Vulnerable Customers Policy


We are committed to providing our customers with fair and transparent financial services. We recognise that some customers may be more vulnerable than others, and we have a responsibility to take extra care to ensure that they are treated fairly and not disadvantaged.

This policy sets out how we will identify and support vulnerable customers. It is compliant with the Financial Conduct Authority (FCA)'s Consumer Duty, which requires us to put the needs of our customers first. What is a vulnerable customer?

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a business is not acting with appropriate levels of care. Vulnerability can be caused by a number of factors, including:

  • Age, in particular, older and younger people.
  • Disability
  • Financial hardship
  • Mental health problems
  • Physical health problems
  • Social isolation
  • Substance abuse.

How will we identify vulnerable customers?

We will identify vulnerable customers through a variety of means, including:

  • Talking to our customers
  • Customer surveys
  • Data analytics
  • Staff training.

It is not always easy to identify a customer’s needs so, if you believe you meet the criteria of a vulnerable customer, please let us know as soon as possible of any needs you may have, or any ways we can help. We welcome you letting us know of your needs when you first contact us.

Our staff have access to the FCA guidance ( We also ask everyone to undertake training to identify vulnerable customers and how best to treat them.

How will we support vulnerable customers?

When we identify a vulnerable customer, we will take steps to understand their individual needs and circumstances, and provide any additional level of assistance they may require.

We will support vulnerable customers in a number of ways, including:

  • Providing them with clear and easy-to-understand information
  • Giving them extra time to make decisions
  • Offering them additional support services
  • Seeking confirmation that they have understood the information we have provided, especially where, for example, customer finance applications are being made.
  • Working with others (including family members and friends) to provide support.

If we can’t help, we will go beyond our normal sales process and try and seek alternatives or point customers to where they can best find answers.

How will we monitor our performance?

We will monitor our performance in meeting the needs of vulnerable customers by:

  • Collecting data on the number of vulnerable customers we serve
  • Measuring the satisfaction of vulnerable customers
  • Reviewing our policies and procedures


We strive to treat all of our customers fairly, and we will go the extra mile to meet the needs of our vulnerable customers. If you feel we have not done so or if you have any suggestions as to how we might do things better, please do get in touch by emailing or calling us on 01323 845849. We promise to review and update our policies and procedures to ensure that we are meeting our customers’ needs.


JUNE 2023