Hello and welcome to this venerable client, Webinar. I just want to explain the context of today session for you, because when we're dealing with vulnerability, we're thinking about issues of vulnerability, and we think about vulnerable clients. We can also think about for no Billy been vulnerability internally within the firm as well. But no ability could be quite a sensitive issue for a, um from a ah social dignity perspective. So today session is really focused around making sure that people feel comfortable in today's session and intended to be a safe session for people. So I'm aware that some of you attending might have large groups of vulnerable clients that you deal with or might be aware, acutely aware off the a ability of clients to access their services. And it's not necessary as part of this session to discuss any information that might be client confidential or otherwise. So what we're going to do, I'm still gonna keep an eye on the chat function as we go through the webinar on. People are welcome to post comments as part of the chap function and ask questions as part the tap function. Although this is intended to be a safe session. So we've got exercises as we go through a recession and as we're looking at things in the session, But those are exercises that I'm asking people to do themselves and take a moment and think about reflected themselves on. There's also no obligation to participate in those things that also, some of those might be personal questions on do you might, because I want to bring out the idea that vulnerability is something that can affect us all on. When we think about vulnerability, we need to think about that definition in different ways according to the different. Regulate the requirements that sit that sit within them. So keep an eye on the chat function and people can ask questions as we go through. However, if you want to ask questions separately because of the sensitive nature of the matter, because of your current situations or any other situations, this is a safe session so you can go directly to date to law who pass your question on to me directly if you don't want to put it into the chat function, so I try to keep up the chap function as we go through just also bearing in mind when we're doing this. I think we've got 140 people just on this webinar alone. We've got more on the YouTube channel, so there are people with lots and lots of people watching this. I will do my best to keep up with what's on the chat function in the interactive element of it. There's a lot of people there and if we don't get round to answering, all the questions will come back to them later on. We can answer them privately if you want to, and there's no obligation. As I've said, it's a safe session, no obligation to participate in the exercises if you don't want to have that something that you don't feel comfortable with. So what we're going to talk about today is the various meanings of the term vulnerable and there's lots of different definitions out there, depending on your regulatory perspective. Who your regulated by Onda, also the types of client groups that you might serve. So we need to think about all of those different definitions of vulnerability when we're thinking about one or all clients on how that works and operate on the various different information that the S away has put out, as I'm gonna cover that today on that is also covered within the notes that accompany this session as well on their some use for additional links that sit within that that link on two different sources of information that you can have a look at as well. We're gonna have a look at regulator requirements particularly related to the S away and CLC on. We're gonna touch on the FCS very wide definition of vulnerability, which I'll come on to in a minute, which really says that vulnerability is something that can affect anybody at all. We're going to think about vulnerability on acting in the best interests of the client on. Then we're going to think about some issues of misconduct where we see sometimes vulnerability as an aggravating factor Within the SL raise requirement, we're gonna have a think about vulnerability and the link into capacity. So mental capacity, we're also gonna have a think about vulnerability and some of those other issues that sit around so reasonable adjustments. For example on we're also gonna have a think about vulnerability and safeguarding on previous definitions, statutory definitions of vulnerability. So there's lots of different things to think about and take into account when we're dealing with vulnerability. But also gonna have a think about what if you wanted to develop a vulnerable client policy or if you wanted to target your products and services towards a vulnerable client, what does that look like? Is there something we can do in respect of that on? How can that work and operate? So we're gonna have a think about some non exhaustive lists, and there's lots of different policy papers out there on this is really where some of those policy bodies that sit around the regulators, such as Illegal Services, consumer Panel and others have different views and voices in this about vulnerability and possible reasonable adjustments as well on it's worth looking at different outside. So what are the various different definitions of vulnerability? There's lots and lots of different definitions of vulnerability out there as definitions of fun of ability. For from the Legal Services consumer panel, there's definitions of vulnerability from the financial, uh uh conduct authority. There's different regulator requirements such as, um ah, the Council for license conveyances, regulator requirement such as the solicitor's regulation authority requirement on There's also requirements