Vulnerable persons toolkit
The identification of vulnerable individuals allows you to both ensure you provide an appropriate level of service to your clients and helps reduce regulatory risk for your firm.
With an increasing focus across a range of situations on a firm’s environmental, social and governance (ESG) credentials, being able to respond appropriately to vulnerable individuals and their situations is increasingly important.
We have created this toolkit and guidance to support our member firms with the identification and support of vulnerable individuals who are clients, and to help take steps that allow you to act in that person’s best interests.
While this guidance and toolkit is aimed primarily at supporting individuals who are clients, the principles within this guidance can also be applied in other situations. This could for example include when you interact with directors of a company where the director themselves are not a client of your firm.
Our checklists are issued as part of the ICAS ‘Dealing with vulnerable persons toolkit and guidance’
The FCA defines a vulnerable individual as follows:
"A vulnerable individual is someone who, due to their personal circumstances, is especially susceptible to harm - particularly when a firm is not acting with appropriate levels of care.
"Our view of vulnerability is as a spectrum of risk. All individuals are at risk of becoming vulnerable, but this risk is increased by having characteristics of vulnerability. These could be poor health, such as cognitive impairment, life events such as new caring responsibilities, low resilience to cope with financial or emotional shocks and low capability, such as poor literacy or numeracy skills.
"Not all individuals who have these characteristics will experience harm. But they may be more likely to have additional or different needs which, if firms do not meet them, could limit their ability to make decisions or represent their own interests, putting them at greater risk of harm. So, the level of care that is appropriate for these consumers may be different from that for others."
These checklists should be used as part of our vulnerable persons toolkit and guidance in order to identify and support vulnerable individuals who are clients.