Vulnerable Customer Policy

At Brufords, we are committed to ensuring that all customers in vulnerable circumstances are not only treated fairly, but with empathy and sensitivity to the circumstances.

Vulnerable customers are likely to need additional assistance at some stage in order to avoid detriment (either financial or psychological) when attempting to purchase goods using financial services.

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.

What Is A Vulnerable Customer?

The Financial Conduct Agency (FCA) defines a vulnerable customer 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”

Here at Brufords, we are committed to ensuring that all our staff can identify vulnerable customers, and that they are able to handle a situation involving a vulnerable customer with the required levels of care, attention and respect.

Types Of Vulnerability

Vulnerability can take many different forms and may not always be obvious. These include, but not limited to:

  • Low literacy, numeracy and financial capability skills
  • Lack of English language skills
  • Physical disability*
  • Severe or long-term illness*
  • Mental health problems*
  • Low income and/or debt
  • Non-standard requirements or credit history (eg armed forces personnel returning from abroad, ex-offenders, care-home leavers, recent immigrants)
  • Caring responsibilities (including operating a power of attorney)
  • Age (being ‘older’ may be associated with cognitive or dexterity impairment, sensory impairments, on-set of ill-health, not being comfortable with new technology; being ‘younger’ may be associated with less experience)
  • Change in circumstances (including not limited to job loss, bereavement, and divorce) 

*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, of they are recently bereaved or frail.

Identifying A Vulnerable Customer

We recognise that some customers will tell us if they have a problem or additional requirements, but others may be more reluctant to do so because they fear that if they admit to a problem this may affect their chances of obtaining products or services.

If we believe that you may be a vulnerable customer, are being pressured into making a purchase, or that something is not quite right, we will ask further questions in line with this policy.

Dealing With A Vulnerable Customer

Just because you may be classed as a vulnerable customer, it does not automatically mean that you are unsuitable for the products and services we supply.

As soon as we think we may be engaging with a vulnerable customer, we will take steps to ensure that we adhere to the requirements in the policy:

  • Make a record that you have been identified as a vulnerable customer. You will be asked for explicit consent before such notes are recorded.
  • Provide additional opportunities for you to ask questions, and ensure you fully understand what you are being told in response.
  • Offer alternative methods of communication (by phone, post, email, in-person)
  • Ask if there is anyone else you need to speak to about your decision.
  • Offer the opportunity to complete the transaction following a further period of consideration.

If we can’t help a customer, we will try and make sure that you understand what alternative options are available.

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