Overview
Claim Market Ltd Version 1.0 Effective Date: 22 May 2026
Introduction
Claim Market Ltd (“the Company”) is committed to ensuring that all consumers are treated fairly, respectfully, honestly, and with appropriate levels of care throughout all interactions with the business.
As a UK-based online lead generation company operating within the claims and financial services sector, the Company recognises that some consumers may be vulnerable due to their personal circumstances, health, financial position, or life events. Vulnerability can impact a consumer’s ability to make informed decisions, understand information provided to them, assess risk, or engage confidently with products and services.
The Company acknowledges the importance of supporting fair consumer outcomes and maintaining high standards of ethical conduct in all marketing, lead generation, and customer engagement activities.
Although Claim Market Ltd is not directly authorised or regulated by the Financial Conduct Authority (“FCA”), the Company works closely with FCA-authorised claims management companies and other regulated businesses. As such, the Company seeks to operate in a manner consistent with good industry practice, FCA expectations regarding vulnerable customers, and wider consumer protection standards.
This Policy outlines the Company’s commitment to identifying, understanding, supporting, and appropriately responding to vulnerable individuals.
Purpose of this Policy
The purpose of this Policy is to:
Promote fair treatment of vulnerable individuals;
Ensure that vulnerable consumers are treated with dignity, empathy, patience, and understanding;
Reduce the risk of harm, detriment, confusion, or exploitation;
Support responsible and compliant marketing and lead generation practices;
Ensure staff understand their responsibilities when dealing with potentially vulnerable individuals;
Provide guidance on recognising and responding appropriately to vulnerability;
Support the Company’s commitment to ethical business practices and consumer protection.
The Company recognises that vulnerability can affect anyone at any time and may be temporary, permanent, visible, or hidden.
Scope
This Policy applies to:
All directors, employees, contractors, consultants, and temporary staff;
All consumer-facing communications and interactions;
All online marketing, advertising, and lead generation activities;
All websites, landing pages, forms, and digital platforms operated by the Company;
All third-party suppliers, introducers, affiliates, and partners acting on behalf of the Company where relevant.
This Policy applies regardless of whether interactions occur by:
Website;
Email;
Telephone;
SMS;
Social media;
Online forms;
Live chat;
Other digital communication channels.
Regulatory and Legal Context
While Claim Market Ltd is not itself FCA authorised, the Company acknowledges the importance of aligning its conduct with recognised UK regulatory expectations and consumer protection standards.
This Policy has regard to:
FCA Guidance for the Fair Treatment of Vulnerable Customers;
FCA Consumer Duty principles;
UK General Data Protection Regulation (“UK GDPR”);
Data Protection Act 2018;
Privacy and Electronic Communications Regulations (“PECR”);
Consumer Protection from Unfair Trading Regulations 2008;
CAP Code and ASA advertising guidance.
The Company also recognises that the quality and integrity of leads generated may impact the regulatory obligations of the FCA-authorised firms that receive them.
Understanding Vulnerability
The Company understands vulnerability to mean circumstances that may make an individual more susceptible to harm, disadvantage, confusion, pressure, or poor outcomes.
Vulnerability may arise due to a wide range of factors and may be:
Permanent;
Temporary;
Situational;
Sudden;
Progressive;
Hidden or not immediately apparent.
The Company recognises that vulnerability is not always obvious and that consumers may not openly disclose personal difficulties.
Types of Vulnerability
Examples of circumstances that may contribute to vulnerability include, but are not limited to, the following:
1 Health-Related Vulnerability
This may include:
Physical disability;
Mental health conditions;
Cognitive impairment;
Learning difficulties;
Long-term illness;
Serious medical conditions;
Hearing or visual impairments;
Addiction, dependency, or substance misuse issues.
2 Life Events and Personal Circumstances
This may include:
Bereavement;
Divorce or separation;
Domestic abuse;
Caring responsibilities;
Job loss or redundancy;
Relationship breakdown;
Trauma or distressing personal events.
3 Financial Vulnerability
This may include:
Financial hardship;
Significant debt;
Low income;
Unemployment;
Reduced financial resilience;
Difficulty managing household finances.
4 Capability and Communication Vulnerability
This may include:
Limited literacy;
Limited digital skills;
Language barriers;
Difficulty understanding technical or legal terminology;
Low confidence when engaging with businesses or online services.
