Privacy Policy, Finance Disclaimers & Help

-The Legal Stuff

Who we are

This privacy policy sets out how Energise Energy uses and protects any information that you give us when you use this website.

At Energise Energy, we are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

Energise Energy may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 24th May 2018.

What we collect

We may collect the following information:

  • Your Name
  • Company Name
  • Company Website
  • Contact information including 
    • Email Address
    • Phone Number
  • Other information relevant to your project that you enter into a contact form on this website

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Internal Record Keeping

  • If you have opted in, we may periodically send emails about new products, special offers or newsletters using the email address which you have provided. We will not send you any emails unless you have specifically opted-in to this communication. All emails of this type have an unsubscribe link if you choose to opt-out of receiving them.
  • We may use the information to customise the website according to your interests.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Third-Party Data

We use two third-party services, Google Analytics and Hotjar, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google or Hotjar to make, any attempt to find out the identities of those visiting our website.

We also use a Facebook ‘pixel’ to track and send website conversions to Facebook and to retarget website visitors for advertising purposes. We have no access to this data and does not allow us to personally identify anyone visiting our website.

Finally, we may also use Google AdWords collect visitor data in for the purpose of showing remarketing adverts.

You can find more information on how cookies are used on this website in the Cookies Policy below.

How we use cookies

A cookie is a small file which asks permission to be placed on your device’s internal storage. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

How long are cookies stored for?

Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie. 

Session cookies – these cookies allow us to link the actions of a user during a session. A session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily and once you close the browser, all session cookies are deleted.

More detailed information about cookies can be found at AboutCookies.org and AllAboutCookies.org.

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing us at the address below to or emailing us at chargeme@energise.energy
  • We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law.
  • We will not send you any marketing or promotional emails unless you have specifically opted-in to this method of communication.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to Energise Energy,  1A,Skypark, First Avenue, Finningley, Doncaster, DN9 3RH.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

INTRODUCTION

Energise Energy Solutions Ltd (“Energise Energy Solutions”) is committed to providing a service that is compliant, professional, efficient, and valued by its customers. A crucial element of this is meeting our obligations under the Consumer Duty and adhering to the Financial Conduct Authority’s (FCA) Principles for Businesses Principle 12 ‘firms must act to deliver good outcomes for retail customers’ and the associated cross-cutting rules and consumer outcomes.

This policy should be read in conjunction with other relevant documents such as the Vulnerable Customer Policy.

SCOPE

This policy and process applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees consultants, contractors, trainees, seconded staff, home employees, casual employees and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located, collectively referred to as employees in this policy.

POLICY STATEMENT

Energise Energy Solutions will ensure that it establishes and implements clear, effective and appropriate policies and procedures to ensure we understand our target market and our products and services are designed to meet our customer needs and are tested to ensure good customer outcomes are being achieved. We will consider our customers’ financial objectives in relation to our services and ensure our service is delivered in a way that enables our customers to pursue their financial objectives. We will act in good faith by ensuring our services are delivered in an open, honest, and transparent way. We will avoid causing foreseeable harm to our customers through our acts and omissions and by ensuring we review our services proactively and reactively.

To measure and improve our service we first need to understand what a good outcome looks like for us and what we mean by good value. A good outcome for us means successfully achieving our goals and objectives, creating a positive impact on our customers, progressing, and improving all aspects of our work and developing good relationships with our customer base.

Good value for us means supplying a service that meets or exceeds expectations at a reasonable price. It doesn’t necessarily mean the cheapest option but rather the best balance between quality and cost.

This policy sets out the approach we will take in achieving our policy statement objectives and the requirements under the Consumer Duty.

THE CROSS-CUTTING RULES

The cross-cutting rules flow throughout the conduct we expect to see in our strategies and interactions with customers and underpin the Consumer Duty. Through delivering high standards of conduct, we will ensure good customer outcomes are achieved. The cross-cutting rules are seen as a set of rules that outline the standard of conduct that we expect. Energise Energy Solutions recognises that a breach of any one of the rules is likely to lead to multiple cross-cutting rule breaches and we therefore appreciate the significance of their application.

ACTING IN GOOD FAITH

Energise Energy Solutions will act in good faith towards our customers by being open, honest, and transparent in the way we communicate and present information to our customers. By conducting ourselves in this way, we will also prevent foreseeable harm towards our customers.

Examples of how we will act in good faith:

  • We will ensure our letters are written in plain English and avoid jargon or technical terms.
  • We will be honest and open with customers during our interactions with them.
  • We will design our service to meet the needs of our customers and we will not exploit behaviour biases or lack of knowledge.

Examples of how we will avoid acting in bad faith:

  • We will not exploit behaviour biases of our customers through the design of our products and services or through our customer interactions.
  • We will not design our service in a way that is not fair value, and we will not hide or disguise our fees or charges.
  • We will not provide incomplete information or mislead the customer regarding the consequences of non-payment.

If we identify that we have acted in bad faith, we will provide an effective remedy that is appropriate in the circumstances.

AVOID CAUSING FORSEEABLE HARM

Energise Energy Solutions will avoid causing foreseeable harm through our acts and omissions by having a robust set of policies and procedures that outline the conduct we expect from our employees, and the conduct that is not acceptable.

We will proactively monitor the impact our products and services have on our customers, and we will regularly test that good customer outcomes are being achieved.

Examples of how we will avoid causing foreseeable harm:

  • We will ensure our processes are clear and easy for customers to navigate, and that we provide easy to access, useful information such as signposting for free debt advice. This will beadded to our website.
  • We will properly test our services in a range of scenarios to ensure that we understand the impact on our customers, and we will test our communications regularly to ensure customers understand the information we present to them.
  • We will be transparent about the charges that are levied and when there are increases or escalated charges and we will ensure the charges represent fair value.
  • We will ensure customers with characteristics of vulnerability are fully supported and can access our service.
  • We will design our services having regard to our customers’ behavioural biases and ensure foreseeable harm is avoided through the design.
  • We will consider relevant indicators of harm such as complaints root cause and trend analysis, Management Information and regulatory publications.

Where we identify actual or foreseeable harm, we will act to effectively remedy the harm and prevent future instances of harm occurring.

ENABLING AND SUPPORTING CUSTOMERS TO ACHIEVE THEIR FINANCIAL OBJECTIVES

Energise Energy Solutions will enable and support customers to achieve their financial objectives in relation to the products and service we offer. We will provide relevant information in a clear and transparent way to enable customers to make informed decisions and to support them in achieving their financial objectives.

Examples of how we will enable and support customers to achieve their financial objectives:

  • We will provide relevant information in a clear and transparent way to enable customers to make informed decisions and we will test our communications regularly.
  • We will signpost customers to relevant third-party organisations who can provide additional information and support.
  • We will not charge unreasonable fees that mean the services we provide are not fair value.
  • We will ensure our channels of communication are effective and do not create barriers for our customers when they want to interact with us.

THE CONSUMER OUTCOMES

Energise Energy Solutions will deliver services to customers in a way that is fit for purpose and achieves good customer outcomes. We will regularly monitor and test that good outcomes are being achieved.

OUTCOME: PRODUCTS AND SERVICES

As a Distributor, we will ensure that we obtain appropriate information from the manufacturer so we can understand the service we distribute. This information will include:

  • The characteristics of the loan
  • The identified target market
  • The needs, characteristics and objectives of customers with characteristics of vulnerability
  • The intended distribution strategy

We will not distribute services that we do not sufficiently understand.

TARGET MARKET

As a distributor, we will ensure that we understand the target market for our service we distribute and mitigate the risk of harm by ensuring the service is distributed as intended. 

APPROVAL PROCESS

We will design our service so it meets our customers’ needs, characteristics and objectives. We will ensure our service is distributed in a way that is appropriate for customers within our target market. We will conduct regular reviews and testing to ensure the service continues to meet our customers’ needs, characteristics and objectives.

Our approval process will ensure a documented assessment of our service is completed and approval is given and signed off by the board.

DISTRIBUTION STRATEGY

As a Distributor, Energise Energy Solutions will have distribution arrangements and a documented distribution strategy for the service we distribute that is aligned to the intended distribution strategy provided by the Manufacturer. We will ensure our distribution arrangements:

  • Avoid causing foreseeable harm, or mitigate the harm caused where harm cannot be avoided.
  • Manage conflicts of interests
  • Ensure the needs, characteristics and objectives of the target market are taken into account.

We will provide the manufacturer with information on any issues we identify with the distribution arrangements.

PRODUCT REVIEWS

As a distributor, Energise Energy Solutions will obtain copies of the product reviews completed by the manufacturer and will take appropriate steps to follow the distribution strategy as required, provide information as requested and meet regularly with the manufacturer to ensure distribution is in accordance with the strategy.

OUTCOME: PRICE AND VALUE

Energise Energy Solutions recognise that customers are subject to harm when the product or service on offer to them does not provide fair value. We will offer fair value by ensuring the services are reasonably priced for the benefits provided and by ensuring the features are suitable for our customers.

As a Distributor, Energise Energy Solutions will undertake value assessments at the design stage and before distributing new services to customers. We will consider the information provided by the manufacturer regarding fair value and the cumulative impact of any other firms within the distribution chain. Our fair value assessments will consider the impact of the charges we levy on the value of the services. We will review the value assessment on a regular basis.

When assessing the value of the service we distribute, we will consider the impact of

  • The nature of the service including the benefits and quality.
  • The limitations of the service
  • The anticipated total price customers will pay
  • Non-financial costs such as the time and effort needed to apply
  • The costs incurred to manufacture and distribute the service.
  • The market rates and charges for comparable services and any significant differences making the service an outlier.
  • Whether there are any products in the firm’s portfolio which are priced significantly lower for similar or better benefit.
  • Any accrued costs and benefits for existing or closed products.
  • Customer research and feedback.

If we find that our distribution arrangements for the service does not provide fair value or cease to provide fair value, we will take appropriate action to mitigate and prevent harm.

OUTCOME: CONSUMER UNDERSTANDING

Energise Energy Solutions will ensure our communications with customers are written in a way that is clear, fair and not misleading and are provided at an appropriate time within the customer journey to enable customers to make informed decisions.  Our communications will be suitable for our target market or the customers receiving them – in content, delivery and channel. Communications will be layered where appropriate to present pertinent information to customers.

The product review or product approval will be the catalyst for understanding the information needs of the target market. Following the product review / approval, communications will be designed with the identified needs in mind.

Testing will then occur as an important step to ensuring consumer understanding. Testing of communication will be by way of:

  1. Customer Feedback.
  2. Complaint log.
  3. Customer reviews on google/trust pilot and our website.

OUTCOME: CONSUMER SUPPORT

Energise Energy Solutions understands that an important element of good outcomes is excellent customer service and support. This is because customers may require support in order to make well informed decisions which contribute to their financial objectives and/or allows customers to avoid harms. The quality of customer service also impacts the value of the product or service.

Energise Energy Solutions recognises that poor support can hinder the customer’s ability to utilise all benefits of a product or service. In order to avoid poor outcomes, the following will occur:

  • Anticipated service needs of the target market will be identified as part of the Product Approval Process and Product Reviews.
  • The service needs will be built into the distribution strategy of the product.
  • Team members will be trained, as appropriate, on the characteristics of the target market, their likely service needs and how to meet those needs, including communication needs.
  • Outcomes monitoring will be used to identify instances where customers are not receiving good outcomes; root cause analysis will be undertaken to identify instances where this is caused by a lack of support.
  • The support provision will be tested through a range of quality assurance measures, including customer journey reviews, first line testing and audit.

