust and clarity.

• Website : www.abmonyplus.com
• Application : ABFX

A4) Onboarding process via Mobile app under KYC / KYB requirement

Customers have the option to open an account through either our website or the mobile application (ABFX). To initiate the process, they are required to complete the application form, providing necessary personal or business information in adherence to our KYC/KYB policy. The required documentation for both business and personal account is outlined below.

Document for Personal Account

• Valid passport / UK driving license
• UK proof of address with no longer than 90 days i.e. Bank statement, Utility bills.
• Photo: Require taking selfie photo under limits of time under fraud prevention check
• Applicant Information under CDD process i.e. contact details, occupation etc.
• The information has been successfully sent to the AB Plus team.

Document for Corporate Account

• Active Company Certificate
• Business proof of address with no longer than 90 days i.e. Bank statement, Utility bills.
• Article & Memorandum
• Products / Services or marketing channel i.e. Website
• SOF/SOW
• Annual Financial Statements

Director

• Valid passport / UK driving license
• UK proof of address with no longer than 90 days i.e. Bank statement, Utility bills.
• Fit & Proper test for all directors and shareholders owned business exceed 25%
• The information has been successfully sent to the AB Plus team for

A5) Customer Screen check i.e. PEPs, Sanction, Adverse Media etc.

Reviews information on pending from customer.

• AB Plus operation team reviews basic data that meet KYC/KYB criteria policy and submit the data.
• The data has automated API check with global screen check for Sanction, PEPs, adverse media and more (Comply advantage).

Compliance firewall has conduct for risk control (On profile base)

• The system has automated the risk measurement through a business-wide risk assessment, utilising data from applications such as the nature of business.
• All profiles are in pending status, awaiting reviews by the compliance team.

Compliance team reviews profile and makes decision.

• The compliance team will conduct thorough double checks on the profile to ensure that all submitted documents meet the criteria under KYC/KYB policies.
• The compliance team will verify that the profiles do not match with global PEPs/Sanctions data reported, ensuring adherence to regulatory standards.
• The compliance team will review risk level on profile that measure by firewall as may request more documents support from the applicant.
• The compliance team will conduct a review of the risk level associated with the profile, as measured by the firewall. If necessary, additional supporting documents may be requested for the applicant.
• The compliance team will make decision on the profile neither approve, decline, or requested additional document.

A6) Incomplete documents and Information

• In the case of incomplete documents and information, compliance team may request additional documentation, such as the case of unaccepted documents, the team will specifically request new documents or additional identification to further verify and enhance fraud prevention measures.
• If the customer failed to provide the required additional documentation or fails to undergo the verification process, the compliance team will proceed to decline the profile.

6.1 Application Rejected

• In the event of an applicant rejection, we promptly communicate with the customer, offering our sincere apologies and providing reasons for the rejection under our risk appetite. Send information to apologised to customer with the reason such as under our risk appetite, Customer onboard account from outside the UK etc.

B1) Onboarding Account completed with Welcome Pack including support documents under T&C to customer.

Once the onboarding process has been completed, signifying the successful opening of the account, the customer will receive a Welcome Pack. This pack is designed to ensure that the customer receives all information about the products and services. The Welcome Pack is sent to the customer via email and includes the following documents.

-Framework contract

-Sigle payment contract

-Consumer account T&C

-Consumer card T&C

-General Data Protection Regulation (GDPR)

-Payments Fee

-Complaint Policy

-AB Plus T&C

-Client Register Plus Confirmation

B2) Support Team/ Help Line over the phone / Emails / Chat

Our support team is committed to providing assistance to customers through a diverse range of channels, ensuring accessibility and convenience. Whether customers prefer reaching out over the phone, via email, or through chat, our team is readily available to address inquires, offer guidance, and provide solution to enhance their overall experience. AB Plus strive to crate a seamless support system that cater to the diverse needs and preferences of our valued customers.

- Card loss / Stolen

- Forget Pin

-Q/A about Products / Services

- Complaint

B3) Customer Unsatisfied

In the event that a customer expresses dissatisfaction, we provide a structured avenue for resolution by inviting them to submit a complaint application through our official website: www.abmoneyplus.com. This streamlined process is detailed in the channel below.

- Welcome Pack

- Website

- Support Team

By making these resources easily accessible, we aim to ensure that any issues raised by customers are promptly and effectively addressed, fostering a positive and responsive customer experience.

Example detail on the Complaint form on the website

Following complaints policy published on Complaint us (abmoneyplus.com)

Customers must be completed to in the complaints form.

• Type of customer either personal or business
• Customer ID
• Customer name
• Incident Title
• Complaint Description
• Submit

B4) Complaint Review Customer Duty Champions

Customer Duty Champion obligates and engages with customers to solve problems.

• Upon customers submitting the compliant form on our website, the details are promptly flagged and alerted within our system. This proactive notification ensures that our team is immediately aware of customer concerns, allowing for a swift and coordinated response to address the issues raised.
• The Complaint team will examine the case and subsequently escalate it directly to the department responsible for addressing the specific complaint.

B5) Decision with Comments & Record for improvement

Upon reviewing customer complaints, our team makes informed decisions to provide resolution.

• Signed off the case for Resolved / Unresolved: The case is carefully examined, and a decision is made to either mark it as resolved or unresolved based on the outcomes of the investigation.
• Case override to Rails for unresolved complaints: In cases where a resolution is not achievable, the case will be overridden to our Rails system.
• Authorised sign-off with comment: An authorized sign-off by detailed comments, is affixed to the case. These comments serve as a valuable record, providing information about the decision-making and specific details related to the resolution.
• Further improvement: As part of our commitment to continuous enhancement, each resolved and unresolved case prompts a reflection on areas for improvement. This ongoing process contributes to refining our complaint-handling procedures and elevating the overall customer experience.

B6) Supervisor Sight off on the case

The final step involves the supervision and oversight of resolved and unresolved cases. This is conducted by key executives below.

-CEO

-COO

-CFO

-MLRO/CCO

Their collective input ensures that decisions align with organizational standards, regulatory compliance, and the overarching goal of delivering exceptional customer service. This muti-layered supervision guarantees a thorough and robust resolution process for customer complaint

A1) UK Base Customer

Upon the case being reviewed and signed off as either resolved or unresolved, we will inform the customer. This communication will include a clear explanation of the resolution status and reasons. Additionally, we will seek valuable feedback from the customers to ensure that their satisfaction is met and to gather insights that contribute to our ongoing commitment to service and product improvement.

We need to ensure that customers acknowledge and understand the products and services which it suitable for customers’ usages.

11. Assist and Support to Vulnerable Customers

Vulnerable customers are defined as individuals who are more susceptible to harm than the average consumer when accessing financial services due to their personal circumstances, including but not limited to:

• Age
• Physical disability
• Mental health conditions
• Learning disabilities
• Long-term illness or health conditions
• Bereavement
• Financial difficulty

AB Money provide Assist and Support to Vulnerable Customers in different method for ensure to help customers able to achievement requirements.

11.1 Support Line

In terms of Ages and Learning disabilities is difficult to customers for access to new technology, mobile applications, web interface. That is mean customers unable to reach, understand on products for achievement.

Customers can contact to support team for learning on products and services or assist process on behalf if necessary.

• Chat support line via Facebook and Line
• Telephone Call: +44 (0) 203 355 9660

11.2 Presentation and VDO

We set up VDO shot for all feature and functionality on mobile applications for allow customers has clear picture and understanding with the products and services.

11.3 E-Meeting

Some vulnerable need specialists to assist and support. AB Money can set up E-meeting via Zoom for demonstration on products and services under requirements.

11.4 Debt management

In the case of Physical disability, Mental health conditions, Long-term illness or health conditions and Bereavement that unable or lack of financial income for remaining the commercial cost on products fee.

We able to negotiate and offer the waiver monthly fees up to 90 days.

Example: The pandemic by Covid19 made customers loss job and unable to effort monthly fees.

AB Money is not bank, we cannot provide credit and loan services for vulnerable customers.

12. Conclusion

AB Money is committed to identifying and supporting vulnerable customers in line with FCA and industry guidance. We have measures in place to mitigate the risks associated with vulnerable customers and to ensure that employees are aware of their responsibilities. We will continue to monitor our performance in supporting vulnerable customers and identify areas for improvement.