Vulnerable Customer Information

Code of Practice


The Financial Conduct Authority (FCA) who regulate our funeral plans define 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’. By following these guidelines, customers/firms/ can be confident we are meeting the obligations that the FPA Code of Practice outlines.

A simple code that a funeral director / staff member can follow identifying a vulnerable customer is to consider the following four questions and whether or not they apply to the customer.  The questions come under the acronym C.A.R.E.


Is your customer able to follow and understand the discussion taking place?
Is your customer able to weigh up the pros and cons of the information provided?
Is the customer able to retain and remember information and recall this at a later point?
Is the customer able to explain and communicate their decisions?


Should With Grace have any concerns, we ask the customer to discuss the plan with their nominated representative or a family member


Developing and implementing Best Practice towards interacting with vulnerable customers is the best practice for interacting with all customers.  There are five key principles that must steer all one-to-one marketing activity and which, if followed correctly, will naturally lead to appropriate care for all customers, whatever their individual needs.


Adapting the way we deal with vulnerable customers


Once we have identified that a customer may be vulnerable, we need to consider how best to take this into account in the way we deal with that person. Every situation is different, and staff must exercise their judgement to determine an approach best suited to helping that individual.

In many cases, our approach may simply be to take particular care to explain everything the customer needs to know clearly and fully and check their understanding as we go along so that they can make an informed decision.  In some cases, it may be helpful to assist or talk customers though key steps in the process such as completing an enquiry form; for example, when we know a customer has poor eyesight.

To ensure staff can adapt a flexible approach, we have deliberately not set out a prescriptive list that maps each type of vulnerability to a particular type of treatment.  However, examples of ways we can help and adapt our approach include:

  • Using alternative methods of contact;
  • Requesting the presence of an authorised carer;
  • Ensuring that customers are explicitly provided with the opportunity to declare themselves vulnerable;
  • Providing information in writing for greater clarity;
  • Contacting customers at specified times;
  • Informing third-party providers of a customer’s vulnerability so the customer does not have to repeat that information; and
  • Providing customers with a warm referral to a support charity.

The only exception to this is where we know or suspect that a customer may have a mental capacity issue.  In these instances, we must refrain from completing any transactions unless these can take place in the presence or with the approval of a designated carer or a person known to the customer who can support them through the transaction.  We must not complete transactions on behalf of customers, unless we can be certain that their decision making is not impaired by their vulnerability.


The five principles are: 


1. Put your customer first

2. Be honest and fair

3. Respect privacy

4. Be diligent with data

5. Take responsibility