Policies

Corporate policies

Corporate and Social Responsibility

Acrobat Marketing Solutions Ltd undertakes to uphold the ten Principles of the, The UN Global Compact

These being:

Human Rights

Principle 1: We will support and respect the protection of internationally proclaimed human rights by  Promoting the rule of law, Addressing consumer concerns, Value chain management, Increasing worker productivity and retention, Building good community relationships

• Principle 2: We will make sure that we are not complicit in human rights abuses.

Labour

• Principle 3: We will: Uphold the freedom of association and the effective recognition of the right to collective bargaining;

• Principle 4: the elimination of all forms of forced and compulsory labour;

• Principle 5: the effective abolition of child labour; and

• Principle 6: the elimination of discrimination in respect of employment and occupation.

Environment

• Principle 7: We will: Maintain a precautionary approach to environmental challenges;

• Principle 8: undertake initiatives to promote greater environmental responsibility; and

• Principle 9: encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption

• Principle 10: We will work against corruption in all its forms, including extortion and bribery.

Health and Safety

• We will promote and maintain a Health and Safety  management system in order to promote employee well being and protect all that are affected by the actions of the company.

Codes of conduct.

• Employees  This policy will be communicated to all employees by way of a code of conduct and training to support same.

• Suppliers  This policy will be communicated to suppliers , support of this policy will be assessed by way of questionnaires.
Jan 2016 (review Jan 2017)

Supply Chain Standards
In our standard production procurement process, we issue purchase orders that incorporate our Terms and Conditions (T&Cs). which expand on our expectations and suppliers’ obligations on specific topics. For example, our Social Responsibility and Anti-Corruption Web-Guide outlines our prohibition of child labour, forced labour (including human trafficking), physical disciplinary abuse and any infraction of the law. Our Environmental Web-Guide sets out environmental requirements, including the elimination of materials of concern and increasing the use of sustainable materials whenever technically and economically feasible.

Internally, we have adopted our Code of Human Rights, Basic Working Conditions and Corporate Responsibility Policy, to address workplace issues such as working hours, child labour, forced labour, non-discrimination, freedom of association, health and safety and the environment. This policy applies to our own operations, and we encourage businesses throughout our supply chain to adopt and enforce similar policies in their own operations. Furthermore, we seek to identify and do business with companies that have aligned standards consistent with our CSR Policy, including working to cascade these expectations throughout their own supply chain.

Slavery and Human Trafficking
Slavery and forced labour can take many forms, including human trafficking or child labour. Acrobat Carbon Services (ACS):  Basic Working Conditions and Corporate Social Responsibility, clearly states that we will not tolerate forced labour (including human trafficking) or child labour in our operations and we conduct internal audits of our manufacturing locations to ensure compliance. Our processes include actions to safeguard against human rights abuses (including forced labour and human trafficking) in our supply chain, including:

• Our Global Terms and Conditions forbid the use of forced labour, child labour and physically abusive disciplinary practices. Our definition of forced labour is inclusive of human trafficking as outlined in our Policy Letter 24: Code of Human Rights, Basic Working Conditions and Corporate Responsibility.. We reserve the right to terminate our relationship with a supplier if issues of noncompliance with our policies are discovered and/or noncompliance is not addressed in a timely manner.

• We conduct training and build capability. We regularly conduct internal training on our  Code of Human Rights, Basic Working Conditions and Corporate Responsibility with our Global Purchasing staff, including management and supplier quality teams. Additional training is conducted regarding our Supply Chain Sustainability Program, including coverage of the Code and our Global Working Conditions Program as required.

PURPOSE

The purpose of this policy is to ensure that the employees of the company take extra care when dealing with vulnerable customers and do not have any negative impact upon vulnerable consumers.
1. For the purposes of this policy Vulnerable Consumers are customers and prospective
2. Customers whose ability or circumstances require us to take extra precautions in the way that we sell and provide our services to ensure that they are not disadvantaged in any way.

