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Vulnerable Customer Policy

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Vulnerable Customers Consideration


Ensuring that customers in vulnerable circumstances are treated fairly, with empathy and sensitivity to their circumstances is a growing priority for the Financial Conduct Authority. The purpose of this policy is to ensure that how we conduct our business does not have a detrimental impact upon our vulnerable customers.

What is a vulnerable customer?

The FCA definition of 'vulnerability' is: 'Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care'

We recognise customer vulnerability as:

An individual experiencing difficulty with everyday living as a result of:

  • Health: health conditions or illnesses that affect the ability to carry out day to day tasks.
  • Capability: low knowledge of financial matters or low confidence in managing money (financial capability); low capabilities in other relevant areas such as literacy or digital skills.
  • Resilience: low ability to withstand emotional or financial shocks.
  • Impact of a life event: major life events such as bereavement, job loss or relationship breakdown or those with significant carer responsibilities.
  • Communication: those who have difficulties with communication including learning disabilities, English not being their first language, dyslexia.

Examples of vulnerability

We have a responsibility to take reasonable steps to identify vulnerable customers and vulnerable customer groups who access our products and services. The following list gives possible examples of vulnerable customers and many of these people may have multiple characteristics of vulnerability.

It is not intended to be exhaustive but merely illustrative:

  • Customers who are younger or older, i.e. below the age of 21 or above the age of 70.
  • Customers who have a learning disability.
  • Customers who express or demonstrate understanding and communication difficulties such as literacy, numeracy or ability to access or use digital systems or on-line platforms.
  • Customers whose first language is not English.
  • Customers experiencing mental health issues.
  • Customers who are experiencing memory issues such as dementia, Alzheimer's etc.
  • Customers with health problems or disabilities that affect quality of life (including those with pre-existing medical conditions in relation to travel insurances for example).
  • A customer who has been recently bereaved, divorced, or lost their job (e.g., redundancy)
  • Customers experiencing financial hardship.

We understand that some customers may only experience vulnerability for a short time whilst others may typically display characteristics that may indicate longer term vulnerability and that in many cases customers will not necessarily perceive themselves to be vulnerable. For this reason, we should not directly refer to a customer as vulnerable in our dealings with them.

Our aim is to consider each customer individually; and we strive to deliver excellent customer service whilst making the necessary adjustments to our processes to achieve the best outcomes for each customer and their particular circumstances.

Our expectation of all Staff

We will ensure all relevant staff understand their role in treating vulnerable customers fairly and have the necessary skills and capability to recognise and respond to vulnerability. Customer-facing staff will have practical and emotional support to help them when dealing with vulnerable customers.

Customer-facing staff need to be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make an informed decision about the implications of the agreements that they are being asked to make. This is not a diagnosis of a condition; it is just an extension of existing skills of listening and identifying needs and adjusting approaches accordingly.

We expect all staff to:

  • Ensure that vulnerable customers are treated fairly and appropriately.
  • Ensure that vulnerable customers achieve good outcomes, at least as good as those achieved by other non-vulnerable customers.
  • Take steps to understand the nature and scale of customer vulnerability in our customer base and target market and its impact, by considering the harm or disadvantage customers may be vulnerable to, and how this may affect customer outcomes.
  • Consider all contacts on their individual merits and tailor the service to meet customer needs.
  • Treat customers with respect.
  • Respect customers' dignity at all times.
  • Focus on the positive outcome for the customer.
  • Work to gain the best possible outcome for the customer.
  • Ensure our records are updated to record when a customer is to be treated as vulnerable and any specialist measures applied as a result.

Our Approach to Vulnerability

Whenever we interact with customers, we must treat them with respect, as individuals, and recognise that any customer may be vulnerable. Our aim is to provide to all our customers well-designed, straightforward, understandable, flexible products and services that respond to individual circumstances. Where vulnerability is identified will approach this practically and sensitively by helping our customers in the following ways:

  • We will ensure that information provided to our customers is clear and transparent.
  • We will take care to ensure explanations are provided in clear plain English.
  • We will act with patience and empathy, taking the necessary time to ensure that our customers understand the information we are providing.
  • Where we feel it will be beneficial, we will offer vulnerable customers a period of consideration before completing a transaction.
  • Where appropriate we will arrange a specific time to contact customers who may be better equipped to deal with their affairs at a particular time of the day i.e., due to medication, carer visits or because they prefer to have a family member or friend present.
  • We will ensure that we confirm understanding and provide opportunity for customers to ask for further information or explanation.
  • We will never take advantage of our customers circumstances.
  • Where a customer identifies a preferred method of communication, we will make best endeavours to use that method of communication in all future contact and transactions
  • Where a customer is prevented from using a particular means of communication due to a disability e.g., sight or hearing loss, we will accommodate alternative means of communication that are more appropriate.
  • We will not place any unreasonable barriers to customers who wish to appoint an appropriate representative to deal on their behalf, we will however ensure that this can be done safely and only to the extent that the customer requires ensuring the customers personal and sensitive data remains protected.
  • If things go wrong they are put right and action is taken to stop the same thing being recurring.

What have we done so far

We are regularly monitoring our customer data and feedback to make improvements to our service and systems for our vulnerable customers.

  • We have engaged with The Samaritans charity and they being experts have delivered training on vulnerability , this training has been provided to all of our call centre agents and is delivered yearly.
  • Large print documents.
  • Variety of ways to contact us for help, support and to get a quote.
  • Our new AI tool, SYD (Search Your Documents) provides support for any questions you may have around your policy wording or policy terms and conditions. Available 24/7, SYD gives quick answers you may have about your policy cover, making your experience faster and more convenient for you.
  • Call centre with trained staff open 7 days a week.
  • Live chat available 7 days a week.

We will monitor and assess our products and services to ensure they meet the needs of vulnerable customers, consider positive and negative impacts, and make improvements where required.

When we design or agree to distribute new products and services, we will ensure that customer vulnerability is factored into our development processes and procedures including the initial idea, development, testing, launch and review stage, to make sure products and services meet their needs and avoid potentially harmful impacts.

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If you have any enquiries about your travel insurance policy, please visit our AI assistant SYD with any questions you have.