FOR INTERMEDIARIES ONLY

The fair treatment of vulnerable customers

The Financial Conduct Authority (FCA) wants to ensure that customers experiencing characteristics of vulnerability receive outcomes as good as those of customers who are not. As a result they published guidance on the fair treatment of vulnerable customers. These recommendations apply to all financial firms with retail clients that are natural persons

The guidance places the onus on financial firms to ensure that individuals experiencing characteristics of vulnerability receive outcomes as good as those as customers who are not and are treated fairly.

In order to ensure the best outcomes for our customers we’re continually making improvements to our processes and in particular our additional support offerings. The following information will provide useful detail on the steps we’re taking and how we can work together to ensure customers experiencing vulnerabilities receive the additional support they need to engage with our products and services.

We’ve been providing insurance products and services for over 130 years and have well-established mechanisms to help support our customers with additional needs.

In our capacity as an insurance provider, we commit to supporting our customers to engage with our products and/or services and to provide additional support throughout the insurance lifecycle to those who need it.

We offer alternative communication formats such as large text, braille and sign video services. However, our additional support offerings extend beyond this and recognise the broad spectrum of vulnerabilities that can affect our customers.  For example, we offer the ability to request a nominated person, we have a payment holiday process for those experiencing financial vulnerabilities and we empower our claims and complaints colleagues with the right tools to handle vulnerable circumstances.

We’re currently implementing “additional support” fields across our key systems to capture what our customers need to access our products and services. This will continue to improve the service we provide to our customers experiencing characteristics of vulnerability.

We aim to support all customers to access and engage with our products and services. Where a customer requires additional support to do this as a result of a vulnerable characteristic please contact your local underwriter to discuss what we can do to help.

We recognise that some firms may not deal with retail clients that are natural persons. However, the FCA’s principles including 6 & 7  detailed below continue to apply to all customers:

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6 Customers' interests firm must pay due regard to the interests of its customers and treat them fairly.  
7 Communications with clients A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading.  
Financial firms should review the FCA’s guidance on the fair treatment of vulnerable customers to ensure that they’ve adopted the guidance appropriately.
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