Vulnerable Clients Policy

Vulnerable clients –

The FCA defines a vulnerable consumer 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.

A client could be classed as vulnerable for any of the following reasons:

• They have had recent bad news such as a job loss, bereavement, divorce, or ill health
• They have no prior experience in making any financial decisions
• They are anxious about understanding the advice given
• They identify as vulnerable
• They want a third party present at all meetings
• They have a short or long terms illness or disability (physical or mental)
• They are either very old or very young
• There is a language barrier
• Their circumstances have recently changed in a dramatic fashion

The advisor must offer the following:

• To have a third party present at key meetings for support or translation
• To take another gender member of staff to the meeting
• To always make an appointment in advance
• To only use technology/ means of communication that the client is comfortable with
• To meet in a neutral venue
• To allow additional time for the client to absorb all the information
• To allow a client time to consider all documents to be signed.
• To ensure that the client is kept updated as to the progress of the transaction at all times.

We expect all advisors and support staff to be aware of vulnerable clients and to work with such clients with empathy, care and diligence.

We have a register of vulnerable clients that is updated periodically as well as an identifier on the client portal.

We have a vulnerable client form which must be completed with every new client and periodically at review date, if applicable.

The majority of our clients communicate with us via our client portal, however each client is also given the opportunity to communicate with us in person, by telephone, via email and by post. Some clients are only comfortable receiving correspondence via post and this is noted on our vulnerable clients register and client data base.