Vulnerable Customer Policy

This Vulnerable Customer Policy outlines TRASTRA’s commitment to identifying, supporting, and protecting vulnerable customers who use our services. We recognize that certain individuals may be more susceptible to financial difficulties or exploitation and are committed to treating them fairly, ensuring their safety, and providing appropriate assistance.


Definition of Vulnerable Customers

Vulnerable customers are individuals who, due to their personal circumstances, characteristics, or situations, may be at a higher risk of experiencing negative outcomes or challenges when using our services. This may include, but is not limited to:

  • Elderly individuals (aged 65 years or more)
  • Persons with disabilities, individuals with mental health issues (physical, sensory, cognitive, or mental health disabilities that can hinder their ability to access services or information, or that may require accommodations for effective communication and access; people with health-related challenges that may limit their mobility and capacity to access services or information etc.)
  • Individuals facing financial hardship (low-income individuals, individuals with unemployment or loss of income, individuals with a high level of debt relative to their income, or those struggling to meet financial obligations, individuals being bankrupt or are at risk of foreclosure on their home, individuals with low savings or investments, individuals receiving government assistance such as unemployment benefits, etc.)
  • Victims of financial abuse or exploitation
  • Individuals with limited English proficiency



Fair Treatment: TRASTRA is dedicated to treating all customers, especially vulnerable customers, with fairness, respect, and dignity. We will not discriminate against or exploit vulnerable customers in any way. In cases where TRASTRA deems it necessary, additional clarification will be provided to vulnerable individuals who may require further understanding.


Identification: We will implement procedures to identify potentially vulnerable customers based on the information available to us, as well as through customer feedback and self-declaration, behaviour.


Communication: We will make efforts to communicate with vulnerable customers in a clear, accessible, and empathetic manner. This includes providing information in plain language and accommodating communication preferences whenever possible.


Support and Assistance: We will offer additional support and assistance to vulnerable customers who require it, such as providing guidance on using our services, understanding fees, and making informed financial decisions. TRASTRA does not provide financial advice and holds no responsibility for the financial decisions made by vulnerable customers.


Privacy and Confidentiality: We will handle the personal and financial information of vulnerable customers with the utmost confidentiality and sensitivity, adhering to relevant data protection laws and regulations.



Identification and Training: All TRASTRA employees will receive training to recognize signs of vulnerability and understand their responsibilities when dealing with vulnerable customers.


Assessment and Support: When a vulnerable customer is identified or self-declares, our customer support team will assess their needs and provide appropriate assistance. This may include offering guidance on using our platform, explaining fees, or connecting them with relevant resources.


Customized Solutions: For vulnerable customers facing financial challenges, we will explore options for flexible payment arrangements, fee waivers, or other solutions based on their circumstances.


Communication Preferences: We will respect and accommodate the communication preferences of vulnerable customers.


Feedback and Improvement

TRASTRA encourages feedback from vulnerable customers and their advocates regarding their experiences and suggestions for improvement. We will use this feedback to continually enhance our processes.

Compliance and Review

This Vulnerable Customer Policy aligns with relevant regulations and industry best practices. It will be reviewed periodically to ensure its effectiveness and relevance. Necessary updates will be made to reflect changes in business operations and customer needs.