Vulnerable Client Policy

Supporting you: Our commitment to clients who may need help

We understand that everyone’s circumstances are different. At times, life events, health conditions or financial pressures can make it harder to manage financial decisions confidently. When this happens, our priority is to ensure you receive the support you need, in a way that feels comfortable and right for you.

This document explains how we identify when clients may need additional help, how we support you, and what we do to keep your information safe.

What do we mean by vulnerability?

We use the term vulnerability to describe situations where a person’s circumstances may make them more likely to experience harm or make it harder to make and act on financial decisions without additional support.

Vulnerability can be temporary, long‑term, or fluctuating, and can affect anyone at any stage of life.

The Financial Conduct Authority (FCA) outline “All customers are at risk of becoming vulnerable and this risk is increased by characteristics of vulnerability related to 4 key drivers:

  • Health – health conditions or illnesses that affect ability to carry out day-to-day tasks
  • Life events – life events such as bereavement, job loss or relationship breakdown
  • Resilience – low ability to withstand financial or emotional shocks
  • Capability – low knowledge of financial matters or low confidence in managing money. Low capability in other relevant areas such as literacy, or digital skills.”

How we support you

The additional support we offer our clients will be flexible and personalised to suit each individual situation. Vulnerability can be temporary, fluctuating or long term, so on-going engagement is key to us providing you with the right level of support. You don’t need to label yourself as ‘vulnerable’, we will ask all the usual questions and look out for signs that suggest some additional support would be beneficial.

You can tell us at any time if something is making your situation or financial decisions more difficult. Anything you share will always be treated with sensitivity and respect.   

Some circumstances, such as a hearing impairment, may be well managed and don’t necessarily require additional support from us. But others, like the loss of a loved one, or a serious diagnosis can have a direct impact on a person’s levels of resilience and even capability.

Some examples of our tailored support we promise to you:

  • Extra time and a slower pace during meetings
  • Written follow-up summaries after discussions
  • Large-print or alternative format documents
  • Video or home-based meetings when helpful
  • Encouraging you to involve a trusted friend, relative, or attorney
  • Checking in with you (outside of financial discussions)
  • Signposting relevant charities or support organisations we feel could help
  • Helping you compare and reflect on options in your own time
  • Speaking with you separately if we feel you may be under pressure or influence

How we keep your information safe

To give you the right support, we may sometimes need to record information about your situation — for example, a health condition, or the details of someone you trust.

We will always:

  • Only record necessary information
  • Comply with all data protection and privacy laws
  • Gain your explicit permission wherever required
  • Ensure only appropriate members of the team have access to this information

You can ask us to update, review or remove this information at any time.

Our Practice standards and commitments to you

To ensure you receive consistent, high‑quality support, our advisers and support colleagues follow these commitments:

  • Every member of our team completes annual training on Vulnerability awareness
  • We also complete annual Consumer Duty and ‘Good Client Outcomes’ training
  • Review our vulnerability and client support processes regularly
  • We assess whether a client has the capacity to enter into a contract, and if in doubt, will pause advice and seek appropriate guidance
  • We record relevant information in a clear and respectful way to ensure the whole team — and St. James's Place — can support you consistently
  • We check whether you have a current Will or Power of Attorney; if not, we will strongly recommend seeking legal advice
  • We follow the SJP long‑term care advice framework where relevant
  • We ensure our communications meet accessibility standards
  • We will discuss Client Assistance rules with you and encourage a trusted third‑party to attend meetings where appropriate

Letting us know when life changes

Life can change in lots of ways, sometimes unexpectedly.

The more we understand about what’s going on for you, the better we can tailor our support and make things easier. You’re never inconveniencing us by telling us; it genuinely helps us help you.

We’ll always take the time to listen, understand and adapt our approach so you feel fully supported and confident in every step of your financial decisions.

If you feel you may benefit from extra support, or if something has changed recently, we warmly encourage you to let us know. You can speak with us at any time — we’re here to support you, not just your finances.