Vulnerable Customers Policy

Black Knights (“we”, “our”, or “us”) is an AI-focused technology company based in Gigiri, Nairobi, Kenya. We believe every customer deserves to be treated fairly, with dignity and respect — and that some customers need additional care to access our services and communicate with us effectively.

This policy explains what we mean by vulnerability, how we identify when a customer may need extra support, and the practical steps we take to deliver good outcomes for customers in vulnerable circumstances.

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm — particularly when an organisation is not acting with appropriate levels of care. Vulnerability can be permanent, temporary, or situational, and it can affect anyone at any time.

We recognise four broad drivers of vulnerability:

These drivers can overlap and interact. We treat vulnerability as a spectrum rather than a fixed label, and we focus on the support a person needs rather than on categorising them.

This policy applies to all interactions between Black Knights and the individuals we engage with — including clients, prospective clients, the customers and end users of systems we build for clients (where we interact with them directly), and visitors who contact us. It applies across every channel: email, phone, web forms, video calls, and in-person meetings.

Customers will not always tell us they are vulnerable, and they are never required to. We aim to create an environment where it is easy and safe to disclose a need for support. Our team is trained to:

• Listen actively and watch for signs that a customer may need additional help
• Ask open, sensitive questions where appropriate, without making assumptions
• Respond flexibly to a disclosure of vulnerability, however and whenever it is made
• Record a customer's support needs only with their consent, and only where it helps us serve them better

A customer can tell us about a support need at any time, and we will adapt accordingly.

Once we are aware that a customer may need extra support, we make reasonable adjustments to help them engage with us on fair terms. Depending on the situation, these may include:

• Giving customers more time to make decisions, with no pressure to act quickly
• Explaining information in plain language and confirming understanding
• Offering an alternative communication channel or format on request
• Allowing a trusted friend, family member, carer, or representative to support the customer (with appropriate authority)
• Adjusting our processes and timelines to accommodate individual needs
• Signposting to specialist external organisations where a need falls outside our expertise

Our goal is always a fair outcome. We will not exploit a customer's vulnerability, and we will never knowingly take advantage of a customer's circumstances.

We strive to make our communications and our website accessible to as many people as possible. We aim to:

• Write clearly, avoiding unnecessary jargon and technical language
• Design our website with accessibility in mind, including readable contrast, keyboard navigation, and descriptive text for images
• Provide information in an alternative format on reasonable request
• Be patient and adaptable in how we communicate, at the customer's pace

Information about a customer's vulnerability is sensitive and is treated with particular care. Where we record support needs, we do so only with the customer's consent, store the information securely, limit access to those who need it, and retain it only for as long as it is needed.

Our handling of this data is governed by our Data Protection Policy and our Privacy Policy.

Treating vulnerable customers well depends on our people. We:

• Train staff to recognise and respond to vulnerability with empathy and good judgement
• Empower team members to use discretion and make reasonable adjustments without unnecessary escalation
• Foster a culture where supporting vulnerable customers is everyone's responsibility
• Review difficult or complex cases to learn and improve

We monitor how well we support customers in vulnerable circumstances and use what we learn — including feedback and complaints — to improve. This policy is reviewed at least annually and updated whenever our practices or applicable guidance change.

If you would like extra support, want to tell us about a need, or have a concern about how we have treated you, please get in touch: