Fraud Awareness

Yeeld Financial Services Limited ("Yeeld" or "the Firm" – Company Number ) is an innovative and comprehensive fi nancial fi rm that empowers individuals to save, earn, and grow fi nancially by using the Yeeld super app. Yeeld is a co-brand of Payload Ltd, who act as a Programme Manager under Transact Payments Limited (TPL), a company which is incorporated and registered in Gibraltar with company number 108217 and registered offi ce is at 6.20 World Trade Center, 6 Bayside Road, Gibraltar, GX11 1AA. Transact Payments Limited is a licensed electronic money institution authorised and regulated by the Gibraltar Financial Services Commission to issue electronic money and provide payment services. By providing essential banking services, enticing cashback and rewards programmes, and effortless round-up functionalities, Yeeld strives to empower its users with the tools and knowledge to save, earn, and grow their wealth, nurturing fi nancial inclusivity and prosperity for all.
Yeeld is proud to collaborate with industry-leading partners to deliver exceptional services and enhance our operational capabilities. Our partnerships with Integrated Finance, Transact Pay Limited (TPL), Thredd, Sumsub, and Bud Financials enable us to provide innovative, secure, and customer-centric solutions across payments, compliance, and fi nancial management.
This document details the steps that Yeeld Financial Services Ltd ("YEELD" or "the Firm”) will undertake to ensure that it appropriately considers and supports its customers during ongoing or temporary vulnerabilities.
The Vulnerable Customer Policy applies to all employees, whether permanent, part-time, contract, or temporary, including anyone who acts on behalf of YEELD regarding the services provided to YEELD's customers. The standards outlined in the Policy will apply to providers where the third party interacts directly with YEELD's customers.
This Policy has been put in place to ensure that YEELD delivers fair outcomes to its customers, considering the circumstances of each customer and tailoring its approach, including removing any barriers that may impact a customer's ability to access YEELD's services.
This Policy is intended to provide direction to all YEELD's staff and third-party partners regarding the regulatory requirements and the expectations YEELD has in identifying and responding appropriately to vulnerable customers' needs and requirements.
This Policy is aligned with the FCA’s final guidance regarding the fair treatment of vulnerable customers, issued in February 2021 and referred to in Appendix A.
YEELD has no appetite for non-compliance with this Policy.

Ensuring that customers in vulnerable circumstances are treated fairly, with empathy and sensitivity to their circumstances, is a growing priority for the Financial Conduct Authority and other regulators such as GFSC. As a fi rm, YEELD acknowledges that vulnerable customers will likely need additional assistance at some stage to avoid detriment (fi nancial or psychological) when accessing its services.
Vulnerability is a key focus area for the Financial Conduct Authority (FCA) and GFSC(Gibraltar Financial Services Commission). By supporting its vulnerable customers, YEELD will align its approach to ensure that its customers are treated fairly.
The FCA and GFSC expect the fair treatment of vulnerable customers to be embedded in a fi rm's culture, processes, and policies. To achieve this, YEELD ensures that this Policy is adhered to across all areas of its business, including any activity that may be conducted on its behalf by any third parties.

