Vulnerable circumstances training and Consumer Duty compliance
Vulnerability Managers helps charities and financial services firms treat people in vulnerable circumstances fairly. We deliver vulnerable circumstances training and policy development for the charity sector, and FCA Consumer Duty compliance support for FCA-regulated firms.
The work is practical, plain-spoken and built around the situations your teams actually meet.
How it works
1. Email us at hello@vulnerabilitymanagers.com with a message about how we can help.
2. Free call. We’ll arrange a 30 minute video call to clarify the details for the support you want.
3. Written proposal. Sent to you within 5 working days, including a project outline and exact price.
8,400+
Professionals trained
2,100+
Organisations supported
33
Countries reached
2012
Working since
Protect, empower and support
Helping organisations protect, support and empower people in vulnerable circumstances
A vulnerable circumstance is any time a person may find it harder to make decisions, understand information, or protect their own interests.
This can happen because of age, health, disability, language, money worries, a life event, or many other reasons.
The same questions come up in fundraising, in financial services, in utilities and in healthcare: how does an organisation behave when the person on the other end of the interaction is having a hard time?
How we frame vulnerability
We treat vulnerability as primarily a circumstance — caused by situations, systems and barriers — rather than a fixed trait of the person. We talk about people in vulnerable circumstances, not "vulnerable people". This framing matters: if the problem is seen as being with the person, the response is to change the person; if it is seen as being with the circumstance, the response is to change the system, process or barrier.
Founded in 2012 by Matt Radford, Vulnerability Managers has trained more than 4,800 professionals across over 2,100 organisations in 32 countries, and advised six major industry regulators and professional bodies. The work is led by people with lived experience of vulnerability themselves and supported by evidence drawn from across the sector.
FCA Consumer Duty
Fundraising Code
Equality Act 2010
EU Digital Fairness
Ofgem / Ofwat / Ofcom
Charity Governance
Data Protection Act 2018
For the charity sector
Vulnerable circumstances training and policy development for charities
Charities meet people in vulnerable circumstances every day — donors, supporters, beneficiaries and members of the public. Fundraising is also one of the most heavily regulated public-facing activities in the sector. We help charities, NGOs and fundraising teams build the knowledge, policies and culture to get this right.
Vulnerable circumstances training for charity teams
Our training equips fundraisers, supporter care teams and frontline staff to recognise when a supporter or service user may be struggling, and to respond with care and confidence. It is practical and plain-spoken — built around real situations, not abstract theory — and delivered in person or online. Sessions are co-designed with lived experience specialists.
Charity training programmes
VM-T01 · Support pillar
Working with Vulnerable Circumstances — Foundation
Half-day foundation training covering the main types of vulnerability, the Before, During, After model, and practical exercises. The right starting point for whole teams.
From£5,850
VM-T04 · Support pillar
Fundraisers & Supporter Care — Vulnerability Training
Fundraising-specific training covering the UK Code of Fundraising Practice, Fundraising Regulator standards, donation acceptance and refusal, and telephone fundraising practice.
From£6,850
VM-T03 · Support pillar
Vulnerability Series — Four-Session Programme
Four half-day sessions over four to eight weeks, building knowledge and skill cumulatively with application exercises between sessions. A whole-team programme.
From£18,500
Policy development for charities
A clear vulnerable circumstances policy gives staff and volunteers a consistent way to recognise and respond when a supporter, donor or service user is struggling. We help charities write and review policies that are accurate, usable, and aligned with the UK Code of Fundraising Practice, Fundraising Regulator standards, and Charity Commission safeguarding guidance — and that trustees can stand behind. Policy development is part of our Empower pillar (advice and case management) and our Protect pillar (compliance audits and reviews).
Empower · Advisory
Vulnerability policy and framework development
Hands-on advisory support to develop a vulnerable circumstances policy, safeguarding policy or staff guidance from scratch, or to bring an existing one up to standard. Advisory engagements start from £3,200.
Protect · VM-A09
Policy Review
A shorter, scoped review of a specific policy area — a lighter-touch engagement that tests one policy against current rules and good practice. From £3,850.
Protect · VM-A02
Fundraising Codes Compliance Audit
A full review against the UK Code of Fundraising Practice, Charity Commission guidance, ICO and direct marketing rules — our deepest area of sector expertise. From £14,850.
What charity teams take away
Confidence to recognise and respond to supporters and service users in vulnerable circumstances
Policies and staff guidance that are clear, current and usable in real situations
Practical alignment with the UK Code of Fundraising Practice and Fundraising Regulator standards
Evidence for trustees and regulators that the duty of care is being met in practice
Inclusive, accessible supporter journeys that work for a wider range of people
Smaller charities. Charities with an annual income under £1 million receive 10% off standard training, audit and advisory rates. Bundled engagements that combine audit, training and advisory are typically 10 to 15% lower than buying the components separately.
