Vulnerable Customers Working Group

To educate and align industry practices relating to the treatment of vulnerable customers

Industry challenge

There is a regulatory and moral imperative to ensure that people are treated appropriately when they deal with financial firms, taking into account whatever vulnerability they may have.

Group purpose

Almost everyone will either have been in a position of vulnerability in their lives, or is currently vulnerable, or will become so as they age or need to care for someone. Financial firms have been working to deliver a consistent standard of fair treatment of customers for many years, but only recently have the needs of vulnerable people become central to fair treatment considerations. Some firms are well advanced with their practices, whilst others are struggling to establish consistent processes and strategy, and need support to help them advance more quickly.


Vulnerable Customers Best Practice

Group strategy

Goal/s: a) To manage the RADAR tool (to ensure it is fit for purpose against finalised FCA guidance); and b) To define, develop and share best practice.

Strategy: Facilitate input from charities/trade bodies/regulator/3rd party suppliers and create a framework for dealing with customers in different vulnerable situations and categories.

Participating member firms


Aegon UK PLC

Altus Limited

Aviva Plc

Aviva UK Insurance

Baillie Gifford & Co

Baringa Partners LLP

BNY Mellon

Brewin Dolphin Ltd

Comentis Ltd


Delta Financial Systems


Fidelity International

HSBC Bank plc

Investec Bank Plc

James Sharp & Co

Janus Henderson

JPMorgan Asset Management

Link Group


M&G Investments

Money Guided


NatWest PLC


Northern Trust

Novia Financial


Pinsent Masons LLP


Punter Southall Wealth Limited

Quilter Cheviot Limited

Quilter PLC

Scottish Widows Plc

Sopra Steria


St James’s Place Wealth Management

Tesco Bank

Thesis Asset Management

Lisa Laybourn, Head of Technical Policy and Regulation leads on this work at TISA

Chair: Anthony Scammell, Quilter

If you are a TISA member, and would like to get involved with the Vulnerable Customers work, please get in touch

Go to

Vulnerable Customers Groups & Resources

Go to