under the GDP are for processing. I'm sensitive personal data as well. So we look at the legal Services consumer panel. That's a body that sets associate it with the Legal Services Board, which is the oversight regulator for the SA way on. Also for the CLC, they have a particular definition of vulnerability which will look at in a minute. We're also gonna have a look at the F. C. A s definition of front of ability, which is the ah financial conduct authorities. Definition of vulnerability. We're also gonna have a look at the various regulator requirements. Andi, think about that and how the regulators have pulled those different definitions of the new ability. So, for example, relating to that safeguarding and also relating to a mental capacity into their work, which we're gonna have also have a look at what they regulate your requirements are that sit within that as well. So those differences in both definitions and also regulator requirement, we might, you say, therefore, that there's lack of consistent definition of vulnerability within legal services. There's lots of different sources of information that we can pull from if we were pulling together a vulnerability policy or that we might take into account, we were thinking about vulnerability. Do bear in mind when you're dealing with vulnerability. You might, as I've said, be dealing with sensitive personal data under the GDP are on. If you're thinking about dreaming with large groups of vulnerable people, you might need to do a data protection impact assessment relating there. As I've already said, there were important links related to safeguarding and also capacity. And it might be worthwhile thinking about whether, within some of the definitions of vulnerability, large groups of clients could fall within that so resolution has in the past, for example, come out and said, You know, all people dealing with family cases should be considered vulnerable. There can be situations where large groups of clients I'm come fall into the definition of vulnerability because of their particular situation because of the stressful life events that take place on that can apply to large groups of people that approached lawyers on, you know. What's generally said is that consumers are accessing services at time of stress. We should also note the link into reasonable adjustments when dealing with disability as well. So what are some important relationships when we're dealing with vulnerability? We've got equality and diversity, and we'll start there. So there are requirements for solicitors for property. Lawyers for other legal services provide us to comply with their obligations under the Equality Act. And we're doing a webinar next week just looking at the quality and diversity. But one of the things is, if you are vulnerable, one of the categories of definition we might look got is disability that falls within that on. One of the examples from the Legal Services consumer panel contained within your notes relates to disability. There might be issues relating to on requirements relating to reasonable adjustments that sit around that. So he might need to make reasonable adjustments for somebody's where there's an overlap between the two, although the two do not necessarily correlate them maybe in some cases, an overlooked during the two. To the extent that somebody has a protected characteristic as well, we might also expect them to be in a situation where we need to take account of the protected characteristic in terms of harassment and also victimizations of those duties and obligations under the equality, and there has in the past been statute treat definitions of vulnerability. And if we go back and look at the safeguarding Vulnerable Groups act that's now so subsequently been superseded by the CARE Act was a statutory definition of a vulnerable adult, which said those that were And I'm just going to read this to you living in residential or sheltered accommodation, receiving certain types of health and social care, receive in certain types of warfare support or detained in lawful custody. So there waas previously a statutory definition off what are vulnerable, that it was now that's been superseded by the care but is worth bearing in mind that there has previously been this definition out there that relates to safeguarding. We'll have a look at the content of the care act in a minute. We should also bear in mind the links across into capacity as well. So where somebody is vulnerable, it's not necessarily to say that they correlate with capacity, although in some cases there may be in over luck in that situation, so the client could have a capacity issue in giving instructions. Obviously, having worked for the regulator, I'm aware that sometimes they regulator will consider whether your client has had capacity as an issue of professional conduct. Well, the S always say at the moment is that practitioners should be aware of their obligations under the mental capacity act on what they say is within that and again, I'm just going to read this to you. Do not make assumptions about clients capacity over wall. You have to assess their mental capacity prior to taking instructions as required by the mental. Passed the act on Considered the client's ability to understand information related to relevant to their decision making understand and way the client's ability to retain that information and use and weigh that information as part of the legal advice giving process. Andi the ability off that client to communicate and make a decision okay on the communication of that decision can be in any means. It also could be by sign language or by other means. You might wish to seek an expert opinion if you're not certain where the client has capacity. So, for example, speaking