Using Ofcom's guidelines as the framework, Consulting Networks Code sets out the standards of behaviour that Consulting Networks will adhere to in marketing and selling our services to our residential and small business customers. As well as setting out the standards of behaviour that customers can expect from us whenever we contact them for sales or marketing purposes, Our code also describes some of our internal procedures regarding recruitment and training of our personnel, including agents who act on our behalf. This code also covers Consulting Networks marketing activities by both direct (face to face) and telephone (telesales) contact with potential customers.

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1. Introduction and Overview

1.1

Our main aim is to avoid issues arising before, during and at the point of sale. “CN” drive, in implementing this Code, is to avoid instances of mis-selling and misrepresentation. We will also endeavor to ensure customers have a full understanding of the services offered and the full terms of any contracts they subscribe into.

1.2

Key objectives:

1.3

Consulting Networks have procedures in place for sales and marketing staff to be informed of the Code of Practice for Sales and Marketing (‘the Code’) and for monitoring their compliance with it.

1.4 

Our Code will be supplied upon request to new customers free of charge and is also available on our website home page  www.consulting-networks.co.uk

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2. Status of Code

2.1

Non-compliance with the Code does not affect the validity of any contract between Consulting Networks and a Customer, unless otherwise required by law.

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3. Sales, Marketing, Advertising and Promotion

3.1

Consulting Networks will at all times act responsibly and in compliance with this Code in connection with promoting, marketing and selling fixed line telecommunications services.

3.2

Customers’ wishes will be respected where they have registered with any relevant preference service, including the Mailing Preference Service, the Telephone Preference Service, the Fax Preference Service and the E-mail Preference Service.

3.3 

Advertising and promotion will comply with the British Codes of Advertising and Sales Promotion.

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4. Recruitment & Sales Training

4.1

Consulting Networks have procedures in place for the selection of staff involved in direct contact with existing and potential customers, for the purposes of sales and marketing.

4.2 

Consulting Networks requires any third party agencies to have appropriate procedures for the selection of sales people, who are involved in direct contact with customers.

4.3 

The recruitment of sales staff will take into account the following criteria:

• Recognizing that the sales person will be representing Consulting Networks. We therefore insist on high standards  of behaviour and appearance from appointed representatives.

4.4

Consulting Networks requires potential UK based sales staff and contractors to:

• Comply with their obligations under UK Employment Legislation.

• Provide referees who are not be related to the applicant;

• Provide business referees who are not from the same company;

• If a sales person transfers to another company a copy of his or her records will be retained for a minimum period of 6 months. 

• CN shall endeavor to retrieve identification badges of staff leaving the company.

4.5 

Consulting Networks requires sales staff and contractors to be trained, so that they have sufficient understanding, that any relevant advice given by such person is not misleading.

Topics covered to include:

• Arrangements for competition in the supply of telecommunications in the UK.

• The different telephone products and services provided by Consulting Networks and how these differ from other competitive telecom products and services.

• Consulting Networks pricing and its terms and conditions of service and, in particular, methods of payment.

• Duration of contract and any termination fees;

4.6

• Ensuring the Code is observed by our selling agents and to handle complaints relevant to the Code.

The Consulting Networks remuneration systems are structured so as to positively discourage misleading or Exploitative sales practices.

Consulting Networks requires its sales and marketing contractors to keep it informed of incentive schemes they provide to their sales staff.

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5. Customer Contact

5.1 

No direct sales representative shall visit a residence before 8.00am and after 8.00pm.No telesales telephone calls shall be made before 8.00am and after 9.00pm, unless requested by the customer.

5.2 

Consulting Networks representatives involved in face-to-face direct sales and marketing will be issued with an identity card that clearly displays

• The Consulting Networks name

• A unique identification number for that representative

5.3 

All representatives will immediately identify themselves as representing Consulting Networks and, the purpose of the call. When visiting or meeting in person, they will show their identity card for examination

5.4 

All representatives will take reasonable steps to be informed of local authority initiatives and password schemes such as the Local Distraction Burglary Initiative

5.5 

Representatives will not misrepresent the services being offered. Representatives will check that customers entering into contracts understand the contract and intend to enter into a contract with Consulting Networks.

5.6 

Representatives will cease contact with any person who indicates that the contact is inconvenient, unwelcome, inappropriate or too long. If the customer requests it, the discussion will be ended immediately and, if making a doorstep call, the representative will immediately leave the premises.

