Vulnerable Customers Policy

Financial Conduct Authority (FCA) Definition of a Vulnerable Customer

The FCA identifies a vulnerable customer as anyone who is susceptible to harm due to personal circumstances.

The FCA’s Principles for Businesses underpins the fair treatment of vulnerable customers: This Policy acts in accordance with the Equality Act 2010, which states that it is illegal to discriminate and strengthens protection for specific protected characteristics.

BCH Business Aims

To achieve good outcomes for vulnerable customers, BCH should take action to:

  • Understand the needs of their target market/customer base
  • Make sure staff have the right skills and capability to recognise and respond to the needs of vulnerable customers
  • Respond to customer needs throughout service design, flexible customer service provision and communications
  • Monitor and assess whether they are meeting and responding to the needs of customers with characteristics of vulnerability, and make improvements where this is not happening

Taking practical action

Service design:

  • Consider the potential positive and negative impacts of a service on vulnerable consumers. Design services to avoid potential harmful impacts
  • Take vulnerable consumers into account at all stages of the service design process, including idea generation, development, testing, launch and review, to make sure services meet their needs

Customer service:

  • Set up systems and processes in a way that will support and enable vulnerable consumers to disclose their needs. Firms should be able to spot signs of vulnerability
  • Deliver appropriate customer service that responds flexibly to the needs of vulnerable consumers
  • Make consumers aware of support available to them, including relevant options for third party representation and specialist support services
  • Put in place systems and processes that support the delivery of good customer service, including systems to note and retrieve information about a customer’s needs


  • Make sure all communications and information about services are understandable for consumers in their target market and customer base
  • Consider how they communicate with vulnerable consumers, taking into consideration their needs. Where possible, firms should offer multiple channels so vulnerable consumers have a choice

Delivering inclusive and accessible customer service:

  • Never assume the existence or absence of a disability
  • Always ask the customer how you can best assist them
  • Remember, to meet the customer’s needs you may need to do things differently, but the standard of service you provide should be the same
  • Be aware of accessible facilities and equipment available, such as ramps and hearing loops

BCH Vulnerable Customer Provisions

  • Braille documentation available upon request
  • Large print documentation available upon request
  • Portable Hearing Loop provisions available upon request
  • Ground floor office attendance is welcome, with guide dog access
  • Ground floor consultation space available for wheelchair access

If a BCH customer is not mentally capable, then a third-party mandate (Power Of Attorney) can be utilised to allow another person (third party) access to their BCH customer files.

A Third Party can:

  • Request and instruct BCH services against a property owned by the donor
  • Retrieve copy reports that BCH have provided against a property owned by the donor
  • Discuss property details and particulars on behalf of the donor
  • View and settle invoices on behalf of the donor
  • Make a complaint on behalf of the donor

Considerations & Commitments

  • BCH commit to enabling our customer groups to disclose any vulnerabilities accordingly so that we can offer additional or adapted services to those who require them
  • BCH will consider vulnerable customer groups when designing, updating or withdrawing any of our service lines
  • BCH will identify the nature and scale of vulnerability in our client base, the type of harm or disadvantage which its customers might be subject to and how this might affect their experience and the outcomes they receive
  • BCH will regularly review our performance to identify any potential issues, providing regular training to our team on this subject, engaging external agencies as required
  • BCH aim to keep our documentation, including any Sales & Marketing material as simple as possible for our customer base, including any vulnerable clients, with consideration of the audience and demographic sector. All product literature will be written in plain, easy to understand language

Any breaches of this policy should be reported to Claire Williams, Data & Partnerships Principal

11th September 2023