Vulnerable Customer Policy

INTRODUCTION

This Vulnerable Customer Policy (“Policy”) is issued by Margarlit Ltd, trading as The Fine Jewellery Company (“The Fine Jewellery Company”, “we”, “us” or “our”).

The Fine Jewellery Company recognises that some customers may experience circumstances that make them more vulnerable to harm, disadvantage, or difficulty in engaging with products and services. We are committed to ensuring that all customers are treated fairly and with respect, and that those in vulnerable situations receive an appropriate level of care and support.

This Policy has been developed in line with the principles of the Financial Conduct Authority (“FCA”), including the expectation that firms deliver good outcomes for all customers, particularly those who may be vulnerable. We acknowledge that vulnerability can be temporary, permanent, or situational, and that it may not always be immediately apparent.

The purpose of this Policy is to:

  • establish a clear framework for identifying and supporting vulnerable customers;
  • ensure that staff respond appropriately and sensitively to individual circumstances;
  • promote fair, consistent, and customer-focused outcomes; and
  • minimise the risk of harm arising from misunderstanding, lack of clarity, or barriers to engagement.

We recognise that vulnerability may arise from a range of factors, including health conditions, life events, financial circumstances, or limitations in understanding. As such, we are committed to adopting a flexible and proportionate approach that takes into account the specific needs of each customer.

This Policy applies to all customer interactions across the business, including pre-sale, point of sale, and post-sale support. It forms part of The Fine Jewellery Company’s broader commitment to responsible business practices and customer care.

All staff are expected to be aware of this Policy and to act in accordance with its principles when interacting with customers. Where potential vulnerability is identified, appropriate steps should be taken to ensure the customer is supported effectively and fairly.

This Policy should be read in conjunction with the company’s Complaints Policy, Complaints Handling Procedure, and other relevant customer care policies.

 

DEFINITION OF VULNERABILITY

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm, disadvantage, or difficulty in making informed decisions.

In line with FCA guidance, vulnerability may arise from one or more of the following drivers:

  • Health: Physical or mental health conditions that affect understanding, communication, or decision-making
  • Life Events: Situations such as bereavement, relationship breakdown, job loss, or financial hardship
  • Resilience: Reduced ability to withstand financial or emotional shocks
  • Capability: Low financial literacy, language barriers, or limited digital skills

Vulnerability can be:

  • Permanent (e.g. long-term disability)
  • Temporary (e.g. illness or short-term financial difficulty)
  • Situational (e.g. stress at the time of purchase)

 

OUR COMMITMENT

The Fine Jewellery Company is committed to:

  • Treating all customers with fairness, dignity, and respect
  • Ensuring vulnerable customers are not disadvantaged
  • Communicating in a way that is clear, transparent, and accessible
  • Taking reasonable steps to adapt processes where necessary
  • Supporting informed decision-making without undue pressure
  • Delivering outcomes that are consistent with good customer care and regulatory expectations

 

IDENTIFICATION OF VULNERABILITY

We recognise that vulnerability is not always disclosed and may need to be identified through customer interaction.

Staff should be alert to indicators such as:

  • Difficulty understanding information or asking repeated questions
  • Signs of confusion, distress, or anxiety
  • Statements indicating financial difficulty or hardship
  • Disclosure of personal circumstances (e.g. illness, bereavement)
  • Unusual behaviour during the purchasing process Where appropriate, staff may ask sensitive, respectful questions to better understand the customer’s needs.

 

SUPPORTING VULNERABLE CUSTOMERS

Where a customer is identified as vulnerable, we will take proportionate steps to provide appropriate support, which may include:

  • Adapting communication (simplifying language, avoiding jargon, providing written summaries)
  • Allowing additional time for decision-making
  • Encouraging questions and ensuring understanding
  • Offering alternative communication channels where possible
  • Permitting a trusted third party (with customer consent) to assist
  • Avoiding pressure-based selling practices

All support measures will be applied in a manner that respects the customer’s dignity and autonomy.

 

STAFF TRAINING AND AWARENESS

The Fine Jewellery Company is committed to ensuring that all relevant staff:

  • Are aware of this Policy and its importance
  • Understand how to identify potential vulnerability
  • Are equipped to respond appropriately and sensitively
  • Know when and how to escalate concerns

Training will be provided on an ongoing basis to maintain awareness and competence.

 

COMMUNICATION STANDARDS

We aim to ensure that all customer communications are:

  • Clear, concise, and easy to understand
  • Free from unnecessary jargon or complexity
  • Delivered in a tone that is respectful and supportive

Where vulnerability is identified, additional care will be taken to ensure that information is fully understood before proceeding.

 

CONFIDENTIALITY AND DATA PROTECTION

All information relating to a customer’s personal circumstances, including vulnerability, will be:

  • Treated as confidential
  • Handled in accordance with applicable data protection laws
  • Used only for the purpose of providing appropriate support

Sensitive information will only be recorded where necessary and with appropriate safeguards.

 

ESCALATION AND INTERNAL SUPPORT

Where staff are unsure how to proceed, or where a situation requires additional support:

  • The matter should be escalated internally to a senior team member
  • Appropriate guidance will be provided to ensure fair and consistent handling

 

MONITORING AND REVIEW

The Fine Jewellery Company will:

  • Monitor interactions and outcomes involving vulnerable customers
  • Review this Policy periodically to ensure effectiveness
  • Make improvements where necessary to enhance customer support

 

CONTINUOUS IMPROVEMENT

We are committed to continuously improving how we support vulnerable customers by:

  • Learning from customer feedback and complaints
  • Identifying trends or recurring issues
  • Updating processes and training accordingly

 

CONTACT INFORMATION

The Fine Jewellery Company
A trading name of Margarlit Ltd (Company No. 12653414)

Registered Office:
Crown House, 151 High Road, Loughton, Essex, England, IG10 4LG

Email: info@thefinejewellerycompany.com
Phone: +44 330 010 2012