KUBE PAY
Vulnerable Customers Policy
Kube Finance Limited
Regulated payment services via Yapily Connect Ltd
Version 1.0 | Last updated: July 2026 | Effective date: July 2026
1. Our Commitment
Kube Finance Limited (trading as Kube Pay) is committed to treating all customers fairly, including those who may be in vulnerable circumstances. We recognise that vulnerability can affect anyone at any time, and that customers in vulnerable situations may have additional needs that require us to adapt how we communicate and deliver our services.
This policy reflects our obligations under the FCA’s Consumer Duty (effective July 2023), which requires regulated firms and their agents to deliver good outcomes for retail customers, including those who are vulnerable. As an agent of Yapily Connect Ltd, FCA No. 827001, we are committed to meeting the standards set out under Consumer Duty and broader FCA expectations on vulnerable customer treatment.
2. What Is Vulnerability
The FCA defines a vulnerable customer as someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care. Vulnerability may be temporary, sporadic, or permanent, and may arise from:
Health: Physical or mental health conditions including anxiety, depression, cognitive impairment, disability, serious illness, or the effects of treatment
Life events: Bereavement, job loss, relationship breakdown, domestic abuse, caring responsibilities, or other significant life changes
Resilience: Low financial resilience or significant financial difficulty, including over-indebtedness
Capability: Low literacy, numeracy, or digital skills; difficulty understanding financial products; language barriers
Kube Pay is primarily a B2B payment platform. However, payers (end customers making payments) may also experience vulnerability, and our obligations extend to ensuring they are not disadvantaged or harmed by our platform or payment process.
3. Identifying Vulnerability
We recognise that vulnerability is not always visible or declared. We will make reasonable efforts to identify signs of vulnerability through:
Communications with our team where a customer appears distressed, confused, or under pressure
Requests for additional time, alternative communication methods, or support with using the platform
Patterns of behaviour that suggest a customer may be struggling, such as repeated failed payment attempts or distressed support enquiries
Direct disclosure by the customer of a health condition, bereavement, or other circumstance
We will never make assumptions about vulnerability based on age, disability, or other protected characteristics.
4. How We Support Vulnerable Customers
Where we become aware that a customer may be vulnerable, we will:
Adapt our communication style by using plain language, avoiding jargon, and taking additional time
Offer alternative communication channels where the standard channel is not suitable (e.g. telephone support in addition to email)
Allow additional time for a customer to make decisions, process information, or provide required documentation
Ensure that vulnerable customers are not pressured, rushed, or disadvantaged in their interactions with us
Refer customers to third-party support organisations where appropriate, such as the Money and Pensions Service (moneyhelper.org.uk) or Citizens Advice
Escalate internally where a situation requires senior review or additional care
5. Complaints and Vulnerable Customers
Customers in vulnerable circumstances who wish to make a complaint will receive additional support through our complaints process. We will not require vulnerable customers to navigate complex processes unassisted. Please refer to our Complaints Policy at kubepay.co.uk/complaints or contact us at complaints@kubepay.co.uk to let us know if you need additional support.
6. Platform Design and Accessibility
We are committed to ensuring that the Kube Pay payment pages and merchant-facing platform are as accessible as possible. Our design principles include:
Clear, plain-language instructions at every stage of the payment journey
High-contrast design and text sizing that meets accessibility standards
No unnecessary time pressure placed on payers completing a payment
Clear signposting at the point of payment authorisation explaining what the customer is consenting to
If you experience difficulty using the Kube Pay platform and believe an adjustment would help, please contact us at hello@kubepay.co.uk.
7. Training and Responsibility
All staff and contractors who interact with customers are trained to recognise signs of vulnerability and respond appropriately. We review our vulnerable customer practices regularly and align them with updated FCA guidance and Consumer Duty outcomes monitoring.
8. Contact
If you need additional support or wish to disclose a vulnerability, please contact us:
Email: hello@kubepay.co.uk
Post: Kube Finance Ltd, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, England
External support organisations:
Money and Pensions Service: moneyhelper.org.uk | 0800 138 7777
Citizens Advice: citizensadvice.org.uk | 0800 144 8848
Mind (mental health): mind.org.uk | 0300 123 3393
Samaritans: samaritans.org | 116 123
Legal Notice
Kube Finance Ltd (trading as Kube Pay) is committed to treating vulnerable customers fairly in line with FCA Consumer Duty expectations. Payment initiation services are provided under the FCA authorisation of Yapily Connect Ltd (FCA Registration Number 827001). Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, England.