Vulnerability Policy

Estate Agency is an unregulated industry. However that does not mean that we cannot self-regulate. At Turners Oak we feel this is especially important due to our client demographic and the raised likelihood that we may be working with vulnerable clients.

We have worked with Independent Financial Advisors and members of the Society of Later Living Advisors (SOLLA) to adapt the Codes of Conduct from the Financial Conduct Authority to create this vulnerability policy. In addition to this policy all members of the Turners Oak team undertake the Consumer Vulnerability in Later Life training developed by SOLLA in collaboration with Just.

Definition of vulnerability

Vulnerability occurs in a variety of ways which may be permanent, temporary, or even sporadic, dependent on its nature. In many circumstances the individual may not recognise themselves as vulnerable. We recognise that vulnerability may not be simply due to the situation of the consumer but caused or aggravated by the actions or processes of the firms they may deal with.

We recognise that clients who might be considered as being in vulnerable circumstances could include clients with:

• Mental capacity deficiencies (including language or communication), including mental illness and dementia
• Stress or subject to financial shock of all types, such as employment concerns, bereavement (or potential bereavement), marital or relationship difficulties
• A physical impairment that may not allow them to engage with automated or other standard process requirements (such as photographic ID, phone keypad recognition, or internet applications)
• Severe and long-term illness (both life-limiting and where recovery is expected)
• Little or no financial experience or no access to mainstream financial services; low income
• An existing distressed financial situation
• Responsibilities for others, such as carers or acting as power of attorney
• No access to the internet or other digital media
• Poor language skills
• A general vulnerability due to being aged 75 and over or aged 18 years and under

Identification of clients in vulnerable circumstances

Vulnerability is broad and may occur at any time. We also recognise that many clients may be supported by family members. Whilst this is generally a good thing, it may also be a sign of vulnerability. When contacted by relatives of clients we will speak to the client directly and alone as part of our initial conversations and before moving forwards with any formal instructions.

The nature of the need area to be addressed may also indicate vulnerability. For example, people wanting to:

• Move home to release equity
• Move home to provide financial support to others
• Move home to facilitate long term care
• Move home to make life more manageable

Assessment and management of risk

Just because somebody is vulnerable does not automatically mean that they are unsuitable for the service of the organisation. As soon as we think we may be engaging with a vulnerable consumer we will make a record of this and ensure we adhere to this policy.

When speaking to the vulnerable consumer we will provide additional opportunities for the customer to ask questions, continuously seek confirmation that they have understood the information provided, and ask if there is anybody with them who is able to assist them.

We will not discriminate against clients in vulnerable circumstances. Where we feel we do not have the expertise to deal with the client due to their personal situation we will make every attempt to refer them to another organisation or third party for the appropriate level of support.