to a doctor, you can also speak to professional ethics as well. If you have any concerns about the capacity and decision making ability of decline and your own professional position in respect of that. So there are important relationships across to capacity. There is a wide or factor based definition off vulnerability that was also adopted. Body s our way in 2016. So there's a way in 2016 reference this previous definition statutory definition of vulnerable don't but also looked at what the legal Services consumer panel Didn't they publish research both the Legal Services Consumer panel and also the S away in 2016 looking at the definitions of vulnerability and factors relating to vulnerability. Now, this list that I've got the screen, there is no exhaustive off that list that was published, and it's based on a British thunder. Now the full list is within the notes that I've supplied there to you. You've got factors within that, such as age, language, difficulty being a carer, somebody who is bereaved, somebody who's gone through a relationship breakdown. Somebody use having health problems, somebody who has inexperience. And one of the things that's come out of some research that's been done by the S away by also by the Legal Services Board is that those who are in experienced in accessing legal services may have anxiety about the ways in which you can access legal services. Andi. That can exacerbate existing problems or can be an issue within itself. So there can be different things that can contribute to somebody's vulnerability or can be an indicator of vulnerability over wall. And there's a longer list within the notes that there. So I've just picked out some of the different thinks there on. What they've said is that this list can fluctuate over time that this that people's vulnerability can fluctuate over time. Sorry, Andi. That vulnerability can be long term or can be short term, so somebody might be a vulnerable crime when they approach you at one instance, then they come back a few years later. In that situation may have resolved itself, although maybe in a different situation. So it's important to think about where the client tears at that particular point in time and give independent voice based on that particular set of circumstances. Consumers can experience anxiety about accessing services, and there can be that aspect of market exclusion. So they're nervous about going to see a solicitor because of the vulnerability, all because of issues around that because of general anxiety. Andi, it means that in some instances people are going without Nikola boys or there might be accessing legal advice and not necessarily in an appropriate way. So this definition on this research came from the S our way in 2016. So this guidance that came from their survey in 2016 What we're looking at now is the situation where the s always published the standards and regulations and there were also publishing various different guidance on updating all of their guidance. We're late into different things at the moment. We haven't seen anything from them relating specifically to vulnerable consumers. This is what they came out within 2016. So it's a few years old now. We're starting to look and to see whether the s always going to come out with anything else, but at the moment. But we're looking back, is is, you know, sort of looking back to say this is what was done at the time. It's based on the British stung when we're thinking about safeguarding, and I gave you that definition there relating to what? This is the statutory definition of vulnerable at all on that was superseded by what's in the care act on the care Act now looks up. The circumstances in which the local authority would make an inquiry on again this can be useful. Asked to whether or not somebody has a particular vulnerability on can be useful for us to have an awareness, often our vulnerability policies, but also, if you deal with anybody who has for new abilities, where they might be under the care of the council, where somebody might be involved in there care or in circumstances where you think somebody might need to be and somebody might need to be notified. These are the kinds of things that would be looked up. So somebody who has needs for care and support, whether or not the authorities meeting any of those needs, is experiencing always at risk of abuse or neglect is as a result of those needs and able to protect himself or herself against the Bruce on neglect or risk of it on. Then it goes on to say what the local authorities responsibilities are in respect of a useful definition relating to financial abuses also contained within the care Act that can be useful for us to be aware of off when looking at situations and asking ourselves, Is somebody in a difficult situation as a result of this? And can we or should we be taking only steps in relation to that? So their definition of financial abuse is as follows. Abuse includes financial abuse, and for that purpose, financial abuse includes having money or other property stolen. So if you're in a concern about that situation, being Defour did being put on the pressure in relation to money or other property, or having money or other property misused so we can use some of this and this could be useful for saying, is somebody vulnerable in relation to their circumstances? Are they vulnerable in relation to abuse or other abuse on How does that work? What does the situation look like? And do we need to take any steps in relation to that If we go back a couple of slides now, just going to look about the F. C. A s definition, which is really wide when we're talking about vulnerability on This is why I asked the question at the beginning of the webinar to say what the FDA says about for new