River Insolvency Limited is committed to ensuring that all employees are sufficiently trained so as to be able to recognise any signs that a client may be vulnerable, how to communicate with such individuals in a respectful and caring manner and to also be in a position to handle any resulting situation with sensitivity in order to ensure that the client’s journey remains a positive experience.
Vulnerable Client Definition
A vulnerable client is a client “who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”1
Employees
All River Insolvency Limited employees are likely to come into contact with clients who may be vulnerable on a daily basis, including those who may find it difficult to make an informed decision about choices they have. A number of examples include – but are not limited to the following:
- Clients with learning difficulties;
- Clients who have suffered a bereavement;
- Clients who are elderly;
- Clients with a diagnosed mental health condition;
- Clients whose first language differs.
Individuals may not be aware that they fall into a vulnerable category or realise that they should not be making significant life decisions without assistance due to the vulnerability.
All River Insolvency Limited employees must read and be familiar with this policy.
Identifying Vulnerable Clients
Whilst all potential River Insolvency Limited clients may be classified as somewhat vulnerable due to their financial difficulties, it is important that this policy is followed to ensure that all clients are treated fairly regardless of vulnerability or any additional risk factors.
Risk factors include – but are not limited to the following:
- Disability;
- Mental Health conditions;
- Language barriers;
- Learning difficulties;
- Sickness;
- Hearing or vision impairments;
- Suicidal thoughts;
- Bereavement;
- Ongoing Medical treatment.
1 FG21/1: Guidance for firms on the fair treatment of vulnerable customers (fca.org.uk)
Risk factors are there to assist in identifying a client’s vulnerability. It is important to recognise that those clients with more than one risk factor would hold particular significance as the risk of vulnerability would be increased.
Employees should be aware and alert to any sign which might indicate that the client they are speaking with may have any form of restricted decision making capacity. Whilst employees must not make judgements or aim to diagnose clients they are required to utilise their skills and experience through listening, identifying client needs and adjusting their approach accordingly.
Employees should be mindful of the following:
- Client appears to be confused;
- Client asks employee to speak up, slower or clearer;
- Client does not seem to understand the information being presented to them;
- Client takes a long time to respond;
- Client strays from the subject of the discussion;
- Client repeats themselves.
Employees are expected to use some of the following methods in assisting vulnerable clients as appropriate:
- Setting client expectations for the call in terms of duration and information required;
- Patience, empathy and clarity;
- Allow the client to take time too provide considered responses;
- Keep the call on topic;
- Make no assumptions about client needs;
- Ask questions and clarify the client’s understanding;
- Offer alternative communication methods;
- Ask if the client has a preferred time for the call;
- Listen carefully to the client;
- Ask the client if there is anyone they wish to speak on their behalf;
- If in doubt, to approach their line manager for further guidance.
River Insolvency Limited take the following steps to ensure this policy is met:
- Client is noted as vulnerable on the system – with consent;
- Gather as much information as possible regarding vulnerability;
- Assess the client’s risk level;
- Ask how the client manages their vulnerabilities;
- Confirm preferred contact methods;
- Confirm if the client wises for a third party consent to be added to the case;
- Encourage client to contact us if and when they are struggling;
- Signpost additional support (website/contact numbers)