Vulnerable Clients Policy

The facilities that we offer to trade in complex financial products, are of a highly speculative nature. As the consequences are that you could end up owing more than you initially deposited, it is highly unlikely that they will be suitable for anyone classified as a vulnerable person.

The following list, which is not exhaustive, is an indication of those persons we feel that it would likely be unsuitable to accept business from as they would more likely to be at risk:

  • • Low literacy, numeracy and/or financial capability skills
  • • Physical disability that impairs the ability to act without cognitive or dexterity impairment, or sensory impairment such as loss of sight
  • • Severe or long-term illness
  • • Mental health problems, whether temporary (e.g. depression) or of a longer-term nature
  • • Low income with debt, or an excessive unsecured debt to income ratio (greater than 1:1)
  • • Caring responsibilities for another (including operating a power of attorney)
  • • Being ‘older old’ for example over 80, although this is not absolute (may be associated with
  • • Cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of
  • • Ill-health, not being comfortable with new technology)
  • • Being young (associated with less experience)
  • • Change in circumstances (e.g. job loss, bereavement, divorce)
  • • Lack of English language skills
  • • Non-standard requirements or credit history (e.g. armed forces personnel returning from/going abroad, ex-offenders, care-home leavers, recent immigrants)

For this reason, we ask that if you fall into any of these categories that we be advised of the situation as soon as possible. This does not preclude you from opening or maintaining an account, but we have to be assured that you are able to enter and/or maintain an account in this highly speculative arena.

We would normally be looking for evidence of a combination of adequate support, experience or financial resources behind you, or it may be that we have to adopt a different process when dealing with you and your account if, following notification, we subsequently find you to be/remain a suitable account holder.

Involvement of a third party

It is true that we cannot disclose information about a client’s account to a third party without authorisation or an arrangement such as a power of attorney or third-party mandate. However, if a customer needs assistance in making a call to our company, and the nominated person has the security information they need to conduct a transaction, they will be enabled to carry out the call on the client’s behalf.

In addition, if a third party contacts our company Limited to let us know that a customer cannot manage their financial affairs for a while, because of, for example, a deteriorating health condition or a sudden crisis, we will make a note of the circumstances so that appropriate action can be taken when we can be in contact with the customer. This does not involve disclosing any information to the caller.

We will also want to use the information provided by a third party to investigate further and seek a separate conversation with the client as it may be important in preventing abuse as well as clarifying the customer’s needs. Technically, if the client is unable to monitor their account, the client will be in breach of their contract and so it would be the default position of GBE Capital Limited to close out all the client’s positions.