Vulnerable Persons Policy
Plant and Machine Mart (plantandmachinemart.co.uk)
Last updated: 25 March 2026
OVERVIEW
The aim of this policy is to outline the practices and procedures for Plant and Machine Mart Ltd and its partners to prevent detriment to customers who find themselves in vulnerable circumstances.
Much of the consumer protection legislation is underpinned by the notion of the "average" or "typical" consumer — what that person might expect, understand, or how they might behave. However, consumers in vulnerable circumstances may be significantly less able to represent their own interests and more likely to suffer harm than the average consumer. Plant and Machine Mart Ltd is committed to ensuring these customers are adequately protected.
The Financial Conduct Authority (FCA) defines a vulnerable consumer as: "someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care." (FCA Occasional Paper No. 8: Consumer Vulnerability, published 23 February 2015).
As an introducer of finance through our FCA-regulated partner Fast n Funded, we are committed to upholding these standards across every customer interaction that involves financial products or services.
1. WHAT IS VULNERABILITY?
Vulnerability can take many forms and may be temporary, sporadic, or permanent in nature. It is a fluid state that requires flexible and tailored responses. Many people in vulnerable situations would not describe themselves as "vulnerable".
Customers who might be considered to be in vulnerable circumstances include, but are not limited to:
- Customers with mental health conditions or mental capacity limitations
- Customers with communication or language difficulties
- Customers who are not financially sophisticated or lack understanding of financial products
- Customers with low incomes who may feel pressured to accept the first offer available
- Customers who are already experiencing financial difficulty or problem debt
- Customers going through significant life events such as bereavement, relationship breakdown, or serious illness
- Elderly customers or those with age-related conditions
- Customers with physical disabilities that affect their ability to engage with our services
2. IDENTIFYING VULNERABILITY
Identifying vulnerability is not always straightforward. It may not be as obvious as a customer verbally disclosing a condition or showing visible signs of distress. Vulnerability can also be indicated through subtleties such as body language, inconsistencies in communication, or what a customer does not say.
All staff and representatives of Plant and Machine Mart Ltd are expected to remain vigilant at all times to the possibility that a customer may be in a vulnerable circumstance. The following are examples of indicators to look out for — this list is not exhaustive.
Mental capacity limitations: Any customer who appears to have a mental capacity limitation must be treated with extra care. This does not prevent us from conducting business with that customer; however, the approach must change to ensure the customer's capacity does not impede their understanding or decision-making. Where appropriate, companies may use the Debt and Mental Health Evidence Form (DMHEF) — available at www.malg.org.uk — if consent to speak with a carer or representative is required.
Difficulty understanding financial matters: A customer may display signs of not understanding, such as asking for information to be repeated numerous times, simply agreeing without questioning, or appearing unable to make sound judgements based on the information provided.
Low income: Customers with low incomes may be more susceptible to accepting the first deal offered rather than exploring the market. They may be seeking finance to supplement income and may not fully appreciate the long-term implications of a financial commitment.
Financial difficulty: Customers who are already in debt or struggling to meet existing financial obligations may face additional pressures. This may also be compounded by associated medical or mental health conditions.
3. HOW WE RESPOND TO VULNERABILITY
When vulnerability is identified or suspected, we will:
- Treat the customer with sensitivity, patience, and respect at all times
- Adjust our communication approach to meet the customer's needs — for example, using plain language, allowing extra time, or offering alternative communication methods
- Never pressurise a vulnerable customer into making a financial decision
- Offer to pause or reschedule any conversation where the customer appears unable to engage effectively
- Signpost customers to appropriate internal or external support services where relevant
- Record any disclosed vulnerability on the customer's account (with appropriate consent) so that future interactions can be handled appropriately
- Refer the matter to our finance partner, Fast n Funded, where a finance application is involved, so that they can apply their own vulnerable customer procedures
We will not use a customer's vulnerability to our commercial advantage, and we will not proceed with a finance introduction where we have reasonable grounds to believe the customer lacks the capacity to make an informed decision.
4. PRACTICAL PROTOCOLS
The following protocols, developed by the Royal College of Psychiatrists and the Money Advice Trust, are used as practical tools to guide conversations involving vulnerability.
4.1 THE TEXAS PROTOCOL
The TEXAS protocol helps staff manage disclosures effectively. It can be used as a framework for initial conversations:
T — Thank the customer for sharing their circumstances.
E — Explain how their information will be used and kept confidential.
X — Obtain explicit consent to the use of their data.
A — Ask three key questions:
- Does your condition or circumstances make it difficult to manage or repay finance? If so, how?
- Does your condition affect your ability to deal or communicate with us? If so, how?
- Does anyone help you manage your finances, such as a carer or relative? If so, how?
S — Signpost to internal or external help where appropriate.
4.2 THE IDEA PROTOCOL
The IDEA protocol is used to structure more in-depth conversations and identify relevant information:
Impact — Ask what the condition or circumstance either prevents the customer from doing, or makes harder for them to do, in relation to their financial situation. This helps assess the severity of the condition and its practical consequences.
Duration — Discuss how long the customer has been living with the reported condition. The duration of different conditions will vary and can inform decisions about how much time a customer may need.
Episodes — Some customers will experience recurring or fluctuating conditions. Consider what impact this may have on decision-making and whether a decision made during a stable period is likely to remain valid.
Assistance — Establish whether the customer has been able to access care, help, support, or treatment for their condition. This may also be relevant when collecting medical evidence.
Throughout any such conversation, staff should keep in mind not only the commercial outcome but also the steps that would result in a better outcome for the customer's health and financial wellbeing.
4.3 THE CARERS PROTOCOL
This protocol assists with handling disclosures from carers, to ensure that useful information is not lost due to data protection concerns.
Check for authority: If the carer can provide evidence of their authority to act on the customer's behalf, a more detailed discussion can take place once this is confirmed.
If the carer cannot provide evidence of authority but needs to share information urgently:
- Do not discuss any account details, and explain to the carer why this is not possible.
- Reassure the carer that their concerns can be recorded as unverified observations on the customer's record, and that these will be taken into consideration.
- Explain that their observations may need to be shared with the customer and relevant colleagues, and obtain their consent for this.
- Listen carefully and record the carer's observations...
5. FINANCE INTRODUCTIONS
Where a customer applies for finance through our website via our partner Fast n Funded, both Plant and Machine Mart Ltd and Fast n Funded have obligations under FCA guidance...
6. TRAINING AND AWARENESS
All staff and representatives who interact with customers are expected to be familiar with this policy...
7. USEFUL RESOURCES
- MoneyHelper — moneyhelper.org.uk / 0800 138 7777
- StepChange — stepchange.org / 0800 138 1111
- Citizens Advice — citizensadvice.org.uk / 0800 144 8848
- Mind — mind.org.uk / 0300 123 3393
- Samaritans — samaritans.org / 116 123
- National Debtline — nationaldebtline.org / 0808 808 4000
8. CONTACT US
Company: Plant and Machine Mart Ltd
Website: plantandmachinemart.co.uk
Email: support@plantandmachinemart.co.uk
We are committed to handling all such enquiries with sensitivity and in strict confidence.