Vulnerable Customer Policy
1. Our Commitment
Aura Capital is committed to treating all customers fairly, with particular care given to those in vulnerable circumstances.
While Aura Capital is not authorised or regulated by the Financial Conduct Authority (FCA), we voluntarily adopt and are guided by FCA principles and best practice, including:
Consumer Duty (Principle 12)PRIN 2A – Delivering good outcomes for retail customers
FCA Guidance on the fair treatment of vulnerable customers
FCA Guidance (for reference):
https://www.fca.org.uk/publications/finalised-guidance/guidance-firms-fair-treatment-vulnerable-customers
Our aim is to ensure that all customers, including those in vulnerable circumstances, receive fair, transparent and appropriate outcomes.
2. Definition of a Vulnerable Customer
We adopt the FCA definition of a vulnerable customer:
Someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care
Full guidance:
https://www.fca.org.uk/publication/finalised-guidance/fg21-1.pdf
Vulnerability may be temporary, permanent, or fluctuating, and may not always be visible.
3. Understanding Drivers of Vulnerability
Vulnerability may arise from:
Health – physical or mental health conditions
Life Events – bereavement, redundancy, relationship breakdown
Financial Resilience – limited income, high debt, low savings
Capability – low financial literacy, language or digital barriersThese factors may impact a customer’s ability to understand or engage with financial decisions.
4. Shared Responsibility & Customer Disclosure
Aura Capital takes reasonable steps to identify and support vulnerable customers. However, effective support relies on customers being open and forthcoming about their circumstances.
We strongly encourage customers to:
Disclose any personal circumstances that may affect their decision-making
Notify us of any changes during a transaction
Ask questions where anything is unclear
Failure to disclose relevant information may limit our ability to:
Assess whether a product is appropriate
Provide tailored support
Ensure the best possible outcome
All disclosures are handled sensitively and confidentially.
5. Our Approach
We aim to apply fair and consistent treatment across all customers, with additional care where vulnerability is identified.
This includes:
Clear, transparent communication
Taking reasonable steps to ensure understanding
Allowing additional time where required
Avoiding undue pressure
Adapting our approach where appropriate
6. Identifying Vulnerability
We may identify vulnerability through:
Customer disclosure
Behavioural indicators (confusion, distress, repeated questions)
Information provided during the application process
Third-party involvement (e.g. solicitor, family member)
Our team is trained to recognise potential indicators of vulnerability.
7. Supporting Vulnerable Customers
Where vulnerability is identified, we take proportionate steps to support the customer, including:
Communication
Clear and simple explanations
Reconfirmation of key risks and obligations
Additional time for decision-making
Process
Slowing the process where appropriate
Offering alternative communication methods
Encouraging involvement of a trusted third party
Understanding
Ensuring customers understand:
The product structure
Their obligations
The risks involved
8. Product Suitability & Risk Awareness
Aura Capital specialises in unregulated bridging finance and short-term property lending.
These products are:
Short-term in nature,
Require a clear and credible exit strategy
May involve higher costs than long-term finance
Are secured against property, meaning failure to repay may result in repossession
We will not proceed where we reasonably believe:
The customer does not understand the risks
The product is clearly unsuitable
Aura Capital does not provide advice to clients or regulated financial advice.
9. Referrals
Where we believe a regulated product may be more appropriate, we may introduce the customer to a firm that is authorised and regulated by the Financial Conduct Authority.
Such referrals are made on an introductory basis only, and Aura Capital accepts no responsibility for the advice, products, or services provided by third parties.
10. Staff Training & Competence
All relevant staff receive training to: Recognise vulnerability Communicate clearly and sensitively Apply this policy appropriately.
11. Data Protection & Confidentiality
Information relating to vulnerability is treated as sensitive and handled in accordance with: UK GDPR Data Protection Act 2018
12. Monitoring & Continuous Improvement
Aura Capital reviews its approach to ensure fair customer outcomes, including:
Internal review of customer interactions
Complaint monitoring
Ongoing policy updates
13. Customer Rights
Customers who are dissatisfied with our service may raise a complaint directly with Aura Capital.
As Aura Capital is not FCA regulated, complaints may not fall within the jurisdiction of the Financial Ombudsman Service.
14. Contact
If you require additional support or wish to disclose any circumstances, please contact:
Aura Capital
enquiries@auracapital.co.uk