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Client Vulnerability

Definition of Vulnerable Client

The Financial Conduct Authority (FCA) characterizes a vulnerable client as an individual who, because of their personal situation, is particularly prone to harm, especially when a company fails to exercise the necessary care. The FCA anticipates that firms, such as HYCM, will treat all their customers equitably, and when interacting with individuals in vulnerable situations, they should consider their vulnerability. This is to guarantee that our sales methods and the way we deliver our products and services do not disadvantage vulnerable customers.

Recognizing a Vulnerable Customer

Vulnerability encompasses a range of risks. While all customers are susceptible to vulnerability, those with vulnerability traits face an increased risk.

The FCA identifies the following elements as contributing to actual or potential vulnerability:

• Health – Health conditions or illnesses that hinder the ability to perform daily tasks.

• Life events – Significant life events such as bereavement, job loss, or relationship breakdown.

• Resilience – Limited capacity to cope with financial or emotional shocks.

• Capability – Limited understanding of financial matters or low confidence in managing money (financial capability). Limited capability in other relevant areas such as literacy or digital skills.

Groups Prone to Vulnerability

HYCM acknowledges that certain clusters of people may be susceptible to vulnerability. While not everyone in these groups may be vulnerable, we will consider a customer’s unique circumstances when a potential vulnerability is detected. These groups encompass, but are not limited to:

• Customers with communication challenges (including learning difficulties, English not being their first language, dyslexia).

• A customer experiencing a decline in physical or mental abilities.

 • Customers with health concerns - illness, whether physical or mental, severe or long-term.

• A sudden diagnosis of a serious illness affecting the customer or a close family member.

• Personal circumstances of the customer - factors such as financial difficulties, bereavement, caring responsibilities, or redundancy.

 • A customer’s age, with particular attention to older and younger individuals.

Indicators of Vulnerability

The specific type of harm or disadvantage a customer is susceptible to, and how this could impact their customer experience, can help us in identifying the unique needs of a vulnerable customer. Here are some examples of harm and disadvantages you could be exposed to:

• Heightened stress levels

• Increasing time pressures due to additional responsibilities

• Increasing preoccupation (their mind is ‘elsewhere’)

• Decreasing processing power and ability due to competing pressures

• Lack of perspective, especially when experiencing something for the first time

• Changing attitudes towards taking risks.

HYCM Action Plan

When HYCM identifies a potential engagement with a vulnerable individual, whether this is through our own detection or a customer reaching out to us, HYCM will:

• Promptly document this and ensure suitable monitoring is carried out.

• Offer extra opportunities for customers to inquire about the information HYCM has shared.

• Continually verify that the customer has comprehended the provided information.

• Inquire if there’s anyone who can assist the customer. If not, and we believe it would be beneficial, we will arrange to resume the discussion later.

 • Give the customer the chance to finalize the transaction after a period of additional contemplation.

HYCM support team will aid clients understand what other options are available.

If HYCM is not able to help the client. we will try to make sure that they understand there are authorities that can assist depending on the personal circumstances.

Organizations that Assist Vulnerable Clients

Mental Heath issues can influence an individual’s capacity to make prudent financial decisions and interact effectively with financial services. It’s important to remember that even when trading outcomes seem overwhelming, assistance is always available, some of many resources available to support you are;

Physical health can indeed restrict an individual’s ability to perform everyday tasks and may impact their financial decision-making and interactions with financial services.

Financial Troubles substantial debt can hinder an individual’s financial well-being and their ability to make informed decisions, which could potentially result in negative consequences. Remember, it’s okay to ask for help, and there are many resources and services available to assist with financial management and debt relief.

Addiction and Gambling can indeed result in harmful financial consequences and can obstruct an individual’s capacity to make sound decisions, potentially intensifying their financial difficulties. It’s crucial for individuals facing such challenges to seek professional help and explore various support systems available.

Please inform us to help you via one of the following contacts.

Email: compliance@hycm.com

Telephone: +44 208 8167812

In Writing: 27-28 Clement’s Lane, St Clement’s House London EC4N 7AE United Kingdom



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