Vulnerable Customers policy

Definition of a Vulnerable Customer

A vulnerable customer, as per the Financial Conduct Authority (FCA) definition, is an individual who, due to personal circumstances, is especially susceptible to harm, particularly when a firm lacks appropriate levels of care.

Identifying a Vulnerable Client - Risk Factors

The following non-exhaustive list outlines factors that may categorize a customer as vulnerable:

• Low literacy, numeracy, and financial capability skills
• Physical disability
• Severe or long-term illness
• Mental health problems
• Low income and/or debt
• Caring responsibilities (including operating a power of attorney)
• Being ‘older old’ (e.g., over 80) or young
• Change in circumstances (e.g., job loss, bereavement, divorce)
• Lack of English language skills

Impact of Change in Circumstances and Income

• Changes in personal circumstances, especially when combined with existing risk factors, can lead to vulnerability. Financial shocks resulting from unexpected expenses or loss of income pose significant challenges, affecting emotional well-being, cognitive ability, and decision-making capacity.

Universality of Vulnerability

• Vulnerability can affect anyone, given life's challenges such as job loss, bereavement, or serious illness. It can be short-lived or enduring, sudden or gradual, fluctuating, and episodic.

Types of Vulnerability

• Vulnerability manifests in various ways—temporary, sporadic, or permanent. A flexible, tailored response is essential to address the diverse forms of vulnerability.

How do we treat vulnerable customers?

We provide inclusive and flexible communication channels that are clear, easy to understand, and meet customer needs (phone, email, post etc.)

Individualized Treatment

Recognizing each individual's unique circumstances, our responses are tailored. We aim to listen without judgment, record information diligently, and be transparent with representatives or carers.

If we identify a vulnerable customer staff should take the following steps:

• Active listening – listen to the customer's needs and concerns, allowing them to express themselves fully, and exercise patience throughout the interaction.
• Accessibility - Ensure all documents and materials are easily accessible and provide alternative formats when necessary to accommodate diverse needs if required.
• Confidentiality - Maintain the highest level of confidentiality in handling sensitive information to ensure the customer's privacy and trust are upheld.
• Communication - Adapt communication methods to align with the customer's preferences. This might involve utilizing larger print documents or talking via telephone etc.
• Financial Guidance - For customers experiencing financial challenges discuss their options or direct them to appropriate financial counseling services.
• Empathy and Patience - Demonstrate understanding and patience, especially when dealing with customers facing mental impairments. Allow them the necessary time to make informed decisions

Training and Feedback

We commit to evolving our approach to vulnerable customers, promoting a culture of empathy. Staff receive training to identify signs of vulnerability and provide appropriate support. Conversations are not rigidly scripted, allowing flexibility and understanding.

We acknowledge that some customers may be vulnerable due to financial profiles or impairments. We assess each customer individually, ensuring financial products are appropriate, staff are trained to identify vulnerability, and communication is respectful and clear. We encourage customers to seek independent advice when appropriate, fostering a customer-centric approach that benefits all.