Vulnerable Customer Policy

1/. Purpose

We are committed to ensuring that our services never disadvantage customers who may be vulnerable. A “vulnerable customer” is anyone whose personal circumstances mean they need extra care to enjoy the same fair outcomes as other customers. This policy explains how we identify, assist and protect those customers, in line with the Financial Conduct Authority (FCA) guidance.

2/. What "vulnerable" means

The FCA defines a vulnerable customer as “someone who, owing to their personal circumstances, is especially susceptible to harm, particularly where a firm does not act with appropriate levels of care.” We therefore consider vulnerability in a wide range of situations, including (but not limited to):
- Health – serious, long-term, sudden or temporary physical or mental health conditions.
- Life events – recent bereavement, redundancy, caring responsibilities, divorce, or any significant change in personal circumstances.
- Financial hardship – difficulty meeting regular commitments, sudden income loss or indebtedness.
- Age-related factors – both younger and older customers may need extra support.
- Low capability – limited literacy, numeracy or digital skills.
- Communication barriers – learning difficulties, English as a second language, dyslexia, hearing or visual impairments.
Treating every customer with fairness and respect is embedded in the Walter Bull & Son Code of Conduct. Where vulnerability is present, we adapt our sales process and service to provide
additional care.

3/. Spotting signs of vulnerability

All team members receive training to recognise potential vulnerability. Indicators include:
- Noticeable changes in behaviour, mood or comprehension.
- Statements such as “I can’t manage the stairs” or “I’m not comfortable using email.”
- Difficulty reading or understanding documents.
- Late, missed or suddenly stopped payments.
- Visible distress, breathlessness, agitation, or references to medication.
- Repeated requests for information to be explained again, or signs of confusion.

4/. How we spot vulnerable customers

When we believe a customer may be vulnerable, we will:
1. Communicate clearly – use plain language and avoid jargon.
2. Check understanding – pause regularly and invite questions.
3. Offer extra time – allow the customer to reflect before making decisions.
4. Suggest assistance – ask if a family member, friend or adviser can help.
5. Provide alternatives – explain other ways to obtain the service if ours is unsuitable.
If we cannot meet a customer’s needs, we will tell them promptly and signpost alternative options.

5/. Training and awareness

Every employee receives regular training covering:
- FCA expectations on vulnerability.
- How to identify signs of vulnerability.
- Effective, empathetic communication techniques.
- Practical steps to tailor support and solutions.

6/. Monitoring and continuous improvement

We continually review how well we serve vulnerable customers by:
- Recording and analysing relevant customer data.
- Auditing interactions for quality and fairness.
- Updating procedures and training in line with FCA guidance and best practice.