ability is that we can all b if it tipo vulnerability at any time in our life. So this is the financial conduct authority. Now some law firms will be regulated by the FDA or some low law firms will be partly regulated by the FDA. For some things, some law firms have exclusion from the license the FC A because of their regulation by the US Away, It's still worth knowing what another regulator is doing in terms of consumers on if you want information about general consumers, including videos to show to your stuff internally on some really great research papers about vulnerability. The FCC has got absolutely loads is really, really great research that they've done there in terms of what constitutes vulnerability. What they say about it is that someone who, due to their personal circumstances, is especially susceptible to detriment. So this could be anybody, really, it all on their definition of vulnerability is so wide. One of the things that they include in their definition of vulnerability, particularly which are a fine example, is people who have cancer or who have had cancer. So this is one of their factors. They say that your vulnerability could be any health problem that can affect us at any time in our lives. And I'm sure we've all known somebody has been in that situation, so we can all pull apart to say, Have we been vulnerable? Do we know somebody who has? And how can we think about our products and services related to that person? What they understand them do we need to take extra steps in relation to that? So what they say is somebody who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care. So thinking about how you can take care and respect of that circumstance on what does that look like? Their requirements are set out within their home book. There was a link within the notes do with that, but what they require is for people to think about treating customers fairly on. They want to build that into their policies and procedures On If you look at some of the work that the FDA has done well, we could make a parallel across into legal services. They did some work around financial lives. So making sure that people are accessing served, this is the appropriate for them. There's lots of different financial products out there for people that people don't always access those financial products appropriately or they're not taking that best advantage. And they could be getting lots of interest on their money they could be doing and building for the future in different ways. But they're not sure about how to do that. And they don't have the units that you see. These things has been quite intimidating, so there can be different things there that are available to people that are that they're not just not being accessed now. The FC A has a particular market focus, so they dive in to support different market outcomes that they want to. The S. R A does not have that same market focus, okay, Their one of their regulator objectives is to promote competition in the profession. But they don't have the overarching same market objectives for market into mention that the FC aiders the F C A r, intervening in the retail banking market, particularly to support vulnerable consumers on improving their financial lives, so they're specifically requiring firms that up their game. If you like to say to people, this is how we're supporting vulnerable consumers But we can see some of this is being really positive, Good practice on a place to look for further research and ideas if we want to. So what they're saying is we're supporting those vulnerable, excluded consumers to provide those essential financial services. Now we can make the contrast with the s always coming policy approach at the moment. So what they're doing as a result of the consumer. A Markets Authority report that said that consumers are didn't other people with no access single, no able to access legal services in the same ways as others and as a result of the regulator objective there introducing freelance solicitors. So this ability toe open the legal services market to promote greater competition. But there, ah, research that the way that they've done this is in favour generally of consumers. It's not necessarily, um, in favour Off um, is that it's not necessarily in favor off specifically vulnerable consumers. Although the Consumer Markets authority did mention that there's not necessarily what The SL Way have done OK, so is something completely different that you know the yes away on the FC A have taken a slightly different approach. You can see the distinction between the two of them, where there are no in future. The SL way will then say we're going to have specific interventions that required for vulnerable consumers We've yet to see. So this is what they're doing. At the moment. They're just generally trying to introduce freelance A listers on looking to see whether that stimulates in itself new products and services without them being specifically targeted, vulnerable consumers as quite different to the FCS approach. Financial conduct authorities approach. You are definitely looking at supporting vulnerable consumers into the market. So let's have a look at what they regulate. Troop requirements are under the standards and regulations which up being introduced in ah in November. So these are still on course to come in in November. I've still got my eye on what's happening with the Brexit position to see whether anything changes. There's a lot of turmoil a moment, but we're still expecting these to come into force in November. So relevant principles which relate to funding for consumers are almost all of the principles on if we have a look, will look at misconduct in a bit on what we can see is in some cases by not taking account of a vulnerable consumers needs. That's arguable that people have in effect breach the other principles around there. So there's definitely relevance relating to the principal around equality, diversity and inclusion because they may be overlaps with reasonable adjustments that need to be made if somebody has a disability. But there can also be concerns around making sure that people have held upheld public trust in the solicitor's profession. So if this was reported in a newspaper that somebody had taken unfair advantage of their position, for example, it could be an issue. In respect of that, people must act with independence. Andi be providing their service and be providing appropriate independent advice that they must act honestly and with integrity on. They must also act in a way that encourages ah quality and diversity and inclusion. As we've said, they also have to think about what the best individual interests of that specific client are on. Those individual interests come very on. If we're in that situation where we're, for example, providing quite standardized legal services. What tailoring do we need to do in order to make reasonable adjustments go in order to take account of clients that have for new abilities? When we're looking at the specific requirements that relate to vulnerabilities and specific mentions of vulnerability within the standards and regulations, we can have a look at things like character and suitability. Andi also have a look at the competent statement and this is detailed within your notes. So the specific mentions of vulnerability that in there, So if we have a look at character and suitability, the character and suitability is relevant when you first become Celester, so the first application they assess the character and suitability of an individual. They also look at this on an annual basis relating to the registration off a registered foreign lawyer or registered European lawyer on what it says within character and suitability is if he s always in possession of any information which suggests that on this within your notes that you have misused your position off trust. I'm just reading this in relation to vulnerable people. Okay, so any situation or circumstance where people have misused their situation now, this could if we during the annual renewal, which we're talking about, The moment is going through its October. Okay, if you're registered European lawyer off your registered European lawyer, you're registered European oil registered foreign lawyer. That's development wording when dealing with character and suitability, but also on that first application, a swell to become a solicitor when we're talking about the annual renewal. There's also wording relating to client vulnerability that exists within the competence statement. Now do Bear in mind on Sean reminded everybody at the beginning of this session that we are in a situation where people are making that annual declaration every year as part of the renewal on what you're saying is you thought about your needs regarding the confident statement and you have addressed those needs now within that, there is a situation relating to vulnerable client within the competent statement. What it says is that you have to provide information on a reading this again, and it's in your notes in a way that clients can understand taken into account their personal circumstances. Andi. Any particular vulnerability? So thinking about vulnerability in the widest possible sense they're taking into account that and provide the information in the appropriate way. So that is part of the confidence statement that needs to be signed to say that you thought about that underdressed then he needs, on an annual basis. So thinking about how you're providing information across to the consumer on what that looks like so thinking about those various different definitions of vulnerability Have we taken it into account? Have we thought about the ways in which we provide that information cost to the consumer? And what does that look like? Can you have actively certifies that? So that might be things like, for example, can somebody come in and see face to face? Can you offer home visits? Can you provide information? In larger font is the different ways in which people can provide information to that's suitable for their circumstances. Then we've also got that situation. Where is part of the enforcement strategy? Okay, so the enforcement strategy. Oh, so the enforcement strategy is there on what the enforcement strategy says is that if you're in a situation where the SA Way feels that you have breached the walls, they might consider taking enforcement action in relation to that. So yes, I way has put that in there, and what they say is that vulnerability is an aggravating factor. They're more likely to take have it reinforcement action where somebody affected by the breach was vulnerable. But also it could be a factor that you take into account when considering whether or not there has been a serious breach. So it's useful bearing in mind the reporting responsibilities off the cold from the coffer, the reporting responsibilities of the firm, on the reporting responsibilities of the individuals to think about what they're somebody is vulnerable on, therefore, to think about the obligations and responsibilities that sit around those various different definitions of vulnerability that we've provided but also that fairy, potentially very wide definition of vulnerability. Thinking about that that we applied in the beginning. So we can also that at some point maybe if we thought about the way the FC a sort of that this is something that might apply to all of us at different points in our life. I'm making sure that we're acting appropriately in accordance with that. Let's