Furthermore, good support and service is an example of Energise Energy Solutions

 acting in good faith, as a result we will never employ practices which prevent or discourage customers from seeking support, including sludge practices designed to limit contact. As a matter of good faith, and in order to support vulnerable customers, a range of contact methods will be available to customers and made equally prominent. Customer journey reviews and outcomes monitoring will be used to test adherence.

OUTCOME TESTING AND MANAGEMENT INFORMATION

Energise Energy Solutions will undertake regular testing of our service assess whether we are meeting the identified needs of our target market, including customers with characteristics of vulnerability. We will use qualitative testing and consider the likely needs of our target market in the future and whether our service will continue to meet their needs. We will also use quantitative data where relevant to assess the risk of harm to our target market.

When testing our service we will use a range of customer data that represents a broad group of customers from our target market.

DISTRIBUTION REVIEW

In order to monitor the effectiveness of the distribution strategy, Energise Energy Solutions  will consider the following key indicators:

  • Sales data and business persistency
  • Customer feedback
  • Complaint data
  • Analysis of whether the service has functioned as expected and if customers use the service as expected
  • Consumer focus groups where appropriate

Where issues are identified within the review that are causing actual harm or could cause foreseeable harm, action will be taken to mitigate the situation and prevent further harm from occurring. Information will be provided to distributors on the nature of any actions being taken.

TESTING COMMUNICATIONS

Communications are tested on an ongoing basis through outcomes monitoring. The following data sets are used to identify instances where communications are not meeting the needs of customers:

  • Business persistency, drop off / withdrawal where the root cause can be attributed to customers’ information needs not being met
  • Complaints root cause analysis
  • Customer feedback

QUALITY ASSURANCE

Energise Energy Solutions will review on a regular basis the following areas as part of its quality monitoring and assurance work:

PRICING AND FAIR VALUE REVIEW

Energise Energy Solutions will review the value assessments regularly during the service life cycle.

We will consider the following data when considering whether good customer outcomes are being achieved:

  • The expected price paid by customers.
  • Whether the price paid is fair; a comparison to similar products in the market will be used to guide this assessment as will the quality of service provided, transparency/understanding, and differential pricing.
  • Profitability data including revenue and profit margins.
  • Complaints, root cause and trend analysis.
  • Customer feedback, trust pilot scores
  • Transactional data and retention rates.
  • Feedback from firms within the distribution chain.
  • Costs of providing the product / service and market conditions.

THE CONSUMER DUTY CHAMPION

The designated Consumer Duty champion is Robert Hewitt and has been allocated the role as their independence and seniority in the business will enable them to complete their responsibilities, which are to:

Promote the firm’s intended culture throughout the business and leadership team.

Ensure compliance, audit and risk activities are conducted through a Consumer Duty lens.

 

  • Monitor compliance with the Duty.
  • Ensure sufficient and accurate MI is provided to enable the governing body to understand the outcomes provided to customers.
  • Challenge MI produced to ensure accuracy.
  • Challenge the governing body to continually produce better customer outcomes ensuring they provide adequate time at meetings to properly review and discuss information provided to them.
  • Oversee action plans to promote effective completion of actions.
  • Complete FCA reporting obligations.

Through the actions above the Consumer Duty Champion will help guarantee customer focused products and services.

 

GOVERNANCE & OVERSIGHT

A key element to implementing the Consumer Duty is the Governance framework of Energise Energy Solutions. The governance framework will:

  • Ensure a clear apportionment of responsibilities is set out between departments and management.
  • Ensure reporting lines are clear and ensure that conflicts of interest are avoided.
  • Set out the methods by which data and management information (MI) is cascaded throughout.

MI is also produced for the governing body. The aim of the MI is to enable the management of the firm to understand and assess the firm’s level of compliance with the Duty and the level to which customers are receiving good outcomes. This is produced monthly and includes:

  • Whether the firm is delivering good outcomes – high level summary using the other information on the dashboard to measure.
  • Evidence of poor outcomes – Using evidence gained from quality monitoring and customer journey reviews.
  • Evidence of different groups of customers getting different outcomes – Using evidence gained from quality monitoring and customer journey reviews.
  • Complaints and RCA.
  • Business persistence – analysis of customer retention records – e.g., claims and cancellation rates. This may flag where poor treatment is contributing to high customer turnover.
  • Distribution of products/pricing and fees and charges – review of whether certain groups of customers are more likely to buy certain products or appear to be receiving outcomes that are not as good as other groups of customers.
  • Behavioural insights – customer interactions and drop off rates; use of different communications channels including digital; consumer testing of user interfaces and design such as websites and apps, and the results of such testing, e.g., whether consumers changed their behaviour as a result of the design.
  • Training and Competency records – providing oversight of the level of training.
  • Customer Feedback – which indicates the outcomes for customers and groups of customers.

The governing body must review the information provided to it, challenge the data as necessary, understand the root cause of identified issues, identify areas where improvement is necessary and/or could be made, set actions to make such improvements and check the progress of previously set actions.

TRAINING & MONITORING

Robert and all staff members will be made aware of this policy at the beginning of and during employment. Employees will be informed during induction training and further ‘refresher’ training will be provided at least annually, or as relevant legislation or regulation changes. Updates to legislation and regulation will be monitored by Robert. Any new employees will be monitored on an ongoing basis to ensure they are adhering to this policy. Monitoring will be by the following methods:

  • Annual test
  • Call monitoring
  • Quality assurance of written communications
  • Customer journey reviews
  • Complaints received
  • Periodic audit
  • Management Information

Where an employee is found to be in breach of this policy, the company’s Disciplinary Policy will be followed.

REVIEW

This policy will be reviewed annually by Robert Hewitt and updated where appropriate. The review will ensure updates are made where any issues are highlighted, and additional updates will be made on an ad-hoc basis following relevant legislative and regulatory change.

However, the policy will be reviewed sooner in the event of any one or more of the following:

  • Weakness in the policy is highlighted.
  • Weaknesses in systems and controls are identified.
  • In case of new threat(s) or changed risks.
  • Changes in regulatory or legislative requirement

-Finance

Finance FAQ Text

How do I choose to PaybyFinance?

Just select the finance option on the checkout page.

Who is eligible to apply for online finance?

To apply for online finance, you must be over the age of 18, work at least 16 hours a week, or be retired with an income. You must also be a resident of the United Kingdom and have lived in the UK for the last 12 months or more.

Unfortunately, we are unable to offer online finance to residents of Eire. Homemakers aren’t excluded from applying under their own names; however the employment details of your spouse / partner will be required in order to process your application.

When do my repayments start?

Your monthly repayments will begin one month after your purchase has been delivered.

 

Are there any arrangement fees or hidden extras for credit?

No. There are no arrangement fees or hidden extras.

Applying for online finance

Applying for online finance couldn’t be easier or more convenient. When you buy online from Energise Energy Solutions Ltd trading as Energise Energy Solutions Ltd you have the choice of applying for finance by adding your purchase to the shopping basket, selecting the finance option, and completing an online application form. Just follow the simple instructions, entering your personal details as required and we’ll do the rest.

The whole process only takes a few minutes and is simple and secure. Once your finance application is approved, you will then be advised of how to sign the finance agreement and you will also receive an email confirming these details.

Please read the agreement carefully checking that all the details are correct, then either electronically sign the agreement or print and sign the agreement in both boxes. Post the signed agreement to the address shown on the covering letter of the agreement.

Following receipt of your finance agreement and a few additional checks, your goods will be dispatched.

 

How quickly will my finance application be approved?

 

All finance decisions will be made within 60 seconds. Once you are approved, we will contact you (during working hours Monday to Friday) to arrange delivery. If you your application is referred Novuna’s Underwriting Team will review your application and may request some further information from you before making their decision.

Once my application is approved, what happens next?

Within minutes of your application being approved, you will be presented with the options to either e-sign or print and return your finance agreement.

If you choose to e-sign your agreement, a PDF of your agreement will be displayed on screen. You should read the agreement carefully before clicking all the relevant sections agreeing to its terms.

Once you have agreed to the terms of the finance agreement Energise Energy Solutions Ltd trading as Energise Energy Solutions Ltd will be notified and you need do nothing more.

If you choose to print and return your agreement you should print the agreement, read it carefully and then sign the document following the instructions on the covering letter. This signed document should then be posted to the address shown on the covering letter of the finance agreement.

Note that products will not be allocated to your order until your completed and signed agreement is returned and received by Novuna Personal Finance. Shipment of your goods will follow soon after your agreement has been returned and received.

Will you credit score me and if so, what does this mean?

Credit scoring is the process used by financial services companies to evaluate the credit risk of new applicants. This technique will be applied to your application for online finance. Credit scoring works by awarding points for each answer given on the application form such as age, income and occupation, together with information obtained from credit reference agencies.

This information allows consistent decisions to be provided, ensuring all applicants are treated fairly. Credit scoring does not discriminate on the grounds of sex, race, religion or disability.

If you decline my application, what is the reason?

In addition to credit scoring, Novuna also takes into account confirmation of your identity, validation of certain application details, existing commitments and information held at the credit reference agencies. Though Novuna is unable to provide you with a main reason for declining your application, it is usually based on one, or a combination of the following:

  • Your credit score (please note that every finance company will score you differently)
  • Adverse credit reference agency information
  • You are considered to be overcommitted
  • You are aged under 18
  • Your existing account performance with other lenders

What type of information do credit reference agencies hold about me?

Some of the information is public information, for example electoral roll, County Court Judgments and bankruptcies. Other lenders may also file information about accounts you hold with them for instance this could include your payment history and outstanding balance on these accounts. Any requests for credit, where a credit reference search has been undertaken, will also be filed, although the result of the request is not recorded.

How do I obtain a copy of this information?

Send a request to the relevant credit reference agency, together with details of all addresses at which you have lived over the last 6 years:

  • Experian Limited, Customer Support Centre, PO Box 9000, Nottingham, NG80 7WF
  • Equifax Ltd., Customer Service Centre, PO Box 10036, Leicester, LE3 4FS
  • TransUnion International UK Limited, Consumer Services, PO Box 491, Leeds, LS3 1WZ

The above listed agencies will provide details of information relating to these addresses. If you believe that the information is incorrect, you can ask the agency to correct it.

If my application is not successful, can I re-apply?

Yes. We acknowledge that circumstances change and just because a previous application has been refused, it does not mean that a further request will automatically be turned down. We do suggest however, that you leave at least 6 months between applications.

Can I request delivery to an address other than my home?

In order to safeguard against fraudulent applications, we regret that we’re able only to deliver goods to the home address of the applicant. 

 

What is APR and Rate of Interest?

