Vulnerable Customers

Support and information for financial advisers
A vulnerable customer is someone, who due to their personal circumstances is especially susceptible to harm, particularly where a firm is not providing the right level of care. We are all subject to the challenges of life that can make us vulnerable, and our customers are no different. Vulnerability can affect anyone, and could be experienced on a shorter term or more permanent basis.

Just like every one of our customers, no two circumstances of vulnerability are the same. It should be considered as a spectrum – everyone is at risk of becoming vulnerable, but the risk is increased through different vulnerability characteristics which may overlap. The FCA determiners the four key drivers to be:

Health Life Events Resilience Capability
Having ongoing health issues that affects the ability to carry out day-to-day activities.

These could include:

• Severe or long term illness
• Physical disability
• Hearing or visual impairment
• Mental health condition
• Addiction

Experiencing a major life event.

These could include:

• Retirement
• Job loss
• Bereavement
• Relationship breakdown
• Caring responsibilities
• Domestic abuse

Having a low ability to withstand financial or emotional shock.

These could include :

• Low savings
• Inadequate or erratic income for outgoings
• Over-indebtedness
• Low emotional resilience

Having low knowledge or confidence in financial matters or managing money; low capability in other areas such as:

• Poor literacy or numeracy skills
• Learning difficulties
• Poor English language skills
• Poor digital skills
• Low knowledge in financial matters

Our Commitment

The nature and longevity of our products means our customers are likely to experience some of these life events, making them more susceptible to becoming vulnerable such as through divorce, aging or bereavement.

We are committed to:

• encouraging customers to disclose their needs
• ensuring staff can identify vulnerabilities and make appropriate adjustments where needed
• supporting channels that create good outcomes for customers
• reducing the probability of customers experiencing harm.


If you believe your client may be vulnerable and would like to discuss support and suitable adjustments, please contact:

T: 0115 841 5000


There are a number of third party resources available to help provide additional support to customers who are vulnerable. The following document may be of use to customers who may be experiencing vulnerability:

External support contact details

Useful Links

The following link provides more information on vulnerable customers:

Fair treatment of vulnerable customers – FCA Guidance