have a look then of the counts off a license conveyances position on what they say in respect of vulnerability very similar to the S R. I. What the council for license conveyances say is that you should activities, independence and integrity that you should, and this is the relevant principles. And again, they have principles that set over the top of the work that they do. They that you should maintain high standards of work on. You should act in the best interest of your clients. They also required to promote equality of access and service as well on then the detail. Within the handbook, you make reasonable adjustments to prevent persons with disabilities from being placed at a substantial disadvantage. I'm not still requirement within the equality accident substantial disadvantages, the word in that used within the equality you provide equal opportunities for partners, employees or applicants in employment and training on you make all reasonable efforts to ensure your services accessible and responsive to clients, including those with vulnerabilities. So this also applies to um, property. Lawyers, though, is regulated by the accounts for license convinces, and that might also be solicitors. They're regulated by the counts for license convinces. What they're saying is thinking about bringing in place policies and procedures to think about people with vulnerability and making reasonable efforts to ensure that they can access your services. Now there are some links within your, uh, within your notes to solicitors disciplinary tribunal decisions related to vulnerable clients where Theo the S r. A. Has prosecuted. And there's been an allegation that somebody has, for example, taking them for advantage, behave dishonestly towards a climb with vulnerability, failed to act in the best interests of the client with the vulnerability, failed to act with independence. Okay, so thinking about the quality of advice that that possibly this arrest issued of taking greater care in respect of the situation, on the advice of a person who, for whatever reason, was vulnerable because of their circumstances. Now, I'm not going to examine these cases in great detail because, unfortunately, it is a very sad state of affairs. In some respects, there are sometimes quite a lot off these cases that come up where there has been some allegation of taking on for advantage on. You can find plenty of these examples if we go back back through time. Suddenly, unfortunately, it's something where the firm needs to think about. I'm very mind, and you can put in place effective safeguards for yourself is a firm to think about. Make sure that you understand own interest conflicts, that people understand the ways in which you might take unfair advantage of a particular situation. On that, you can understand the instructions that being given from the right and we know when they might be upto worry that decision or how they might be placed under any undue pressure or be subject to any do influence in respect. If that so there's differently. And there's just a few examples within three the references to the notes for you to have a look at if you want to. So it's a STD test. S D T decisions of where people have one example was solicited. The vulnerable climb. Whether was gifts to this Celestine Well, I know the one was where there was conflict of interest situation in making investments in the idea that some did potentially made inappropriate investments not been given appropriate voice. I don't know the situation where there was some issue with money being taken from the client account in respect of somebody who was vulnerable. So I'm there are different circumstances where there can be issues there were sister can be allegations can be made in respect of those situations with clients with new abilities on the S away. As I've said, enforcement strategy considers it more serious or an aggravating factor. If somebody does have that issue of bility, it's important when thinking about that on dure, thinking about issues of in your ability to think about how you're going to demonstrate that you've acted in the client's best interests and taken account their wishes as well on what those decision making processes are and how they've been documented in some cases in the cases that I'm talking about, the situation is where people that's been manifestly not demonstrated, okay on thinking about making sure that you've got in place. Those internal policies around only trust conflicts and also very strong fall review policies can help you have a look into that as well. I make sure any issues are ironed out at an earlier stage. Solicitous professional judgment is obviously paramount in doing that on that independence of a bus that can then reflect the situation relating to the vulnerability of decline. So what are some ideas for internal policies for your firm and How can you work and think about that? And what does that look like? Well, what we've seen is that the s a way to think. Um, choir firms, to have, you know, made that annual declaration and to think about to make sure that they thought about their competency needs and address them on that. That includes providing information to clients, taking account, their personal circumstances and any vulnerability and also, yes, away. Think about vulnerability is part of the enforcement strategy is an aggravating factor. So they all requirements there that a firm needs to think about a bear in mind. It's also relevant on character and suitability, said the first application for the trainee or any European lawyers registered European. Or he's a registered foreign noise. You think about that on an annual basis. So the question is, do you need a policy which doesn't specifically say that, However, within