Vulnerable Customer Policy

Code of Practice

The Financial Conduct Authority(FCA) who regulate our funeral plans define a vulnerable customer as ’someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care'. By following these guidelines, customers/firms can be confident we are meeting obligations that the FCA Code of Practice outlines.

A simple code that a funeral director / staff member can follow identifying a vulnerable customer is to consider the following the four questions and whether or not they apply to the customer. The questions come under the acronym C.A.R.E:



Is your customer able to follow and understand the discussion taking place?


Is your customer able to follow and understand the discussion taking place?


Does your customer appear able to retain the information you are giving them? Can they recall details or are you having to repeat?


How well do the express, explain or communicate their decisions? Is the dialogue genuinely two-way or are they simply agreeing with what you say?

Should Plan with Grace have any concerns, we ask the customer to discuss the plan with their nominated representative or a family member

Developing and implementing Best practice towards interacting with vulnerable customers is the best practice for interacting with all customers. There are five key principles that must steer all one-to-one marketing activity and which, if followed correctly, will naturally lead to appropriate care for all customers whatever their individual needs.

The five principles are:
Put your customer first
Be honest and fair
Respect privacy
Be diligent with data
Take responsibility

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Once a plan is purchased, the money is held securely in the Plan with Grace Funeral Payment Trust, until such a time it is required to pay for the funeral.