Lions

Principal Partner of The British & Irish Lions

east
0818 223000
0818 223000

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Caoga and JF Dunne Insurances are now part of Howden. Find out more about Caoga merger here and JF Dunne Insurances here.

Vulnerable Clients

Supporting Customers in Vulnerable Circumstances

Definition of Vulnerability

The Central Bank of Ireland defines a consumer in vulnerable circumstances as:

A consumer whose personal circumstances, whether temporary or permanent, make them especially susceptible to harm, particularly where a regulated entity is not acting with appropriate levels of care.

Our commitment to you

At Howden, we're committed to supporting all our customers. We focus on doing what's right, delivering on our promises, and treating all customers fairly, including those in vulnerable circumstances.

What is vulnerability?

Sometimes life presents challenges that can affect how customers engage with financial services. Vulnerability may arise due to factors such as health conditions, significant life events, financial pressures, or reduced capacity. It can be temporary or long-term and is not always immediately visible.

How we recognise vulnerability

We are not required to formally identify every customer in vulnerable circumstances. However, we design our processes to recognise and respond to potential signs of vulnerability throughout the customer journey.

This includes:

  • Encouraging open conversations
    Asking supportive, open-ended questions to help customers share anything that may affect their understanding or decision-making

  • Observing behavioural indicators
    Noticing signs such as hesitation, confusion, repeated questions, or distress

  • Using available information
    Taking account of any needs disclosed, such as requests for clear explanations or alternative formats

  • Monitoring engagement where appropriate
    Identifying unusual interaction patterns and following up where necessary

  • Respecting customer comfort and dignity
    Avoiding intrusive questioning and ensuring customers feel comfortable sharing information

How we support you

Our approach is flexible, ongoing, and embedded in everyday interactions. We focus on understanding individual needs rather than applying rigid categories.

We support you by:

  • Training our staff to recognise when additional support may be needed

  • Listening carefully and responding with empathy and respect

  • Adapting our approach to suit individual circumstances

This may include:

  • Adjusting how we communicate with you

  • Allowing additional time to make decisions

  • Providing clear explanations at an appropriate pace

  • Using internal processes to ensure you receive the right level of support

Our commitment to care and protection

Where vulnerability is identified or disclosed, we take reasonable steps to provide ongoing support and help prevent any potential harm. This includes:

  • Tailored communication
    Offering clear explanations, written summaries, or alternative communication methods where needed

  • Suitability and understanding
    Taking extra care to ensure products and services are appropriate, clearly explaining risks, and supporting informed decision-making

More Information

What is a Trusted Contact Person?

A Trusted Contact Person (TCP) is a person nominated by a consumer and recorded by a regulated firm, with the consumer's consent, whom the firm may contact in specific circumstances (such as concerns about the consumer's wellbeing, potential financial abuse, or difficulty contacting them), but who has no authority to make financial decisions on the consumer's behalf.

When We May Contact Your TCP

We may reach out to your Trusted Contact Person if:

  • We have concerns about potential financial abuse

  • We need help to confirm:

    • Your contact details

    • Your wellbeing

    • The details of a legal guardian, executor, or trustee

  • We are unable to contact you directly

What a TCP Can and Cannot Do

Your Trusted Contact Person:

  • Can help us get in touch with you or confirm key information

  • Acts as a point of contact in specific situations such as:

    • When we are unable to reach you using your usual contact details

    • Where we have concerns about your wellbeing or vulnerability

    • If we suspect financial abuse or exploitation

    • Where there are concerns about your ability to manage your affairs

    • To confirm or update your contact details or circumstances

However, they:

  • ❌ Do not have access to your policy details

  • ❌ Cannot make decisions or give instructions on your behalf

  • ❌ Are not a legal representative

How to Appoint a TCP

If you would like to nominate a Trusted Contact Person, please complete the relevant form:

  • General Insurance (Car, Home, Van, Farm, Business): General Insurance Trusted Contact Person Form

  • Life (Pensions, Savings & Investments, Protection): Life Trusted Contact Person Form

Or ring us at 0818 223000 to confirm your TCP

How to let us know

If you would benefit from additional support, or if your circumstances change, please contact us at any time. You only need to share what you feel comfortable with.

Any information you provide will be handled sensitively and in line with data protection requirements.

Financial Abuse

Under the Consumer Protection Code (CPC) 2025, financial abuse is recognised as part of the protections for customers in vulnerable circumstances.

Financial abuse includes:

  • The unauthorised or improper use, taking, or withholding of a customer's money, assets, or property

  • Gaining control over a customer's finances through deception, intimidation, or undue influence

  • Interfering with or denying a customer's right to use or benefit from their money or assets

Our staff are trained to remain alert to potential signs of financial abuse and will escalate any concerns in line with our internal procedures to ensure customers are protected.

Protecting yourself

If you are concerned about financial abuse:

  • Do not share your bank cards, PINs, or passwords

  • Limit who has access to your online banking or insurance accounts

  • Ask a trusted person or contact us for help if anything feels unusual or suspicious

Here is also a list of independent services to avail of:

Health Service Executive National Safeguarding Office

Provides support if you are worried about your own safety or at risk of abuse, neglect, or harm - including situations where someone steals or misuses your money, property, or possessions. The HSE can guide you on how to report concerns or request support.

✅ Contact Details - www.hse.ie

✅ Tel: 071 9193259

An Garda Síochána

If you wish to report the abuse in confidence without giving your name, you can contact the Garda Confidential Line. Emergency or immediate risk, if a person is in immediate danger, contact the Garda Síochána or Emergency Services at 999 or 112.

✅ Contact Details - Station Directory - Garda

✅ Tel: Freephone: 1800666111