The ‘rate of interest’ is the cost you will pay each year to borrow the money, expressed as a percentage rate. It does not reflect fees or any other charges. The ‘APR’ is a broader measure of the cost of borrowing than the interest rate. The APR reflects the interest rate, and other charges that you pay to get the loan. The FCA description of any APR is “APR stands for the Annual Percentage Rate of charge. You can use it to compare different credit and loan offers. The APR takes into account not just the interest on the loan but also other charges you have to pay, for example, any arrangement fee. All lenders have to tell you what their APR is before you sign an agreement. It will vary from lender to lender

 

Complaints

If your complaint relates to your finance agreement

If your complaint relates to the finance linked to your purchase you can still let us know about this, but we will forward it on to your credit provider Novuna. Novuna will acknowledge your complaint and investigate it thoroughly and issue their response within eight weeks.

What to do if you can’t reach an agreement

 

If you are not satisfied with Novuna’s response to your complaint relating to the finance agreement, you may be able to refer the matter to the Financial Ombudsman Service. You must contact them within six months of the date of Novuna’s final response letter to you.

They can be contacted in the following ways:

· Write: Financial Ombudsman Service, Exchange Tower, London, E14 9SR · Telephone: 0300 123 9 123 · E-mail: complaint.info@financial-ombudsman.org.uk

 

Further details can be found on the Financial Ombudsman Service website: www.financial-ombudsman.org.uk

INTRODUCTION

Energise Energy Solutions Ltd (“Energise Energy Solutions”) is committed to preventing financial crime, including money laundering, fraud, bribery, and corruption. The purpose of this policy is to ensure that we comply with the obligations and requirements set out by UK legislation, regulations and rules regarding the prevention, identification and reporting of money laundering, bribery, fraud or terrorist financing. This includes ensuring that we have adequate systems and controls in place to mitigate against risks posed to the firm and its clients, including the strict verification and due diligence checks on customers, transactions and third parties with whom we do business.

Energise Energy Solutions Financial Crime Policy incorporates key points from the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Money Laundering Regulations 2022, and the Bribery Act 2010, including:

  • Detection and reporting of suspected money laundering, fraud, and bribery.
  • Employee vigilance and prompt reporting of suspicious activities.
  • Prohibition of accepting cash payments exceeding EUR10,000.

Failure to comply with the procedures defined within this policy may lead to disciplinary action.

POLICY SCOPE AND APPLICATION

The policy relates to all staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with our company in the UK or overseas) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.

Failure of any staff member to adhere to the guidance and objectives laid out in this policy, may lead to disciplinary action.

WHAT IS MONEY LAUNDERING?

Financial crime, as defined by the FCA and FSMA is any kind of criminal conduct relating to money or to financial services or markets, including any offence involving: –

(a) Fraud or dishonesty; or

(b) Misconduct in, or misuse of information relating to, a financial market; or

(c) Handling the proceeds of crime; or

(d) The financing of terrorism

We aim to identify, mitigate against and prevent financial crime within its business activities by implementing policies and procedures that identify, assess, monitor and manage money laundering risks and any other associated financial crime risks.

Money laundering is the term used to describe the process or act of disguising or hiding the original ownership of money that has been obtained through criminal acts such as terrorism, corruption or fraud. Such monies are then moved through legitimate businesses and sources to make it appear ‘clean’.

The UK has numerous Acts made by Parliament and regulations that govern money laundering and terrorist funding. These include: –

  • The Terrorism Act 2000 and Proceeds of Crime Act 2002
  • Serious Organised Crime & Police Act 2005
  • Anti-Terrorism, Crime & Security Act 2001
  • The Serious Crime Act 2007
  • The Money Laundering, Terrorist Financing and Transfer of Funds (Amended) Regulations 2022

WHAT IS BRIBERY AND CORRUPTION?

Bribery is offering, giving, receiving, or soliciting something of value to influence the actions of an individual in a position of trust. Corruption is the abuse of entrusted power for private gain and may include bribery. Examples of bribes include:

  • Gifts
  • Hospitality or entertainment
  • Money or cash equivalents
  • Kickbacks or unreasonable commissions
  • Invalid allowances or expenses
  • Unwarranted rebates
  • Charitable contributions

ANTI-MONEY LAUNDERING PROCEDURES

Energise Energy Solutions implements regular reviews to detect and report any suspicious activities. Employees receive comprehensive training to recognise and respond effectively to potential fraud and money laundering.

In accordance with The Money Laundering Regulations 2022, we will monitor and manage the following: –

  • Complex or unusually large transactions
  • Unusual patterns of transactions which have no apparent economic or visible lawful purpose.
  • Any other activity which the relevant person regards as particularly likely by its nature to be related to money laundering or terrorist financing.

We operate a Risk Based Approach with regards to preventing money laundering and terrorist financing and utilise risk assessments, measures, and controls to mitigate the risks.

Our risk-based approach involves: –

  • identifying the money laundering risks that are relevant to our business.
  • recording these risks on our risk register.
  • carrying out detailed risk assessments on the risk areas detailed below.
  • develop controls and procedures to directly manage and reduce the impact of the identified risks.
  • monitor the controls and improve their efficiency.
  • keep records of all risk assessments, reviews and improvement action plans.

 

  • When assessing the risks of money laundering and terrorist financing, we will consider: –
  • The types of customers we have.
  • Where those customers are based (i.e. FATF high-risk countries).
  • Transaction types and volumes.
  • Products and services offered.
  • Channels for individuals/companies to become customers.
  • Third-party reliance and/or use.
  • Customer Behaviour monitoring.
  • Delivery channels of products/services.
  • Payment processing (i.e. cash, transfers (electronic or wire) etc).
  • How funds are allocated, accepted and held.
  • Internal and external risks (i.e. customers, outsourcing, markets, systems etc).

In accordance with the HMRC requirements on preventing money laundering and financial crime, we will operate a risk-based system which is fully documented and ensure that ‘source of funds’ checks and additional verification is obtained on payments below €10,000 when:

  • the customer has presented cash in payment for the transaction, which is five times the size of an average transaction.
  • the customer has paid for the transaction by cheque or debit card, which is ten times the size of an average transaction.

ANTI-BRIBERY AND CORRUPTION MEASURES

We operate a zero-tolerance policy with regards to bribery and corruption, we have a structured Anti-Bribery & Corruption Policy in place with our intent and objectives in this area and realise the impact that bribery and corruption have on the money laundering prevention.

As bribery and corruption are often associated with organised crime and/or money laundering, we are committed to applying high standards of honesty and integrity throughout our organisation and ensure that all staff operate in accordance with the intent.

Energise Energy Solutions strictly prohibits offering, giving, soliciting, or accepting any bribe. Employees are trained to identify and report potential bribery and corruption. The policy includes the following principles:

  • Proportionality in actions taken to mitigate risks.
  • Top-level commitment from senior management to enforce anti-bribery measures.
  • Risk assessments for new business and business relationships.
  • Due diligence on staff, suppliers, and service providers.
  • Clear communication and training on anti-bribery measures.
  • Regular monitoring and review of anti-bribery procedures.

REPORTING PROCEDURES

We are responsible for monitoring all anti-money laundering measures and raising SAR’s when needed. We will be responsible for reporting SAR’s to NCA as soon as an incident or suspicion arises.

All documents relating to money laundering reporting, business transactions, client identification and customer due diligence are retained for a minimum of 5 years.

We will ensure that the below minimums are met with regards to the information disclosed on any reports: –

  • Full details of the people involved
  • Full details of the nature of their/your involvement
  • The types of money laundering activity involved
  • The dates of such activities
  • Whether the transactions have happened, are ongoing or are imminent
  • Where they took place
  • How they were undertaken
  • The approx and/or exact amount/s of money/assets involved;
  • What has given rise to the suspicion

 

Using all the information available at the time, we will make an informed decision using sound judgment as to whether there are reasonable grounds for knowledge or suspicion of money laundering and to enable them to prepare their report for the NCA where appropriate.

Any employee who suspects financial crime, including money laundering, fraud, or bribery, must report their suspicions promptly to senior management. Upon receipt, senior management will evaluate the report and, if necessary, report the matter to the National Crime Agency (NCA).

No further inquiries or steps in related transactions should be taken without authorisation from senior management. Employees must not disclose suspicions to others, as this may alert suspects and hinder investigations.

GUIDANCE AND TRAINING

We have implemented Anti-Money Laundering and Financial Crime training to ensure that all staff undergo AML knowledge and awareness training.

Our Financial Crime and AML training program ensure that all employees are: –

  • Confident and competent in the risk assessment and prevention of money laundering and financial crime.
  • Made aware of the law and associated regulations relating to money laundering and terrorist financing.
  • Provided with regular and relevant training in how to recognise and deal with transactions and other activities which may be related to money laundering or terrorist financing.
  • Given additional training and support where their role is directly relevant to the compliance with any requirement in the regulations, or
  • Capable of contributing to the: –
    • identification or mitigation of the risk of money laundering and terrorist financing
    • prevention or detection of money laundering and terrorist financing

GIFTS, ENTERTAINMENT, AND HOSPITALITY

Gifts and hospitality must comply with Energise Energy Solutions’s standard practices and should never be used to exert improper influence. Acceptable gifts and hospitality must:

  • Comply with local and national laws.
  • Not be given or received with an expectation of a return favour.
  • Not result in business or personal advantage.
  • Be of appropriate value and type.
  • Be given/accepted openly and fully documented.
  • Not exceed £250 in value.
  • Not involve people of influence, government officials, or political representatives.

FACILITATION PAYMENTS

Energise Energy Solutions does not accept facilitation payments to expedite routine tasks or services.

DUE DILIGENCE

Energise Energy Solutions understands that knowing exactly who we are in working relationships with (e.g., staff, suppliers, service providers) is crucial to mitigate against financial crime. We have a strict recruitment, selection, and induction program aimed at checking the background and references of all new and existing employees as well as ongoing criminal background checks (where applicable).

IDENTIFIED RISK AREAS

Bribery and corruption risks can occur in many areas of the firm. Key risk areas identified include:

  • Regulatory and Compliance Risks
  • Sales
  • Influence on Lender Selection
  • Bribes or Kickbacks
  • Supplier Selection
  • Influence on Terms
  • Failure to Disclose
  • Gifts and Entertainment
  • Insufficient Due Diligence
  • User Reviews and Testimonials
  • Lack of Training and Awareness

RAISING A CONCERN

Energise Energy Solutions takes seriously any attempt (or suspicion of an attempt) to accept monies, gifts, payments, kickbacks, or any form of incentive that contravenes this policy and the regulations set out under The Bribery Act 2010. All staff are provided with training on what constitutes a ‘bribe’ and what types of gifts and hospitality are acceptable.

Where an employee suspects that they or another member of staff have been approached with an intended ‘bribe’ or have accepted such ‘gifts/payments’ that contravene The Bribery Act 2010, they are to report this to the Director, who will follow the internal Whistleblowing Policy.

RESPONSIBILITIES

Robert Hewitt, Energise Energy Solutions’ SMF29 will be responsible for AML/Financial Crime oversight.

We will ensure that all staff are provided with the time, resources and support to learn, understand and implement processes and actions to prevent money laundering and will be expected to be vigilant at all times with respect to any acts of suspected financial crime. Any suspicions are to be reported to immediately.

We will ensure that any actual or suspected case of money laundering is detailed on a Suspicious Activity Report (SAR) and is reported to the National Crime Agency (NCA) with immediate effect and to complete the required ‘Standard Report Form’ which can be found here.

-Helping you

POLICY STATEMENT

 

Energise Energy Solutions Ltd (“Energise Energy Solutions”) complaint handling policy has been created to meet general standards and requirements. We take all concerns and issues seriously and use our robust and structured complaint processes to ensure a satisfactory resolution is reached.

 

The aim of this policy is to ensure that all customer complaints, either written or verbal, are handled in a consistent and regulated manner and that further complaint incidents are mitigated and where possible, prevented. Where a customer has cause to complain, the complaints handling procedure will be followed in every instance and a record will be made of the complaint nature and details to help improve our services and reduce the occurrence of similar complaints.

 

We follow specific codes of conduct. We have an obligation to provide our customers with complaint handling procedures. This policy and our associated customer complaint procedures are aligned with the rules and requirements set out by the FCA.

 

PURPOSE

 

We are committed to delivering a fair, open and clear process for complaints and ensure a satisfactory outcome for all customers who raise a complaint. We provide thorough staff training in our complaint handling procedures and support our staff in how to handle complaint situations in a face-to-face, written and telephone environment. 

 

This policy sets out our intent and objectives for how we handle complaints, from offering a clear and approachable system for customers to complain, through to conducting root cause analysis on all complaints received to identify the cause, issues, and corrective actions regarding the complaint, and to implement measures to prevent recurrences where applicable.

 

SCOPE

 

This policy applies to all staff within Energise Energy Solutions. Adherence to this policy is mandatory and non-compliance could lead to disciplinary action.

 

OBJECTIVES

 

Our objectives are set out below regarding customer complaint handling. For the purposes of this policy, a complaint is defined as any customer contact whereby a negative communication or outcome has occurred. The customer does not have to formally address their communication as an official complaint or to request a response for the company to treat the incident as a complaint and to follow the related procedures.

 

Our objectives for complaint handling are: –

 

  • To provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint.
  • To ensure that our complaints procedure is fully accessible so that people know how to contact us to make a complaint. We ensure the complaints procedure is available through our website.
  • To ensure everyone at Energise Energy Solutions knows what to do if a complaint is received.
  • To ensure all complaints are investigated fairly, and in a timely manner.
  • To gather information which helps us to improve what we do and how we do it.
  • To comply with any obligations for complaint handling rules as applicable to our industry.

 

Our objectives for our customer complaint procedures are: –

 

  • Complaints will be investigated and responded to within 8 weeks from the initial customer contact.
  • Customers will be sent a copy of our complaint procedures with the initial acknowledgement.
  • We will enclose any relevant information with the initial acknowledgement.
  • Complaint responses will always be provided in writing (unless the complainant makes a specific request for an alternate form of communication, which will be provided in addition to the written format).
  • Complaint procedures and forms will be available via our website as well as upon written and/or verbal request.
  • All complaints will be investigated by Robert Hewitt.
  • Complaint records will be used to gain valuable management information to revise company procedures and to improve communication and business practices where applicable.
  • Complainants are advised of their rights and provided with any relevant right to refer/lodge the complaint and the applicable contact details (e., FOS, FCA, the ICO)

 

RAISING A COMPLAINT

 

Customers can raise a complaint by any reasonable means, including in person, letter, email, social media, text, and verbally. Customers who request our complaint handling procedure will be provided a copy of the procedure and form either by email, in a PDF format or in the post. All complaints even where received, for example, as a text message, will be referred to the appropriate person for review and response.

 

If a customer contacts us and wishes to raise a complaint, they will be passed through to Robert Hewitt who will try to resolve the complaint then and there.

 

Even if the complaint is resolved at the time, the customer will be offered the option of receiving the complaints handling procedure and form prior to ending the call and the call recording will be retained and logged in the complaints record.

DATA PROTECTION RELATED COMPLAINTS

 

Where a complaint is related to the processing of personal data, this policy ensures that we comply with the data protection laws and notification requirements.

 

Every individual has the right to lodge a complaint with the supervisory authority where they consider that the processing of personal data relating to them infringes GDPR/DPA18 or we have breached data protection law. All individuals using our products or services and those employed by us are notified of this right via our Privacy Notice, in our complaint handling procedures, and in our information disclosures.

 

Robert Hewitt is responsible for informing the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy where the supervisory authority does not handle a complaint or does not inform the data subject within three months on the progress or outcome of the complaint lodged.

 

INFORMAL COMPLAINT – SUMMARY RESOLUTION

 

We consider and respond to all complaints and issues, no matter how they are raised or what they refer to. Some issues and complaints we can resolve immediately or within a 3-working day timeframe and are referred to as informal complaints.

 

Where Energise Energy Solutions deals with a complaint by the close of the third business day, it does not have to adhere to the following guidance detailed within the policy below. It does however need to undertake the following in the form of a ‘Summary Resolution Communication’ –

 

  • The fact that a complaint has been made.
  • Informs the complainant of the outcome – i.e., it is now resolved and
  • Sets out the complainants right to defer the complaint to the Financial Ombudsman Service including the contact details below.

 

A log of such complaints is to be made to record the number of such complaints versus that of a formal complaint.

 

In cases where complaints are not resolved within three business days, a written acknowledgement is sent to the customer within five business days.

 

Such instances are where an investigation is not required because the nature of the complaint is clear, and a resolution can be obtained without further review of the facts. Where we resolve a complaint within the timeframe, the details are still logged on our complaint log, and the complainant is still informed of their rights.

 

We take every opportunity to resolve complaints at the first initial point of contact where possible. Informal resolution is always attempted where the issues raised are straightforward and potentially easily resolved, requiring little or no investigation.

 

However, the complainant is always offered the option of making the complaint formal if the resolution is not to their satisfaction.

 

Frontline staff are trained to deal with basic issues and informal complaint resolution and are aware of their obligations and the subsequent reporting lines. Such employees are equipped to attempt to resolve a complaint relevant to their area of service or expertise, wherever possible.

 

TIMEFRAME FOR INFORMAL RESOLUTION

 

It is our aim resolve informal complaints immediately, or at least within the first 24-hours. Such complaints and issues will have a quick, but informative response and do not need to have an investigation or enter the formal complaint process.

 

No matter how small or informal the complaint, if a satisfactory resolution has not been achieved within 3 working days of the complaint being raised or identified, the issue will enter the formal complaint process.

 

FORMAL COMPLAINT RESOLUTION

 

We have specific procedures in place for the receipt of a formal complaint, regardless of the medium in which it was received. This includes the progression of an informal complaint that we were unable to resolve during the initial point of contact.

 

For acknowledgements made by post, the procedures are enclosed in a hard-copy letter format. Where the customer has requested to correspond via email, we provide the complaint procedures.

 

Robert Hewitt is the only staff member who responds to customers regarding their complaints. They have been provided with the time, resources, and training to communicate effectively with customers regarding concerns and formal complaints.

 

RESPONSE TIME FOR FORMAL RESPONSE

 

For all formal complaints, a written acknowledgement is sent to the customer within 3 working days. We provide approximate timelines and expectations for the investigation and future responses within the initial acknowledgement response.

 

All investigations take place within 6-weeks of the initial complaint being received. We aim to send our final response (decision letter) to the customer within our designated 8-week period. Where this is not possible, the customer will be updated using our 8-Week Holding Letter response to provide them with an update and reason(s) for the delay.

 

INVESTIGATING THE COMPLAINT

 

Robert Hewitt will be assigned the role of investigating complaints and will gather all necessary documents, recordings, and information to make an independent review of the incident.

 

If internal interviews are to be conducted, a note taker will be present alongside the investigator and interviewee and a copy of the interview notes will be written up and signed by the interviewer and interviewee prior to them being added to the complaint history.

 

All investigations must take place within 6-weeks of the initial complaint being received so that a final response (decision letter) can be sent to the customer within our designated 8-week period.  

 

Investigations must utilise all the facts and any previous, related information to produce an unbiased outcome and an expected course of action. A complaint reference should be assigned and all documents relevant to the complaint should have the reference written on them for continuity.

 

The reference will also be added to the Complaints log so that the complaint and document can be audited and traced back in the future.

 

All employees are provided with clear guidelines of when a complaint is formal and requires an appropriate investigation. Complaints must be referred to the Complaints Officer where:

 

  • The complainant has requested such a referral or investigation.
  • The complaint involves any type of personal data issue.
  • The informal complaint resolution stage failed or was inappropriate.
  • There is a conflict of interest between the complainant and an employee.
  • The issues are complex and require an investigation.
  • The complaint represents a high or serious risk to the company.
  • The facts are unclear, or the complaint will require additional time to resolve.
  • The complainant is identified as being vulnerable.
  • There has been any media contact or attention.
  • Child protection issues are involved.
  • The issues do or may affect more customers (whether identified or not)

 

DECISION LETTER (FINAL RESPONSE)

 

After the complaint has been investigated in full and an outcome decision has been reached, Robert Hewitt will draft a final response letter to the complainant with their findings and decision regarding any action(s) to be taken or compensation awarded.

 

The final response will be sent within 8 weeks of the initial complaint being raised and will also specify the complainants right to refer to or lodge the complaint with the appropriate body (where applicable) should the customer be unhappy with the final decision.

 

the final response will detail the Financial Ombudsman Service’s (“FOS”) telephone number and address and the financial ombudsman’s Services consumer leaflet will also accompany the final letter. The complainant will be provided with the options for taking the matter further and that they have only 6 months to log the complaint with the FoS.

 

For complaints related to personal data and/or breaches of the data protection laws and regulations, the final response will reiterate the complainants right to lodge a complaint with the supervisory authority (the Information Commissioners Office) and will detail the ICO’s telephone number and address, along with the possibility of seeking a judicial remedy.

 

COMPLAINT FORWARDING

 

If we have reasonable grounds to be satisfied that another party may be solely or jointly responsible for the matter detailed in the complaint, we will forward the complaint or the relevant part, in writing, to the other party. We will do so.

 

  • Promptly
  • informing the complainant promptly in a final response of why the complaint has been forwarded by it to the other respondent and of the other respondent’s contact details; and
  • where jointly responsible for the fault alleged in the complaint it complies with its own obligations under this chapter in respect of that part of the complaint it has not forwarded.

 

When a respondent receives a complaint that has been forwarded to it under DISP 1.7.1 R, this complaint is treated for the purposes of DISP as if made directly to that complaint and as if received by it when the forwarded complaint was received.

 

Complaints will be forwarded by email. On receiving a forwarded complaint, the standard time limits will apply from the date on which the respondent receives the forwarded complaint.

 

TIME BARRED COMPLAINT

 

The FOS cannot consider a complaint if the complainant refers it to the FOS more than six months after the date on which Energise Energy Solutions sent the complainant its final response, redress determination or summary resolution communication; or more than:

  1. six years after the event complained of; or (if later)
  2. three years from the date on which the complainant became aware (or ought reasonably to have become aware) that he had cause for complaint unless the complainant referred the complaint to Energise Energy Solutions or to the Ombudsman within that period and has a written acknowledgement or some other record of the complaint having been received.

Unless:

  • in the view of the Ombudsman, the failure to comply with the time limits in DISP 2.8.2 R or DISP 2.8.7 R was as a result of exceptional circumstances: or
  • the Ombudsman is required to do so by the Ombudsman Transitional Order; or
  • Energise Energy Solutions has consented to the Ombudsman considering the complaint where the time limits in DISP 2.8.2 R or DISP 2.8.7 R have expired.

