AILO launches Vulnerability Code of Conduct

New code aims to help firms achieve positive customer outcomes

We’re proud to launch our Vulnerability Code of Conduct which is designed to help our Members develop greater insights into vulnerability, and how it impacts customers.

The Code (which is published in full here includes a set of principles, plus a list of actions, processes and behaviours.

Mike Foxall – Chair of AILO’s Proposition & Customer Outcomes Committee – led the project to create it. He said: “The Code of Conduct is a guide that will help Members to evolve strong and consistent behaviours and enable firms to deal confidently with customer vulnerability. It’s an issue of growing importance, especially since the publication of the FCA’s Guidance on Treatment of Vulnerable Customers (FG21/1). In a world where every single one of us could be vulnerable tomorrow, our Code of Conduct is a demonstration of the cross-border life sector’s commitment to protecting and supporting those who are vulnerable today.”

In addition to the FCA’s guidance, Mike and the Proposition & Customer Outcomes Committee took into account MiFID guidelines; relevant regulatory developments in Europe (including EFPA Nov 2020, EUC Consumer Vulnerability 2016); and in North America where regulators have growing concerns relating to customer vulnerability caused by cognitive decline.  

But the most valuable resource was the widely respected Financial Vulnerability Taskforce (FVT) Charter. Commenting on the AILO Code, FVT Chair Keith Richards said: “We welcome this development, especially because the Code is aligned with the statements in the Financial Vulnerability Taskforce Charter. It’s encouraging  to see trade organisations such as AILO showing leadership on this important issue and the Vulnerability Code of Conduct adds tangible support and professional standards value to its membership.”

AILO CEO, Bob Pain, congratulated Mike and fellow Proposition & Customer Outcomes Committee members for their work, and added: “This is an excellent example which shows how AILO is promoting best practice in our industry, and adding value for our Members.”

It took many months of work to create AILO’s Vulnerability Code of Conduct – here’s the story behind it in more detail.

Work began with the creation of a ‘Report on Vulnerable Customers’ document which was aligned to the key points in the FCA’s Guidance on treatment of Vulnerable Customers (FG21/1) and took into account other reports and developments already noted above. The emphasis was on drawing out those elements of FG21/1 which focused on how product providers needed to consider vulnerability, not just when dealing directly with customers, but also in relation to product design and distribution.

Mike Foxall added: “At our Members’ meeting in summer 2021 it was agreed that AILO should progress its own Charter to help encourage Member firms to better recognise and develop processes and procedures that take account of vulnerable customers. This gradually evolved into the final Code of Conduct which includes a first section setting out six principles, followed by a section which focuses on the types of actions, processes, and behaviours which firms need to consider when aiming for adherence with the Code. Within principles one and two there are references to the Financial Vulnerability Taskforce (FVT), including a link to the FVT Consumer Guide. These were advocated by Keith Richards (FVT CEO) and his team, who were asked to review it. That gives our Vulnerability Code of Conduct a really strong endorsement.” 


Mike Foxall, Chair of AILO’s Proposition & Customer Outcomes Committee.

Bob Pain, CEO, AILO.