Vulnerable Customer Policy

The Financial Conduct Authority (FCA) defines a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”.

The FCA expect firms such as ourselves to treat all customers fairly when dealing with those with vulnerable or perceived vulnerable circumstances and we must take account of this to ensure the methods we employ to describe and sell some of the services we offer, such as IFC finance, are clear and do not cause any detriment to them. 

Core Principles 

When a vulnerable customer is either identified by us, or the customer approaches us with a known vulnerability, we pledge that we will action the following: 

• Consult with the customer to see if they have anybody with them or someone that they can come back with, to assist them with the transaction. If we believe this is an essential support required, we will happily reschedule the transaction.
• Record (signed and dated with a witness) that we believe this is a vulnerable customer and that we will adhere to this policy throughout the transaction.
• Give the customer additional time and opportunity to ask questions and be patient with repeating any information in a clear and concise manner. 
• Continuously confirm throughout the interaction that the customer has understood the information provided.
•  If the customer in any way seems unsure, uncomfortable, or confused, we will offer to give them additional time to consider the purchase before completion. 
• If we cannot assist the customer with our products and services we will endeavour to suggest other avenues which may benefit them.

All staff should feel confident in voicing concern if they suspect they are dealing with a vulnerable customer and know how to proceed with the transaction with the above safeguards in place. If assistance or support is required, the company will provide this. See below for guidance in identifying potentially vulnerable customers. 

Potential Vulnerable Groups 

Certain groups of customers may be considered vulnerable, although not all people in these groups may identify as this and therefore we will assess based on a case by case basis. The below list of groups is not exhaustive and may be amended at any time. 

• Particularly old or particularly young customers (younger customers may be inexperienced and older customers less able with technology).
• Customers who have difficulty with communication and language or for whom English isn’t their first language.
• Personal difficulties – employment issues, caregivers, bereavement, or financial difficulties.
• Health issues – physical or mental illnesses which are chronic, or severe.
• Customers with reduced mental or physical capacities.