 

Energise Energy Solutions will accept complaints from a customer for a period of 6 years following the event complained about, after which the right to complain will lapse. If a customer submits a complaint regarding the alleged acts or omissions of Energise Energy Solutions that occurred more than six years ago, Energise Energy Solutions will seek to sensitively ascertain from the customer whether there are exceptional circumstances, such as incapacitation or another form of vulnerability, that prevented the customer from filing the complaint within the six-year timeframe. Should Energise Energy Solutions identify that there are exceptional circumstances related to the timing of the complaint, it will accept and process the complaint in accordance with the policies and procedures outlined herein.

Furthermore, if Energise Energy Solutions chooses to reject the complaint, Energise Energy Solutions is obligated to clearly explain the reason for rejection to the complainant in a final response, adhering to the requirements set out in DISP 1.6.2 R or DISP 1.6.2AR. This explanation will include information on the time limit restrictions as per the FOS and provide guidance on the complainant’s rights and next steps.      

COMPLAINT RECORDING

 

All complaints, whether formal or informal, are recorded on a Customer Complaint Register. The register consists of the below information and is audited on a monthly basis to ensure that incidents are not being repeated and improvements are being made.

 

  • Date
  • Nature of Complaint
  • Department(s) Involved.
  • Complaint Reference
  • Lead Investigator
  • Decision Letter Sent (Y/N)
  • Date Complaint Closed

 

The register is made available to any relevant authority, ombudsman or body who relates to or oversees the firms’ complaints, as well as being made available with the local Trading Standards should a representative work alongside the organisation.

 

PATTERNS AND ANALYSIS

 

The complaint registers and forms are reviewed monthly by Robert Hewitt to identify any patterns or reoccurring issues. We are dedicated to improving our performance, services and functions through the auditing of our complaint records and our investigation process.

 

COMPLAINT ANALYSIS

 

We must identify and remedy any recurring or systemic problems and therefore minimise the risk of compliance failures, for example, by:

 

  • analysing the causes of individual complaints so as to identify root causes common to types of complaint.
  • considering whether such root causes may also affect other processes or products, including those not directly complained of.
  • correcting, where reasonable to do so, such root causes; and
  • feedback to staff on lessons learned from complaints, including assessing any training needs, so that we can improve our service to clients in the future.

 

Where we identify recurring problems, we will consider whether other customers may have suffered detriment from, or been potentially disadvantaged by, such problems but who have not complained. If so, we will take appropriate and proportionate measures to ensure that those customers are given appropriate redress or a proper opportunity to obtain it.

 

We will collate management information on the causes of complaints and the products and services complaints relate to, including information about complaints that are resolved by the firm by close of the third business day following receipt.

 

We will carry out regular internal monitoring of complaints, feedback from customers and/or lenders, and MI to ascertain if customers have suffered foreseeable harm as a result of our acts or omissions.

 

Should we find that we identify foreseeable harm we will immediately initiate a thorough investigation to understand the underlying causes and circumstances leading to such outcomes. This will involve a comprehensive review of the specific complaint or feedback, analysing the patterns in our MI, and identifying any systemic issues within our operations.

 

Upon identification of the root causes, we will take swift and appropriate corrective actions, which may include process enhancements, staff training, or even revisiting our partnerships with the lender.  

 

Additionally, we will engage in open communication with affected customers, reassuring them of our commitment to their satisfaction. Regular reviews and updates to our monitoring processes will be undertaken to ensure that such incidents are minimised in the future. 

 

TAKING ACCOUNT OF OMBUDSMAN DECISIONS

 

The FCA requires us to put in place procedures to ensure lessons learnt as a result of determinations by the FOS are effectively applied when investigating complaints. To ensure we take appropriate account of decisions and guidance produced by the FOS, the FCA we operate the following management processes:

 

  • FOS decisions are fed back to individual complaint handlers and used in their training and development.
  • FOS decisions are analysed and communicated to relevant staff; and
  • Guidance produced by the FOS, the FCA and other relevant regulators is analysed and communicated to relevant staff.

 

PUBLISHED COMPLAINT PROCEDURES

 

We have a user-friendly version of our complaint procedures that are made available to customers. This provides them with easy to access and understand guidance on how to raise a complaint and the process and timeframes for resolution. The customer complaint procedures are published on our website at www.energise.energy.

 

We also provide a hard-copy complaint procedure letter and a PDF digital version for responses by post and email.

 

RESPONSIBILITIES

 

We will ensure that all staff are provided with the time, resources, and support to learn, understand and deal with customer complaints and that full training will be provided for new and existing employees on the complaint handling policy, procedures and expectations.

 

Robert Hewitt will be appointed the role of overseeing, investigating and recording all customer complaints and is responsible for regular monitoring of the complaint register to ensure mitigating actions and improvements are put into place where required.

 

COMPLAINT REPORTING

 

As a smaller consumer credit firm, Robert Hewitt will report our complaints data annually through the Regdata system. 

 

RECORD-KEEPING

 

We are required to keep a record of each complaint received and the measures taken for its resolution and retain that record at least 3 years from the date that the complaint was received.

 

REPORTING TO THE FCA

 

Every 12 months we are required to submit a report to the FCA regarding all complaints received from eligible complainants, including those complaints resolved informally by the close of the third business day. Our reporting periods are aligned to our financial year-end must be submitted to the FCA within 30 business days of these dates.

 

SENIOR MANAGEMENT OVERSIGHT OF COMPLAINT HANDLING

 

To ensure complaint handling is given appropriate priority, Robert Hewitt has responsibility for oversight of the firm’s compliance with the FCA’s complaint rules. While we are not required to notify the FCA or the FOS of the name of the individual, we must ensure that an appropriate individual is appointed and in place at all times so that, if requested, we can comply promptly with any request. In addition, we are required to provide the FCA with details of a single contact point for complaints. This is done at the time of authorisation and is made public on the FCA Register. Should these details change, we must update the FCA’s records.

 

COMPLAINT HANDLING LETTER SUITE

 

  • Informal Acknowledgment & Final Response (where response is within 3 days of complaint receipt and has followed the informal process, being quickly/easily resolved)
  • Complaint Acknowledgement
  • 4-Week Holding Letter
  • 8-Week Holding Letter
  • Final Response – Complaint Upheld
  • Final Response – Complaint Rejected

 

INFORMAL ACKNOWLEDMENT & SUMMARY

 

[Enter Date]

[Enter Complaint Reference]

Dear [Enter Name]

 

Thank you for your [visit/phone call/letter/email] received on [date]. As discussed with you after receipt of the initial complaint, I was sorry to learn that [insert complaint issue] and that you had cause to raise your concerns with us.

 

As you are aware, I was able to review your complaint immediately and concluded that your concern(s) were valid and have now been addressed. Because of the complaint, we agreed to [insert the actions taken/response given to the complainant]. This outcome was agreed to be in final resolution to your concerns and you have confirmed that the complaint can now be closed.

 

Please note that, under the terms of our Complaints Procedure and with your agreement, this is our final response, and we now consider the complaint to be closed. However, if you are dissatisfied with the agreed outcome or this decision, you have the right to ask us to reopen the complaint and complete a formal investigation. Please find enclosed a copy of our internal Complaints Procedure for your information. Please take the time to read this as it explains what your rights are.

 

If you are still dissatisfied with the outcome, you may refer your complaint to the Financial Ombudsman Service. You need to do this within six months from the date of this letter.

 

Write – Financial Ombudsman Service, Exchange Tower, London, E14 9SR.

Telephone – 0300 123 9 123 or 0800 023 4567

 

E-mail: complaint.info@financial-ombudsman.org.uk

 

Please do not hesitate to contact me in the meantime using the contact details below.

Yours sincerely,

 

[Enter Name Complaint Officer/Person handling complaint]

[Enter Job title of person handling the complaint]

[Enter direct contact methods (i.e., direct dial, direct email, extension etc)]

 

Enc: [enclose any ombudsman leaflets or required material if applicable]

 

Yours sincerely,

[Enter Name Complaint Officer/Person handling complaint]

[Enter Job title of person handling the complaint]

[Enter direct contact methods (i.e., direct dial, direct email, extension etc)]

 

Enc: [Name of company] Complaints Procedure leaflet

 

WRITTEN COMPLAINT ACKNOWLEDMENT LETTER

 

[Enter Date]

[Enter Complaint Reference]

 

Dear [Enter Name]

 

Thank you for your [letter/email] received in our office on [date].

 

I am most sorry to learn that [insert complaint issue] and can confirm that we take this matter most seriously and will be conducting a thorough investigation into your concerns. Once we have completed this, we will write to you again.

 

Please find enclosed a copy of our internal Complaints Procedure for your information. Please take the time to read this as it explains how we will deal with your complaint and when we will contact you again.

 

In the interim if you have any queries, please do not hesitate to contact me.

 

Yours sincerely,

 

[Enter Name Complaint Officer/Person handling complaint]

[Enter Job title of person handling the complaint]

[Enter direct contact methods (i.e., direct dial, direct email, extension etc)]

 

Enc: [Name of company] Complaints Procedure leaflet

 

4-WEEK HOLDING LETTER

 

[Enter Date]

[Enter Complaint Reference]

 

Dear [Enter Name]

 

Further to my letter dated [insert date of latest correspondence], I am still investigating the details of your complaint and wanted to keep you informed of our progress and continued efforts in this matter. The investigation is still ongoing due to [insert reason for delay/prolonged investigation].

 

I apologise for the delay and thank you for your patience. I will write to you again as soon as our investigation into your complaint has been finalised, and at the latest, within eight weeks of the date from which we received your complaint.

 

If you need to contact me in the meantime, please do not hesitate to do so. My contact details are below.

 

Yours sincerely,

 

[Enter Name Complaint Officer/Person handling complaint]

[Enter Job title of person handling the complaint]

[Enter direct contact methods (i.e., direct dial, direct email, extension etc)]

 

8-WEEK HOLDING LETTER

 

[Enter Date]

[Enter Complaint Reference]

 

Dear [Enter Name]

 

Further to my letter dated [date of latest correspondence], I am sorry that I have still been unable to write to you with the results of my investigation.

 

This is due to [insert reason for the delay/prolonged investigation]. I apologise for the delay and hope to be able to respond to you within [insert expected response time]. Thank you for your continued patience.

 

If you are dissatisfied with the progress of the investigation into your complaint, you may refer your complaint to the Financial Ombudsman Service.

 

Write – Financial Ombudsman Service, Exchange Tower, London, E14 9SR.

Telephone – 0300 123 9 123 or 0800 023 4567

 

E-mail: complaint.info@financial-ombudsman.org.uk

 

Please do not hesitate to contact me in the meantime using the contact details below.

Yours sincerely,

 

[Enter Name Complaint Officer/Person handling complaint]

[Enter Job title of person handling the complaint]

[Enter direct contact methods (i.e., direct dial, direct email, extension etc)]

 

Enc: [enclose any ombudsman leaflets or required material if applicable]

 

FINAL RESPONSE LETTER – COMPLAINT UPHELD

 

[Enter Date]

[Enter Complaint Reference]

 

Dear [Enter Name]

 

Further to my letter dated [insert date of latest correspondence], I have now investigated your complaint fully and would like to apologise for [short summary of mistake/poor service/issue], and for any inconvenience/distress this has caused you.

