CLIENT VULNERABILITY

What is a vulnerable client?

Spreadex defines a vulnerable client as someone whose ability to effectively engage with, and make effective decisions in relation to, Spreadex’s leveraged trading services might be negatively impacted because of their personal circumstances.  Vulnerable clients might be more likely to experience detrimental outcomes, which in the event they materialise, are likely to be greater than for other (non-vulnerable) clients.

Factors which contribute to vulnerability:

There are numerous reasons why a person might feel vulnerable during their lifetime.  Some of the characteristics that might contribute to a client’s vulnerability are as follows:

Health – physical or mental disabilities or illnesses that affect an individual’s ability to carry out day-to-day tasks;

Life events – major life events such as bereavement, job loss, or relationship breakdown;

Capability – lack of knowledge of financial matters or low confidence in managing money (financial capability) and low capability in other relevant areas such as digital and media literacy; and

Financial and emotional resilience – reduced ability to withstand financial or emotional shocks.

These factors may impact a client’s trading behaviours and outcomes.

What Impact can vulnerability have on clients?

Vulnerability characteristics can potentially have a number of detrimental impacts on a Spreadex client.  Some examples are listed below:

1. A lack of technological ability and experience or a physical disability can lead to a reduced ability to operate Spreadex’s investment platforms.
2. A lack of mental capacity can lead to erroneous trading decisions, in particular in relation to higher risk products.
3. Certain characteristics or events which can lead to reckless or emotionally-driven investment decisions, such as:

• Financial hardship.
• An unexpected diagnosis of serious illness to either the client or a close family member.
• Addiction-related health conditions, such as gambling addiction or compulsive behaviours.
• Mental health disorders including depression, heightened levels of anxiety, and suicidal thoughts.

It is possible to have healthy trading behaviours for months or years before becoming vulnerable due to a change in personal circumstances.

How does Spreadex support Vulnerable Clients?

Vulnerability is often not easily visible and Spreadex relies on our clients being open and making us aware of any concerns. If you believe you might be impacted by any characteristics of vulnerability, it is important that you notify us as soon as possible.  Should you wish to notify us about your situation, or if you believe that you are a vulnerable client, you can let us know through any of the methods of communication available to Spreadex clients including telephone (freephone 08000 526 575 or 08000 526 570), live chat or via email [email protected].

Steps Spreadex may take when responding to client vulnerability

Spreadex has a variety of policies and procedures for addressing client vulnerability. The firm recognises that no two cases of vulnerability are alike and so the firm will take a tailored approach to each case of vulnerability that arises. The firm will generally operate in line with the following principles:

1. Where a client’s vulnerability is owing to particular disability the firm will seek to take appropriate steps to adjust and tailor their communications with the client in such a way as to support them and their specific needs.
2. Spreadex believes that the vulnerable client’s welfare is paramount and will seek to act in a manner that best supports the vulnerable client with their goals.
3. Depending upon the vulnerable Client’s personal circumstances, Spreadex may recommend a temporary or permanent suspension of the clients trading account where the firm believes that this would be in the vulnerable client’s best interest.

External Support

Vulnerable clients may seek external support from the following organisations:

• Vulnerable clients that are suicidal or in a state of depression or heightened anxiety should contact the
•  (formerly known as the Money Advice Service);