5.7 

Representatives will respect and will not abuse the trust of vulnerable customers including the elderly or whose first language is not English, or those who have special needs. Representatives “CN” Code of Practice for Sales and Marketing. We shall not sell to customers where it is apparent that they may be economically vulnerable.

5.8 

No sales or marketing activity will be directed to persons who are under the legal age for entering into contracts.

5.9 

Marketing campaign records will be maintained for 6 months, including the date and the approximate time of the contact with the customer. Records maintained will allow subsequent identification of the sales representative and to assist in dealing with any complaint or query.

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6. Entering into a Contract – information, order forms and contracts

6.1 

Our representatives will check if the customer is authorized to enter into contract for any of its services.

6.2 

“CN” order forms and contract forms are designed to make it clear that the customer is signing a legally binding contract. They contain a statement of the contractual nature of the document immediately adjacent to where the customer signs. This statement cannot easily be obscured or concealed.

6.3 

Where face-to-face selling takes place, the customer will be given the following information in writing, in a clear and comprehensible manner:

6.4 

Customers to be made aware of the existence of the Code. Copies will be provided on request, free of charge to customers.

6.5 

“CN” rates are available by phone and on our website. New customers will get this information in their Welcome Pack.

6.6 

If a customer signs an order form following face to face contact, or enters into a written contract, the customer will be given a copy of the order form or contract. The customer will also be given the  following details in writing either at the same time or within 5 working days, unless previously supplied in writing prior to contract:

6.7 

Orders placed by distance selling will comply with Distance Selling Regulations.

6.8 

In the case of internet orders, a well sign-posted hyperlink to Distance Selling Regulations, which is easily visible to the website visitor, will be prominently displayed. This information should be printable or downloadable.

6.9 

Customers may cancel orders by telephone, in writing, by fax or by e-mail. They may terminate contracts in writing under the terms and conditions of the contract.

6.10 

Consulting Networks will send a letter to the customer by mail within five working days of a contract being agreed, informing the customer of the details of the transfer, including but not limited to the Date of notification; CLI(s) affected; List of services affected/unaffected; If relevant, information about call barring; Date of switchover; Consulting Networks contact details for any queries.

6.11 

Notification will be by letter although may it may be sent electronically where consumers have initiated contact by applying online, and have confirmed online that they wish all future correspondence to be sent electronically. Otherwise customers would need to positively request by written correspondence that information be sent electronically.

6.12 

The order that Consulting Networks submits to your existing provider will not mature until the switchover period is complete and customers have been made aware of their right to change their mind before the switchover period. There is a ‘no cost’ cancellation for customers where they change their mind during the switchover period.

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7. Consumer Protection and other Legal Requirements

Consulting Networks procedures shall comply with applicable legislation.

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8. Audit of Contracts

8.1 

Consulting Networks procedures have been developed to minimize the risk of errors or mis-selling when taking orders/making contracts during face-to-face or telephone selling. Representatives will check that customers entering into contracts have understood, and intended to sign a contract, and will carry out regular audits of systems, procedures and documentation.

8.2 

Audit contact may either be as part of the mandatory customer ‘notification of transfer’ letter referred to in paragraph above or through a separate process. Audit contact will be made by a person not involved with “CN” sales and marketing activities.

8.3 

If it is found that the contract was not understood or intended, or if the order matured before the expiry of the switchover period, and the customer wishes to cancel, Consulting Networks will terminate the contract without charge or other penalty. Consulting Networks will keep under review the procedures by which contracts are agreed and to take appropriate steps to prevent recurrence of any problem identified from the audit process.

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9. Complaints Procedure

9.1 

Consulting Networks internal procedures for handling customer complaints include those relating to sales and marketing activities. Consulting Networks staff and representatives who deal directly with Customers are aware of this procedure. They will inform Customers of the existence of the Consulting Networks complaints procedure on first contact.

9.2 

The complaints procedure sets out how Customers may complain about sales and marketing activity and what further steps are available if they believe their complaint has not been dealt with satisfactorily.

9.3 

In addition, Customers may use the Consulting Networks dispute resolution arrangements with the Office of The Telecommunication s Ombudsman (‘Otelo’).

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10. Publicising our Code

10.1 

The Code is available to customers on request, free of charge and in a reasonable range of formats.

10.2 

This Code of Practice will also be available on “CN” UK website.

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11. Compliance Officer details

For questions regarding the code, please write to:

The Compliance Officer Consulting Networks Limited  40 March Road, Wimblington, Cambridgeshire, PE15 0RN P                                                                      The Compliance Office © 2005 - 2006