Last reviewed: 17/10/2025
Next review due: 01/05/2026
Policy owner: Finance & HR Manager
Banks Lyon Jewellers is committed to treating all customers fairly and ensuring that the way we conduct our business does not have a detrimental impact upon anyone in vulnerable circumstances.
This policy sets out how we identify and support vulnerable customers and how we comply with the FCA’s Consumer Duty, which requires us to deliver good outcomes for all customers, including those whose personal circumstances may make them especially susceptible to harm.
The Financial Conduct Authority (FCA) defines a vulnerable customer as:
We recognise that vulnerability may be temporary, sporadic, or permanent, and that anyone can become vulnerable at any stage of their life.
We take a proactive approach to identifying vulnerability.
Our staff are trained to recognise indicators of vulnerability during customer interactions, including verbal, written and behavioural cues.
We also encourage customers to tell us about any personal circumstances that may affect their ability to make fully informed decisions or manage their commitments.
Indicators may include (but are not limited to):
Communication difficulties (e.g. language barriers, learning differences such as dyslexia)
Reduced physical or mental capacity
Health issues (long-term or serious illness, including mental health)
Recent life events (bereavement, redundancy, caring responsibilities, separation)
Financial hardship or low financial resilience
Age-related vulnerability (inexperience, cognitive decline, or reduced digital confidence)
Limited access to or confidence with digital channels
Whenever we believe a customer may be vulnerable - whether identified by us or disclosed by the customer - we will:
Record this appropriately in line with data-protection requirements.
Adapt our communication to ensure understanding (e.g. slower pace, plain language, written follow-up).
Provide additional opportunities for the customer to ask questions or seek clarification.
Offer the chance to defer decisions until further consideration or after support from a trusted person.
Confirm understanding before proceeding with any finance application or agreement.
Where we cannot assist, signpost to alternative sources of support or information.
All staff involved in customer interactions receive training on:
Identifying and supporting vulnerable customers
Handling sensitive disclosures appropriately
Understanding obligations under the Consumer Duty
Product knowledge and communication best practice
Training is refreshed annually, with completion recorded and monitored as part of our compliance oversight.
We maintain records of interactions where vulnerability is identified to ensure consistency and continuous improvement.
Regular reviews of these records help us:
Monitor outcomes for vulnerable customers
Identify trends or recurring issues
Update training and processes where needed
We recognise that digital exclusion can create or worsen vulnerability.
We strive to ensure our website, online finance application processes, and communications are accessible and easy to use for all customers.
Where a customer prefers to transact in-store or by phone, we will always provide that option with the exception of taking payment details, such as payment card numbers over the phone.
This policy is owned by the Finance & HR Manager, who ensures it remains up to date and reviewed at least annually or following any FCA guidance updates.
Findings from our Consumer Duty and compliance reviews will feed into this process to strengthen our approach.
Banks Lyon Jewellers is committed to treating every customer with fairness, empathy, and respect.
We will continue to review and enhance our practices to ensure that vulnerable customers experience the same positive outcomes as any other customer.
