Vulnerability policy

We are committed to providing an easy-to-use and accessible service.

We recognise that vulnerability can arise in a variety of circumstances, because of personal, health, financial, or situational factors. So we adapt our processes to:

• take individual customers’ circumstances into account sensitively and proactively
• remove barriers and tailor our support
• make reasonable adjustments and provide additional assistance where reasonable and appropriate.

The following four principles underpin this approach.

• Clarity and understanding – we provide information that is clear and easy to understand, to ensure customers feel informed and not overwhelmed.
• Accessible and inclusive – where appropriate, we tailor communications to the individual needs of our customers and stakeholders, providing tailored support and reasonable adjustments.
• Reliable and trusted – we manage expectations, deliver on our commitments, work transparently and strive to continuously improve.
• Empathy in action – we treat customers with compassion and professionalism, approaching individual situations with understanding and respect, conducting interactions impartially and sensitively.

Vulnerability refers to a situation where an individual is at risk of harm or is unable to protect their own interests. The Financial Conduct Authority (FCA) has grouped customer vulnerability into four key driversfour key drivers – health, life events, resilience and capability.

A customer may be vulnerable due to one or more of the drivers, which may be permanent or temporary. Harm may be a known risk, based on circumstances the individual has disclosed, or a potential risk identified through our interactions and observations.

Recognising vulnerability is essential for ensuring fair, accessible, and compassionate support.

By identifying those at risk and responding sensitively, we can remove barriers and provide tailored assistance, where appropriate. This approach:

• helps individuals to participate fully and safely in our processes
• is consistent with our role as an impartial body
• enables a quick, independent and impartial answer to their complaint.

We have a safe disclosure environment that allows our customers to feel comfortable disclosing personal information. However, some customers won’t recognise that their circumstances make them vulnerable.

It is therefore important that we can identify indicators of vulnerability in customer interactions and recognise when a customer may need support. 

To determine how to support customers, we use the framework devised by Chris Fitch and the Money Advice Trust (2026) in Vulnerability: the golden thread:Vulnerability: the golden threadVulnerability: the golden thread

1. To identify the specific harm the customer faces, we ask ‘Vulnerable to what?’
2. To assess what reasonable adjustments and proportionate support are required we ask ‘Supported how?’
3. If we’re not the right organisation to help the customer, we ask ‘If not us, who?’

We ensure that our staff are given the tools, resources and training to adequately support our customers. Safeguarding training is mandatory for all our staff, regardless of their role.

Our Learning and Development team actively seeks opportunities to enhance our customer service.

We regularly monitor the effectiveness of training and adapt our programmes accordingly. By fostering a culture of continuous learning, we ensure that our staff are equipped and empowered to provide compassionate and appropriate customer service to all customers.

Identifying vulnerability is a collective effort, not an isolated task.

It has been necessary to integrate support for customers in vulnerable circumstances into the design of our services. Every part of our organisation plays a part in supporting our customers, with interconnected responsibilities.

We have integrated identification of, and support for, these customers into our:

• channels and content
• systems and technology
• policies, practice and processes
• employee learning, knowledge and support
• organisational structure
• culture and leadership
• risk and quality
• data and insights
• outreach and partnerships.