 

As a result of our investigation, we have concluded that [enter your final response/investigation outcome and actions taken]. As we have upheld your complaint, we will [insert what compensation/actions are to be taken/offered].

 

Please note that, under terms of our Complaints Procedure, this is our final response.

 

If you are dissatisfied with it, you may refer your complaint to the Financial Ombudsman Service You need to do this within six months from the date of this letter.

 

Write – Financial Ombudsman Service, Exchange Tower, London, E14 9SR.

Telephone – 0300 123 9 123 or 0800 023 4567

 

E-mail: complaint.info@financial-ombudsman.org.uk

 

 

Once again, we are sorry for the inconvenience we caused you and hope you will find that the points above offer an appropriate explanation and fair resolution.

 

Yours sincerely,

 

[Enter Name Complaint Officer/Person handling complaint]

[Enter Job title of person handling the complaint]

[Enter direct contact methods (i.e., direct dial, direct email, extension etc)]

Enc: [enclose any ombudsman leaflets or required material if applicable]

 

 

FINAL RESPONSE – COMPLAINT REJECTED

 

[Enter Date]

[Enter Complaint Reference]

 

Dear [Enter Name]

 

Further to my letter dated [insert date of latest correspondence], I have now investigated your complaint fully. While I understand the [inconvenience/distress] that this has caused you, I regret that I am unable to [summary of customer’s request/demand].  The reason for this is [give full detail/results in investigation/final response].

 

Please note that, under terms of our Complaints Procedure, this is our final response.

 

If you are still dissatisfied with it, you may refer your complaint to the Financial Ombudsman Service. You need to do this within six months from the date of this letter.

 

Write – Financial Ombudsman Service, Exchange Tower, London, E14 9SR.

Telephone – 0300 123 9 123 or 0800 023 4567

 

E-mail: complaint.info@financial-ombudsman.org.uk

 

I acknowledge the [inconvenience/difficulties/distress] this situation has caused you, but considering my comments above, I am sorry that we are unable to [offer the response you were looking for/take this matter further].

 

Yours sincerely,

 

[Enter Name Complaint Officer/Person handling complaint]

[Enter Job title of person handling the complaint]

[Enter direct contact methods (i.e., direct dial, direct email, extension etc)]

 

Enc: [enclose any ombudsman leaflets or required material if applicable]

 

COMPLAINTS PROCEDURE FOR WEBSITE

 

Energise Energy Solutions strives to meet our customers’ expectations in every aspect of our business. However, we understand that sometimes things go wrong. We take all concerns and complaints seriously and will work with you to resolve any issues that you raise with us. We encourage feedback from our customers and welcome the opportunity to put things right where you are not satisfied.

 

Our complaints procedure allows us to investigate your concerns and for you to provide additional information so that we can address the problem as quickly and effectively as possible. Our adherence to a structured complaints process enables us to improve our service and ensures that our customers can communicate with us effectively.

 

WHO TO COMPLAIN TO?

 

To raise a complaint with us email us at rob.hewitt@energise.energy. Alternatively, if you would prefer to make your complaint in writing, please contact us at: –

 

Robert Hewitt

Energise Energy Solutions

1st Floor, Premier House

Carolina Court

Doncaster

DN4 5RA

 

THE COMPLAINTS PROCESS

 

We take every opportunity to resolve complaints at the first initial point of contact. Immediate resolution is always attempted where possible and where little, or no investigation is required. We aim to resolve most face to face and telephone issues in this manner.

 

Our frontline employees are trained to deal with your issues and are equipped to resolve your complaint as it relates to their area of service or expertise. However, should you feel that your concerns remain unresolved, you will be offered the option of making a formal complaint.

 

Our complaint handling process is simple and easy to use. Once you have lodged a formal complaint with us, we will: –

 

  • Assign your complaint to Robert Hewitt who will record your complaint on our CRM system.
  • Assign your complaint a unique reference number and provide you with a written acknowledgement.
  • Assess your complaint and investigate the matter fully.
  • Where applicable, refer your complaint for further investigation with an expert on subject matter and issues raised.
  • Where applicable, contact you to request clarification or additional information.
  • Provide you with a final written response containing details of our investigation, the findings and any actions taken as a direct result of your complaint.
  • Provide you with details of who you can contact should you be unhappy with our final decision.

 

WHAT YOU CAN EXPECT

 

When you submit a formal complaint to us, we follow our formal complaints procedure to ensure that all issues and concerns are addressed quickly and effectively. When you lodge a complaint with us, you can expect: –

 

  • To have your complaint resolved in a timely, effective, and fair manner.
  • An experienced and trained officer to deal with your complaint.
  • A written acknowledgment within 3 working days of your formal complaint being received.
  • All responses to be made (or followed up) in writing.
  • Your complaint to be fully investigated in an independent and compliant manner.
  • To receive our findings and final decision within 8-weeks of the initial complaint being received.
  • To be provided with the details of our investigation and our findings regarding the issues you have raised. This includes being provided with the measures and actions we have taken as a direct result of your complaint.
  • To be kept updated on our progress if we are unable to provide a satisfactory response within our target response times.
  • To be provided with details of any relevant ombudsman should you not be happy with our final decision.

 

TARGET RESPONSE TIMES

 

We always aim to respond to your complaint as quickly as possible. As soon as a formal complaint has been received, we will send you a written acknowledgement (or email where requested), within 3-working days.

 

Below are our approximate timelines and expectations for investigation, responses and final resolution. However, each complaint is different and there may be times when we, or you, need additional time to ensure a satisfactory response.

 

All investigations take place within 6-weeks of the initial complaint being received. We aim to send our final response (decision letter) to you within 8-weeks. Where this is not possible, you will be provided with an interim update letter. This will provide information on how long we expect the investigation to take and any reason(s) for the delay.

 

NOT SATISFIED WITH THE OUTCOME?

 

If you are dissatisfied with the progress of the investigation into your complaint or our final decision, you may refer your complaint to the Financial Ombudsman Service 

 

They can be contacted in the following ways:

 

Write – Financial Ombudsman Service, Exchange Tower, London, E14 9SR.

Telephone – 0300 123 9 123 or 0800 023 4567

 

E-mail: complaint.info@financial-ombudsman.org.uk

 

GDPR & DATA PROTECTION RELATED COMPLAINTS

 

If your complaint concerns the processing of your personal data and you remain dissatisfied with our actions, you have the right to lodge a complaint with the Commissioner. The Information Commissioner’s Office (ICO) can be contacted at: –

 

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

Fax: 01625 524 510

Email: enquiries@ico.org.uk

POLICY STATEMENT

 

Energise Energy Solutions Ltd (“Energise Energy Solutions”) is committed to identifying, assessing, and managing vulnerable customers in accordance with our own defined objectives and policy, as well as any regulations and guidelines set out by our regulators.  We aim to treat all customers, who we define as being vulnerable, in a fair, clear, and respectful manner.

 

We have implemented several identification and assessment tools within the procedure section of this document, aimed to identify, assess, and deal with all Vulnerable Customer situations and to consistently ensure that our staff are aware of and knowledgeable about Vulnerable Customers, including how to handle certain situations. Our policy content states our intent and obligations with regards to handling customers with vulnerabilities and includes external guidance in our procedures and information as provided by the Money Advice Liaison Group (MALG). 

 

PURPOSE

 

The purpose of this policy and procedure document is to identify and support vulnerable customers and to promote transparency and openness in all the business practices and processes that our staff create and engage in. It also defines the steps to be taken by all staff when dealing with a Vulnerable Customer situation. 

 

Energise Energy Solutions are committed to ensuring that all customers are treated in a fair and consistent manner, but also understand that some circumstances require additional interactions and/or steps to ensure that the customer is getting a product and service that is suitable and ethical.

 

SCOPE

 

This policy and procedure document relates to everyone within the organisation and has been created to ensure that we deal with customers in accordance with legal, regulatory, contractual, and business expectations and requirements. 

 

DEFINITION

 

The 2 main definitions of vulnerable customers are:

 

  1. Customers who are unable, for whatever reason, to make an informed decision at the time of dealing with them – customers falling into this category include those with language barriers, hearing difficulties, those with mental health issues, suffering from bereavement, learning difficulties or the elderly. These customers may struggle to decide on whether the service or product we are providing is in their best interests.

 

  1. Customers whose welfare (financial, mental or physical) could be put at risk through choosing the service or product we offer – these customers include anyone who is going to be put at detriment from taking up the offer. This could be financially if taking out a loan or setting up a payment plan causes them to add financial stresses.

 

The FCA defines a Vulnerable Customer as: –

 

“Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

 

The FCA notes four factors that can act as drivers to actual or potential vulnerability. These factors (and the examples provided) are non-exhaustive, but are referenced in this policy as part of our approach to vulnerable customer awareness and communication: –

 

  • Health – examples can include physical disability, chronic illness, visual/auditory impairments, mental health issues, impaired mental capacity.
  • Life Events – examples can include caring responsibilities, bereavement, income/job reduction/loss, relationship issues, non-standard requirements (i.e., ex-offenders, refugees)
  • Resilience – examples can include low/fluctuating income, debt, low/no savings, lack of support.
  • Capability – examples can include low knowledge/understanding/confidence in managing financial matters, poor literacy/numeracy skills, language barriers, learning impairments.

 

In February 2021, the FCA published further guidance for treating vulnerable customers fairly in their FG21/1 Guidance for Firms on the Fair Treatment of Vulnerable Customers. The regulator noted that protecting vulnerable customers was still one of their key focus areas and the additional guidance aimed to ensure that firms are treating vulnerable customers fairly. Through driving improvements in the way firms treat vulnerable consumers, the FCA wants to bring about a practical shift in the actions and behaviour of regulated firms.

 

The FCA advised that because anyone can find themselves in vulnerable circumstances at any time, their guidance and rules apply to most firms who should be focusing on four main areas to achieve good outcomes for vulnerable customers: –

 

  • Understanding the needs of the target market and/or customer base.
  • Making sure staff have the right skills and capability to recognise and respond to the needs of vulnerable customers.
  • Responding to customer needs throughout the service
  • Monitoring and assessing whether they are meeting and responding to the needs of customers with characteristics of vulnerability and making improvements where this is not happening.

 

THE CONSUMER DUTY

 

Vulnerable Customer awareness goes hand in hand with treating customers fairly and ensuring adequate consumer protections. In accordance with the Consumer Duty, Energise Energy Solutions has carried out an assessment of the nature and scale of characteristics of vulnerability that exist in our sector and within the target market we operate in.

 

Complying with the Consumer Duty requirements mean us going above and beyond considering generic customer vulnerabilities that are person or situation specific and reviewing and monitoring vulnerabilities and characteristics that apply because of our target market. We have developed policies, controls and tools to comply with the Consumer Duty and specifically the requirements contained in PRIN 2A.

 

Customer interests are considered from product/service design through to after-sales care and everywhere in between.

 

Energise Energy Solutions with the guidance for firms on the fair treatment of vulnerable consumers and aims to improve outcomes for customers in vulnerable circumstances. We are committed to ensuring that good outcomes are attainable for all customers, regardless of circumstance, situation or vulnerabilities.