Company Commitments
Claim Market Ltd is committed to:
Treating all consumers fairly and consistently;
Acting honestly, responsibly, and professionally;
Ensuring communications are clear, fair, and not misleading;
Avoiding pressure-based or exploitative practices;
Taking reasonable steps to support vulnerable consumers;
Encouraging staff to act with empathy and understanding;
Protecting consumer privacy and confidentiality;
Maintaining appropriate standards of data protection and security;
Working responsibly with regulated business partners.
The Company will seek to ensure that vulnerable consumers are not disadvantaged by the Company’s processes, communications, or marketing activities.
Identifying Vulnerability
Employees and representatives should remain alert to indicators that a consumer may be vulnerable.
Potential indicators may include:
Confusion or misunderstanding;
Difficulty processing information;
Repeated questions or requests for clarification;
Emotional distress or anxiety;
Difficulty completing online forms;
Statements relating to illness, financial hardship, or personal difficulties;
Reliance on family members or third parties;
Signs of pressure, coercion, or distress.
Employees are not expected to diagnose or categorise vulnerability. However, they are expected to respond appropriately, professionally, and sensitively where indicators are present.
Supporting Vulnerable Consumers
Where vulnerability is identified or reasonably suspected, staff should take reasonable and proportionate steps to support the individual.
This may include:
Speaking clearly and calmly;
Avoiding jargon or overly technical language;
Allowing additional time for understanding;
Repeating or clarifying information where necessary;
Confirming consumer understanding;
Offering alternative communication methods where feasible;
Avoiding aggressive or pressurised communication;
Escalating concerns internally where appropriate.
Staff should avoid making assumptions and should treat each situation individually and respectfully.
Responsible Marketing and Lead Generation
Claim Market Ltd is committed to ensuring that its marketing and lead generation activities are conducted ethically and responsibly.
The Company will take reasonable steps to ensure:
Marketing materials are clear, accurate, and not misleading;
Consumers understand the nature of the services being promoted;
Consent mechanisms are transparent and compliant;
Consumers understand they may be contacted by relevant claims or financial services firms;
Vulnerable individuals are not unfairly targeted or exploited;
Advertising does not intentionally create fear, urgency, or distress;
Consumer expectations are managed appropriately.
The Company will not knowingly engage in misleading, deceptive, coercive, or exploitative marketing practices.
Handling Vulnerability Concerns
Where concerns arise regarding a potentially vulnerable consumer, the Company may take appropriate action, including:
Escalating the matter internally;
Limiting or ceasing communications;
Suppressing a lead from distribution;
Reviewing the circumstances surrounding consent or engagement;
Cooperating with relevant regulated partners where appropriate.
The Company reserves the right to refuse to process or distribute a lead where doing so may create a risk of consumer harm.
Data Protection and Confidentiality
Information relating to a consumer’s vulnerability may constitute sensitive personal data.
The Company will ensure that:
Personal data is processed lawfully, fairly, and transparently;
Sensitive information is handled carefully and securely;
Access to personal information is restricted on a need-to-know basis;
Excessive or unnecessary information is not recorded;
Data retention practices comply with applicable legislation.
All staff are expected to maintain confidentiality and comply with the Company’s data protection obligations at all times.
Staff Training and Awareness
The Company recognises the importance of staff awareness and training in supporting vulnerable consumers.
Relevant staff will receive appropriate guidance and training covering:
Understanding vulnerability;
Recognising indicators of vulnerability;
Appropriate communication methods;
Consumer protection expectations;
Escalation procedures;
Data protection and confidentiality obligations.
Training may be refreshed periodically to reflect regulatory developments, operational changes, or identified risks.
Monitoring and Review
The Company will periodically review:
Consumer complaints and feedback;
Marketing practices;
Lead quality and compliance concerns;
Internal processes and controls;
Staff awareness and understanding.
This Policy will be reviewed at least annually or sooner if required due to:
Regulatory developments;
Operational changes;
Material incidents;
Identified compliance risks.
Breaches of this Policy
Failure to comply with this Policy may result in:
Internal disciplinary action;
Contractual consequences for third parties;
Reputational damage;
Legal or regulatory exposure.
The Company takes consumer protection and ethical conduct seriously and expects all personnel to uphold the standards set out within this Policy