The BBA fully supports and will abide by the following statement contained in the BMA Draft Code of Banking Conduct

https://www.bma.bm/viewPDF/documents/2021-12-07-09-42-26-Stakeholder-letter-Banking—CP—Banks-and-Deposit-Companies-Act-1999—Code-of-Conduct.pdf

“Code of Conduct: Vulnerable Customers
It was noted that paragraphs 52 through 54 contain broad language relating to vulnerable customers; therefore, clarification was sought as to whether it will be up to each Institution to define in order to drive compliance.
Response: It is expected that each Institution will identify vulnerable customers in its own way. A broad definition is given in the Code; however, Institutions are encouraged to review their existing business model and customer base for instances where customers may be in a vulnerable position. The Authority’s expectation is not that an Institution seeks to proactively identify every customer with a vulnerability, appreciating that circumstances may change and customers may not wish to reveal personal information.
It is expected that where a customer identifies themselves to the Institution as vulnerable, there are processes and facilities available to assist them. For example, the visually or hearing impaired may request communication via channels more accessible to them, or seniors may request additional explanations from staff or support in decision-making.”