Customer Vulnerability Policy

Denaee Super App & Fintech Group

1. Introduction

At Denaee Super App & Fintech Group, we are committed to ensuring that all customers, including those who may be vulnerable due to financial, physical, or personal circumstances, receive fair treatment and support. We recognise that vulnerability can affect a person’s ability to manage their finances, make informed decisions, or fully engage with our services. As a responsible financial and digital service provider, we strive to identify, understand, and support vulnerable customers while upholding the highest standards of ethics, fairness, and regulatory compliance.

2. Defining Vulnerability

A vulnerable customer is someone who, due to personal circumstances, financial hardship, or other conditions, may be at a higher risk of harm or disadvantage when using financial or digital services. Vulnerability can be temporary, situational, or long-term, and may arise from:

• Health-related issues – including mental health conditions, disabilities, or chronic illnesses.

• Life events – such as bereavement, divorce, or job loss.

• Financial difficulties – including low income, debt, or economic instability.

• Lack of digital literacy or financial knowledge – affecting the ability to use online services effectively.

• Language barriers – limiting access to essential support and services.

• Cognitive or learning impairments – impacting decision-making abilities.

3. Identifying and Supporting Vulnerable Customers

We have comprehensive policies and procedures to identify and support customers who may be experiencing vulnerability. Our approach includes:

3.1. Staff Training

• Our customer support teams receive specialist training to recognise signs of vulnerability and provide appropriate assistance.

• Employees are trained to communicate with empathy, patience, and clarity, ensuring that customers receive the support they need.

3.2. Flexible and Personalised Support

• We offer customised financial solutions such as payment plans, fee waivers, or financial counselling referrals for customers experiencing hardship.

• Vulnerable customers can nominate a trusted representative to manage their accounts on their behalf.

• Our digital accessibility features ensure that all customers, including those with disabilities, can navigate and use our services with ease.

3.3. Clear and Accessible Communication

• We provide information in plain, jargon-free language to ensure full comprehension.

• Customers can access support through multiple channels, including phone, email, live chat, and in-person assistancewhere applicable.

• Translation services are available for customers facing language barriers.

4. Protecting Vulnerable Customers from Financial Harm

Denaee takes proactive measures to protect vulnerable customers from financial harm, including:

• Implementing strict security measures to prevent fraud and unauthorised transactions.

• Monitoring accounts for signs of financial distress, such as unexpected withdrawals or difficulty making payments.

• Providing budgeting tools, spending alerts, and financial education resources to help customers make informed decisions.

• Allowing customers to set self-imposed spending limits to prevent financial overextension.