Consumer Duty and Vulnerable Customers Policy

1. Purpose

Finaap Ltd ("Finaap") provides a financial management and tax platform. Part of what we offer, Open Banking bank connections, is a regulated account information service. Finaap Ltd is registered with the Financial Conduct Authority as an agent (firm reference number 1053812) of Finexer Ltd, which is authorised by the FCA under the Payment Services Regulations 2017 (firm reference number 925695) to provide account information services. Open Banking connections in Finaap are provided by Finexer, with Finaap acting as its agent.

The FCA's Consumer Duty requires authorised firms to deliver good outcomes for retail customers. It applies to the Open Banking service, and Finexer is responsible to the FCA for how Finaap delivers that service as its agent. This policy sets out how we meet that responsibility.

The rest of the Platform (budgeting, insights, debt organisation and tax features) is not regulated by the FCA. We have chosen to apply the same standards across everything we do, because our customers are often managing tight finances and the stakes for them are real.

2. Scope

This policy applies to our directors, staff, contractors and developers, and to every stage of the customer relationship: marketing, sign-up, use of the Platform, support, complaints, cancellation and account closure.

3. Our customers

Our customers are individuals, sole traders and small companies in the UK. Many are managing debt, irregular income or tax for the first time. Their financial knowledge, digital confidence and circumstances vary widely. We design and run the Platform on the basis that any customer may be, or may become, vulnerable.

4. The four outcomes

5. Open Banking specifically

For the Open Banking service we commit to the following, in line with Finexer's requirements and the Payment Services Regulations 2017:

• explicit consent before any bank data is accessed, with a clear explanation of what will be accessed and why
• read-only access; no payments or changes to the customer's account
• reconfirmation of consent at least every 90 days, with a reminder before it expires
• disconnection at any time, with deletion of bank data within 30 days
• no use of bank data for marketing, no sale of data, and no sharing beyond the providers listed in our Privacy Policy
• Open Banking complaints passed to Finexer promptly and handled within the FCA's timescales, with customers told about the Financial Ombudsman Service
• cooperation with Finexer's monitoring, audits and regulatory reporting

6. Avoiding foreseeable harm

We have identified these main risks of harm and how we manage them:

7. Vulnerable customers

A customer may be vulnerable because of their health, a life event (such as bereavement, job loss or relationship breakdown), low financial resilience, or low capability with money or technology. Many Finaap customers are managing debt, which can itself be a sign of vulnerability.

We will:

• treat any customer who tells us they need extra help, or whose circumstances suggest it, with additional care
• communicate clearly and in the way the customer prefers, and allow a trusted person to help them where authorised
• never pressure a customer, and give them time to make decisions
• make it easy to cancel, pause, or reduce their plan if money is tight
• signpost free, impartial sources of help: MoneyHelper, StepChange, National Debtline and Citizens Advice
• record what a customer tells us about their needs only with their agreement, keep it secure, and use it only to support them
• train everyone who deals with customers to recognise and respond to signs of vulnerability

8. Governance and review

Our director has overall responsibility for this policy and for customer outcomes. At least quarterly we review complaints, cancellations, support queries and usage data for signs that customers are not getting good outcomes, and record what we found and what we changed. We review this policy at least annually and whenever the Platform, the law or Finexer's requirements change materially.

9. What this means day to day

• Every new feature is checked against sections 4 and 6 before it goes live.
• Every customer-facing message about money, debt or tax is written in plain English and labelled as information.
• Every HMRC submission has a review and confirm step.
• Every complaint is logged, acknowledged and answered within our published timescales, and Open Banking complaints go to Finexer the same or next business day.
• Every customer who tells us they are struggling is signposted to free advice and offered a cheaper or free option.
• Everyone who speaks to customers has read this policy and knows how to recognise vulnerability.

10. Contact