1. Understanding Vulnerability
Cosmo Graham and Linda Lennard, Centre for Consumers and Essential Services (CCES)

2. Reality of vulnerability
Utility legislation took “group” approach
CCES argued that this approach outdated
Too rigid, under and over inclusive
Ofgem first regulator to revise approach
Consumer vulnerability strategy 2013
Since taken up by Financial Conduct Authority (2015) and other regulators
Also trade associations
Ofgem now looking to develop enforceable principles

3. Understanding vulnerability – who is at risk?
Nearly all of us
Constellation of risk factors
Short term or fluctuating
Or long-lasting and cumulative
`Vulnerable consumers’ aren’t a separate group

4. Some numbers 10.8 million in poverty in 2014 in UK
~ 4 million in persistent poverty
11 million disabled people in Britain
6.5 million carers in UK
Hidden issues: literacy or numeracy difficulties
Multi-dimensional: many are dealing with multiple risk factors
Poverty statistics from ONS: assuming 64.1 million population

5. Thinking about vulnerability
Changes in circumstances: stuff happens
Multiple risk factors
Not just about personal situations: the role of markets and companies
Barriers to complaining

6. Key challenges for Ombudsman
Accessibility!
Training staff – active listening
Getting the whole organisation on-board
Reviewing, learning and improving
Good networks – including people at risk of being marginalised
Sharing insights and lessons
Be prepared to influence and intervene to change company behaviour – using all available routes

7. Inclusive service Design for all rather than special schemes
Consistent with Equality Act obligations
Organisational commitment
Openness, planning and scrutiny
Organisational learning

8. Contact details
Centre for Consumers and Essential Services, Leicester Law School, University of Leicester LE1 7RH United Kingdom
Tel: 44 (0)
Web: