Internal Complaint Policy

Introduction

This policy is a fundamental part of this company’s business. The policy is required by law if the company is to operate. Also the policy ensures that as a company we continually strengthen and promote the cornerstones of our business: integrity, quality service and reputation. In turn those cornerstones support our growth and success.

We recognise that from time to time a customer may feel, rightly or wrongly, that they have not received a level of service that they are entitled to expect. Whatever the case such views must be addressed as per this policy.

The Energy Ombudsman

Should a complaint not be resolved via our internal complaint procedure then the customer may complain to the Energy Ombudsman. All should bear in mind the requirement to “sign post” the customer to that possible route.

There is therefore a need that all customer complaints are in all ways dealt with as per this policy: positively, swiftly, courteously and effectively.

This policy (and the complaint procedure to become available on our website) provides for a greater degree of activity on our part than as per the example complaint procedure produced by the Energy Ombudsman.

Our aim in adopting a more comprehensive complaint policy and implementation of the same is to resolve as many complaints as possible thereby preventing the possibility of a subsequent complaint to the Energy Ombudsman (whilst of course at all times observing the requirement to clearly signpost the customer’s right to complain to the Energy Ombudsman once our procedure has been exhausted).

This approach mirrors the stated aim of the Energy Ombudsman that as few complaints as possible should reach the Energy Ombudsman: through the provision of quality services to customers coupled with an effective and fair internal complaint procedure any complaints made to the Energy Ombudsman will be minimised.

Website visibility

The complaint procedure will as required by the Energy Ombudsman be visible and accessible on our website. The website will also inform customers that they are entitled to ask for a copy of the complaint procedure to be emailed or posted to them (in either case no charge to the customer).

Internal issues

Complaint record

Every complaint must be recorded in the complaint spreadsheet. Access to the record and the ability to change the record is confined to the directors, the complaint manager (the term complaint manager includes any deputy complaint manager) and such other persons as the directors may decide from time to time.

The record is primarily administered by the complaint manager who shall have responsibility to ensure it correctly functions and is utilized in an appropriate manner.

Complaint or grumble?

Every person communicates in their own way. Some may be aggressive whilst others may adopt a more considered approach to words used. Therefore a mildly worded email, letter or telephone call from a customer may not use the word “complaint” or similar clear message of the customer’s grievance.

All members of staff must be alert to a complaint, whether expressly stated or otherwise. The company must avoid overlooking or misinterpreting a complaint as being merely a grumble.

Once any member of staff becomes aware of a complaint or grumble they must without delay refer the same to their line manager in accordance with complaint procedure. Failure to so notify the line manager is a disciplinary offence.

The line manager shall then having made initial enquiries report to the complaint manager and in doing so provide a summary of the issues.

Early and positive resolution

The company recognises that an efficient, positive and effective response to a complaint will often conclude the matter to the customer’s satisfaction. The handling of a complaint may be of greater importance to a customer than the source of the complaint itself.

Further the Energy Ombudsman may expel a broker from the scheme should he determine that an internal complaint procedure fails to comply with the Energy Ombudsman guidelines or fails to be implemented as per those guidelines.

We recognise that if we are unable to resolve a complaint within our procedure then an inevitable risk is created of a complaint decided by the Energy Ombudsman. The customer has twelve months from receiving from us a deadlock letter to make a complaint to the Energy Ombudsman. We aim to make a fair and impartial decision as to all complaints and thereby avoid the fees, resource and uncertain outcome that a complaint to the Energy Ombudsman brings. This of course also benefits our customers.

Complaint manager

This a key role within the company as appointed from time to time by the directors.

In the absence or unavailability of the complaint manager the deputy complaint manager shall assume the responsibilities of the complaint manager.

The manager will be of sufficient seniority and experience within the company that:

Staff have confidence in them to appreciate the issues raised;
They appreciate and observe the need for discretion;
They have thorough knowledge and understanding of our business and its requirements;
Staff will find them approachable and supportive; and
The matter will be dealt with in a responsible and appropriate manner.

If the complaints manager is not a director the manager shall report to a designated director on a regular basis (no less than once every calendar month) as to all complaint related matters that have arisen. Should no matters have arisen and there be no progress to report the manager shall report to that effect. That exercise will provide the complaints manager and the designated director with an opportunity to review all complaints logged, progress and outcomes.

The complaints manager shall be provided with such resources, training and support as may be identified as required from time to time.

This report and review process is aimed to provide the company with information that assists in both revising and improving the complaints policy and invaluable guidance to the company’s operations as a whole.

