Vulnerable customers

The purpose of this policy is to provide a set of objectives to be used to shape internal procedures to identify and transact with Vulnerable Customers. It also takes into account Offa's and Offa Money’s obligations under Consumer Duty.


Confidentiality notice: This document is confidential and contains proprietary information and intellectual property of Offa. None of the information contained herein may be reproduced or disclosed under any circumstances without the express written permission of Offa.

Offa means any company within the group of companies within Offa Holdings Limited including the operating and finance special purpose vehicle companies.

Ownership: This policy is owned by the Risk Manager who is tasked with ensuring it is kept in line with Offa's risk management practices and UK legal and regulatory requirements.
Changes will be controlled by the Risk Manager, and subject to approval by the Board which has delegated its authority to the Board Risk Committee. The Board of Offa Money has reviewed and accepted the group’s policy for implementation in Offa Money.

Regular Oversight: Senior Management are tasked with ensuring that this policy is followed by Offa's employees and agents.

Additional Oversight: The compliance function will monitor that the policy has been followed as part of its regular monitoring activities.


1.1 Scope & Risk Appetite

The FCA 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” and Principle 12 “Consumer Duty: A firm must act to deliver good outcomes for retail customers” is particularly responsive to the delivery of good outcomes to vulnerable customers.


2.1 Committee responsibilities
The Board Risk Committee and the Executive Committee are responsible for overseeing the effective implementation of this policy by all levels of management and operations.

This policy is approved by the Board Risk Committee which has been mandated by the Board.

2.2 Executive responsibilities
Offa will ensure all staff are provided with the time, resources, and support to learn, understand and implement the Vulnerable Customers policy and associated procedures into their business practices. Senior Management are responsible for a top-down approach in ensuring all staff are included.

The Risk Manager and Executive Committee are responsible for Vulnerable Customer audits and gap analysis monitoring, their subsequent reviews and follow up actions. There is to be an audit trail of all Vulnerable Customer audits and feedback to ensure continuity through each process and task.

The Head of Operations is responsible for ensuring all complaints raised are logged and actioned in accordance with the Complaints Policy and procedures; also, in ensuring outcomes are matched against the TCF objectives and appropriate changes are made where gaps are identified.

2.3 Review process
This policy will be reviewed at least once a year or more frequently should changes to regulatory guidelines occur. The Risk Manager is authorised to amend the policy as and when required to address regulatory rule changes or product additions/modifications. Such modifications will be put to the Board Risk Committee for confirmation and approval.

Minimum standards and requirements

3.1 Definitions
To expand on the FCA definition (see 1.1), the most likely – but not exhaustive, and unranked – parameters

For a Vulnerable Customer encountered by Offa staff and agents are:

  • Low literacy, numeracy, and financial capability skills
  • Acute or long-term physical or mental health conditions
  • Caring responsibilities for others (including exercising a power of attorney)
  • Significant change in life circumstances (e.g., job loss, bereavement, divorce)
  • Physical impairments
  • English as a second language
  • Subject of criminal activity relating to the account or person
  • Being an “older old” customer (e.g., may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, or being uncomfortable with forms of technology)
  • Being a younger customer (e.g., may be associated with less experience of financial products)
  • Non-standard requirements or atypical consumer history (e.g., ex-pats, armed forces personnel returning from overseas posting, ex-offenders, care-home leavers, recent migrants)

3.2 Objectives
3.2.1 Identification of a Vulnerability
Customers may be recognised as vulnerable or potentially vulnerable through self-identification or through indicators that Offa has identified. All staff and agents have a responsibility to remove unnecessary barriers for customers and should consider the objectives of this policy in their assessment of vulnerabilities as with any other customer needs. 

A non-customer-facing colleague who identifies a potential vulnerable customer must communicate the details to the appropriate Origination Lead or Servicing Lead immediately, where exploration of circumstances will be carried out with the non-customer-facing colleague if required in order to understand the situation better prior to engagement with the customer.

3.2.2 Interaction with Vulnerable Customers
The range and diversity of the factors that can constitute a customer vulnerability mean there cannot be a single approach to fit all circumstances. The overriding principle must be to make every effort toward achieving good outcomes and avoiding foreseeable harm throughout the customer’s journey. It is therefore essential that Offa staff and agents take a flexible approach as our malfunction could lead to financial and non-financial determinants for customers.

Offa staff and agents must consider vulnerable customer needs in all interactions; alternative communication methods, such as Braille, Large Print, electronic versions of physical documents, or in languages other than English will be reasonably accommodated to remove access barriers. Processes and procedures will be engineered to enable the identification and support of vulnerable customers across the whole customer journey.

Offa staff and agents must offer customers who have been identified as vulnerable with regular reviews at appropriate intervals to establish whether their classification and support approach continues to be appropriate to their needs.

Offa staff and agents must escalate individual cases where a vulnerable customer is at risk of a detrimental outcome because of situations falling outside of existing procedures. The Origination Lead or Servicing Lead will confer with appropriate colleagues to determine the most suitable outcome for the customer, and inform the Risk Manager root cause, actions resulting, and suggestions for improvements to be adopted.

Key framework of controls

The policy framework set out in this document is designed to ensure Offa acts in a transparent and consistent way with regard to customers who are at risk from becoming, or who have already been identified as vulnerable.

