Vulnerable Customer Policy


Gudrum Classics Limited has a Vulnerable Customer Policy which is designed to ensure that the way in which we conduct our business does not have a detrimental impact upon vulnerable customers.

For the purpose 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 sell and provide our services in order to ensure that they are not disadvantaged in any way.

Requirements of the Policy

To deliver fair outcomes to our customer we must consider the circumstances of each individual and in our dealings with them tailor our approach, removing any barriers that restrict the customer achieving a resolution and accessing our products and services.

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”

Identifying a vulnerable customer

Gudrum Classics Limited is committed to ensuring that all its staff are capable of identifying vulnerable customers, and that they are able to handle a situation involving a vulnerable customer with the required levels of care, attention and respect. A customer may find it difficult to make an informed decision about their available options for a variety of reasons.

The following are types of circumstances and characteristics which may suggest vulnerability, but these are not exhaustive, and the identification of the vulnerable customer must be individual, responsive and aimed at removing barriers to accessing our products and services.

·         Age

·         Mental health

·         Low-income levels

·         Addictions such as gambling, drink and drugs

·         Medial and/or health condition

·         Financial hardship

·         Language barriers

·         Mental capacity limitations

·         Life changing event

·         Victims of financial crime

·         Environmental impacts

When engaging with customers over the phone it is often difficult to identify a vulnerable customer because it is not possible to see many of the characteristics, such as body language and facial expressions, which may identify whether the prospective customer requires additional information and guidance to enable them to make an informed decision. For this reason, it is critically important to listen carefully to all customers and to identify people who may be classed as a vulnerable customer.

Typical telephone characteristics include:

·         An inability to hear or understand what is being said

·         Repeated questions of a similar nature

·         Comments or answers which are inconsistent with the telephone discussion, or which indicate they have not understood the information which has been provided.

·         Verbal confirmation that they don’t understand or that they require the assistance of somebody else in making a decision.

Treatment of Vulnerable Customers

Due to the diversity of the factors that can contribute to the level of customer vulnerability there will not be one approach that can be adopted to fit each circumstance. The over-riding principle that much be adhered to by staff in their dealings with vulnerable customers is that fair outcomes are achieved throughout the customer journey, and any barriers are removed to access our products and services. It is therefore essential that staff take a flexible approach as our failures can lead customers to suffer financial and non-financial impacts.

When speaking to a vulnerable customer we:

·         Remain patient and empathetic; do not rush the customer, interrupt or appear impatient. Allow the customer to arrive at their own decisions and process the information sufficiently.

·         Provide additional opportunities for the customer to ask questions about the information we have provided.

·         Ensure the customer is able to hear and understand what you are saying, continuously seek confirmation that they have understood the information that has been provided.

·         Allow the customer to explain thoroughly; do not assume you already know what their requirements or needs are, and do not finish their sentences which often implies you are rushing them to progress the conversation.

·         Listen carefully to the client and remain conscious of any absence of understanding, hints at unawareness, or forgetfulness of topics already discussed.

·         Clarify that the customer is comfortable with the standards and method of communication and offer to provide details in an alternative format such as via post or email for clarity.

·         Ask if there is anybody with them who is able to assist them and offer them the opportunity to have a family member or friend present during the conversation.

·         Offer them the opportunity to complete the transaction after a period of further consideration.

If for any reason, we think the customer does not understand the service which is being offered to them we will not proceed with the transaction and advise them that we will write to them with further information about the product or service they are seeking.

When a vulnerable customer has been identified a relevant note should be added to their order to ensure that awareness extends to all staff within the company who deal with the customer. It is important that we maintain a consistent level of service, and that a vulnerable customer receives adequate care irrespective of which staff they liaise with. Any such notes should describe the reasons for the assessment of the customer as vulnerable and be respectful.

Data Protection

Personal information that relates to an individual’s health, ethnicity or race is considered sensitive and should be handled with particular care. Gudrum Classics Limited will obtain the customer’s consent to record their vulnerability on its system to facilitate future contact.


Gudrum Classics Limited will conduct a review of this policy on an annual basis, or sooner, if triggered by internal changes (e.g., business process changes) or external changes (e.g., changes in law).