Your provision of your personal data and our processing of that data is necessary for each of us to carry out our obligations under the contract (known as the customer terms and conditions or similar) which we enter into when you use our payment services. At times, the processing may be necessary so that we can take certain steps, or at your request, prior to entering into that contract, such as verifying your details or eligibility for the payment services. If you fail to provide the personal data which we request, we cannot enter into a contract to provide payment services to you or will take steps to terminate any contract which we have entered into with you.
Thus, YEELD considers vulnerability any personal, social, or other factors(s) that may impact an individual's ability to exercise informed decision-making, rendering them vulnerable to suggestion or lacking the necessary confi dence. This can include long-term or short-term factors.
There is a broad range of circumstances and situations including, but not limited to:
- Customers - Anyone who is in direct contractual agreement with Yeeld Financial Services Limited/Yeeld.
- Illness/Sickness – This could be owing to a short-term condition or something of a longer-term nature and greater severity, such as convalescing or coping with terminal ill health. There is no defined list, but it is essential to be aware that someone may be suffering from an illness, recovering from surgery, or coming to terms with a debilitating or terminal condition.
- Vulnerable Customer: A vulnerable customer is someone who due to their current personal circumstances may be susceptible to detriment and therefore may require us to engage with them in a different and specific way to meet their individual needs.
- Vulnerability: A characteristic which renders someone susceptible to physical or non-physical harm.
- Age – Elderly customers and our increasing aging population mean we will deal with people with various age-related conditions. This could range from being hard of hearing and unable to clearly articulate their requirements owing to conditions such as dementia or Parkinson's.
- Disability – Disability has a broad definition and could range from a form of deafness, being partially sighted, to the restricted use of limbs or limited mobility. As such, interacting with such customers may require us to be patient in accommodating them. At the same time, they organise themselves whilst communicating with us, or where the disability means we must take time to listen or explain things.
- Bereavement – Losing a partner, a relative, or a close friend may temporarily render a customer susceptible or vulnerable while they deal with the grief. For many, this may mean being unable to think straight or make rational decisions. As with some other areas, it may not always be immediately evident, and the customer may not mention this.
- Communication – If a communication issue arises, such as a language barrier where a customer's first language is not English, the customer should be treated equally to those who do not have communicative barriers. Adequate provisions should be implemented to give the customers fair service and ensure they are treated fairly and equally.
- Mental Capacity – Those customers who may have or are suspected of having limitations in mental capacity should be provided with assistance to overcome this. The assistance should be provided to overcome this to ensure customers are treated equally to those who do not face such constraints. Appropriate protections are to be put in place to mitigate the potential risks to such potentially vulnerable customers.
Given the broad range of potential scenarios that may render an individual vulnerable, staff are required to consider all aspects of a customer's circumstances when dealing with them and to exercise utmost care and professionalism. Notably, as a customer may be vulnerable due to circumstances, these may not always be evident in our dealings with them.

The treatment of vulnerable customers is considered within the FCA Principles for Businesses (PRIN). Principle 6 is the regulatory cornerstone for directing regulatory expectations on fi rms, requiring that fi rms' must pay due regard to the interests of its customers and treat them fairly.' The approach to the treatment of vulnerable customers evolves in line with consumer and regulatory demands. Treatment of vulnerable customers is covered within FCA (Financial Conduct Authority) principles, GFSC principles and is supported through industry and regulatory guidancewhich is monitored and refl ected within the Policy. The principles are:
a) From the FCA:
- Principle 2 (Skill, care, and diligence): Firms must conduct their business with due skill, care, and diligence, considering the needs of different customers, including vulnerable ones.
- Principle 3 (Management and control): Firms must take reasonable care to organise and control their affairs responsibly and effectively, with adequate risk management systems. This includes considering the potential risks associated with the treatment of vulnerable customers.
- Principle 6 (Customers' interests): Firms are expected to pay due regard to the interests of their customers and treat them fairly. This principle emphasises the fair treatment of all customers, regardless of their vulnerability.
- Principle 7 (Communications with clients): Firms must pay due regard to the information needs of their clients and communicate information to them clearly, fair, and not misleading. This is particularly important when dealing with vulnerable customers who may require added clarity and support.
- Principle 9 (Customers: relationships of trust): Firms must take reasonable care to ensure the suitability of their advice and discretionary decisions for any customer who is entitled to rely on their judgment. This principle underscores the importance of building and maintaining trust in customer relationships, which is especially critical for vulnerable customers.
- Principle 12 (Consumer duty): A firm must deliver good outcomes for retail customers.
b) From the GFSC:
- Principle 3 (Due skill, care and diligence): Financial service providers must conduct their business with due skill, care and diligence, having proper regard to risk and to its business clients.
- Principle 6 (Regard to interest of clients): A fi nancial service provider must have due regards to the interests of its clients and treat them fairly.
- Principle 7 (Communication with clients): A fi nancial service provider must have due regard to the information needs of its clients and communicate with them in a way that is fair, clear and not misleading.
- Principle 9 (Suitability of advice to clients): A fi nancial service provider must take all reasonable steps to ensure that any advice it gives to, or discretionary decision it takes in respect of, a client is suitable for that client.
c) From the European Union:
- The European Union uses the Unfair Commercial Practices Directive (UCPD) to underline the various factors which seem to be common in between the multiple definitions available of the term ‘vulnerable consumers’. The UCPD highlights that the most popular definitions of this term include key factors such as powerlessness, lack of control over the interactions on the market and the higher risk of suffering harm or detriment.
- In addition, this Policy reflects the firm's legal obligations in respect of:
  - The Equality Act (2010) – YEELD will not discriminate against such customers and, where necessary, will make reasonable adjustments.
  - The UK General Data Protection Regulation and the Data Protection Act 2018 – YEELD will consider its regulatory obligations when processing special category data (please refer to the Data Protection Policy).
- This general requirement clearly indicates fair customer treatment and embraces all customer interaction and service aspects.
- The term vulnerable customer emerged as part of the Financial Conduct Authority's Treating Customers Fairly initiative, which focused on the importance of delivering fair customer outcomes, a key principle of the FCA.
- Much consumer protection legislation is underpinned by the notion of the average or typical consumer and what that typical consumer might expect, understand, or how they might behave. However, consumers in vulnerable circumstances may be significantly less able to represent their interests and be more likely to suffer harm than the average customer. Firms, therefore, need to ensure that consumers are adequately protected.
- Vulnerability can affect people's interaction with any consumer market. Still, it is particularly challenging in financial services due in part to the long-term nature of commitments and the complexity of products and information.
- YEELD is required to treat all its customers

