Vulnerable Client Policy

Overview

This policy sets out how Crowe Financial Planning UK Limited aim to identify and treat clients and prospective clients who may be considered as being vulnerable by virtue of their age, disability or circumstances.

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 we treat any vulnerable client as an individual. We will do this by being:

• flexible in our approach to client communications
• empathetic to any specific needs or concerns they have.

Definition of a vulnerable client?

The Financial Conduct Authority defines a vulnerable client as: ‘Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care’.

All clients are at risk of becoming vulnerable on a permanent, temporary or sporadic basis and this risk is increased by characteristics of vulnerability related to four key drivers:

• Health: physical disability, severe or long-term illness, hearing or visual impairment, mental health condition or disability, addiction and low mental capacity or cognitive disability.
  
  
• Life events: retirement, bereavement, income shock (job loss), relationship breakdown, domestic abuse (including economic control) and caring responsibilities.
  
  
• Resilience: inadequate or erratic income, over-indebtedness, low savings and low emotional resilience.
  
  
• Capability: low knowledge or confidence in managing finances, poor literacy or numeracy skills, poor English language skills, poor or non-existent digital skills, learning difficulties and no or low access to help of support.

Not all clients with characteristics of vulnerability will be vulnerable and we are mindful that those that are identified as vulnerable may not want the label ‘vulnerable’ applied to them.

What are the types of vulnerability?

There are a number of factors that could result in a client being deemed vulnerable on a permanent, sporadic or temporary basis.

A vulnerable client could be considered to be anyone who by virtue of their health, age or circumstances 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.

This means that we may consider individuals affected by the following factors to be potentially vulnerable:

Identifying a vulnerable client

The presence of one or more of the types of vulnerability does not necessarily mean that a client is vulnerable. We will assess the client’s personal circumstances and ensure that every client is treated individually and with respect and empathy.

In all cases Crowe Financial Planning UK Limited staff will ensure the following:

• robust records are created and retained
• seek consent to obtain, record and retain sensitive personal data
• obtain copies of anti-money laundering verification from the client and attorneys or deputies where required.

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’.

Dealing with vulnerable clients

We will make sure that in all cases, a client has the capacity to understand the advice they are being given.

If we identify a client as being vulnerable or becoming vulnerable, we will consider the following:

Vulnerability - All types

• Where clients are identified as being vulnerable the client file will be clearly marked to enable speedy identification.
• Clients will be encouraged to invite a family member or trusted third party to participate in future
  meetings.
• Should Crowe Financial Planning UK Limited staff have any concerns that the client is being pressured
  into a particular course of action by a family member, the advice process will be postponed until the
  client can be met on their own.
• Where appropriate the client will be offered meeting times outside of standard office hours.
• The client will be offered a choice in how we communicate with them.
• Where appropriate, the client will be given the option to have a further meeting to give them the opportunity to discuss any recommendations or arrange for a third party to attend?

Vulnerability - physical disabilities

• Clients will be given the option (where appropriate) for Crowe financial Planning UK Limited staff to
  attend their premises or a location of their choosing.
• Information can be provided in large print where requested and where available from providers.
• Hearing difficulties – Clients will be offered the opportunity to invite a sign language interpreter of their choosing. If they do not have an interpreter we will provide one if possible.

Vulnerability - where English is not the client's first language

• Clients will be offered the opportunity to invite an interpreter of their choosing to all meetings at their cost.

Vulnerability - not being computer literate

• Clients who have disclosed difficulty using computers and/or electronic communication platforms will have correspondence sent by post.