Vulnerability Policy
JBW Employee Information Manual V2 January 2015
Introduction
JBW recognises it has a role in ensuring that people of all equalities, backgrounds and demographics
are treated appropriately and with respect, and that the vulnerable and socially excluded are
protected and that appropriate discretion must be used during the recovery process.
JBW accept they may be the first to identify the vulnerability of the person and that this must be
reported to the creditor immediately.
JBW ensures that all staff are trained to adhere to our Equality and Diversity policy.
Equality and diversity definition
JBW define Equality as ensuring individuals or groups of individuals are treated fairly and equally and
no less favourably, specific to their needs, including areas of race, gender, disability, religion or belief,
sexual orientation and age in accordance with the Equalities Act.
JBW defines Diversity as recognising, respecting and valuing people’s differences by promoting an
inclusive culture for all.
Vulnerability definition
It is impossible to define vulnerability completely. JBW class a vulnerable person as one who fails to
understand the situation and potential consequences of enforcement action or where the enforcement
action will cause serious distress to the individual.
Categories
Those who may potentially be vulnerable are classed;

the elderly

people with a disability

the seriously ill

the recently bereaved

single parent families

pregnant women

the unemployed

those who have obvious difficulty understanding, speaking and/or reading English
Where the vulnerability is obvious and where it would be inappropriate to continue the recovery
process the Enforcement Agent will compile a report and return the case to the creditor.
Where a claim of vulnerability is made but it is not visually clear the Enforcement Agent will seek
evidence in order to report the situation to the creditor.
JBW Employee Information Manual V2 January 2015
Where the case is not returned to the creditor discretion will be used and an alternative recovery
method sought (payment arrangement, referral to an advice centre, etc).
Minors
The Enforcement Agent will withdraw from a property where the only available person appears to be
under the age of 18.
Training and monitoring
JBW will ensure all appropriate employees that have contact with customers will have attended and
taken part in mandatory City and Guilds accredited training on dealing with Vulnerable Debtors and
Equality and Diversity before commencement of work with JBW.
Refresher training will be provided to all employees as part of their ongoing training & development
and incorporated into audits which may involve:

enforcement agent on-street audit and compliance visits

contact centre agent audit
The results of any monitoring procedure will be reviewed at regular intervals to assess the
effectiveness of the implementation of this policy.
Language assistance
At the request of a customer or the Councils we will provide documentation in any of the GLA
Languages, large print, Braille or appropriate audio format in compliance with the Disability
Discrimination Act (DDA) provision.
Enforcement Agents will have access to IT applications via equipment supplied by JBW for translation
of documents and voice translation.
We use the services of LanguageLine to offer translation services to speakers of languages other
than English. The process for this is as follows:

customer selects their language from an identification sheet

counsellor/agent contacts relevant LanguageLine translator

translator explains purpose of visit

translator confirms if customer willing to discuss case through translator (for data protection
reasons)

once confirmation received translated visit takes place
JBW Vulnerability Policy January 2015
Version 2 May 2014
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The following languages can be provided under this service include:

Albanian

Arabic

Bengali

Cantonese

Croatian

Czech

Farsi

French

German

Greek

Gujarati

Punjabi

Hindi

Romanian

Italian

Russian

Japanese

Somali

Korean

Spanish

Kurdish

Swahili

Lithuanian

Turkish

Mandarin

Ukrainian

Polish

Vietnamese

Portuguese
Advice sector
The advice sector plays a large role in negotiating with enforcement agents on behalf of their clients.
They find that those they most commonly represent are often vulnerable. JBW work closely with the
advice industry to ensure vulnerable persons are identified swiftly and handled appropriately, with the
minimum of stress to the individual. JBW offer a direct line and a dedicated team to assist the advice
sector reach an early resolution. This partnership enables prompt eradication of those who cannot
pay and ensures a sensitive and sensible approach to those classed as vulnerable.
JBW Vulnerability Policy January 2015
Version 2 May 2014
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Vulnerability Process
The below diagram illustrates our vulnerability process:
JBW Vulnerable Customer Process
Vulnerability identif ied
through client data or
propensit y sc oring
Vulnerability identif ied
through cont act centre
Vulnerability identif ied
during enforcem ent agent
visit
Update details on AR-12
Add de tails to eAgent
Case plac ed on hold
Case plac ed on hold
Call tra ns ferred to
customer care t eam
Enforc ement agent
withdraws from case
AR-12 genera tes task for
customer care t eam
Cus tom er ca re and we lfare (CCW)
team
CCW team contacts
customer to confirm
circ um stances
CCW team contacts
clie nt to a gree
course of action where
appropriate
Revise de bt or fees /
esta blish payme nt pla n
JBW Vulnerability Policy January 2015
Version 2 May 2014
Return case
CCW team Liais es with
Independe nt debt a dvisor
where requested or
appropriate
Continue enforc ement
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