Introduction and Overview

Covertax Ltd vulnerable customers’ policy should be read and understood by all members of the organisation.

The Financial Conduct Authority 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.’

This policy seeks to ensure that Covertax Ltd undertakes its responsibilities regarding protection of vulnerable customers and will respond to concerns appropriately. The policy establishes a framework to support staff in their practices and clarifies the organisation’s expectations.

Understanding the customer

Vulnerability can be defined in several ways and can be of a temporary or permanent nature.  We recognise that some of our own customers may be considered vulnerable, so to enable us to provide a flexible, tailored response to meet our customer’s needs, vulnerability needs to be recognised.

Examples of personal circumstances that may indicate permanent vulnerability are old age, physical or sensory disabilities, severe physical illness, mental illness (including dementia) or learning disabilities. Temporary vulnerability may be caused by stress because of unemployment, adverse physical or mental health or a personal trauma. All customers have the potential to be vulnerable whether it be temporary or permanently, due to a change in their personal circumstances.

We also acknowledge that vulnerability can be caused or exacerbated by our own actions and processes. For example, poorly designed internal processes may cause additional stress to a customer which may be detrimental to them.

We feel that a key aspect of treating our customers fairly, is to deal with vulnerable customers appropriately.


In practice, this vulnerable person’s policy it will be implemented and to ensure:

  • Regular reviews are undertaken; how we deal with vulnerable customers, identifying and overcoming any issues which may prevent us from improvement.
  • Customers interfaces are inclusive and accessible.
  • Considered business decisions which consider the impact on vulnerable customers.
  • When updating or developing business processes, vulnerable customers are considered.
  • The training of existing and new customer-facing staff, to have an awareness of vulnerability, and to be able to recognise and respond appropriately. This includes an awareness of procedures for referral for help, both internally and externally, if applicable.
  • Development of our customer record systems to ensure that, the circumstances indicating vulnerability are clearly recorded and appropriately flagged so that all appropriate staff are made aware of these circumstances.
  • Relevant senior staff are trained and empowered to use their judgement to make appropriate decisions, and that they are consistently made aware of vulnerable customers whenever it is appropriate.
  • Appropriate training and support for staff who are likely to deal with vulnerable customers.

DBS Checked

All of our staff have been DBS checked and it is our policy for new joiners to undertake the check.

Responsibility and review

This policy and the procedures arising from it are reviewed at least annually.

Steve Botham is responsible for this policy.

Last updated 27 November 2017