Vulnerable Client Policy

Access Financial Services Limited – Policy for dealing with customers
with characteristics of vulnerability
Overview
This policy sets out how we aim to identify and treat clients and prospective clients who may be
considered as being vulnerable by virtue of their personal circumstances. These circumstances might
include health, financial capability, age, financial/emotional resilience or exposure to key life events
such as retirement or bereavement. These circumstances may be temporary, sporadic or permanent.
Although vulnerability can come in many forms, it is important that such individuals are dealt with
appropriately, fairly and consistently.
We are committed to making sure that all clients, regardless of their situation receive good
experiences and outcomes. We will do this by:
● Considering the needs of vulnerable clients as part of the design and delivery of our services.
● Equipping staff to recognise and respond to the needs of vulnerable clients.
● Having processes in place to support and enable vulnerable customers to disclose their needs.
● Being empathetic to specific needs or concerns vulnerable clients may have and flexible in our
approach to client support and communications.
● Monitoring whether we are meeting and responding to the needs of customers with
characteristics of vulnerability and make improvements when this is not happening.
We will provide training all our staff to identify the key indicators of vulnerability and to providing
appropriate support and solutions for vulnerable clients.
What is a vulnerable client?
The FCA defines a vulnerable client 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’.
A vulnerable client may be less able than others to:
● Realistically and objectively identify and prioritise their own needs.
● Fully understand the risk, cost or implications of any advice provided.
● Assess information in the usual format, for example, orally during meetings or visually in respect
of written advice.
We are mindful that many clients in vulnerable situations may not think of themselves as being
‘vulnerable’. Where possible, we will not refer to vulnerability in our interactions with clients but
explain that we need to know what their needs are so that we can provide the most appropriate
service in the best way to suit them.
Further information on types of vulnerability is available in ‘Equipping staff to recognise and respond
to the needs of vulnerable clients’ below. Considering the needs of vulnerable clients as part of the
design and delivery of our services

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When designing our services or making changes to existing services, we will:
● Consider the needs of vulnerable clients and any potential benefits and drawbacks of our
services for vulnerable clients.
● Design services to avoid harmful consequences for vulnerable clients.
● Ensure that all information provided to clients about our services is understandable.
● Assess whether there is a need to alter our customer support services to help vulnerable clients
and take appropriate action.
Equipping staff to recognise and respond to the needs of vulnerable
clients
Types of vulnerability
There are a number of factors that could result in a client being deemed vulnerable on a temporary,
sporadic or permanent basis. We would consider individuals affected by the following factors to be
potentially vulnerable:
Health Life Events Resilience Capability

⮚ Physical
disability.
⮚ Severe or
long-term
illness.
⮚ Hearing or
visual
impairment.
⮚ Poor mental
health.
⮚ Addiction.
⮚ Low mental
capacity or
cognitive
impairment.

⮚ Retirement.
⮚ Bereavement.
⮚ Income Shock.
⮚ Relationship
Shock.
⮚ Domestic
abuse.
⮚ Caring
responsibilities
.
⮚ People with
non-standard
⮚ requirements
such as people
with
convictions,
care leavers
and refugees.
⮚ Significant
financial gain –
inheritance /
lottery win.

⮚ Low or erratic
income.
⮚ Low
emotional
resilience.
⮚ Over
indebtedness.
⮚ Low savings.

⮚ Low financial
capability
skills.
⮚ Poor literacy
and numeracy
skills.
⮚ Low English
language
skills.
⮚ Poor or
non-existent
digital skills.
⮚ Learning
impairments.
⮚ No or low
access to help
or support.

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Other factors which would prompt us to consider a client to be vulnerable:
● Being ‘older old’ (for example over 80) although this is not absolute – this could be associated
with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of
ill-health, not being comfortable with technology)
● Not possessing standard documents or credit history (for example armed forces personnel
returning from abroad, ex-offenders, care-home leavers).
● Clients adversely affected by the rising cost of living.
The presence of one or more of the above factors does not necessarily mean that the client is
vulnerable. These factors can impact clients in different ways. One client might have circumstances
which result in a permanent significant vulnerability while another not be impacted at all by the
circumstance they have been exposed to. The impact of a factor on a client will determine our
approach to dealing with that client.
Each adviser/support staff member will need to assess their client’s personal circumstances and
ensure that every client is treated individually and with respect and empathy. Any concerns around
assessing clients should be referred to Jeremy Lock, Compliance Director.
Training
We will make all staff aware of this policy when they join our firm.
All staff will also be given training on identifying and dealing with vulnerable clients upon joining and
on an annual basis.
Our training will include:
● How to identify a vulnerable client and how to deal with them, which office systems to use and
update.
● Annual Testing, which is monitored by the T&C Team.
Enabling vulnerable customers to disclose their needs
Identifying a vulnerable client
To be able to identify if an existing or potential client falls within our definition of a vulnerable client,
we have the following processes in place:
Our advisers as part of our Know Your Client assessment and Fact Finding.
If you use a Know Your Client assessment, how do your staff undertake this process? For example:
We have a Vulnerable Client Assessment form to record specific data.
Staff and advisers watch out for indicators of vulnerability when dealing with clients such as:
o Regular requests for one off withdrawals
o Extreme changes in attitude to risk
o The language used by client – ‘’I can’t pay’’, ‘’I don’t understand’’

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o Physical signs – agitation, shortness of breath, mention of medical treatment
● Responsibility of identifying a vulnerable client is incumbent to all staff and advisers.
● If we identify a client as being vulnerable, we will treat them in line with the steps noted below
under the heading ‘Dealing with a vulnerable client with empathy’.
Capturing data on client needs
As part of delivering financial services to vulnerable clients, we will gather detailed information from
them, especially about their physical and / or mental health. This information will be dealt with in
accordance with our data protection policy.
Documentation of a customer’s vulnerability is held in our Mortgage Magic CRM.
Being empathetic to the needs of vulnerable clients and flexible in
our approach
Dealing with a vulnerable client with empathy
We will make sure that in all cases, a client has the capacity to understand the advice they are being
given. If they don’t and there is no attorney or deputy in place, the advice process will be paused and
the case will be referred to Jeremy Lock, Compliance Director.
In addition to our usual systems & controls, to make sure that we treat all vulnerable clients fairly, we
have the following additional processes in place:
● Jeremy Lock, Compliance Director is the nominated person who is responsible for dealing with
staff queries about vulnerable clients
o Alexander Robinson is the Deputy
External support
There are many organisations that can provide help and support to vulnerable clients.
Where appropriate, we will provide client relevant contact details.
Monitoring outcomes for vulnerable clients
We will collect management information at different points in the client journey to allow us to
understand the experiences of vulnerable clients and to monitor the outcomes we are delivering.
This information will be analysed and used to drive improvements in our processes.
Board Meetings has an agenda point under Consumer Duty to discuss the fair treatment of
vulnerable clients.
Our aim is to ensure that our vulnerable clients experience outcomes as good as those experienced
by our other clients. To achieve this, we will use the following data sources:
● Our advice and new business register/back-office system to identify that a client has
characteristics of vulnerability.
● Business persistence: analysis of client retention records – for example, why clients leave, which
may flag up where poor treatment is contributing to high turnover of clients.

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● Training and competence records
● Client feedback to identify trends and areas for improvement.
● Complaint root cause analysis
● Compliance reports (internal and external) – to check if standards are being met in terms of
treating clients fairly and meeting our obligations under the Consumer Duty
● File reviews to check for errors and assess if clients were treated fairly (particularly useful for
sales processes).
● We will maintain vulnerable client data of sufficient quality across the firm so that we can
identify vulnerable clients and the impact of their vulnerability in all business areas.
Reviewing this policy
To ensure this policy continues to accurately reflect the process we have in place, Jeremy Lock
Compliance Director will review this policy on a annual basis.
If any updates are required, these will be made within 5 business days following the latest review and
all staff will be notify by email

This policy was last reviewed by Jeremy Lock Compliance Director on 06.06.2024
This policy has been approved by Karl Wilkinson, SMF 16 Compliance Oversight.