For the financial services sector
FCA Consumer Duty compliance for financial services firms
Since July 2023, the Financial Conduct Authority has required firms to deliver good outcomes for retail customers — including extra care for those in vulnerable circumstances. We check your Consumer Duty implementation is working in practice, not just on paper, and train your teams to deliver it.
Consumer Duty applies to FCA-regulated firms of any size — banks, insurers, lenders, investment firms and brokers. It expects firms to identify customers in vulnerable circumstances and treat them with appropriate care across the whole customer journey. In March 2025 the FCA published a review, Delivering good outcomes for customers in vulnerable circumstances, setting out where firms' practice still needs to improve.
The four Consumer Duty outcomes
Products and services. Designed to meet the needs, characteristics and objectives of target customers.
Price and value. A fair value assessment against what customers pay and what they receive.
Consumer understanding. Clear communication — with particular care for customers in vulnerable circumstances.
Consumer support. Customers can use products and pursue their goals in the real world, with support available throughout.
The cross-cutting rules
Act in good faith towards retail customers.
Avoid causing foreseeable harm.
Enable and support customers to pursue their financial objectives.
Identify and appropriately treat customers in vulnerable circumstances across the whole journey.
Report annually to the board on Consumer Duty.
Consumer Duty services
VM-A01 · Protect pillar
FCA Consumer Duty Compliance Audit
An outcome-by-outcome gap analysis across all four outcomes and the cross-cutting rules, with customer journey mapping, a vulnerable customer treatment review, a board-ready annual Consumer Duty report draft, and a prioritised staff-facing action plan.
From£18,500
VM-T05 · Support pillar
FCA Consumer Duty — Frontline Training
Consumer Duty training for frontline staff in FCA-regulated firms — focused on identifying and supporting customers in vulnerable circumstances and meeting the Duty in everyday interactions.
From£7,850
VM-A09 · Protect pillar
Policy Review
A scoped review of a single policy — for example a vulnerable customer policy — tested against Consumer Duty expectations and FCA guidance on the fair treatment of vulnerable customers.
From£3,850
What a Consumer Duty engagement delivers
A clear view of where your implementation meets the Duty and where the gaps are
Customer journey mapping with vulnerability touchpoints flagged
A whole-journey review of how customers in vulnerable circumstances are treated
A board-ready draft of your annual Consumer Duty report
A prioritised, costed action plan your teams can act on, and evidence for the regulator
Lived experience
Led by lived experience, supported by evidence.
Built by people who understand the barriers
A network of lived experience specialists shapes our frameworks, delivers the training and holds the work to account. We work with lived experience specialists, not just about them.
Sector recognition
Trusted by regulators and professional bodies
We have advised the Fundraising Regulator, the Chartered Institute of Fundraising, the Data & Marketing Association, the Federation of European Data and Marketing, and fundraising bodies in Australia, New Zealand and the United States.
Principle-based
Capability, not just checklists
Our approach builds genuine professional capability rather than long checklists that mostly favour majority populations. We name the regulator, the code and the clause — and we are honest about what we do not cover.
Vulnerability Managers is led by founder and director Matt Radford, who holds senior committee positions including Deputy Chair of the Chartered Institute of Fundraising's Professional Conduct work, and roles with the Data & Marketing Association and the Association of Fundraising Professionals. The consultancy traded as Vulnerable Paths until its 2026 rebrand.
Common questions
Frequently asked questions
What is vulnerable circumstances training?
Vulnerable circumstances training equips staff to recognise when someone may find it harder to make decisions, understand information or protect their own interests, and to respond in the right way. A vulnerable circumstance can come from age, health, disability, language, money worries or a difficult life event. The training is practical and built around real situations staff actually meet.
Why do charities need a vulnerable circumstances policy?
A vulnerable circumstances policy gives staff and volunteers a clear, consistent way to recognise and respond when a supporter, donor or service user is struggling. It helps a charity meet the UK Code of Fundraising Practice, Fundraising Regulator standards and Charity Commission safeguarding guidance, and shows trustees and regulators that the duty of care is being met in practice, not just on paper.
What is FCA Consumer Duty?
The FCA Consumer Duty has, since July 2023, required financial services firms to deliver good outcomes for retail customers. It is built around four outcomes — products and services, price and value, consumer understanding, and consumer support — and a set of cross-cutting rules. It places particular emphasis on extra care for customers in vulnerable circumstances across the whole customer journey.
Does Consumer Duty apply to vulnerable customers?
Yes. Consumer Duty expects firms to identify customers in vulnerable circumstances and treat them with appropriate care at every stage of the journey. In March 2025 the FCA published a review of how firms deliver good outcomes for customers in vulnerable circumstances, setting out where practice needs to improve.
Do you offer a discount for smaller charities?
Yes. Charities with an annual income under £1 million receive 10% off standard training, audit and advisory rates. Bundled engagements that combine audit, training and advisory are typically 10 to 15% lower than buying the components separately.
Can training be delivered online?
Yes. Training is available in person and online. In-person delivery is the baseline; online-only delivery typically runs a little lower in price, and hybrid delivery sits in between. We will recommend the format that best suits your team during the scope call.