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


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: 

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: 

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: 

Employees are expected to use some of the following methods in assisting vulnerable clients as appropriate: 

River Insolvency Limited take the following steps to ensure this policy is met: