Vulnerable customer policy

1. Introduction

We care about all our customers, including those who are vulnerable. We aim to treat all customers fairly, sensitively, compassionately and with empathy to their individual circumstances. 

Our vulnerable customer policy makes sure that our vulnerable customers are well taken care of. We’ll also take extra care when making any decisions so we’re never putting our vulnerable customers at undue risk.

We understand that sometimes, vulnerable customers may need extra help or support and that’s okay – we’re here to help.

Our staff are trained to identify and help vulnerable customers so that we can always handle sensitive situations with care, attention, and respect. As a business, we have a duty of care to make sure that we don’t harm our customers with what we do or how we do it.

There might be times when vulnerable customers  find it difficult to make an informed decision. Here are some examples of how a customer might be vulnerable:

  • They find it challenging to read and understand information, they struggle with numbers, or they have limited knowledge managing money
  • Physical disability
  • Severe or long-term illness
  • Hearing or visual impairment
  • Challenges with mental health
  • Low income and/or debt
  • Caring responsibilities (including operating a power of attorney)
  • They’re young and have less experience
  • They’re at an age with wealth of knowledge and wisdom. They feel less confident using new technology, or they’re dealing with health matters
  • Things have changed like job loss, bereavement, and divorce
  • English language barrier
  • They’re in a unique situation. For example they fall into one of these (not limited to) categories: armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants
  • They live with someone vulnerable, so things can be a little harder for them sometimes

2. Recognising customers who need extra support

It is important that we can recognise who our vulnerable customers are so that we can offer them the right support. We listen to them carefully and pay attention to any signs they might be struggling. Here are some thing we might look out for:

  • Can a customer hear and understand us when we talk to them? Do they ask us to slow down or talk louder? Do they ask for clarification or do they mention they don’t understand the words we use?
  • Can a customer hold a conversation? Are they distracted? Are they confused? Does their response match our conversation?
  • Does a customer take longer than usual to respond to questions?
  • Does a customer indicate they may have a disability or impairment based on their voice, pronunciation, breathing, or hearing? Are they able to respond fluently in English?

3. Offering support to vulnerable customers

Here is our customer promise for our vulnerable customers:

  • We’ll be patient and understanding. We won’t rush or interrupt
  • We may ask a customer to explain their understanding of our conversation
  • We’ll actively ask questions during the conversation just in case we need to revisit anything
  • We’ll never assume a customer’s needs and we’ll give them the time and space they need to digest anything
  • We’ll watch out for things like unawareness and forgetfulness
  • If a customer prefers to email rather than talk, we’ll be happy to do that, and vice versa
  • If we feel a customer would benefit from a written summary of our call, then we’ll send one
  • A customer might need extra time to think or respond, or seek independent advice
  • If we think it’ll help the customer, we might engage in 3rd party to help us support the customer better
  • We’ll keep our customer team in the loop about a customer who requires extra attention so that we can deliver a consistently respectful service
  • We’ll happily work with a customer’s chosen representative should a customer feel like they need one
  • A customer might need flexibility and options within our legal standards 

We’ll keep a record of the customer’s full picture, including what we’ve learnt, advice we’ve given, and any thoughts for future consideration.

Mental capacity

When we say “mental capacity”, what we mean is our customer’s ability to understand the information we share with them and their ability to make a decision based on that.

When our team identifies a customer who is struggling at any point in our sales process including making a final decision, we ask that a caregiver or a family member who can legally make a decision for them, help them decide.


Sometimes, just because we haven’t identified a customer as vulnerable, doesn’t mean that they aren’t. So we’ll always give a customer the chance to tell us anything that we should be mindful of; we might ask you if you have any known vulnerabilities at any interaction point during the sales process. Any information a customer shares with us will allow us to provide them with a better service.

4. Policy Governance 

We keep note of everything we’re doing to help all customers, including those that are vulnerable. This information is often shared within Glowb to help us meet other legal standards and to help us consistently improve.