This product is sold to companies, not individuals. But the director on the other side of the conversation is a person, and people can be vulnerable. We treat the FCA's guidance for the fair treatment of vulnerable customers (FG21/1) as the floor for how we behave with directors.
How we recognise vulnerability
The FCA describes four drivers of vulnerability: health, life events, resilience and capability. Any of these can affect a director's ability to engage with us. Specific examples that would prompt us to flag a customer:
- Mental or physical health conditions that affect day-to-day life
- Bereavement, divorce, serious illness in the family
- Sudden loss of income — the company's or the director's
- English not being a first language to a degree that affects comprehension of credit terms
- Cognitive or sensory impairments that affect signing electronic documents
How we identify it
Mostly by listening. Anyone in our team who picks up a call or reads a message can flag the customer's record. The flag is stored on the customer record (not on the loan), is visible only to staff, and can be added with a note describing what we have heard so the next colleague to speak to the customer is prepared.
What changes when a customer is flagged
- Top-up borrowing offers are suppressed. We do not proactively offer further credit to a flagged customer; if they ask, a senior staff member reviews the request manually.
- Marketing emails are paused.
- Default-stage collection actions are paused while we agree a plan; we do not pass flagged accounts to third-party collectors.
- Forbearance requests from flagged customers are prioritised in the staff queue.
Reviewing the flag
Vulnerability is not necessarily permanent. We review every flagged record annually, and at any point the customer asks. The record carries a note from the staff member who set the flag and a timestamp; staff who change or remove a flag are recorded too.
Training
Everyone on the team completes vulnerability awareness training at induction and refreshes it annually. The training emphasises practical things — listening for signals, asking open questions, knowing when to escalate.