IDENTIFYING A VULNERABLE CONSUMER

A vulnerable customer is a customer who is over 18, but who is, or may be, unable to take care of themselves, or protect themselves against any significant visual or hearing problem, or are old and/or frail.

When engaging with customers over the phone it is often difficult to identify a Vulnerable Consumer because it is not possible to see many of the characteristics, such as body language and facial expressions, which may identify whether the prospective customer requires additional information and guidance to enable them to make an informed decision. For this reason, it is critically important to listen carefully to all customers and to try to identify people who may be classed as a Vulnerable Consumer.

Typical telephone characteristics include:

  • An inability to hear or understand what is being said
  • Repeated questions of a similar nature
  • Comments or answers which are inconsistent with the telephone discussion or which indicate they have not understood the information which has been provided.
  • Verbal confirmation that they don’t understand or that they require the assistance of somebody else in making a decision

Agents who are assisting with signing up consumers will regularly engage with customers face to face. When doing this the same characteristics are likely to be evident but body language and facial expressions may also assist in identifying the vulnerability.

WHAT TO DO IF WE ARE ENGAGING WITH A VULNERABLE CONSUMER

Just because somebody is vulnerable does not automatically mean that they are unsuitable for the products and services the Firm supplies. As soon as we think we may be engaging with a Vulnerable Consumer we should immediately make a record of the same and ensure we adhere to this policy.

When speaking to the Vulnerable Consumer we should:

  • Provide additional opportunities for the customer to ask questions about the information we have provided.
  • Continuously seek confirmation that they have understood the information that has been provided.
  • Ask if there is anybody with them who is able to assist them.
  • Offer them the opportunity to complete the transaction after a period of further consideration

If for any reason, we think the customer does not understand the service which is being offered to them we must not proceed with the transaction and advise them that we will write to them with further information about the product or services they are seeking.

If a customer decides to use our services, you must be satisfied that they fully understand the scope of the work to be done and the price payable.

You must ensure that no customer is put under pressure that will make them feel obliged to buy. You must always ensure that the customer understands the conditions of any contract and their rights of cancellation.

If the customer wishes to proceed, you should ensure that they do not want to contact anyone else before signing an order. Only once these conditions are met can you accept a contract for work.

All contracts taken from customers who fall into the category of vulnerable customers must be verified by a manager. An elderly customer can appear interested initially but can quickly become confused or distressed. An order must never be taken if there is even the slightest doubt of the customers full understanding of the contract and costs involved. We reserve the right to withdraw from contract at any time if it feels inappropriate to proceed with work due to vulnerability of the customer.

WHAT IS MENTAL CAPACITY?

Mental capacity is a person’s ability to make a decision. Whether a person has the ability to understand, remember, and weigh-up relevant information will determine whether he is able to make a decision based on that information. The person will also need to be able to communicate his decision.

The mental capacity of a person may be limited in a way which prevents him from being able to make certain decisions because of an impairment of, or disturbance in the functioning of, his mind or brain.

Making decisions

Mental capacity is always defined in relation to a specific decision at a specific time.

Consequently, when considering an application for a product, or change in product factors, the Firm should take account of the customer’s circumstances at the time at which the application or request is made.

The Firm should take appropriate steps to identify whether the customer appears able to understand, remember, and weigh-up the information and explanations provided to them, and, when having done so, make an informed decision.

Mental capacity limitations can be either permanent or temporary (including fluctuating over time).

Consequently, the fact that a person may not have had the mental capacity to make a decision in the past, does not necessarily mean that they currently do not have, or will never have, the capacity to make such a decision.

Mental capacity limitations may also be partial. Under such circumstances the person concerned is likely to be able to make certain decisions but not others. Decisions, that may require the understanding, remembering and weighing-up of relatively complex information, are likely to be more challenging for many individuals with mental capacity limitations than more straightforward spending decisions.

