Our Aim
The aim of this policy is to outline the practice and procedures for staff to contribute to the prevention of detriment to clients who find themselves in vulnerable circumstances.
The policy covers all staff within the company, and in particular those operating in areas that deal directly with customers.
Vulnerability is broad and may occur at any time. It will usually involve the interplay of characteristics of the individual, their circumstances, and static or transitory status. We only deal with customers in vulnerable circumstances where we are aware of their needs:
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mental capacity deficiencies – the FCA provides clear guidance on the identification of mental capacity limitation issues in their Handbook, specifically under CONC 2.10.8.
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.stress or financial shock – may be identifiable (facial expression, posture or stance etc.), but otherwise may be revealed through conversation before and during the process.
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physical impairment – may be identified visually, or through interview
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severe and long-term illness – may be identifiable through conversation.
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“financially unsophisticated” or “under banked” – may be identified through the fact find process and their credit profile
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low income – may be identified through credit profile
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.in financial distress – may be identified through credit profile
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carers – may be identified through conversation
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poor language skills – may be audible or identifiable via routes of engagement
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.clients aged 75 and over – should be offered the opportunity to have a relative or friend accompany them.
The nature of the need area to be addressed may also indicate vulnerability. For example, in connection with arranging finance
In these circumstances we will apply additional safeguards, as appropriate, to ensure fair treatment.
