Vulnerable Customer Policy

Last revision:  13th February 2025

1. Introduction
Warwick Financial Services Limited is committed to treating all customers fairly, with particular consideration for those who may be vulnerable. This policy sets out our approach to identifying and supporting vulnerable customers in compliance with the Financial Conduct Authority (FCA) guidance and relevant UK regulations.

2. Definition of a Vulnerable Customer
A vulnerable customer is someone who, due to personal circumstances, may be at a greater risk of harm when engaging with financial services. Vulnerabilities may be temporary or permanent and could arise from:

  • Health issues (physical or mental illness, cognitive impairments, addictions)
  • Life events (bereavement, job loss, divorce, domestic abuse)
  • Financial difficulties (low income, over-indebtedness, lack of financial literacy)
  • Capability limitations (low literacy or numeracy skills, lack of access to technology, language barriers)

3. Identifying Vulnerable Customers
All employees must be trained to recognise signs of vulnerability, which may include:

  • Confusion or difficulty understanding financial products
  • Repeated questions or inconsistency in responses
  • Indications of distress or anxiety about financial decisions
  • Requests for third-party involvement (family members, carers, charities)

4. Supporting Vulnerable Customers
Warwick Financial Services Limited takes a proactive approach to assisting vulnerable customers, including:

  • Clear Communication: Using plain language, avoiding jargon, and confirming understanding
  • Flexible Processes: Allowing extra time for decision-making, offering alternative communication methods
  • Referral to Support Services: Signposting customers to relevant charities or financial advice services
  • Safeguarding Measures: Ensuring that decisions made by or on behalf of vulnerable customers are in their best interest

5. Training and Staff Awareness
All employees receive training to:

  • Understand the types of vulnerabilities and their impact on financial decisions
  • Recognise indicators of vulnerability
  • Respond appropriately while maintaining customer dignity and confidentiality

6. Recording and Monitoring

  • Staff must document any identified vulnerability and actions taken to assist the customer, ensuring compliance with data protection regulations
  • Regular reviews will be conducted to assess the effectiveness of our vulnerable customer support measures

7. Complaints and Feedback
Any customer who feels they have not been treated fairly can raise a complaint through our standard complaints procedure. We will take all concerns seriously and seek to resolve issues promptly and fairly.

8. Policy Review
This policy will be reviewed annually or as necessary to ensure ongoing compliance with regulatory changes and best practices.

Contact Information
Warwick Financial Services Limited
18 St Cross Street, London, EC1N 8UN
Email: team@warwickfinancial.co.uk
Phone: 0800 599 9334