Vulnerable Client Policy

Monenti Partners has established clear and effective policies and procedures for identifying and dealing with vulnerable clients.

The Financial Conduct Authority (FCA) definition of a Vulnerable Client 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”

Protecting vulnerable clients is a key priority for us. We want vulnerable clients and potentially vulnerable clients to experience outcomes that are as good as those for other clients. The fair treatment of vulnerable clients is embedded into our culture, policies and processes throughout the whole client journey.

We recognise, for instance, as clients get older, other factors can come into play and in many circumstances, we need to apply further checks and balances to ensure our advisers provide the most appropriate advice to the highest possible standard.

Vulnerable clients may also include anyone by virtue of health, age or circumstances, may be more likely to be;

• Be easily influenced
• Accept advice without consideration to its suitability
  

With vulnerable clients, there are factors that may limit their ability or willingness to make reasonable decisions and choices. These clients may be at a higher risk of harm. So, the level of care that is appropriate for these clients will be different from that for others.

All staff, whether customer facing or not undergo training on vulnerable clients, by undertaking specific training and passing the relevant test.

We have identified 4 key drivers which may increase the risk of client vulnerability:

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

Characteristics of the 4 key drivers are shown in the table below. We understand that these may well overlap and become more complex.

Monenti Partners also has measures in place to distinguish between actually vulnerable and potentially vulnerable clients. Therefore, there are three groups of people; vulnerable clients, potentially vulnerable plus the non–vulnerable. The firm will assess all clients into one of these three groups, when taking them on board, and this information will be recorded and will remain on file for auditing purposes.

Where there is an ongoing relationship, a client’s vulnerability will be assessed at each client meeting where any advice is provided, or decisions are to be made. We also recommend and are happy to accommodate an accompanied meeting/interview, with the inclusion of a family member or trusted representative should this be required, and where financial advice is involved, we will always recommend discussing this with a family member or trusted representative to assist in the understanding and decision making process.

The firm have measures to understand whether a client is vulnerable or not. We question all clients very carefully, as well as assessing their requirements as part of a fact find and risk assessment. At no stage will we proceed where we believe that the client is actually vulnerable and has no additional assistance to enhance their understanding and decision making. We will ensure that we provide additional time to vulnerable consumers to make a decision on any recommendations made and will never pressurise any client into a decision.

In treating customers fairly, we are also aware of our obligations under the Equality Act 2010.

We will record any specific requests from clients to assist in meeting their needs to ensure that we continue to meet their requirements in any ongoing contact.

We encourage all of our clients to stay in regular contact with us and to inform us of any changes in their requirements and circumstances. We will also proactively keep in contact with all clients where there is an ongoing agreement and will ensure that we continue to meet each individual’s needs and ensure they are treated fairly.

We recommend that clients be scam aware and where they are able to access the internet, visit the Friends Against Scams website at www.friendsagainstscams.org.uk where they will find a wealth of information. Friends Against Scams is a National Trading Standards initiative, which aims to protect and prevent people from becoming victims of scams.

Monenti Partners – Vulnerable Client Policy V1.3 – January 2022