Vulnerability is far-reaching and has many forms, it can be permanent or temporary and; it can include but is not limited to, living with physical health issues or a mental illness, suffering from a mental impairment, having a learning disability, literacy or numeracy difficulties, having a speech impairment, life changes, or not speaking English as a first language.
NSG is a responsible group and follows ethical practices for our vulnerable clients and the situations they may find themselves in. We are committed to providing an excellent quality of service and make sure that our products and services meet the needs of all our clients. Our guidelines follow procedures outlined in Energy UK's 2018 policy: 'Customers in Vulnerable Circumstances.'
Prior to the Covid19 pandemic, NSG explored how business clients in vulnerable situations had been affected by a lack of simplicity and clarity. Poor communications can have a range of negative consequences;
Businesses may suffer financial detriment, for example, if they are a victim of mis-selling, been badly advised, or if they are unable to access the best deals;
They may become isolated if they are unable to keep in touch with family and friends;
They may not be able to participate as fully in business society as they would wish.
From inception, we believe it is imperative that vulnerable clients are able to be identified at an early stage; whether we identify them from a) a video call, an email, or from a request for help from the client directly; b) a guardian/family member of the client, or c) a third party representative. Our policy from the outset is to explain procurement (or buying products and or services) in Plain English, to ensure the client is aware of the legal ramifications on the business and business owner, and that legal consent from the authorized person, guardian, or a third party representative who acts on their behalf has been granted. It is also imperative, that a client is in a contract fit for purpose. This allows us to keep an audit trail because we wish to do the right thing.
Following Energy UK's Independent Review chaired by Lord Whitty and evidence from stakeholders, OFGEM, suppliers, energy networks, the UK Government, and Citizens Advice Bureau; we have rolled out the following findings in our policy decisions.
1. Excellence in Service - A Quality End to End Service
We identify the needs of prospective and current clients; and match these needs to a supplier that will provide them with an end-to-end service, excellent accessibility policy, and quality client service.
2. Comprehensive Regulation - Support and Protection
All clients receive the same level of service, support, and regulatory protections, regardless of how their business is heated or who supplies their energy.
3. Priority Service Register - Protecting Clients
We easily identify clients who would benefit from a priority service, by providing them with how to disclose information about any vulnerabilities - with security and privacy respected.
4. Communication - Specialist Communication
We understand that some people’s ability to participate in communications, markets, and society is affected by factors such as their age, disability, business income, or geographical location.
We, therefore, ensure that our range of options allows you and/or your client to communicate with your supplier. Clients must be able to reach, and hear from, their supplier(s) in a way that meets their needs.
5. Advocacy - Specialist Support
Effective links have been created between suppliers and support organizations: Clients in vulnerable circumstances will benefit from effective links established between their energy supplier and organizations that provide support and advocacy.
6. Technology - Specialist Support
A smart energy system will be put in place (where feasible) that works for and benefits clients in vulnerable circumstances. The transition to a smarter energy system will help, not hinder, the experiences of our clients, particularly through improved support to prevent self-disconnection and accurate billing.
Affordable energy usage: Vulnerable business clients will be placed into a 'fit for purpose' contract over a 12 month period, so we can identify the needs of the client and how they utilize their business energy. It is imperative that it is affordable to ensure there are no periods of difficulty. Short-term help can be provided if required, but should not be necessary. We would ensure a payment plan is put in place to rectify any such issues. If there is a repeat of the same issue, we would carefully look at ending our business relationship with the vulnerable client, once the 12 month period has ended. In such a situation, we would look to provide details of an alternative company or supplier who could look to help the client with their personal circumstances. At NSG, we ensure that plans are put in place with our vulnerable clients for long-term sustainability and solutions are in place to reduce their energy costs.
Businesses can be affected by life events such as the bereavement or illness of a sole trader, business partner, or directors; it can temporarily reduce people’s ability to participate in business life and/or increase their dependence on certain communications services.
At NSG, we look to support every situation individually and with sensitivity. You can update us on your specific needs at any time. N.B. This policy does not limit your rights under the “Consumer Contracts Regulations”, the “Sale of Goods Act” or any other statutory rights that you may have. However, if you need us to consider something else that we might not have or overlooked, contact us directly to allow us to assist or direct you appropriately.
• Debt management/financial hardship/Unemployment. Because we have open channels with suppliers, please ensure that you get in touch with us should you experience any financial issues. If you cancel a direct debit mandate(s), without communicating with us, this can impede not only your business credit file; but could lead to financial repercussions with the instruction of bailiffs and/or debt agencies chasing you for payment. It is always best to either email us at firstname.lastname@example.org or leave a voicemail if we are away from the office.
If required, please contact us to discuss. Or if you’d prefer, you can gain advice externally through organizations, such as
Step Change - https://www.stepchange.org;
The Money Advice Services - https://www.moneyadviceservice.org.uk/en;
National DebtLine - https://www.nationaldebtline.org
• Bereavement. NSG will make the process for account closure for a deceased customer as seamless and stress free as possible. All our channels are aware of the process for handling and supporting this situation. If required, please contact us to discuss.
Or if you’d prefer, external support is also available through support agencies, such as,
• Power of attorney. On receipt of legal documentary evidence and all available information, NSG can get in touch with the supplier(s) on your behalf; whether we liaise on your behalf or if you prefer, provide your contactable details for them to get in touch with you directly. If you unsure of your legal rights visit: https://www.gov.uk/power-of-attorney
• Authorised Contact. NSG allows a client to nominate a friend or relative to help communicate on their behalf. You can choose the level of access you want to give to an authorized contact. They could have full access to your account with NSG, which would give them permission to do everything as if they were the main account holder. Or if you want to restrict what they can do, please just let us know when you contact us, and we can set up the correct access level. To proceed, we would need to speak to the client directly and for this to be followed up in writing.
• Imprisonment. NSG offers support and guidance when a client is facing imprisonment. If required, please contact us to discuss your account.
• Armed forces. NSG offers support and guidance when a client joins the Armed Forces. If required, please contact us to discuss.
• Serious health issues, mental health issues, terminal illness, or long-term illness(es). Following the provision of the required documentation, the account will be supported as appropriate.
Or if you’d prefer, you can gain advice externally through organizations such as,
Mind - https://www.mind.org.uk,
Time To Change - https://www.time-to-change.org.uk or,
Heads Together - https://www.headstogether.org.uk.
• Victim of fraud. There are many types of fraud and ways fraudsters will try to gain access to an account or private information.
NSG is committed to supporting victims of fraud in the following ways; Articles detailing different types of fraud, guidance on how customers can best protect themselves, and how to report fraud re: available on our website. Access to a fraud team to manage customer concerns.
Or if you’d prefer, you can gain advice externally through organizations such as
ActionFraud - https://www.actionfraud.police.uk. or
Victim Support - http://www.victimsupport.org.uk
• Age. Although age is not always a vulnerability, the 85+ age group is a fast-growing segment in the UK. This means the proportion of the population with hearing, sight, or other age-related difficulties is set to increase. Older clients can be vulnerable not only because of their age; but due to a range of linked factors or situations, they may be in. We promote customers to appoint an authorized contact to help manage affairs. If required, please contact us to discuss.
Or, if you’d prefer you can gain advice externally through organizations, such as,
Age UK -https://www.ageuk.org.uk;
Independent Age - https://www.independentage.org;
At present, the Group Managing Director Ian Smith acts in this position - and will be responsible for the delivery of commitments to improve services to vulnerable business clients.