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9. Vulnerable Customers

The 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”. Accordingly, such customers may require a different level of engagement in order for their particular needs to be met. ‘Particularly’ vulnerable customers are those who might not have the mental capacity to make financial decisions.

Consumers in vulnerable circumstances may be significantly less able to represent their own interests than the average consumer, and more likely to suffer harm. Any consumer can become vulnerable at any time in their life, for example through serious illness, bereavement or loss of income. It is expected that more consumers will be in vulnerable circumstances since the onset of Covid-19, and many of those will be newly vulnerable and/or have multiple drivers of vulnerability.

Our policy

  • Access - The overriding objective of handling vulnerable customers is to seek to provide them with the same access to products and services as is available to all customers.
  • Support - Vulnerable customers will be provided with support suited to their specific vulnerability.
  • More favourable treatment - Where appropriate, vulnerable customers may be offered more favourable treatment than non-vulnerable customers in order to account for their vulnerability, e.g. provided with more time to make financial decisions.
  • Systems and processes - We will seek to ensure that our systems and processes do not cause additional stress for vulnerable customers.

What it means to you

If you are or become vulnerable, we will seek, where appropriate, to:

  • ensure you are not disadvantaged in accessing our products and services,
  • provide you with support to suit your particular circumstances,
  • take a flexible approach to applying our policies, e.g. for collecting arrears, and
  • take a flexible approach to applying our standard operating procedures to accommodate your requirements.