Legal
At Trebla, we are committed to identifying and supporting customers who may be in vulnerable circumstances — ensuring everyone receives fair, appropriate, and compassionate service.
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If you are in a vulnerable situation and need us to adjust how we work with you, please get in touch or call us on 021 0271 2712. We are here to help.
Trebla Partners Limited is committed to treating all customers fairly — including those who may be experiencing vulnerability. We recognise that vulnerability is not a fixed characteristic; it can affect anyone at any time, depending on their personal circumstances.
Our approach is aligned with the Financial Markets Authority (FMA) Customer Vulnerability Guidance, the Conduct of Financial Institutions (CoFI) Act 2022, and the Code of Professional Conduct for Financial Advice Services 2025. We take our obligations seriously and have embedded vulnerable customer considerations throughout the way we deliver our services.
Vulnerability is circumstance-based, not person-type-based. It is not about labelling or categorising individuals — it is about recognising that certain circumstances can reduce a person's ability to engage with financial services, make informed decisions, or protect their own interests.
A customer may experience vulnerability temporarily (for example, following a bereavement or sudden job loss) or on an ongoing basis. The same person may be vulnerable in one situation but not another.
We use the Consumer Vulnerability Framework recognised by the FMA, which identifies seven key drivers of vulnerability:
Financial stress caused by low income, significant debt, job loss, benefit dependency, or inability to cover essential living costs.
Difficulty understanding financial products, limited numeracy or literacy, or low confidence engaging with financial concepts and decisions.
Significant personal events such as bereavement, separation or divorce, redundancy, new parenthood, or caring for a family member.
Serious illness, injury, disability, or a medical diagnosis that affects a person's capacity to engage with financial matters.
Physical, sensory, cognitive, or intellectual disabilities — including conditions that are not immediately visible — that may affect communication or decision-making.
English not being a first language, low literacy, or difficulty reading and understanding written financial documents and disclosures.
Anxiety, depression, grief, cognitive impairment, or other mental health conditions that may affect a person's ability to make decisions or engage with financial advice.
We do not assume vulnerability. Instead, our advisers are trained to listen carefully, ask open questions, and remain alert to signs that a customer may need additional support. These may include:
We will always follow the lead of the customer and will never make assumptions based on age, ethnicity, disability, or other characteristics.
You do not have to disclose personal or sensitive information to receive our services. However, if there is something in your circumstances that you feel may affect how we work with you, we encourage you to let us know. This helps us tailor our service appropriately.
You can:
Any information you share will be treated with sensitivity and in accordance with our Privacy Policy.
Where we identify or are told that a customer may be in vulnerable circumstances, we will take reasonable steps to adjust how we work. This may include:
We will record any adjustments we make in our client file notes so that all team members are aware of the customer's needs.
We are committed to ensuring that vulnerability is never exploited. Our advisers are required under the Code of Professional Conduct for Financial Advice Services 2025 to:
If we have concerns that a customer is being subjected to undue influence, financial abuse, or coercion, we will take appropriate steps to protect their interests.
If you are experiencing financial hardship, emotional distress, or need additional support, the following services may be able to help:
All Trebla advisers and staff receive training on identifying and responding to customer vulnerability. This is reviewed regularly to reflect updates to FMA guidance, the Code of Professional Conduct, and industry best practice.
Executive accountability for our vulnerable customer policy rests with the Partners of Trebla Partners Limited. We review this policy annually and update it as required.
If you feel we have not adequately recognised or responded to your vulnerable circumstances, we want to know. You can raise a concern through our Complaints Process. We take all feedback seriously and use it to improve our service.
This policy has been developed in accordance with:
Last reviewed: May 2026
If you have any questions about this policy or would like to discuss your circumstances with us, please get in touch: