Q: Let’s start at the beginning. What sparked the idea for the Vulnerable Customer Compliance Pathway?

A: Having worked as a Vulnerability Champion in a leading insurance firm, I had a good understanding of the internal challenges firms face when it comes to supporting vulnerable customers.

Yes, there are regulations and guidance in place for financial services. I also believe that most firms agree that the dial has turned to the right place in terms of ensuring they support their vulnerable customers. Yet, keeping pace with the updates and core requirements is a significant challenge. That is before work is done to apply and embed those vulnerability principles to transform outcomes.

I know that firms traditionally have high-level customer support strategies documented. Yet, Consumer Duty has a strong focus on evidencing the outcomes and impact of implementing those strategies. When talking with managers and other vulnerability teams, I felt their overwhelm. There was a sense of, ‘Where do we find the resources, time, support and clear direction to be compliant?’ I wanted to provide a solution to make it easier.

Another issue I was acutely aware of was disconnect. There are compliance teams monitoring and advising on regulatory updates and asking what will be actioned as a result of the changes. However, this isn’t necessarily aligned with the firm’s top-down strategy. It leads to competing priorities from differing stakeholders and insufficient resource allocation. The scale of the task is also underestimated and, in some cases, vulnerability strategy work is allocated as a ‘side of desk’ role. I felt there was a need to get everyone on the same page.

Q: You’ve worked in the vulnerability space for a long time – what patterns were you seeing that told you organisations needed more structured support?

A: I think the first challenge for many organisations is not having a clear picture of where they are currently ‘at’ when it comes to supporting their vulnerable customers. Some firms think they are starting from scratch with Consumer Duty and yet, good practice is already in place, they just need support with piecing it together. Other firms believe they have it covered when there is plenty of room for improvement.

In my experience, a major challenge is monitoring, measuring, and assessing outcomes specific to customers facing vulnerable circumstances. Firms are experienced in monitoring internal systems, yet identifying and evidencing customer outcomes is new territory. This means there is uncertainty about what metrics, measures and assessment points to use.

Leading on from this, I see different teams capturing consumer insight in silos. So, there is no holistic review of all channels of customer feedback, issues, pain points and trends. This means that emerging themes and patterns are missed. Another fact I am aware of is the overwhelm of front-line teams. They are regularly having challenging and sometimes distressing conversations with customers, whilst being expected to maintain internal company targets. As a result of life pressure, customers can be stressed, demanding and desperate when speaking with front-line staff. Equally, these colleagues may be facing similar circumstances to the customers. It is little wonder that many feel ill-equipped, unsupported and burnt out.

Q: Why a “pathway” and not a different training course or toolkit?

A: I was aware that training doesn’t always stick, but not because of the content or delivery. The delegates report a deeper understanding of vulnerability and how to identify and respond to customers. However, back at work, they lacked the resources, support, time and systems to apply it.

I know firms that are keen to make the fair treatment of vulnerable customers part of their company culture but don’t know how. Training seems like the logical starting point, as it shows they are taking action to upskill the team. Yet, without supporting frameworks and practises in place the training fails to drive change and deliver better customer outcomes or colleagues’ experiences. I see training as part of a wider journey, rather than a quick fix. The concept of a pathway was to create a roadmap of milestones. Each milestone helps firms to embed vulnerability principles and practises into their organisation. It recognises what is already in place and keeps the team focused and accountable. It ensures there are ways to measure outcomes while driving actions that help firms negotiate Consumer Duty and achieve compliance.

Q: Who did you create the VCCP programme with and how did their input shape it?

A: My concept for a support programme became the Vulnerable Customer Compliance Pathway (VCCP) through a conversation with Helen. She was open to fresh ideas on how to help firms make a difference to customers. So, we took the opportunity to share thoughts and draw on our wealth of knowledge in the vulnerability space. Coupled with expert insights and practical support from the Helen Pettifer Training team, we brought VCCP to life.

The next step was to find three clients, across differing sectors, that were willing to be part of the pilot. They worked through the milestones with me over 6 months. This trial and their insights and feedback helped to fine-tune the programme’s content. We were then ready to promote it as part of our offer.

Q: Can you briefly walk us through the five milestones within the Pathway?

A: Milestone 1 focuses on understanding where the company is at. That includes reviewing customer policies, frameworks and existing training material from the perspective of supporting vulnerable customers and meeting regulatory requirements. The collaboration also analyses the current customer base and how their needs are identified and responded to.

We also invite front-line teams to complete an anonymous ‘colleague survey’ to identify their skills and confidence in supporting vulnerable customers, and what they need in place to do their job effectively.

Through this stage, we identify gaps and recommend areas for improvement. The methods of recording and collating data to enable continuous review are also agreed on.

Milestone 2  delves deeper into the customer. This includes exploring what drives customers to contact you, the customer journey and customer feedback to identify themes or patterns. This helps to identify gaps and prioritise the allocation of resources, training and support where it is likely to have the greatest impact.

Milestone 3 focuses on colleagues. This includes analysing the findings of the Colleague Survey. We also support the provision of training or resources that address gaps and best equip colleagues to identify and support vulnerable customers. This includes working with internal training teams, delivering our training or collaborating with other external organisations.

We also review colleague performance measures. This is to understand what your teams are accountable for and the impact on performance criteria when supporting vulnerable customers. If targets are hindering opportunities to spot and address additional needs, we consider options to better balance the two objectives.

Milestone 4 is about how to practically apply and elevate the learning to better meet customer needs and evidence good practice and positive outcomes. This can include support in board and team meetings, reviewing recorded customer calls and revisiting customer journey interactions.

Milestone 5 embeds every step of the VCCP journey to build a company culture where vulnerable customers stay on the agenda. We agree on customer metrics to monitor and may support action including the creation of a customer reporting dashboard to monitor, measure and provide insight on outcomes.

Q: You’ve offered the programme in three tiers – why was that important?

A: We recognise that each firm is engaging with us at different stages of its journey, with specific challenges. Equally, not all are within the finance sector, so they may be governed by differing regulations or priorities. By offering VCCP at three tiered levels, we intend to offer relevant and accessible support. With clarity on what each level offers, we make it easy to select the best option for their needs and available resources.

Q: How have organisations responded so far and what kind of impact are you seeing?

A: The firms on the VCCP journey state they have a clear assessment of where they currently are, what they are doing well and where they can improve. They have also shared that the milestones help them to visualise the journey and easily explain the process to other stakeholders in the organisation. It has been a privilege that they have been open and honest when sharing information with us. Building trust is an essential part of this partnership and I’m pleased that they have been receptive to different perspectives, our recommendations and being held accountable for agreed actions. It has been great to see the implementation of best practices without it being a complicated, drawn-out process.

Q: What are the most common pain points organisations have when they come to you?

A: The firms that have enquired about VCCP typically have a vulnerability strategy or vision, but they are unsure if it meets all the regulatory requirements. Others know they need to make improvements, but are unsure where to start. Either way, they want ongoing support to move forward. In conversation, there are often other triggers, such as staff feeling overwhelmed by the situations that customers are sharing with them. Without clarity about professional boundaries, the resilience and well-being of the team are being depleted. Some are driven by the need to increase customer satisfaction rates and be the best they can. Underpinning it all is wanting to be compliant and avoid FCA fines.

Q: What would you say to leaders who think they’ve already ‘done’ vulnerability?

A: There are some great examples of customer service excellence, yet no organisation has completely cracked it. That’s because customer needs and priorities are always evolving. When we focus on vulnerable customers, those needs are complex and impacted every month by changing circumstances, from their personal lives to economic and global developments. Therefore, this is an aspect of business that is never ‘done’.

Let’s look back to 2019 when the FCA identified that changes were needed to ensure the fair treatment of vulnerable customers. At that time, we had no idea that COVID-19 and significant Cost of Living increases were on the horizon. Any training and resources offered in those early days no longer reflect customer and colleague support needs.

Equally, we can’t predict what will happen in the future. What we can do is put measures in place to gather insight and adapt to changes. We can work to better understand what is needed to make services inclusive to people facing challenging life experiences.

The FCA reinforces that point by stating that Consumer Duty is not ‘one and done’.

Q: What’s been the most rewarding moment since launching the Pathway?

A: A stand out for me has been each time we look at the responses in the colleague survey. This builds an understanding of the reality of supporting customers and encourages action to fill gaps and better equip front-line teams. This is fundamental to retaining both customers and colleagues, so it feels like a transformative moment. In addition, I get such great job satisfaction when I receive feedback from participating firms that state it is making a positive difference to their customers and organisation.

Q: Finally, what’s one message you’d like every organisation to hear about vulnerable customer care in 2025?

A: Thinking beyond regulations and compliance, when reviewing customer journeys, support and feedback, I’d encourage organisations to think:

‘If my loved one or someone I cared about were in this situation and going through this process, would I be happy with the service and outcome they’ve received, and do I feel it’s the right one?’