Vulnerable Customers Policy

Focus Insurance Services is committed to delivering fair, consistent outcomes for all customers. We understand that some customers may experience circumstances that make them more vulnerable to harm, especially during complex insurance decisions or at stressful times (such as after an incident or claim).

In line with FCA Consumer Duty requirements and FCA guidance on the fair treatment of vulnerable customers (FG21/1), we will take reasonable steps to:

• Recognise vulnerability where a customer tells us (or where it becomes apparent)
• Adjust our approach to help you understand information and make informed choices
• Provide additional support and flexibility where appropriate

2. What We Mean by "Vulnerability"

Vulnerability can be temporary, sporadic, or long-term. It can affect anyone.

We recognise that vulnerability may arise from a wide range of circumstances, including (but not limited to):

You do not need to share details you are not comfortable sharing. If you tell us you need support, we will focus on what practical steps we can take to help.

3. How We Can Support You

If you tell us you need extra help, we can offer support options such as:

Communication and Understanding

Contact Preferences

Representatives and Third Parties

You can ask us to speak with:

• A family member
• A carer
• A friend
• A professional representative (e.g., solicitor/accountant)

We may ask for confirmation that you consent to them acting on your behalf (to protect your privacy).

4. What We May Ask You

To tailor support, we may ask a small number of questions such as:

• What type of support you need (e.g., more time, clear summaries, contact preference)
• Whether you want a representative involved
• Whether there are any communication barriers we should accommodate

We will keep questions proportionate and focused.

5. Data and Privacy (Vulnerability Information)

If you choose to share information about vulnerability, we will:

• Use it only to provide appropriate support
• Restrict access to those who need to know
• Handle it in line with our Privacy Policy
• Keep records only as necessary for service quality and governance

You can ask us at any time how we have recorded your preferences.

6. Claims and Complaints Support

If you need extra support during a claim or complaint:

• Tell us what would help
• We will aim to accommodate reasonable adjustments
• We can provide clearer explanations of next steps and timeframes

7. How to Request Support

If you need additional support, please contact us:

8. If You Are Unhappy

If you are unhappy with the way we have supported you, you can raise this with us using our Complaints Procedure. We treat these matters seriously and will investigate fairly.

9. Reviewing This Policy

We review this policy periodically to ensure it remains appropriate and aligned to regulatory expectations and good customer outcomes.