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