Vulnerable Customer Policy

Vulnerable Customer Policy


The purpose of this policy is to ensure that the operations of Chained and Charged LTD do not have any negative impact upon vulnerable customers.

For the purposes of this policy vulnerable customers are customers and prospective customers whose ability or circumstances require us to take extra precautions in the way that we conduct business and provide our services to ensure that they are not disadvantaged in any way.

What is a vulnerable customer?

The Financial Conduct Authority (FCA) defines a vulnerable customer as "someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care."

The FCA expects firms like ourselves to treat customers fairly when we are dealing with people with vulnerable circumstances.

Identifying a vulnerable customer

Our staff are trained to identify vulnerable customers so we can take extra steps to assist outside of our standard procedures. However, it is not always possible to recognise these characteristics. Therefore, if you believe you may fit the criteria for a vulnerable customer, please read this policy and notify us immediately of your particular needs.

Signs we look out for:
Do they ask us to speak up or speak more slowly?
Do they understand what we are saying, or do they miss important bits?
Do they appear confused about what is being offered?
Do they ask any unrelated questions?

Vulnerability groups

We recognise that certain groups of customers may be vulnerable. Whilst not all customers in these groups may be vulnerable, we will consider a customer's individual circumstances where a potential vulnerability is identified. These groups may include, but are not restricted to:

Customers with communication difficulties (including learning difficulties and English not being their first language, dyslexia).

A customer with a reduction in physical or mental capacity.
Customer with health issues - illness, whether physical or mental illness, severe or long term.

A sudden diagnosis of serious illness to the customer or close family member
Personal circumstances of the customer -- factors such as financial difficulties, bereavement, caring r
esponsibilities, or redundancy.

The customers age particularly older and younger people. For example, a younger person may be considered inexperienced and the older person may be less technologically able.

Steps we take if we believe a consumer may be vulnerable:

We speak slowly, clearly and explain fully.
We are patient and empathise where appropriate.

We don't rush as it may sometimes take the consumer time to get relevant information together such as account details.

We keep on the subject under discussion.
We do not make assumptions about a consumer's needs.

We clarify understanding at every point and always ask if there is anything else, they would like us to explain.

We ask the consumer to explain to us what they understand the agreement to be. We offer alternative types of communication -- phone, post, email, in person.

We do not make assumptions that the person we are dealing with is sighted as they may be unable to read or understand serial numbers or account numbers.

We do not make assumptions that the person we are talking to can hear everything we say as they may have a hearing impairment.

We always remember that the person we are speaking to may sometimes be forgetful or overly trusting and believe that a sales representative is always acting in their best interest.

We understand that some people may be lonely and welcome the opportunity just to talk to someone.

We give the consumer time to explain their circumstances fully and don't interrupt or appear impatient.

We also listen for what is NOT being said for example lack of questions about price, lack of commitment, timing of responses, extended silences.

We always ask if there is a better time to discuss matters as some people may perform better at different times of the day.

We ask if there is anyone else they may need to talk to before making the decision.


Contact Us

To discuss this policy in more detail or to register yourself as a vulnerable customer, please contact us using the information below:

Email –
Phone – 01174270572