The key risks we face when dealing with vulnerable customers are summarised as follows:
- The failure to identify a customer vulnerability where this may not be obvious and forming inappropriate judgements that then drive the wrong types of behaviour directed at customers.
- Failure to adopt a consistent, customer-centric approach, irrespective of whether the customer has a vulnerability, creates a difference in customer service standards – notwithstanding that the fi rm needs to respond to individual customer needs.
- A poor customer experience leads to misunderstanding customers' requirements and needs, resulting in them making inappropriate purchases.
- Negative customer feedback, complaints, and costly remediation when things go wrong.
- Reputational damage and loss of market share.
- Regulatory intervention, censure, or fine.

The following are fundamental principles that must be adopted. Failure to adopt them may result in performance management being invoked.
The following are some examples of principles that the Firm will adhere to. All staff should be vigilant to identify and respond appropriately:
- 1. YEELD will treat all customers with courtesy and respect.
- 2. The Firm will adopt the necessary skills and behaviours to ensure customers receive professional customer service, including, where necessary, affording them the necessary time to deal with us.
- 3. YEELD will seek support from colleagues or the management team if we encounter a vulnerability we do not feel able to handle. This is not a performance management issue but a prudent and professional response to dealing with a difficult circumstance.
- 4. The firm will not form preconceived ideas or responses based on how customers interact with us.
- 5. The Firm will not make defamatory comments or remarks (either to colleague(s) internally) or externally about our customers.

YEELD will consider its target market, including the potential for customer vulnerability when designing its products or services, enabling customers with vulnerabilities to achieve the same outcome as customers who do not exhibit vulnerability characteristics. As such, all products and services will be designed and regulatory monitored to ensure they are appropriate for the target audience. This will include considering a product or service's positive and negative impact and addressing any adverse effects. The Firm will ensure that communications with its clients are clear, fair, and not misleading and will be reviewed periodically to ensure they continue to meet the target audience's needs.

