AIM OF THIS POLICY

The aim of this policy is to outline the practice and procedures for staff in Consilium Asset Management to contribute to the prevention of detriment to clients who find themselves in vulnerable circumstances.

The policy covers all staff within the firm and in particular those operating in areas that deal directly with customers.

DEFINITION OF VULNERABLE

The Financial Conduct Authority (FCA) has developed the following definition to guide work in this area:

A vulnerable consumer to be someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

Vulnerability occurs in a variety of 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.

Consilium Asset Management is a Financial Advisory Firm

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;

As a firm we must remain mindful of the potential for enquiry by these clients and the potential for any change of circumstance in respect of existing customers.

IDENTIFICATION OF CLIENTS IN VULNERABLE CIRCUMSTANCES

Vulnerability is broad and may occur at any time.  It will usually involve the interplay of characteristics of the individual, their circumstances, and static or transitory status.

Consilium Asset Management may only deal with customers in vulnerable circumstances where we are aware of their needs.

The nature of the need area to be addressed, for example, in connection with arranging mortgages and/or home finance,  equity release, sale and rent back, right-to-buy, or where the main purpose of raising funds is to consolidate debt, or advising on and / or facilitating the provision long-term care may also indicate vulnerability.   Here additional safeguards will be applied as appropriate to ensure fair treatment.

ASSESSMENT AND MANAGEMENT OF RISK

Consilium Asset Management will not discriminate against clients in vulnerable circumstances by way of adjustment to fees or any refusal to assist purely on the grounds of the client’s circumstance (unless that circumstance creates a situation which is likely to lead to a detriment or a risk that removes the availability of any finance facility).

We will review our practices periodically for consistency and to determine adherence to the stated policy.

RIGHTS & RESPONSIBILITIES

Responsibilities of Consilium Asset Management

Responsibilities of Consilium Asset Management’s employees