 

THE EQUALITY ACT 2010

 

In its aim to ensure adequate and fair customer protections, the Consumer Duty requires that the needs of customers in vulnerable circumstances and customers with protected characteristics under the Equality Act 2010 are considered. This includes developing and implementing policies, controls and tools that meet the needs of customers with protected characteristics, as defined by The Equality Act 2010.

 

Energise Energy Solutions is aware that certain groups of customers may have, or be more likely to have, characteristics of vulnerability. These groups can often share a protected characteristic which could result in vulnerable circumstances. We continuously monitor the outcomes of all customers and review the associated management information on a regular basis.

 

Where there is a pattern or any evidence that customers that share a protected characteristic are more susceptible to experiencing harm from our products or services, we carry out an assessment and ensure that we are complying with both the Equality Act 2010 and the Consumer Duty.

 

OBJECTIVES

 

We aim to: –

 

  • Ensure that we have the suitable, relevant and compliant tools, controls and measures in place to identify, handle and monitor vulnerable customers.
  • Have structured induction training workshops and support tools to explain and guide in the vulnerable customer requirements.
  • Train all staff on a rolling basis in the identification, communication and understanding of what vulnerabilities are and how to approach them.
  • Have robust vulnerable customer procedures in place at all times and ensure their continued relevance and compliance with the regulations and guidelines.
  • Use ongoing assessment tests and evaluations for all staff to ensure understanding and knowledge of vulnerabilities.
  • Ensure that all materials, content and information are user-friendly, easy to understand and jargon free.
  • Ensure that all systems and automated processes are regularly audited for compliance.

 

VULNERABILITIES SPECIFIC TO TARGET MARKET

 

Energise Energy Solutions’ target market is typically male and females, aged 40-60, middle- and high-income earners, nationwide.

 

Energise Energy Solutions have identified the following potential characteristics of vulnerability in the target market.

 

Health

 

  • High Stress Levels – Senior-level professionals often face significant responsibilities, decision-making pressures, and the need to meet performance targets. These factors can contribute to high stress levels, potentially leading to physical and mental health issues.
  • Heath-related challenges – aged individuals may face health challenges that limit their ability to earn income or manage their finances. Medical expenses can strain their financial resources, leading to difficulties in repaying credit.
  • Mental health – older individuals may face mental health challenges such as depression, anxiety, and cognitive decline. Social isolation, retirement, and loss of loved ones can contribute to these issues.

 

Life Events

 

  • Job Insecurity – In today’s rapidly changing work environment, even individuals in higher positions can face job insecurity due to factors such as company restructuring, mergers and acquisitions, or technological advancements. This uncertainty can lead to stress and anxiety.
  • Limited Time and Information – Middle-income customers often lead busy lives, balancing work, family, and other responsibilities. This can result in limited time to research and compare products, services, or financial options. This vulnerability can lead to uninformed decisions, potentially exposing them to suboptimal choices or financial risks.
  • Isolation – Social isolation can be a concern for the elderly, which might limit their access to financial advice and support networks. This isolation can prevent them from seeking help when facing financial difficulties.

 

  • Caregiving responsibilities – In some cases, retired individuals may find themselves responsible for caring for aging spouses, family members, or grandchildren. Balancing caregiving duties with personal needs can be physically and emotionally demanding.

 

Resilience

 

  • Technological Disruption – The rapid advancement of technology can pose challenges for professionals in terms of keeping up with new tools, processes, and industry trends. Failure to adapt and upskill can make individuals vulnerable to job displacement or reduced employability.
  • Housing Affordability – There are some areas nationwide with high cost of living and housing prices. Middle-income earners in these areas might struggle to find affordable housing, leading to potential financial strain or inadequate living conditions.
  • Debt and Financial Strain – Middle-income customers may be vulnerable to debt accumulation and financial strain due to various factors such as mortgages, car loans, student loans, or credit card debt. Unexpected financial emergencies or job loss can exacerbate these vulnerabilities.
  • Retirement Planning Challenges – These individuals may face challenges in adequately planning for retirement due to competing financial priorities, limited access to employer-sponsored retirement plans, or inadequate knowledge about retirement savings options. This vulnerability can impact their long-term financial security.

 

  • Phishing and Scams – Older adults may be targeted by phishing emails, fake websites, or phone scams that aim to steal personal information or financial details. They may be less familiar with the latest scam techniques and more likely to fall victim.

 

  • Identity Theft – Older adults may be at risk of identity theft if they unknowingly provide personal information to malicious individuals or fall victim to scams. This can result in financial losses and damage to their credit.

 

Capability

  • Targeted Marketing and Sales Tactics – Middle-income customers may be targeted by aggressive marketing and sales tactics that exploit their desire for upward mobility or the perception of affordability. They may face pressure to make purchases or sign up for financial products that may not be suitable for their needs or financial situation.
  • Aging-Related Vulnerabilities – As individuals age, their physical and cognitive capabilities may decline, making them more susceptible to accidents, health issues, or fraudulent activities. Retired males may face challenges in managing day-to-day tasks, making sound decisions, or identifying potential threats.

 

  • Online Security – With the increasing use of technology, retired males might face cybersecurity vulnerabilities. They may be unfamiliar with online security practices, making them targets for phishing attempts, identity theft, or malware attacks. It’s crucial to educate them about internet safety and help them establish secure online practices.

 

CONTROLS AND MEASURES – VULNERABLE AWARENESS REVIEW

 

Energise Energy Solutions has identified and reviewed multiple factors that may pose harm or act as a barrier for vulnerable customers using our services and have developed measures and controls to reduce or eliminate the impact of these.

 

We have assessed the impact of vulnerability on the needs of our customers by reviewing our target market and existing customer base to identify the types of harm or disadvantage that are relevant to our industry and business activities.

 

We have reviewed and incorporated the FCA guidance on dealing with vulnerable customers and have used their accurate understanding of the drivers of vulnerability and the impact that being vulnerable can have on a person’s ability to engage in consumer credit.

 

We recognise that vulnerable customers are more likely to experience certain barriers or issues because of their vulnerability and we continuously work hard to ensure that our products, services and advice are flexible, accessible and inclusive.

 

In accordance with the FCA guidance, we understand that the below potential harms can be a factor for many vulnerable customers, and we pay specific attention to these areas when dealing with any customer who has been identified as vulnerable or potentially vulnerable.

 

AWARENESS & TRAINING

 

We recognise that we are often the first contact a vulnerable customer will have and their understanding and ability to handle such situations is essential to achieving good outcomes.

 

We also recognise that a consumer may find it difficult to make an informed decision about their available options for a variety of reasons. The risk factors that contribute to consumer vulnerability in financial services include:

 

  • low literacy, numeracy and financial capability skills
  • physical disability
  • severe or long-term illness
  • mental health problems including common mental disorders (CMD)
  • low income and/or debt
  • caring responsibilities (including operating a power of attorney)
  • being ‘older old’ for example over 80, although this is not absolute (may be associated with cognitive or dexterity impairment, sensory impairments such as hearing or sight, onset of ill- health, not being comfortable with new technology)
  • being young (associated with less experience)
  • change in circumstances (e.g., job loss, bereavement, divorce)
  • lack of English language skills
  • non-standard requirements or credit history (e.g., armed forces personnel returning from abroad, ex-offenders; care-home leavers, recent immigrants).

 

Living with a disability, illness or diagnosis does not in itself make someone vulnerable. In the context of financial services, it is the person’s situation and barriers to accessing such services that may make them vulnerable. Equally a person may be vulnerable without any disability, illness or diagnosis, for example if they are recently bereaved or frail.

 

Based on the above factors, we have been able to consider the impact to customers and possible effects and outcomes of these potential harms. This has enabled us to consider the needs of vulnerable customers and to develop effective controls, products and services aimed at making our company approachable, inclusive and accessible.

 

TRAINING

 

We ensure that all current staff are provided with the training and tools to identify, understand, and deal with vulnerabilities and vulnerable customers.

 

Our training programme is provided to all new and temporary staff reminding and updating them on the requirements, guidelines and company ethos of managing Vulnerable Customers.

 

We recognise that informing, training, and assessing front line staff and those with dedicated vulnerable customer roles is essential in removing barriers and reducing potential harm. We work hard to ensure that our staff have adequate and effective skills and knowledge to help vulnerable customers and to ensure that the right and relevant product, service, or advice is provided every time.

 

Training is provided through eLearning assessment. Training involves the identification of vulnerable customers as above and correct procedure as outlined below.

 

PROCEDURE

 

Signs we look out for when identifying vulnerability in customers:

 

  • Do they ask you to speak up or speak more slowly?
  • Do they understand what you are saying, or do they miss important bits?
  • Do they appear confused about what is being offered?
  • Do they ask any unrelated questions?
  • Do they keep wandering off the point in the discussion and talk about irrelevant things or things that don’t make sense?
  • Do they keep repeating themselves?
  • Do they take a long time to answer questions or say that someone else deals with these things for them?
  • Do they have a language barrier?
  • Do they say they don’t understand their bank statements, a previous phone conversation or recent written correspondence?

 

Where a customer has been identified and/or declared as being vulnerable, Energise Energy Solutions follows the steps below.

 

  • We speak slowly, clearly and explain fully.
  • We are patient and empathise where appropriate.
  • We don’t rush as it may sometimes take the customer time to get relevant information together such as account details.
  • We keep on the subject under discussion.
  • We do not make assumptions about a customer’s needs.
  • We clarify understanding at every point and always ask if there is anything else they would like us to explain.
  • We ask the consumer to explain to us what they understand the agreement to be.
  • We offer alternative types of communication – phone, post, email, in person.
  • We do not make assumptions that the person we are dealing with is sighted as they may be unable to read or understand serial numbers or account numbers.
  • We do not make assumptions that the customer we are talking to can hear everything we say as they may have a hearing impairment.
  • We always remember that the customer we are speaking to may sometimes be forgetful or overly trusting and believe that a sales representative is always acting in their best interest.
  • We understand that some customers may be lonely and welcome the opportunity just to talk to someone.
  • We give the customer time to explain their circumstances fully and don’t interrupt or appear impatient.
  • We also listen for what is NOT being said, for example, lack of questions about price, lack of commitment, timing of responses, extended silences.
  • We always ask if there is a better time to discuss matters as some customers may perform better at different times of the day.
  • We ask if there is anyone else the customer may need to talk to before making the decision.

 

We also use the TEXAS Model outlined by many advocates of vulnerable customers, including MALG and the FCA. This model enables us to train our employees in effective handling of disclosures of vulnerabilities. It helps employees to identify, assess and support vulnerable customers.

