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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:
  1. 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.
  2. .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.
  3. physical impairment – may be identified visually, or through interview
  4. severe and long-term illness – may be identifiable through conversation.
  5. “financially unsophisticated” or “under banked” – may be identified through the fact find process and their credit profile
  6. low income – may be identified through credit profile
  7. .in financial distress – may be identified through credit profile
  8. carers – may be identified through conversation
  9. poor language skills – may be audible or identifiable via routes of engagement
  10. .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.

Our responsibilities:

  • To abide by the FCA’s principles and rules in this area
    1. FCA Principles for Business 6 & 7
    2. ICOBS 2.2.2R; and 6.1.5R;
    3. CONC 8.2.7;
    4. DEPP 6.5A.2 (calculation of enforcement fines); and
    5. Individual conduct rules (treating customers fairly).
      1. To ensure staff are aware of this policy and are adequately trained to identify and deal with clients who are or may appear “vulnerable”
      2. To support individuals in relation to identified risk and vulnerability
      3. To provide means of reporting any instance where they believe that a client might be in vulnerable circumstances

Responsibilities of our employees:

  • To be familiar with this policy and procedures, and be able to recognise where additional support or sign-posting to other agencies may be required
  • To take appropriate action in line with this policy
  • To report any instance where they believe that a client might be in a vulnerable circumstance, and act accordingly in line with the policy


91-99 Duke Street



LA14 1RH

01229 832 094


Mon to Sat 9am - 5pm

Sun 11am - 4pm

Bank Hol 11am - 4pm

Monday 9am–5pm

Tuesday 9am–5pm

Wednesday 9am–5pm

Thursday 9am–5pm

Friday 9am–5pm

Saturday 9am–5pm

Sunday 11am–4pm

Bank Hol 11am–4pm

Dandy's Ltd
Reg. Office: 91-99 Duke Street, Barrow In Furness, Cumbria, LA14 1RH
Reg No: 4393426