4.1 General Controls
Where a customer has been identified and/or declared as being vulnerable, or potentially vulnerable, Offa will act to ensure the methodologies laid out below are followed in every instance:

  • Staff have appropriate lines of reporting should they need to escalate a matter
  • Customer-facing written materials are clear, to the point, and jargon free
  • Offer braille and/or large print materials on request
  • Offer materials in alternate languages on request
  • Contact pathways are clearly visible in all communications and our website
  • Provide a choice of ways to communicate with us, including:
    • Post
    • Email
    • Telephone
    • Online Chat services
    • Face to face
    • Through an authorised third-party representative
    • Deal with any 3rd party authorised by a customer as if they were the customer
    • Any and all sensitive or confidential information disclosed to us regarding a customer’s vulnerability is used, retained, and destroyed is a secure manner in accordance with The Data Protection Act, specifically in relation to Special Category Data
  • Systems have the ability to readily and clearly flag a Vulnerable Customer and capture details of the vulnerability on a ‘tell us once’ basis, and subsequent interactions see at-a-glance the customer has additional support requirements
  • Distance sales or advice interactions are to be followed up in writing, detailing the content and context of the discussion, relevant terms & conditions, and disclosure information
  • Where appropriate, the products offered have flexibility in form and outcome to suit a customer’s needs and requirements. In short, Offa staff and agents will be equipped to recognise a customer’s need for additional support and provide such support to allow our customers to make informed decisions and maintain access to products and services and fulfil their financial objectives.

4.2 Specific controls
4.2.1 Mental Health Conditions
Whilst the General Controls apply, the design of Offa's policies, processes, and procedures will be attentive to the Money Advice Liaison Group ‘Good Practice Awareness Guidelines for Helping Consumers with Mental Health Conditions & Debt’ (MALG Guidelines)

4.2.2 Customers in Financial Distress
Financial distress could be a cause, indicator, or consequence of vulnerability in an individual. 

Whilst the General Controls apply, Offa's policies, processes, and procedures in relation to the sale of products and management of accounts payment shortfalls will be explicitly designed to accommodate customers on a case-by-case basis, and with specific regard to the MALG Guidelines referenced at 4.2.1

4.2.3 Customers with Sensory Impairments or English as a Second Language
Customers with hearing or visual impairments, or where English is not their first language, must not be allowed to suffer detrimental outcomes or poor service simply because OUR systems cannot accommodate THEIR needs as a customer. 

Whilst the General Controls apply, it will be policy to be considerate of the need to build in additional time in a contact strategy or action plan with a customer to allow for the production and consumption of printed materials in large print, braille, other languages, or scheduling with 3rd party representatives, as per the merits and circumstances of the case.

4.2.4 Young or Inexperienced Customers
What may be common terms or assumptions for customers who have experience taking out financial products and services can be confusing or unconsidered for those who have not. This is especially true in products and services relating to financing property ownership where a poor customer outcome could have profound consequences.

Whilst the General Controls apply, it will also be prudent to emphasise the long-term and long-lasting aspects of a particular event or consequence of events when engaging with a younger or inexperienced customer, as per the merits and circumstances of the case.

4.2.5 Elderly Customers
Whilst the General Controls accommodate a customer’s unease with particular forms of technology or their need to access information in a particular manner (e.g., letters rather than emails, phone calls rather than apps), it will also be policy to be considerate of the need to build in additional time in a contact strategy or action plan with a customer to allow for the possibility the customer may need longer to process information; as per the merits and circumstances of the case.

4.2.6 Circumstantial Vulnerabilities
A customer may experience temporary or unexpected change in circumstances which might in turn cause a situation of vulnerability. These may be generally pictured as significant life events which could affect anyone and are often unexpected. Unlike trait-based causes of vulnerability, circumstantial vulnerability tends to be short- or medium-term in nature. These include for example (again not limited to):

  • Bereavement
  • Job loss or other loss of income or livelihood
  • Victim of an external catastrophe (e.g., flooding)
  • Sudden change situations causing strife (e.g., acute illness or relationship breakdown)
  • Gradual change situations at or reaching a threshold of difficulty (e.g., chronic illness or increasing carer responsibilities)
  • Whilst the General Controls apply, it be policy to be considerate of the need to build in additional time in a contact strategy or action plan with a customer to allow for the possibility the customer may need longer to process information, as per the merits and circumstances of the case.


Offa is committed to ongoing professional development in the area of identification and interaction with Vulnerable Customers.

Initial and rolling programmes of training, assessment, and feedback will be provided to staff and agents on the requirements of this policy and the company culture in relation to providing products and services to our Vulnerable Customers.

Monitoring and reporting

The Head of Compliance undertakes regular internal audits and gap analysis monitoring on all business practices and procedures to determine how our Vulnerable Customers standards and objectives are being met.

These audits test policy and procedure against assessments designed to test the Vulnerable Customer processes and regulatory compliance. This would include reviewing customer complaints with Vulnerable Customer flag, or complaints without flag but results in identifying a Vulnerable Customer.

Regular reviews of the audit results are held with Senior Management and an ongoing record of gaps, actions resulting, and improvements made will be maintained. These forums will also anticipate potential emerging changes or risks resulting from regulatory developments.

Customer service calls are subject to regular review to assess them against Offa objectives and standards for dealing with Vulnerable Customers.

The Risk Manager will define the Key Risk Indicators (KRI) required in relation to Vulnerable Customers. These KRIs are to be monitored and reported on a monthly basis to the Executive

Committee and quarterly to the Board Risk Committee. Reports will also be made to the Board of Offa Money where the product relates to regulated long-term HPP and short-term bridging HPP.

Waivers, breaches and exceptions

Any transactions identified as being undertaken outside the standards laid out in this policy will be classed as a breach which will be recorded on the breach log in conjunction with Offa's Regulatory Breach procedure and must be informed to the Risk Manager immediately.