 

The steps of the model include: –

 

  • Thanking the customer for their disclosure.
  • Explaining how their disclosed information will be used.
  • EXplicit consent or carry out checks to ascertain if the customer objects to data processing (depending on the basis on which the data will be processed).
  • Asking the customer questions to find out key information to understand the situation better.
  • Signpost to internal support, or to external services with specialised expertise (where appropriate)

 

Prior to moving ahead with the sale:

 

  • We ensure that the consumer demonstrates that they understand the decision they need to make, why they need to make it and that they understand the consequences of making, or not making that decision.
  • We ask if they need to discuss the matter with anyone else, or if they would like us to explain anything else, or if there anything else we can do further to help.
  • We are always prepared to repeat anything to clarify understanding.
  • We do not assume that the customer fully understands all the implications of the agreement and explicitly and clearly confirm all the key features.
  • We suggest that they talk it through with someone else and offer to re-contact them. If appropriate we suggest that a third person could be present

 

After the sale:

 

  • If we identify particular communication needs, we store that information so future contacts are handled appropriately with their permission.
  • We record that Energise Energy Solutions is satisfied that the customer completely understood everything that was discussed.
  • We allow customers to make a personal declaration about their capabilities or communication needs and store this information with their permission.
  • Any records that are held are with the full knowledge and consent of the customer and are deleted when the relationship no longer exists in accordance with GDPR.

 

RECORDING INFORMATION

 

We recognise that it is essential to know and understand how to record information relating to vulnerable customers. If a vulnerability or issue is raised, it is imperative that this information is accurately logged, so that all subsequent dealings with the customer have the same approach and continuity of care. We add this information to the customer’s account on our CRM.

 

SYSTEMS AND PROCESSES

 

All new employees are to be trained on the above during induction and have access to ongoing support where it is needed. We provide all new employees with access to the latest guidance on vulnerabilities and at-risk groups and ensure regular updates are received from such professional bodies or trade.

 

EMPLOYEE ASSESSMENTS

 

We also utilise vulnerable customer assessment eLearning to check the understanding, skills and capability of those who deal with vulnerabilities as part of their role. Any new staff will be required to test and verify skills and capability annually. We are responsible for ensuring that all employees have access to resources and publications relevant to vulnerabilities.

 

SIGNPOSTING

 

We are proactive in ensuring that all customers know how and where to access internal and external support and guidance. Where this applies to vulnerable customers, we actively tell customers where to obtain additional support as relevant to their situation.

 

If we identify a customer who may need specialist advice which we are unable to offer we will refer them to, or we will seek guidance from an appropriate organisation such as:

 

 

Such signposted information is provided: –

 

  • Via links in customer emails
  • On customer communication letters
  • During sales, advice, or customer service calls
  • A copy of this Vulnerable customer policy will be added to our website.

 

COMMUNICATIONS

 

We recognise that how we communicate with all customers, but especially those who are vulnerable, is essential in ensuring good outcomes. All forms of communication are assessed by Robert Hewitt to ensure that any potential vulnerabilities are taken into consideration.

 

We provide multiple communication methods and options and do not insist that one way only be used. An example of this is those who are suffering with depression or anxiety often cannot talk on the phone or interact socially, and so insisting on face to face or telephone communication would lead to additional harm to the customer.

 

We have ensured that all forms and methods of communication and information are presented in a way that is accessible and understandable for all customers. Such methods include (but are not limited to): –

 

  • Website
  • Emails
  • SMS
  • Marketing
  • Complaints Procedure
  • Point of Sale
  • Service Information
  • Contracts/Agreements
  • After Sales/Post Contract Communication

 

Energise Energy Solutions will make reasonable adjustments to its service delivery considering the service scope and the type of services it provides. A reasonable adjustment could consist of any of the following:

 

  • Liaising with the customers third-party representative during the process – If a potentially vulnerable customer wishes to have a family member, caregiver, or another trusted individual speak on their behalf, we will support and facilitate this. It is our commitment to provide a service and environment that is both respectful and adaptable to the unique needs of each customer, particularly those who are most vulnerable.

 

  • Offer alternative communication methods to suit the customer’s needs. We can allow the customer to use email, letter, or telephone and we will offer written correspondence.

 

  • We aim to provide the best outcome with regards to customers individual needs and circumstances. This may include speaking to them at a different time/day.

 

All employees will be given extensive training on using our CRM system and understand how to record and log information and how to action any specific system controls to flag vulnerable customers or potential concerns.

 

TELEPHONE COMMUNICATION

 

In accordance with its customer journey, Energise Energy Solutions anticipates that most of the pre-sale and post-sale customer interactions will be via online, email or telephone.  

 

Where Energise Energy Solutions have a telephony pre-sale conversation with customers, we will seek to understand the customer’s needs and individual circumstances up front to determine whether the credit product is suitable for the customer’s needs. Our rationale for doing so is that customers with apparent or more subtle vulnerabilities are more likely to enter into an unsuitable credit agreement on a poorly informed basis, and therefore we will seek to ensure that the structure of the credit products aligns to the customer’s needs by seeking to understand the same at the start of any telephony sales conversations with customers.  

 

EMAIL COMMUNICATION

 

When interacting with customers by email, a different skillset to be attentive to detail is required. Our staff, when reading email communications from customers, must be attentive to read what is being communicated by the customer (i.e., the content) and how it is being communicated (i.e., the manner). The ‘how’ element may indicate characteristics which denote that the customer is vulnerable or may give insight into a driver of a customer’s vulnerability.

 

Our staff will be observant to establish what a customer’s written communication style says about the customer and whether this can indicate the existence of an indicator of vulnerability. For example, an email communication from a customer littered with significant grammatical and spelling errors may indicate low literacy skills or maybe that the customer is not fluent in English. We will seek to make things as easy as possible for the customer by facilitating contact through a channel that is most suitable for the customer and which they are comfortable using.

 

THIRD PARTIES AND VULNERABLE CUSTOMERS OF THE FIRM

 

Where a customer or third party (e.g., a third party acting under an Ordinary Power of Attorney, Lasting Power of Attorney etc.) makes representations on behalf of a customer, it is likely to be indicative that the customer will have health-related vulnerabilities (i.e., mental capacity limitations). In such circumstances, the Senior Manager will contact the relevant third party to obtain further information about the customer’s circumstances to inform the most appropriate action to take.   

 

Where a customer informally provides consent for a third party to manage their account either by email or via telephone conversation on a recorded line post-sale, staff should reiterate their understanding for absolute that explicit consent is being received from the customer and to ensure both parties are clear on the scope of their consent. as confirmation that a customer is giving explicit consent for a third-party to manage their transaction.

 

Should a customer who has been identified as vulnerable by Energise Energy Solutions and been flagged to no longer receive any communications due to a third-party making representation on behalf of the customer, we ensure that staff do not describe the customer as vulnerable as this can be extremely offensive for the same bearing in mind that some vulnerable customers may not consider themselves to be vulnerable.  

 

FRONTLINE STAFF DEALING WITH VULNERABLE CUSTOMERS

 

Our goal is to make sure that everyone in our company has the training they need to support customers’ wellbeing. Whether that’s managing difficult conversations or signposting them towards external organisations that can provide extra support, we want to make sure our employees feel empowered, comfortable and confident when helping our customers in vulnerable circumstances.

 

All members of staff will be provided with vulnerable customer training before being permitted to speak to customer on the phone which includes training of the procedures outlined in this document. Further training will consist of completing courses that focuses on the rules required of a credit broker, one of which the subjects covered is Dealing with Vulnerable Consumers.

 

Vulnerable Customer Training will be carried out on at least annual basis.

 

Staff will also be offered practical and emotional support where it is required, particularly if they have handled a particularly distressing call.  Support will include allowing time out following a difficult or challenging phone call, time off for staff to share experiences, either face-to-face meetings or remotely and/or the provision of self-help information.

 

SPECIFIC VULNERABILITIES

 

We recognise that any person can become vulnerable at any time and not all vulnerabilities can be categorised or labelled. However, through our research and assessments of publications into vulnerabilities, we have developed and implemented certain measures and controls for vulnerable categories and issues that are more common and identifiable.

 

Energise Energy Solutions has dedicated procedures in place for dealing with specific vulnerabilities such as financial difficulties and mental health issues.

 

We have ensured that adequate and effective signposting is available to assist those who require extra help, and we also carry out regular reviews on our written materials and products/services to ensure that they are accessible for all.

 

We welcome customer feedback and include customer communication in our vulnerable customer training sessions. Feedback and complaints are reviewed regularly to ensure that any issues raised by those considered vulnerable are addressed and revised as soon as possible.

 

We have ensured that our communication channels and customer service processes encourage customers to share information about their vulnerability and associated needs and we use this information to further develop our existing procedures, controls, materials and products/services.

 

PROTECTED CHARACTERISTICS

 

The Consumer Duty requires us to focus on the needs of customers in vulnerable circumstances and those customers with protected characteristics as defined under the Equality Act 2010. With the aim of ensuring that all customers can expect to receive good outcomes, the Duty requires us to consider the characteristics, situations and circumstances of vulnerable and protected customers and to develop products, services, processes and communication models that meet the needs of all.

 

The Equality Act 2010 is intended to reduce socio-economic inequalities relating to the discrimination and harassment of any individual based on certain personal characteristics and to prohibit victimisation in certain circumstances. The Equality Act 2010 specifies protected characteristics upon which it is unlawful to discriminate (either directly or indirectly), harass or bully.

 

These characteristics are: –

 

  • Age
  • Disability (physical or mental impairment)
  • Gender reassignment
  • Marriage and civil partnership
  • Pregnancy and maternity
  • Race (colour; nationality and/or ethnic or national origins)
  • Religion or belief
  • Sex
  • Sexual orientation

 

Energise Energy Solutions already has an effective Equal Opportunities Policy in place which highlights our obligations and policy on complying with The Equality Act 2010 in relation to our employees. The Consumer Duty requires us to go further in our compliance with the Act by also considering the needs of our customers where they are categorised by one or more of the protected characteristics.

 

We monitor customer outcomes and where available, consider the impact a protected characteristic may have on a customer’s vulnerability. We continuously review and improve our products, services and materials to ensure that they are effective and offer flexible options in these areas to meet the needs of vulnerable customers and/or those categorised by one or more protected characteristics.

 

AUDITS AND MONITORING

 

We carry out regular internal audits and gap analysis monitoring on all business practices and procedures to ensure that our Vulnerable Customers ethos and objectives are being met. These audits include using a Vulnerable Customer Audit Checklist which enables us to assess every policy and procedure area against assessment questions designed to test our Vulnerable Customer processes and regulatory compliance.

 

Monthly reviews of the audit results are held, and an ongoing record of gaps, actions and improvements are maintained. We will carry out daily call monitoring on all calls to assess against our objectives and standards for dealing with vulnerable customers.

 

We have several measures and controls for monitoring and assessing our approach to vulnerable customers. These include: –

 

  • Providing monthly management information reports on our approach to vulnerable customers and the outcomes of delivered solutions and controls.
  • Evaluating and recording instances where we have not met the needs of one or more vulnerable customers and developing an action plan to ensure improvements are made.
  • Assessing and testing employee skills and capabilities for dealing with vulnerable customers and providing feedback to employees. eLearning assessments are carried out on all staff.
  • Carrying out data analysis on complaints and accounts involving vulnerable customers to evaluate outcomes and effectiveness and implement improvement where necessary.

 

RESPONSIBILITIES

 

We will ensure that all staff are provided with the time, resources, and support to learn, understand and implement the Vulnerable Customers procedures and associated policy into their business practices. Senior Management is responsible for a top-down approach and in ensuring that all staff are included. 

 

Robert Hewitt is responsible for Vulnerable Customer audits and gap analysis monitoring and their subsequent reviews and action follow ups. There is a continuous audit trail of all Vulnerable Customer audits and feedback to ensure continuity through each process and task.

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