Impartiality, interference and confidentiality

An effective complaints procedure will, to the extent reasonably practical, be kept confidential within the company. Reasons for confidentiality:

The procedure requires impartiality. A complaint must be addressed and reviewed from an impartial standpoint. The views and inputs of employees may be welcome and valuable however only when invited.
Avoid the risk of the risk of internal interference with the procedure.

Board review

The directors meet on a monthly basis.

An item on the agenda for those monthly meetings will be complaints.

A minimum 48 hours prior to the meeting either the complaints manager or designated director shall circulate by email to all directors a report setting out:

Any complaints received since the previous report;
The outcomes of any complaints;
Identify any assistance required to deal with complaints; and
Make recommendations as to any improvements to the services we provide, complaint procedure and its implementation.

Internal approach to our complaint procedure

Decision: initial

All decisions shall be reviewed and approved by the complaint manager/designated director from time to time before the customer is notified of the decision.

A decision will include the following:

Confirmation that the complaint has been investigated.
Summarise the issues raised by the customer and identify documents (hard copy or electronic) that the complaint refers to.
Correct and or comment as to the issues raised by the customer and where appropriate comment as to the relevance or otherwise of documents referred to.
If the complaint includes financial loss: explain whether or not with reasons why that is accepted or rejected and if accepted in part why part is rejected.
If the customer’s complaint in reality lies with the supplier then explain why that is so and consider offering support or guidance to the customer.
Explain the decision reached: why is it fair and reasonable?
If an offer is to be made say what it is and explain why that offer is fair and reasonable in the circumstances.

Decision: reviewed

Should the customer reject the initial decision then the decision will be reviewed, this exercise may involve the production by the customer of additional documents and information.

A reviewed decision will include the following:

Confirmation that the complaint has been reviewed.
Summarise the issues raised by the customer and identify documents provided by the customer (hard copy or electronic) in rejecting the initial decision.
Correct and or comment as to any additional issues raised by the customer and where appropriate comment as to the relevance or otherwise of documents referred to.
If the complaint includes financial loss: explain whether or not with reasons why that is accepted or rejected and if accepted in part why part is rejected.
If the customer’s complaint in reality lies with the supplier then explain why that is so and consider offering support or guidance to the customer.
Explain the initial decision reached: why was it fair and reasonable?
If an offer or a revised offer is to be made say what it is and explain why that offer is fair and reasonable in the circumstances.

Range of outcomes

This company recognises that there is inevitably a range of outcomes appropriate to conclude a complaint. These outcomes include:

An apology.
An offer of a gift voucher.
An offer to pay compensation.
An offer to at least explore an alternative energy supply in future.
Rejection of the complaint.

The investigation of a complaint may reveal occasional standards of service that whilst not in themselves gave rise to any financial loss on the part of the customer do fall below the consistently high service levels that we aim to deliver.

It is anticipated that where the customer has suffered no financial loss but has not received the level of service they may expect an apology together with the offer of a gift voucher will satisfy the customer.

Interim update

Where is may not be possible to respond to the customer with a decision (be that initial or reviewed) within ten working days the customer shall be provided with an update letter.

Acceptance of offer

Where the complaint is accepted and an offer made (apology alone or apology and other action) confirm the customer’s acceptance. The aim is to avoid any uncertainty as to whether to not the customer has accepted the outcome of our internal procedure.

Deadlock letter

In the event a customer rejects the reviewed decision a deadlock letter will be sent to the customer.

This letter is required to inform the customer of their right to complain to the Energy Ombudsman free of charge to the customer.

Eight week letter

Irrespective of whether or not the customer has (i) been notified of our decision as to their complaint or (ii) accepted, rejected or not replied to any offer we make it is entitled to receive an eight week letter eight weeks after it made its complaint.

Similar to the deadlock letter the eight week letter must inform the customer of their right to complain to the Energy Ombudsman free of charge to the customer.

Complaint to Energy Ombudsman

Once the customer has made a complaint to the Energy Ombudsman we are required to make a payment to the Energy Ombudsman of £340 plus VAT. That payment is non refundable whatever the Energy Ombudsman’s decision.

Energy Ombudsman’s decisions

The Energy Ombudsman’s decision is binding on us. If we do not comply with the decision within 28 days we face expulsion from the Energy Ombudsman’s scheme.

The range of decisions the Energy Ombudsman may make include that we:

Apologise to the customer; and
Pay compensation of up to £10,000.

Whilst the customer may chose not to accept the Energy Ombudsman’s decision (for example the customer could start court proceedings instead) we must do so.

In the event a complaint is made to the Energy Ombudsman we look to demonstrate through the application of a fair and rigorous internal complaint procedure that the customer’s complaint has been taken seriously, fully investigated, the customer has been dealt with promptly and courteously throughout the procedure and our decision, initial or reviewed, is reasonable and balanced.