The Renewable Energy Consumer Code (RECC) is a Trading-Standards-Institute Approved Code.
In April 2013 Trading Standards Institute (TSI) took over responsibility for the Consumer Codes Approval Scheme (CCAS) from the Office of Fair Trading. As a result, RECC has been approved by TSI rather than OFT since that date.
All approved Codes must monitor members’ compliance with the Code. This is so that Code Sponsors can be confident in their Code’s performance and continue to satisfy stakeholders that they are working effectively to reduce consumer detriment.
RECC has always devoted considerable resources to monitoring members’ compliance. RECC summarises monitoring results every three months for its Supervisory Panel and annually on the website and for TSI. The latest annual report is here.
This document sets out RECC’s Monitoring Strategy to be implemented from October 2014 onwards.
The strategy aims to provide, when taken as a whole, a clear picture of:
RECC has undertaken an analysis of the results of all its activities since its inception in 2006. This has enabled us to identify the ten key compliance areas of the Code against which it will monitor members and, as far as possible, entrants to the Scheme.
These are:
Gathering data on members’ performance against these CAs going forward will give RECC a clear picture of the state of compliance of the individual member, of the individual member against the average and across the Scheme as a whole.
At an individual member level, monitoring enables RECC to pinpoint areas where needs to improve and to assist them to reach compliance, as well as to identify instances where disciplinary action may be required.
RECC has identified a number of performance indicators under each of the key Compliance Areas. These indicators cover performance of members at audit, results from Customer Satisfaction Surveys and complaints received about the key Compliance Area.
Applications
The Application process is intended to check whether applicants are compliant under all the relevant key compliance areas.
RECC makes available guidance on the code and various model documents, including a model contract as well as technology-specific model performance estimates and quotes, to assist applicants to achieve compliance.
All applicants must:
Applications are then monitored by RECC.
Monitoring applicants
RECC checks all applications.
To do this RECC carries out:
a) a review of all the evidence provided in the application; and
b) a due diligence/risk assessment exercise to check:
At the end of the process, RECC identifies an applicant either as:
Low-risk applicants
These applicants are admitted to the Scheme. If they are unable to submit certain evidence for legitimate reasons (eg they are unable to access deposit insurance until admitted) they may be granted temporary membership to give them a chance to put their arrangements in place (link to explanation in Bye-Laws).
Higher-risk applicants
These applicants will be subject to additional monitoring They are applicants assessed at the end of the checking process as high-risk or where there is any suggestion of non-compliance or any other cause for concern will be referred for additional monitoring.
Additional monitoring comprises a full external remote audit by one of RECC’s independent auditors.
RECC expects approximately 1 in 5 applications to be referred for external audit in 2015.
Applicant audits
Applicants referred for external audit will be assessed by RECC’s independent auditors. They may be required to submit further evidence for monitoring.
RECC’s independent auditors will then:
The auditor will report back to RECC.
RECC determines whether to admit the applicant or, if there may be circumstances for refusing membership, may refer the application to the independent Applications Panel.
This section describes the design of RECC’s monitoring of members and the methods it uses.
It covers:
Risk-based monitoring
RECC’s Monitoring Strategy for members is designed to be both:
In this way, RECC targets its most intensive auditing (site visits) and its mystery shopping efforts where it considers consumers to be at higher risk of detriment and/or where there is potentially a higher risk of non-compliance.
In keeping with this most audits of medium- or low-risk members are desk-based rather than site visits.
All members are monitored with reference to Consumer Satisfaction Survey results and may be the subject of a complaint registered with RECC.
Assessing risk
Based on experience of operating the Code, RECC has found the level of risk associated with a member to be related to:
Monitoring methods
RECC’s methods of monitoring members, described in more detail elsewhere on this website, include:
AUDITS
RECC devotes a considerable proportion of its resources to auditing compliance with the Code.
Audits are described in more detail on RECC’s website. They can be:
Audit results are:
On-site audits
Members considered to be high risk are subject to the most intensive level of monitoring, an on-site audit visit carried out by an external independent auditor using the audit questionnaire.
(In practice, an audit visit can be triggered for any member if there is concern about their compliance or if a complaint is received at RECC).
Estimated number of onsite audits to be carried out in 2015: 175
Passing the audit
The on-site audit questionnaire covers the ten key Compliance Areas (CAs) with a number of questions within each area.
The CAs are weighted such that 7 of the ten are high priority and three are medium priority.
Members being audited are assessed as compliant or non-compliant on each question within a CA and on each CA overall.
To pass the audit overall, members have to be compliant:
Non-compliance in more than 2 of the 7 high priority areas automatically triggers consideration for disciplinary action.
All members audited are then subject to follow-up
Desk-based audits
Medium and lower-risk membersare subject to a remote or desk-based audit, either by an external independent auditor or by RECC staff (for the lowest-risk members).
Members will:
There may also be a telephone-based, semi-structured interview. And, if necessary, RECC may decide a site visit should be carried out.
Estimated number of desk-based audits by external auditors in 2015: 75
Estimated number of desk-based audits by RECC staff in 2015: 250
Passing the audit
The audit questionnaire covers the 10 key Compliance Areas (CAs) with a number of questions within each area.
The CAs are weighted such that 7 of the 10 are high priority and 3 are medium priority.
Members being audited are assessed as compliant or non-compliant on each question within a CA and on each CA overall.
To pass the audit overall, members have to be compliant:
Non-compliance on more than 2 of the 7 high priority CAs automatically triggers consideration for disciplinary action.
All members audited are then subject to follow-up
Audit follow-up
All members audited as part of the Monitoring Strategy receive follow-up from RECC and their auditor. This sets out:
If monitoring identifies extensive non-compliance there may be additional action. The action will depend on how severe the non- compliance is and whether the member is making efforts to achieve compliance.
There is more information on this in RECC’s Bye-Laws.
MYSTERY SHOPPING
Each year, RECC identifies a sample of members to be ‘shopped’.
Members are selected for a mystery shop on the basis of some intelligence received, for example:
RECC has recruited and manages a panel of shoppers based all around the country. These shoppers:
Where a mystery shop reveals non-compliance, RECC:
Shops also assist RECC in identifying particular problem areas where it may need to issue guidance.
CONSUMER SATISFACTION SURVEY
RECC’s Consumer Satisfaction Survey (CSS) is available for consumers to complete online via RECC’s website.
Hard copy questionnaires are available on request from. These surveys have a freepost return to RECC.
Hard copy questionnaires are also distributed by QANW to every consumer whose contract is registered with them (QANW is the insurer with whom RECC has negotiated a bespoke deposit and warranty insurance package known as the DAWWI Scheme).
The questionnaire:
RECC reviews every CSS questionnaire returned. It identifies any obvious unusual patterns of responses and /or adverse comments.
Poor performance reported in a CSS questionnaire returned can lead to the member concerned being referred for additional monitoring.
CSS data is summarised and reported at regular intervals to identify overall levels of compliance and satisfaction.
CSS data provides a ‘benchmark’ against which RECC can:
COMPLAINTS
RECC receives more than 1000 consumers’ complaints about small-scale renewable generation systems annually. The complaints team works very hard to broker a resolution to all those complaints that fall within RECC’s remit.
RECC has a comprehensive, bespoke database in which all such complaints, and feedback, are registered.
The database:
Complaints analysis also:
RECC makes good use of the findings of the monitoring programme. RECC:
The monitoring mechanisms themselves and their outcomes are also reviewed at round-tables:
RECC summarises monitoring results every three months for its Supervisory Panel and annually on the website and for TSI. The latest annual report is here.