Our commitment  

One of our core values is to uphold responsible and fair business practices.

We  are committed to ensuring that our operations do not have any negative impact upon vulnerable clients. We understand the effect financial distress and problems can have on individuals and there are extra precautions required to be taken in our dealings with a vulnerable client.

There is a guide issued by the ICAEW – Dealing with vulnerable consumers and the Insolvency Practitioners Association – Dealing with Vulnerable Individuals Aide Memoire for Insolvency Practitioners which aims to summarise some of the key indicators of vulnerability. It also highlights some of the risks of working with vulnerable debtors or other individuals involved in an insolvency such as directors or creditors, and ways of supporting them effectively. For ease of reading the term ‘client’ is used in this document to refer to such individuals.

Vulnerable clients are individual who, due to their personal circumstances, are especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care. Vulnerable clients are clients and prospective clients whose abilities or circumstances require us to take extra precautions in the way that we recommend and provide our services in order to ensure that they are not disadvantaged in any way.

There is no typical vulnerable client – their vulnerability may be temporary due to a life changing event or it may be permanent due to a long term health condition. Many people who are vulnerable would not necessarily recognise themselves as being so and may not describe themselves as vulnerable in their dealings with us.

We treat all disclosures of vulnerability with courtesy, sensitivity and appropriate levels of confidentiality.

To assist in identifying vulnerability, we have adopted a risk factor approach.  The Guides gives this list as factors to be considered when assessing vulnerability but recognises that they will not be relevant all the time. Example of risk factors for vulnerability includes:

• Low literacy, numeracy and financial capability skills;
• Physical disability;
• Severe or long term illness;
• Mental health problems;
• Low income and/or debt;
• Caring responsibilities (including operating a power of attorney);
• Being ‘older old’ for example over 80;
• Being young;
• Change in circumstances (eg job loss, bereavement, divorce);
• Lack of English language skills and
• Non-standard requirements or credit history (eg armed forces personnel returning from abroad, ex offenders, care home leavers, recent immigrants)

Vulnerability may arise in a number of ways. Some common examples (though this list is not exhaustive) include:

• Mental capacity;
• Financial literacy
• Infirmity Disability;
• Bereavement;
• Age;
• Addiction;
• Sudden changes to employment or familial circumstances and/or
• Adverse domestic circumstances

Vulnerability is not just about the individual’s situation. It can be caused or aggravated by the actions or processes employed by a firm. A lack of empathy in a difficult situation or letters that are complex and difficult to understand may increase an individual’s vulnerability.

When dealing with individuals we will ensure that we follow the examples of good practice below:

• Offer a choice of ways of communicating choices including face to face, phone, email, post and try to communicate by the client’s preferred method;
• Arrange meetings at a time which suits the client or allow for extra time for appointments.
• Communicate in a clear, jargon-free way;
• Provide additional opportunities for the client to ask questions about the information we have provided;
• Refer individuals to appropriate not-for-profit debt advice body;
• Ensure easy access to buildings – for example, a problem that deaf clients can encounter is their inability to hear the entry phone;
• Offer home visits if accessibility is a problem;
• Make a quiet area available for discussions if someone has difficulty concentrating or completing forms;
• Have somewhere private for sensitive discussions, for example if someone is recently bereaved;
• Properly recording information about the client and their circumstances. For how we deal with personal data please refer to our Privacy Policy which can be found here.  
• Continuously seek conation that they have understood the information that has been provided;
• Ask if there is anybody with them who is able to assist them; and
• Offer them the opportunity to discuss matters again and/or in person, after a period of consideration.

If for any reason we think the individual does not understand the service or information which is being offered to them, or to which they are subject, we must advise them that we will write to them with further information about our advice and services and provide them with an added opportunity to obtain additional support.

When communicating with a vulnerable or potentially vulnerable client we should consider whether there is a need for a responsible adult to be present or for them to take independent advice.

We are not medically trained to diagnose vulnerability but we should nevertheless be aware of some of the indicators that may cause someone to be regarded as vulnerable and treated accordingly is required.