Vulnerable Customer Policy

The Antique Jewellery Company is committed to treating all customers fairly, and to giving particular care to those who may be in vulnerable circumstances. This policy sets out how we identify customers who may be vulnerable, the steps we take to make sure they receive an appropriate level of service, and where we will refer them for specialist support if needed.

What we mean by “vulnerability”

Following the Financial Conduct Authority’s guidance, a vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm — particularly when a firm is not acting with appropriate levels of care. Vulnerability can be temporary or long-term, and can arise from a wide range of factors, including:

• Health — physical or mental health conditions, disabilities, or cognitive impairments such as dementia.
• Life events — bereavement, relationship breakdown, serious illness, or caring responsibilities.
• Resilience — low income, financial difficulty, or limited ability to withstand financial or emotional shocks.
• Capability — low confidence using digital or financial services, language barriers, or limited literacy.

A customer may be vulnerable in one of these ways without being vulnerable in any other, and many vulnerabilities are not visible. We treat vulnerability as a spectrum rather than a fixed category, and we aim to recognise and respond to it sensitively whenever it arises.

Customers using Interest Free Finance

Where a customer is purchasing using our Interest Free Finance option or any other regulated credit product, we take particular care to consider whether they may be in a vulnerable position. In line with FCA guidance (CONC 2.10 and the FCA’s guidance on the fair treatment of vulnerable customers), we may ask:

1. Whether anything about the customer’s health or personal circumstances might affect their financial situation;
2. Whether anything might affect their ability to communicate with us or to understand the agreement;
3. Whether someone else helps them manage their finances, such as a family member, carer or attorney.

We will only ask these questions where it is appropriate to do so, and we will treat the answers in confidence.

Signs that a customer may be vulnerable

We train our team to be alert to signs that a customer may be in a vulnerable position. These can include:

• Asking us to speak up, slow down, or repeat ourselves
• Appearing to miss key information or seeming confused about what is being offered
• Asking unrelated questions, repeating themselves, or finding it difficult to stay on topic
• Taking a long time to respond, or saying that someone else deals with these matters for them
• Mentioning a language barrier, or difficulty understanding written correspondence, statements or previous conversations
• Showing signs of distress, anxiety or recent significant life events such as bereavement or illness
• Showing reluctance or pressure to commit to a purchase, particularly a high-value one

How we adapt our service

If we believe a customer may be vulnerable, we will:

• Speak clearly, at an appropriate pace, and avoid jargon
• Be patient, empathetic, and not rush the conversation
• Stay on the subject under discussion, without making assumptions about the customer’s needs or capabilities
• Check understanding at each stage and invite the customer to explain back what they understand the agreement to be
• Offer alternative ways to communicate — phone, email, post, video call, or in person at our showroom
• Recognise that the customer may have visual or hearing impairments, and adapt our communication accordingly
• Be aware that customers may be forgetful, isolated, or trusting, and not exploit those circumstances
• Listen carefully — including for what is not being said, such as hesitation, extended silences, or a lack of engagement with price or terms
• Offer to pause and resume the conversation at a more suitable time
• Ask if there is anyone else the customer would like to consult before making a decision, such as a family member, friend or adviser
• Where appropriate, suggest that the customer take time to reflect before committing to a high-value purchase or finance agreement

Recording communication needs

• Where a customer tells us about particular communication needs, we will, with their consent, record this so that future contacts can be handled appropriately.
• Where appropriate, we record that we are satisfied the customer fully understood the discussion before any commitment was made.
• Customers may make a personal declaration about their communication needs or circumstances, which we will store with their consent.
• All such records are held in accordance with our Privacy Policy and the UK GDPR and Data Protection Act 2018, and are deleted when no longer needed.

Referring to specialist support

If we identify a customer who may benefit from specialist advice that we are not able to offer ourselves, we will, with their permission, signpost them to an appropriate organisation. Useful sources of help include:

• StepChange Debt Charity
• Money Advice Trust (including National Debtline)
• Citizens Advice
• Samaritans — emotional support, 24 hours a day on 116 123
• Age UK
• Alzheimer’s Society
• Mind — mental health support and information
• MoneyHelper — free, impartial money guidance from the Money & Pensions Service

Guidance and legislation we follow

• Equality Act 2010
• Mental Capacity Act 2005
• FCA Handbook, CONC 2.10 (Mental capacity guidance)
• FCA Finalised Guidance FG21/1: Guidance for firms on the fair treatment of vulnerable customers
• FCA Consumer Duty (PRIN 2A)
• Money Advice Liaison Group (MALG) Good Practice Awareness Guidelines for Helping Consumers with Mental Health Conditions and Debt

Reviewing this policy

We review this policy regularly to make sure it continues to reflect best practice and changes in regulation. If you have any feedback or would like to raise concerns about how a vulnerable customer has been treated, please contact us at hello@antiquejewellerycompany.com or follow our Complaints Policy.

Last updated: 26 May 2026