Vulnerable Customers Policy


Having a defined and structured Vulnerable Customer Policy in place is not just a regulatory requirement; it is an essential business function. This manual provides guidance in everyday regulated business activities on how to identify customers that may be particularly vulnerable, what action should be taken and how to help support the customer.  This is to ensure that all customers are treated in a clear, fair and consistent manner.

From the 31st July 2023, Treating Customers Fairly (Principle 6) was superseded with the Consumer Duty (Principle 12).  Vulnerability featured explicitly as a factor within the Consumer Duty; therefore we updated our manual to reflect this.  This includes training staff with the knowledge on how to identify characteristics of vulnerability so they can provide additional support and help customers receive good outcomes.

In addition to this the FCA expanded the scope of insurance aspects of the Covid Guidance to cover all customers in financial difficulty.  This follows on from their Financial Lives Survey, which highlighted that 1 in 4 UK adults had low financial resilience.  As such, we decided to produce a new section ‘Supporting Customers in Financial Difficulty’.  This section provides additional guidance to staff and advisers on how to support customers and the options available to those in financial difficulty.

FORMAT: All documents are downloadable via email upon receipt of payment.


WORD DOCUMENT – 13 PAGES – Last Updated – Sept 2023


  1. Introduction
    1. Good Outcomes
    2. Embedding Consumer Duty
  2. What is a Vulnerable Customer?
    1. Main Characteristics of Vulnerability
    2. Impact of Coronavirus
  3. What should you look out for?
    1. Identifying vulnerability
  4. What to do
    1. Recording and Assessing Customer Needs
  5. Staff Training and Awareness
    1. Staff Capability Requirement
  6. Supporting Customers in Financial Difficulty
    1. Customer Support