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Vulnerable Consumer Policy


Vulnerable Consumer Policy

1.0 Introduction

Ensuring that customers in vulnerable circumstances are treated not only fairly, but with empathy and sensitivity to their circumstances is a growing priority for the Financial Conduct Authority and other regulators. Vulnerable clients are likely to need additional assistance at some stage in order to avoid detriment (financial or psychological) when attempting to arrange insurance. The purpose of this policy is to ensure that the way in which we conduct our business does not have a negative impact on vulnerable customers.

A vulnerable consumer is defined as someone who has personal circumstances that place them at a higher risk of detriment, particularly if a company does not act with the appropriate level of care. Blue Whale Spa is committed to ensuring that all its staff are capable of identifying vulnerable consumers, and that they are able to handle a situation involving a vulnerable customer with the required levels of care, attention and respect. A consumer may find it difficult to make an informed decision about purchase for a variety of reasons. The risk factors that contribute to consumer vulnerability in financial services include:

  • low literacy, numeracy and financial capability skills
  • physical disability
  • severe or long-term illness
  • mental health problems
  • low income and/or debt
  • caring responsibilities (including operating a power of attorney)
  • being ‘older old’ for example over 80, although this is not absolute (may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill-health, not being comfortable with new technology)
  • being young (associated with less experience)
  • change in circumstances (e.g. job loss, bereavement, divorce)
  • lack of English language skills
  • non-standard requirements or credit history (e.g. armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants).

Living with a disability, illness or diagnosis does not in itself make someone vulnerable. In the context of financial services, it is the person’s situation and barriers to accessing such services that may make them vulnerable. Equally a person may be vulnerable without any disability, illness or diagnosis, for example if they are recently bereaved or frail.

2.0 Identifying Vulnerable Consumers

For Blue Whale Spa staff to correctly address the needs of a vulnerable consumer, it is important to be able to identify them.

Training and Awareness: All employees undergo training to recognise signs of vulnerability in customers. This includes understanding the various forms vulnerability may take, such as physical disabilities, cognitive impairments, mental health issues, or financial difficulties.

Customer Communication: We encourage our customers to inform us if they or someone they are purchasing for may require additional support due to vulnerability. Our communication channels are designed to be accessible and inclusive, allowing customers to disclose their needs comfortably and confidentially.

Key indicators that often highlight a Vulnerable Customer include:

a) Can the client hear everything you are saying and do they understand what you are saying? Do they ask you to slow down or to speak louder? Are you sure they have heard and understood all the relevant details?

b) Does the client stay on topic and hold a conversation that is coherent, or do they appear distracted or confused?

c) Does the client take an unusually long amount of time to answer a question that suggests they are struggling to process the information provided to them?

d) Does the client indicate they may have a disability or impairment based on their voice, pronunciation, breathing, hearing or ability to understand the conversation? Are they coherent and fluent in the language being used?

3.0 Dealing with Vulnerable Consumers

Just because somebody is vulnerable does not automatically mean that they are unsuitable for the products and services the firm supplies. As soon we think we may be engaging with a vulnerable consumer we should take care to adhere to the requirements set out in this policy:

a) Remain patient and empathetic; do not rush the client, interrupt or appear impatient. Allow the consumer to arrive at their own decisions and process the information sufficiently.

b) Ensure the client is able to hear and understand what you are saying; ask the client to explain their understanding of what you are telling them, or include questions as frequently as possible to ensure they are aware of and understand what is being discussed.

c) Allow the client to explain thoroughly; do not assume you already know what their requirements or needs are, and do not finish off their sentences which often implies you are rushing them to progress the conversation. Listen carefully to the client and remain conscious of any absence of understanding, hints at unawareness, or forgetfulness of topics already discussed.

d) Clarify that the consumer is comfortable with the standard and method of communication, and offer to provide details in an alternate format such as via post or email for clarity. Before acting on a vulnerable consumer’s advice, ask if there is anybody else they need to speak to about their decision.


When a vulnerable customer has been identified a relevant note should be added to their record if consent from the customer has been given. We must also inform them how this information will be used. This ensures awareness extends to all staff within the company who deal with the client

4.0 Product Governance

The design and distribution of new products, promotions and finance offers will take into account the requirements of vulnerable customers and this will include collecting relevant management information to monitor the company’s performances in treating vulnerable customers in accordance with the requirements set out in this policy.

5.0 Continuous Improvement

Feedback Mechanisms: We welcome feedback from our customers, including suggestions for improving our support for vulnerable individuals. We regularly review our policies and procedures to identify areas for enhancement and strive to implement best practices in customer care.

Staff Training and Development: We invest in ongoing training and development for our staff to ensure they have the knowledge, skills, and empathy required to support vulnerable customers effectively.

6.0 Conclusion

At Blue Whale Spa, we are committed to upholding the principles of equality, diversity, and inclusion in our interactions with all customers. Our Vulnerable Customer Policy reflects our dedication to providing a safe, supportive, and accessible environment for vulnerable individuals, ensuring that they receive the assistance and respect they deserve.

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