the regulations, however, it might be a good idea. We can take so much different information in there, which relates to the various different definitions that you could apply to vulnerability on the various different ways that you could look at it. We could build that into some form of policy in order to safeguard the firm. I have a rule taking into account or having a relationship with any policy that you have in respect of equality and diversity and potentially dealing with client capacity and also dealing with issues of safeguarding. If, for example, you do a lot of work with a local authority, for example, you can turn this around as well and say, You know, how come we sell this product bearing in mind our ability to act in the best interests of the client to market that effectively and appropriately and honestly. But also it can be an opportunity to engage people with your service in different ways on to say, and to demonstrate your expertise in dealing with different circumstances and situations. You could then build in things like vulnerability assessment. When we talk about the provisioning information to people that we've talked about, when we're dealing with that competency statement, we might talk about larger funds or we might talk about things where you might record meetings for the client and allow them toe play them back. So you provide an audio there or you might make videos of your client care information to make it seem more accessible to make the service, you know, more accessible to the time we talked about anxiety at the beginning of the session. We can also talk about clear information about service and price. Another mark price transparency requirements. I don't know about you. You I still find some of that quite lengthy, but some of those examples that are provided by the way they some of them, are quite lengthy in If you can break that down in, you know, chunks of information will discuss that with a client in different ways that could also help and serve pull. You can offer clients the opportunity to take time for self care, so they've got the time to make decisions. That might mean coming into the office 15 minutes early and just having to sit in the meeting room getting used to the space. Or it might mean the opportunity to go and sit Klein on there, the 50 lakh on their grounds. Andi, where that sits and operates, and how that that looks. You can provide partnerships with local charities bearing in mind the independence issue in respect of that, but it might be a good idea, and people couldn't get that sign posting and additional support. And that can also help. When you're dealing with somebody who is working with the clients or carer, for example, allowing people to feel welcome and they come into the office, I think about how the office space reflects who you are, on how that works and you know, is it Are you going to see people that signal to you access in the service there? Can you point people to the nearest disabled parking? What are the things that make the service accessible? Make people feel ready for achieving that meeting, achieving a good outcome from that meeting with their solicitor? If you've got automated systems, can you allow update out of that so people aren't having to access it a service in that particular way, so they don't have to use those numbers for examples? There's a nice link in the notes to information Leaflets there are provided by the Legal Services Board that could be handed out to clients about using legal services Now. These were particularly designed for clients with dementia on the on people in caring responsibilities. But you might find the more generally useful as well. So that could be another thing that you can use to demonstrate that you've taken it into account. You could put in place a financial abuse policy, taking into account the vulnerability of the consumer that we talked about that definition of financial abuse that sits within the care. You might think about providing information in different ways. So we've thought about it about making your service available. But what about if you provided information in text message? So making service accessible does not necessarily have to me and making it slower? It depending on the client, it might mean making that service scene more accessible to them on a day today basis. So if you're texting a point that can also be an example, you're skyping your client that can also be an example off how you're communicating in the client in a way that they prefer. That isn't necessarily say, for example, anxiety inducing. It might be something that they're quite used to. So there are lots of different ways, and that those suggestions aren't exhausted, their them or their but also include you to have a look around at the different websites of people who also provide services. So charities partnerships on those people who are working with and who are available to support those kinds, but also within the legal services sector. So you might think resolution. Is that a good example that I've referred Teoh, where people are working with groups of clients to provide those and suggest different solutions as well. So what I want to do now is just to take five minutes to think about that on to think about. And this is an exercise for you to do, to think about whether or not there's different policies and procedures that you could put in place all whether there's different services that you offer within your firm that you could think about for different groups. Now I've just put a few different groups across the top. There, you can do this all just yourself. Just take five minutes and again, this is because I'm saying to people I wanted to make this that really safe session, so just a think about that. So do you serve any particular vulnerable groups and should weigh what's our strategic direction? Does that look on how to our policies are. How do our services sit with that dramatic? Any particular additional requirements? Do we think about how we serve them on? You can take those different categories that have come from the legal services consume upon. I'll make a list. You don't have to use these categories there. There there's lots of different ones there. Should we offer any specific products or could retailer our products in any particular way? And you can then start to build that to think about how you've done that, which would be good evidence or useful evidence, or just an alternative way about thinking about your strategic direction and how you could evidence that and serve, you know, demonstrate that client. Um, now, this is something where you can just take five minutes to do that. Do our products cover, for example, particular issues around anxiety? Or can we do anything about that? Help and support people who come in on, and one of the things from being a care where people found their relative inexperience in daily mid legal services, but then having to support somebody else in accessing that now, for those belong, just gonna use a different example just what you're fighting there. I'm just going to use a different example to illustrate this. I don't know if anybody else lives in or near Coventry, but on the local radio in Coventry, there is always adverts for a dentist in Coventry, that is therefore, clients who have particular issues would be nervous and have anxiety. Okay, so on they might have different health concerns, for example. But they provide specialist services that sit around that, and they use that as a marketing and selling point. So what that was one example of Well, I was thinking about this where you can take this and say, Have we used? And have we thought about this in any particular way? Could we look at the ways in which we provide services to different clients with different particular vulnerabilities? Could we adapt our services to cover these particular client groups? Should we? I mean, if you're in a situation where this is where you'll provide almost exclusively service is too small business, for example. You might need to think about the clients that come through the door. I who you're targeting your services out on how this works and operates, but you there might be circumstances in which you could advertise that reasonable adjustments are available, for example, on your website, which is something that the SA recommend you do. Or you might be able to think about access in new client groups and new streams of income, even in partnership with other organizations or by targeting a particular sector on segment. If you think you've got the experience that they know how in the ability to do so, this can be a very positive promotional point for your first. So thank you very much for having you look at that. That brings us towards the end of the weapon all. I just want to thank everybody for participating in this as a safe session. So as I said at the beginning, if you've got any questions, I was very aware of the sensitive nature off the subject matter on the potential. So we're discussing that wide definition of vulnerability, and there is the potential that people could then have that discussion about how for new ability is either affected them personally, yeah, or has affected their clients. And obviously you can see names in respect of that in terms of the chap function and were disclosing that information. So I wanted to make that a very safe session in a vote respectful session from that perspective. So thank you very much for that. If you have questions, you can post them in the chat function, or you can email data Lord directly. Andi, um, we will. And I'm happy to, you know, take that field Those questions you can anonymous them if you want to make them very general, post them in any way that you want to. I know I'm happy to come back and correspond with you in respect of that, given the sensitive nature of the subject matter. So let's have a think about what we've covered. We thought about the various different definitions of the term vulnerable, so I thought about capacity. We thought about reasonable adjustments in terms of equality and diversity on disability and relationship There. We've thought about safe guarding on. We've thought about the various different definitions that have come from the various regulators on the distinction in the relationship with the markets of the market intervention that's distinct from the S our way and their market intervention in favour of vulnerable consumers on the s our way and their market information in intervention generally, but the difference in the regulatory approach. We've also thought about the specific requirements from the SA Way. So thinking about that annual declaration on the competence statement that you have to fill in every year on the relationship to fund her ability and also making sure that you understand thinking about how you're going about dealing with any potential preaches. So taking into account for new ability. In respect of that, we've also thought about the CEO sees requirements. We thought about vulnerability and acting in the best interest of the client on the link between that unfair advantage and that you know the relationship then into the STT decisions. We've thought about the things that you can do to evidence that that is non existent, exhaustive, less and more ideas in your notes and also links to go away and do further reading as well. So evidencing that and ideas for policies and procedures. So thank you very much for watching
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