YEELD provides training to its staff to identify any vulnerable customers and provide the additional level of assistance that may be required to achieve a good outcome. The Firm acknowledges that recognising vulnerability characteristics may not always be easy. Therefore the Firm must recognise and identify the potential triggers or signs of vulnerability to allow the Firm to make reasonable adjustments or support the additional needs of its customers. The FCA has identifi ed four drivers of vulnerability:
- i) Health
  ii) Life Events
  iii) Resilience
  iv) Capability
- Any banking partner which provides underlying banking services;
- Identity verification agencies to undertake required verification, regulatory and fraud prevention checks;
- Information security services organisations, web application hosting providers, mail support providers, network backup service providers and software/platform developers;
- Document destruction providers;
- Mastercard, Visa, digital payment service partners or any third party providers involved in processing the financial transactions that you make;
- Anyone to whom we lawfully transfer or may transfer our rights and duties under this agreement;
- Any third party as a result of any restructure, sale or acquisition of TPL or any associated entity, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us; and
- regulatory and law enforcement authorities, whether they are outside or inside of the United Kingdom (UK) or European Economic Area (EEA), where the law requires us to do so.
The FCA has identified the key drivers of vulnerability, detailed below. Please note this is not an exhaustive list:
- Table 1 Characteristics associated with the 4 drivers vulnerability
  Health
  Life events
  Resilience
  Capability
  Physical disability
  Retirement
  Inadequate (outgoings exceed income) Or erratic income
  Low knowledge or confi dence in managing fi nance
  Severe or long-term illness
  Retirement
  Over-indebtedness
  Poor literacy or numeracy skills
  Hearing or visual impairment
  Income shock
  Low savings
  Poor english language skills
  Mental health condition of disability
  Relationship breakdown
  Low emotional resilience
  Poor or non existing digital skills
  Addiction
  Domestic abuse (Including economic control)
  Learning difficulties
  Low mental capacity or cognitive disability
  Caring responsibilities
  No or low access to help or support
  Other circumstances that affect people’s experience of fi nancial services e.g. leaving care, migration or seeking asylum, human trafficking or modern slavery, convictions.
YEELD recognises that its customers may sit within a spectrum of vulnerability, putting certain customers at greater risk of harm than others. Those customers disclosing or displaying any or multiple drivers of vulnerability are likely to require more support. Early action is vital to prevent and reduce the risk of harm to such customers.
Signs of vulnerability can be identified during conversations with the Firm’s customers. These should serve as flags to employees. This may include disclosure of the following:
- Long-term underlying illness;
- Physical or mental disability;
- Bereavement of a family member or close friend;
- Loss of income;
- Financial difficulty;
- Substantial debt.
- Struggles with financial matters or obligations.
- Business restructuring.
- Signs of agitation.
Other signs may be uncovered during a conversation with a customer, such as:
- Difficultly understanding simple matters;
- Difficulty retaining information – including over multiple interactions;
- Relying on a third party for advice;
- Avoidance of certain types of communication channels, e.g., digital channels.
- A change in behaviour e.g. suddenly missing payments.

