Vulnerable Persons Policy

The Financial Conduct Authority (FCA) defines vulnerable customers as the following:

'A vulnerable consumer 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,'

How can a customer be vulnerable?

Vulnerability can come in a range of guises and can be temporary, sporadic or permanent in nature. It is a fluid state that needs flexible, tailored response from firms. The following are examples of how customers can be vulnerable:

  • Mental health problems i.e depression or anxiety
  • Difficult financial circumstances i.e recent unemployment
  • Physical health problems i.e disability or long term illness
  • Communication skills i.e an individual who has limited English

How can businesses assist vulnerable customer?

Firms should have effective policies and procedures in place to ensure a consistent approach across operations. 

Clear Information
Providing clear information to customer before and after sale ensures that vulnerable customers are more likely to make informed decisions. 

Staff Training
Providing staff with sufficient training to enable vulnerable customers to be identified and have their sensitive issues handled appropriately. 

Empowering Staff
Referring vulnerable customers to staff who have the authority and discretion to take a tailored approach to a customer's circumstances. 

Flexibility in Service
Treating customers as individual and considering how our service can be adapted to meet their specific circumstances. 

Being Pro-Active
Pro-actively contacting customers and offering a tailored service to meet their specific circumstances. 

Specialist Advice
Referring customers to organisations that can offer specialist advice to assist a customer with their vulnerability

What guidance is available?

UK WHEELS LIMITED believe that to deliver a truly ethical approach in delivering a service that is extremely sensitive the commitment has to permeate throughout all activity as the business as a whole. We believe that the adoption and application of the right policies, standards and approach will deliver an ethical approach in a particular and measurable way.

UK WHEELS LIMITED also give full consideration to any mitigating or vulnerable conditions, and seek the advice and approval of our clients before proceeding with any action in the following circumstances:

  • Serious illness/long term sickness
  • Ethnic minorities who cannot understand or speak English
  • Pregnancy or recent birth of a child
  • Recent bereavement
  • Recent unemployment
  • Severe financial difficulties
  • Any other guidelines stipulated by our client

UK WHEELS LIMITED process for identifying vulnerable claimants is set out in 3 stages:

  1. Prior to receiving a case
  2. Once we have received a case
  3. Whilst making first contact with the client

All staff are trained, display a positive attitude, and are considerate to customers in financial difficulties, responding sympathetically to their difficulties and encouraging them to obtain guidance from the relevant advisory organisations.

Through regular dialogue with customers and advisory bodies, we will ensure that staff is kept up to date with any changes in our collective / sign-up policy and carry the most up-to-date contact details for advisory groups within the client's area.

In accordance with legislation and best practice UK WHEELS LIMITED will establish and maintain effective quality assurance systems for monitoring and reporting adult safeguarding issues and will share all adult protection information across agencies.

Whilst UK WHEELS LIMITED is unable to offer business advice, the FCA and the British Bankers' Association offer guidance about how to identify and respond to vulnerable customers. This can be found at:

There are also a number of organisations that can provide specialist assistance to customers; here are some that may be considered:

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