The fair treatment of our clients is central to the behaviour and values of
our firm. An important part of this is how we treat vulnerable clients. Some
estimates are that around half of UK adults display one or more
characteristics of being potentially vulnerable at some point in their lives.
We recognise the long-term cost to a client who ends up with an inappropriate
product or service, and we work to make sure that does not happen.

What is a vulnerable client?

A vulnerable client is someone who, due to their personal circumstances, is
especially susceptible to detriment, particularly when a firm is not acting
with appropriate levels of care. We recognise that this may not be a
permanent situation and that we need to respond in a flexible way that is
tailored to the individual.

What a vulnerable client should receive from us

• Information about insurance products that is clear and easy to understand, and which does not contain any hidden surprises, terms, conditions or costs.
• A choice of how to communicate with us — face to face, over the phone, via email, post or video call — at a time that is convenient.
• The feeling that they are treated as an individual, that their circumstances are being taken into account, and that they are not being treated as part of an ‘automated process’.
• The ability to talk to someone who will take the time to listen and who is sufficiently knowledgeable to spot signs of vulnerability and to refer the matter to someone with the authority, discretion or specialist knowledge where necessary.
• The knowledge and confidence that any information they disclose will be accurately recorded so they do not need to repeat it on every contact.

What we do

• We take the time to listen and care — we don’t make assumptions. We recognise that some clients may feel reluctant to admit vulnerability, but we will always act on the information available to us.
• We do our best to offer a flexible outcome so that clients do not have to rely solely on an automated process.
• We always work in the best interests of all clients, working with them to achieve a positive outcome. We offer the choice of having a friend or relative present, while considering whether that person is exercising undue pressure or influence on the client. We will work with any Powers of Attorney whom clients have appointed.
• We record disclosed information from a client on our back-office system (Open GI), meaning the information is held securely and the client does not have to repeat their vulnerability issues every time they make contact. We add a flag to the client file so that whenever anyone within the firm opens it, they see this flag and can deliver the individual care the client needs.
• We keep a confidential register of those clients who we deem to be vulnerable — whether permanently or temporarily — to ensure they receive the individual care they need.
• We do our best to spot suspicious activity which may signal abuse or fraud, and take the appropriate action.
• If we felt that we were unable to provide a vulnerable client with a product appropriate to their needs, we would not proceed and would instead refer the client to a charity or support group who may be able to help them.

Key drivers of vulnerability

We have considered the four drivers of vulnerability identified in the FCA’s
guidance for firms on the fair treatment of vulnerable customers (FG21/1).

Health	Life events	Resilience	Capability
Physical disability	Caring responsibilities	Low or erratic income	Low knowledge or confidence in managing financial matters
Severe or long-term illness	Bereavement	Over-indebtedness	Poor literacy or numeracy skills
Hearing or visual impairments	Income shock	Low savings	Low English-language skills
Poor mental health	Relationship breakdown	Low emotional resilience	Poor or non-existent digital skills
Low mental capacity or cognitive impairment	Non-standard requirements (e.g. ex-offenders, care leavers, refugees)	Lack of support structure	Learning impairments

At Apex Insurance Brokers, age on its own — either young or old — is not
necessarily a key indicator. We will consider whether there are other factors
in the table above which flag a potential concern.

Triggers that may highlight a vulnerable client

Our staff are alert to triggers that may indicate vulnerability, including:

• Late or missed payments or contributions;
• Lack of response to requests for information;
• Comments about ability to pay;
• Saying they cannot read or understand a letter we have sent;
• Comments about their own health or that of another person;
• Indications of concerns about changes in their domestic or employment situation;
• Requests to deal with a person rather than a computer.

Other observable signals can include shortness of breath or signs of
agitation, asking for repeated information, signs of confusion, or mention
of medication.

Data protection

Data protection should not act as a barrier to recording information in the
right circumstances, where doing so would lead to a fair outcome for the
client. We:

• record things in the client’s own words;
• do not make assumptions — we ask questions to fully understand a situation;
• record the needs and adaptations that the client asks for, rather than assume an underlying condition.

We are not authorised to disclose information about a client’s financial
arrangements to a third party without the client’s consent or an arrangement
such as a Power of Attorney or third-party mandate.

Examples of how we deal with vulnerable clients

Recently bereaved clients

This is a distressing time, and extra care will be given to ensure that
recently bereaved clients are emotionally stable and strong enough to receive
and understand any communication we have with them. We may suggest that a
close relative or trusted friend be present at meetings or on calls, and we
will copy them on any correspondence if asked.

Emotionally stressed clients

Factors such as divorce, job loss, severe or long-term illness, or caring
for elderly relatives can also place clients under significant stress. Extra
care will be given to make sure clients in these situations are able to
absorb any communications, and we will offer the same option of involving a
close relative or trusted friend.

Clients with hearing, vision or learning difficulties

We are aware of our obligations under the Equality Act 2010 to provide equal
access to our services irrespective of disability. For clients with vision
difficulties we can make documentation available in Braille or larger print.
For those with hearing difficulties we will recommend that a qualified signer
or a trusted relative or friend be present, who can review the information
and confirm it has been understood. For clients with learning difficulties we
will similarly recommend a trusted relative or friend.

Clients for whom English is not a first language

We ask that a close friend or relative who is fluent in both the client’s
own language and English be present to act as interpreter, and confirm in
writing that our client has fully understood the information given.

Continuous improvement

Client feedback is central to how we improve. If we receive negative
feedback in relation to a vulnerable client, we will use it to reassess our
approach and implement any improvements needed. All staff will be notified
and our procedures amended and re-issued where appropriate.