
Scottish Financial Enterprise Vulnerability Summit
It was a pleasure to join the Scottish Financial Enterprise Summit for Vulnerability this week. On a sunny day in Edinburgh, our Senior Partner Lauren Peel and CEO Lisa Edgar both spoke on the importance of knowing consumers, measuring outcomes, and providing tools to help organisations understand their current performance.
Three takeaways from the day
- 1
Putting customers at the heart of your organisation and culture is key for good outcomes
- 2Knowing your customers is never “once and done”
- 3More organisations are thinking about the needs of people in financial difficulty
1. Putting customers at the heart of your organisation and culture is key for good outcomes
We heard a lot of examples about the difference this can make. A customer-centric culture is a key pillar of the Consumer Duty for financial services, and will no doubt be a focus for other regulators as they revise their vulnerability policies. Firms should consider how this works in practice, and how they evidence this to ensure it’s happening from top to bottom across the organisation.
2. Knowing your customers is never ‘once and done’
This is especially true when it comes to vulnerability, in all its diverse and unique forms. From regular testing of literature and customer journeys to continuous feedback loops with front line staff (who really see the hard impact of vulnerability), there’s always more to understand and act upon.
Best practice includes qualitative and quantitative methodologies to ensure consumer understanding and bring consumer vulnerability to life for colleagues in front line roles and beyond.
3. More organisations are thinking about the needs of people in financial difficulty
In October there were two significant fines from the FCA in this area; Volkswagen Finance for £5.4m for failing to treat customers in financial difficulty fairly between 2017 and 2023, and TSB for £10.9m for failing to ensure customers who were in arrears were treated fairly between 2014 and 2020.
Financial vulnerability is on the rise, and more organisations are considering what this means for customers and responding to those needs. Many are doing this through partnerships with organisations like Citizen’s Advice and benefit calculator providers to support customers in financial difficulty.
Understanding current performance and best practice
One thing we heard repeatedly is a desire to understand how a firm’s performance in customer vulnerability compares to others in the market, and to learn from best practice.
The Inclusive Outcomes Pathway allows organisations to understand where they are against key pillars of vulnerability and focus on areas of improvement. This approach can be tailored to firms of all sizes and product lines – get in touch if you’d like to learn more.
Thank you to Jayne and the Scottish Financial Enterprise team for having us, and creating a space to share challenges, learnings and insight.