YEELD understands that just because someone is vulnerable does not automatically mean they are unsuitable for its products and services. Where the Firm may be engaging with a vulnerable consumer, it will adhere to the requirements set out in this Policy.
Treatment
When dealing with vulnerable consumers, all staff are required to remain aware of the following guidelines:
- Remain patient and empathetic; do not rush the client, interrupt or appearimpatient. Allow the customer to arrive at their own decisions.
- Ensure the customer can hear and understand what is being said; ask the client to explain what is being said or include questions as frequently as possible to ensure they know and understand what is being discussed.
- Allow the customer to explain thoroughly; do not assume the customer already knows their requirements or needs, and do not ﬁnish their sentences, which often implies you are rushing them to progress the conversation. Listen carefully to the customer and remain conscious of any absence of understanding, hints at unawareness, or forgetfulness of topics already discussed.
- Clarify that the customer is comfortable with the standard and method of communication and offer to provide details in an alternate format, such as via post or email, for clarity. Before acting on a vulnerable customer's instructions, ask if there is anybody else they need to speak to about this.
- Offer alternative formats of communication such as using a larger print, Braille or alternative formats, such as via post or email, for clarity. Regularly check with the customer that the method of communication is suitable to their needs.
- Processes and procedures, including any changes, should be tailored to identify and address vulnerability speciﬁc to the nature of the product or service offered and interactions throughout the customer journey. Before acting on a vulnerable customer’s advice, inquire if there is anyone they need to speak to about their decision.
When a vulnerable customer has been identiﬁed, a relevant note should be added to their record to ensure awareness extends to all staff within the company who deal with the client. However, this should only be done where the Firm has explicit and informed consent from the customer, in line with the data protection regulation.
CS agents must offer regular reviews for customers identiﬁed as vulnerable, adjusting the frequency based on their circumstances to ensure continued appropriate classiﬁcation and treatment.
Where a vulnerable customer has cause to complain and their complaint cannot be resolved by the customer service team, the complaint should be triaged by the complaints team. Where the complaint may impact upon the customers vulnerability the complaint will be given priority status and share with Transact Pay(TPL) and all other relevant partners.
Identiﬁcation
Yeeld is committed to treating all customers fairly and ensuring that vulnerable customers receive the support and care they need throughout their interactions with our services. Our approach is centred on fostering understanding, empathy, and ﬂexibility to help vulnerable customers achieve good outcomes and maintain equitable access to our products and services.
Indicators of vulnerability may surface during interactions with our customers. These should serve as ﬂags to customer services agents, who should then ask searching questions to uncover the full extent of the vulnerability.
These conversational indicators may encompass the revelation of:
- Long-term underlying illness.
- Physical or mental disability.
- Bereavement of a family member or close friend.
- Loss of income.
- Substantial debt.
- Struggles with ﬁnancial matters or obligations.
- Financial difﬁculty.
- Business restructuring.
- Signs of agitation.
Additional cues may emerge during discussions with the customer, such as:
- Difﬁculty grasping simple ﬁnancial concepts.
- Challenges in retaining information, even across multiple interactions.
- Dependence on a third party for advice.
- Aversion to speciﬁc customer platforms, indicating a lack of proﬁciency in digital skills.
- A change in behaviour e.g. suddenly missing payments.
Approaching the initial discussions with patience, consideration, sympathy, and ﬂexibility is crucial. Extra caution is warranted when multiple ﬂags coincide, signalling a vulnerability that may necessitate extensive external support for achieving a positive customer outcome.
Products, Channel and Business change
Implementation and adherence to this guidance is mandatory for all areas of the business of Yeeld as required by TPL including any third parties who operate on behalf of Yeeld.
The product scope includes:
- All customer products:
- From design through to implementation and any changes to existing products.
- Including, but not limited to, personal and business payment accounts, e- wallets, andcards (prepaid, credit, debit).
- All customer interactions:
- Customer Promotions / Advertisements.• Any processes or services that have been outsourced to a third party.
Product Design
Products are reviewed to ensure they enable vulnerable customers to achieve the same outcomes as others. Any potential negative impacts on vulnerable customers are identiﬁed and addressed during the design process.
Digital Channels
- Inclusive digital products are designed to accommodate diverse customer needs, including those with limited digital skills.
- Content, navigation, and accessibility features (e.g., font readability, keyboard navigation, and audio descriptions) are prioritised.
Customer Service
- Systems and processes are designed to facilitate disclosure of vulnerabilities.
- Responsive customer service ensures unique needs are addressed, including options for third-party support and alternative communication methods.
Monitoring and Implementation
Yeeld ensures adherence to its Vulnerable Customer Policy through robust monitoring and training programs.
Training
- All employees, particularly customer-facing staff, complete mandatory training on vulnerable customer care during onboarding and annually thereafter.
Monitoring Measures
- 1. Monthly Management Information (MMI) Reports:
  - Provide updates on strategies, actions, and outcomes for vulnerable customers.
  - Ensure senior management oversight.
- 2. Incident Evaluation:
  - Document instances where customer needs were unmet and develop action plans for improvement.
- 3. Employee Skills Assessment:
  - Evaluate and enhance staff capabilities through eLearning and constructive feedback.
- 4. Data Analysis:
  - Monitor complaints and account activity to identify patterns and emerging risks.
- 5. Continuous Improvement:
  - Regularly evaluate interventions and outcomes to reﬁne processes and policies.

Stay Alert, Stay Safe — Yeeld Fraud Prevention Guide