ZYC-CONSUMER-001 Consumer Duty & Vulnerable Customers Policy
(Applies to all Zeyro staff, directors, contractors, and consultants — Updated October 2025)
Background
Zeyro operates under the FCA’s Consumer Duty (PRIN 12), which requires us to act to deliver good outcomes for retail customers. We approve and monitor financial promotions that may reach UK consumers and therefore must ensure that our decisions, communications, and oversight uphold the Duty and protect vulnerable customers as defined in FG21/1.
This policy sits within the Conduct & Governance Suite and underpins all Zeyro activities — including onboarding, promotion approvals, and ongoing monitoring.
Purpose
To ensure Zeyro:
Acts in good faith towards retail consumers.
Avoids foreseeable harm by identifying and mitigating risks in client promotions.
Enables informed decisions through clear, fair, and not-misleading communications.
Recognises and supports vulnerable customers in line with FCA expectations.
Scope
Applies to every Zeyro business line — Cryptoasset promotions, OFR fund promotions, and Facilities services — and to all staff involved in reviewing, approving, or monitoring client communications that could reach UK consumers.
Key Principles
1. Acting in Good Faith
Always assess whether a client’s promotion or disclosure could mislead or disadvantage its audience.
Challenge clients constructively and record any remedial guidance provided.
Controls risk by embedding fairness and integrity into the approval process.
2. Avoiding Foreseeable Harm
Identify potential risks to retail consumers before approval (complexity, volatility, or unrealistic claims).
Consider the product’s full customer journey, not just the promotion in isolation.
Withdraw or amend approvals promptly when new risks emerge.
Controls risk by preventing foreseeable detriment before promotions go live.
3. Enabling Informed Decisions
Apply the “clear, fair, and not misleading” test in every review.
Check that risk warnings are prominent, specific, and understandable.
Use readability testing (e.g. Flesch-Kincaid ≤ grade 8).
Controls risk by ensuring retail investors can understand the products being promoted.
4. Vulnerable Customers
Recognise vulnerability across four categories: health, life events, resilience, and capability.
When reviewing promotions, ask whether the content or medium might disadvantage these groups.
Require clients to demonstrate fair treatment and suitable support mechanisms.
Controls risk by preventing exclusion or harm to vulnerable or less-experienced customers.
5. Responsibilities and Oversight
The MLRO/Compliance Officer owns this policy and reports Consumer Duty performance to the Board.
Each reviewer must apply the Duty’s principles in daily work and record outcomes in Jira.
Breaches or concerns are escalated immediately to the MLRO.
6. Training and Culture
All staff receive annual Consumer Duty and vulnerability training.
Case studies are used to reinforce judgment and proportionality.
Controls risk by embedding customer-centric thinking throughout Zeyro’s culture.
7. Monitoring and Review
Outcomes monitoring is built into:
Financial Promotions approvals (clarity and comprehension testing).
Ongoing monitoring (checking live promotions and client conduct).
The MLRO reviews this policy annually or sooner if FCA guidance changes.
Controls risk by ensuring continuous alignment with regulatory expectations.
Last updated