1. IntroductionPeople can find themselves in vulnerable circumstances at any time. The Financial Conduct Authority’s recent Financial Lives Survey1FCA, Financial Lives 2022: key findings from the FCA’s Financial Lives May 2022 survey, 2023, fca.org.uk/publication/financial-lives/financial-lives-survey-2022-key-findings.pdf shows that 27.7 million adults in the UK now have characteristics of vulnerability such as poor health, experiencing negative life events, low financial resilience or low capability. Not all people with these characteristics will suffer harm, but they may limit people’s ability to make reasonable decisions or put them at greater risk of harm. 1 FCA, Financial Lives 2022: key findings from the FCA’s Financial Lives May 2022 survey, 2023, fca.org.uk/publication/financial-lives/financial-lives-survey-2022-key-findings.pdf »