Delivering services to Consumers
As a Code Member we will not engage in high pressure selling techniques and will ensure that any individual or third-party organisation they contract with does not engage in high pressure selling techniques.
We will deal with Consumers politely and quickly and take steps to make sure that important information is passed to them clearly. When made aware of a complaint, Code Members will act to resolve the complaint as speedily and effectively as possible.
We will give all Employees training in delivering services to Consumers and will keep records on the training provided and extra training needs. It will often be appropriate for Code Members to be accredited to a recognised standard for quality and continuous improvement.
We must make Consumers aware of any responsibilities they will have as a result of the Contract in question. This includes any requirements on Consumers to provide information and to operate and maintain any Goods provided.
We must ensure that all written information given to Consumers is in plain English. In the case of Consumers in vulnerable circumstances, Code Members are expected to provide extra care and support.
Consumers in Vulnerable Circumstances
We must put in place a process and training for their Employees, including those working on their behalf, on how to safeguard consumers in vulnerable circumstances. When creating this process, attention should be paid to the Code Administrator’s guidance on Consumers in Vulnerable Circumstances (see attachment C below). Code Members must be able to demonstrate that their Employees have been appropriately trained and have followed this process where necessary.
We will take steps to identify whether a Consumer has any additional needs, or who, by way of their circumstances, may be potentially vulnerable, and to deal with them appropriately.
A Consumer may be in circumstances which make them vulnerable for a number of reasons, including as a consequence of their physical or mental health, disability, age, personal circumstances (both short and long term), ability to understand the information they are presented with, illiteracy or if their first language is not English and English is the only language information is available in. Code Members should recognise that vulnerability and additional needs are very much a matter for individual circumstances. Code Members should also recognise that individual characteristics or circumstances can change over time such that consumers may find themselves in vulnerable circumstances at different stages of their contacts with the Code Member.
Where a Code Member has identified a Consumer as potentially being in vulnerable circumstances, they must pro-actively suggest measures which will help the Consumer. All information provided must be tailored to the Consumer, taking account of any apparent vulnerability. Code Members should take special care to ensure that Consumers understand the key documents, including the quotation, the Contract, and the guarantee arrangements. (See the Code Administrator’s guidance on Consumers in Vulnerable Circumstances for more information).
Where appropriate, Code Members must seek the involvement of a trusted friend or relative in any contacts they have with the Consumer and arrange for a trusted friend or relative to be present during a visit to the Consumer’s home. If this has not been possible, Code Members must re-schedule the visit at a time when a trusted friend or relative is available to be present.
Behaviour of sales representatives
Our Employees and those who sell on their behalf must act with integrity and must respect Consumers’ right to privacy and bring any contact to an end immediately if requested to do so. They must answer Consumers’ questions honestly and clearly.
We will take steps to identify whether a Consumer has any additional needs, or who, by way of their circumstances, may be potentially vulnerable. In such a case, they must adapt key information accordingly, and suggest that the Consumer reads it with a trusted friend or relative.
False or misleading information
Our Employees and those who sell on their behalf must not give false or misleading information about their business or the product, services or facilities being offered. They must not make any statement that is likely to mislead a Consumer in any way. Providing misleading information is prohibited by this Code and the law. In line with the Consumer Rights Act 2015 any statements or information which the Consumer relies on in making a buying decision are now considered an implied term of the Contract. If such statements or information are false or misleading in any way they are likely to be considered as a breach of contract.
Our Employees and those who sell on their behalf must not use any selling techniques designed to pressurise a Consumer into making an immediate decision. These high-pressure selling techniques may be prohibited by law as well as contravening this Code. They include, but are not limited to:
- staying in a Consumer’s premises for more than two hours (except in exceptional circumstances which must be recorded, for example when an energy assessment is being carried out);
- offering a Consumer an inflated initial price followed by a discount, or equivalent (for example, additional equipment or monitoring devices for free), for:
- signing on the day;
- agreeing to provide testimonials
- providing customer referrals
- displaying a board outside their home
- providing performance monitoring data;
- withholding price information until the end of the visit;
- making unrealistic projections for future inflation rates or energy prices;
- claiming that there is limited availability of the Energy Generator; or
- offering payments over £50 for:
- agreeing to provide testimonials
- providing customer referrals
- displaying a board outside their home.
Our Employees and those who sell on their behalf are only permitted to offer discounts of more than £200 where:
- the undiscounted price quoted is a genuine price at which the Code Member can show that they have made a significant number of retail sales of Energy Generators; and
- the discounts have been specifically advertised by the Code Member a reasonable time beforehand on the website or in press or other media advertising; and
- the discounted price cannot be confused with the undiscounted price; and
- the discounts apply to every-one irrespective of postcode, region, date, house type or any other limiting factor clearly intended to pressurise a Consumer into signing a Contract.
Our Employees and those who sell on their behalf, must not follow up sales visits by further visits or telephone calls offering further discounted prices or other information intended to pressurise a Consumer into signing a Contract.