Amongst the most common potential causes of mental capacity limitations are the following (this is a non-exhaustive list):
• mental health condition
• dementia
• learning disability
• developmental disorder
• neuro-disability/brain injury
• alcohol or drug (including prescribed drugs) induced intoxication.

A customer may be understood to have, or suspected of having, any of these (or other) conditions which are potential causes of mental capacity limitation (for example, a mental health condition) – but that does not necessarily mean that they do not have the mental capacity to make an informed decision.

In some instances, it may constitute disability discrimination for the purposes of the Equality Act 2010 (EA) to decline a customer’s application for a product on a presumption that he doesn’t have the mental capacity to make a decision based solely on the knowledge that he has a condition of the type listed above

FINANCIAL LITERACY

Mental capacity is not the same as financial literacy

– although, in practice, it may often be difficult for the firm to differentiate a limitation of one from a limitation of the other. In terms of a limitation of mental capacity, the customer has some impairment of mind or brain function.

There are only likely to be limited circumstances in which the firm will have substantive evidence that a customer has such an impairment and, in the absence of such evidence, can reasonably be expected to (proactively seek to) establish whether a customer has such an impairment of mind or brain function.

In the alternative, a limitation in financial literacy is likely to result from inadequate financial education rendering a customer unable to, or feeling insufficiently empowered to, manage his finances, engage confidently with firms, and make informed financial decisions.

Those with limitations in financial literacy and those with limitations in mental capacity can both be classified as groups of actual or potentially ‘vulnerable customers’ by their respective limitations. Given that customers with either form of limitation (or both forms) might have difficulty making informed decisions – rather than taking steps with a view to seeking to differentiate between the two categories of persons the firm will apply its vulnerable customer’s policy in both circumstances.

IN SUMMARY

While acknowledging that there are limits that the firm can reasonably be expected to go to in seeking to form a view as to whether or not a customer has, or may have, some form of capacity limitation, it is good practice in literature provided to customers prior to providing a product or service to invite customers to disclose (on a voluntary basis) whether there are any issues relating to their health or general well-being which may be relevant to the consideration of any product or decision by the firm.

Any such invitation should make very clear that the only purpose such information would be used for would be to better facilitate an informed service being provided.

If a customer provides information which indicates that he does, or may, have some form of mental capacity limitation that might impact on his ability to make an informed decision, this should not lead to him automatically being denied access to the product or service being sought.

It should act as a trigger for the firm to consider what reasonable steps might be taken to amend its ordinary processes to ensure that the customer is treated fairly and a positive outcome results for the customer.

Definition of a complaint

Any expression of dissatisfaction from or on behalf of a customer whether oral, electronic or written and whether justified or not WHICH includes an actual or potential financial loss, material distress or material inconvenience.

Note that if there is any potential for financial loss or material distress or inconvenience then however vexatious the complaint may appear, it must still be treated as an ‘eligible’ complaint and dealt with in line with the regulatory rules that apply if the complaint is about any form of regulated business.

There are of course complaints that are made which relate to minor inconveniences; inconsequential distress and no financial loss and these can be called ‘soft’ complaints as opposed to eligible or ‘hard’ complaints.

If you are unable to establish the nature of the complaint or if you have insufficient authority to make this decision then the matter must immediately be referred to your line manager or the complaints manager without delay.

The procedure

Any complaint verbal or written must be referred to our complaints manager at the earliest opportunity or to a member of the senior management if the complaints manager is unavailable. All emailed complaints should be sent to complaints@acrobat.uk.com. It is essential that whoever is dealing with the complaint sends our initial response letter to the complainant promptly using our set template and adding the details known about the complaint.

Following this, the matter must be passed to our complaints manager for investigation.

Complaints about product providers/advisers/sales staff

Clients may express dissatisfaction to us about a product provider, sales staff or an adviser and although the issue may not be our fault we need to be clear about whether the client wishes us to help complain to a third party or whether the client wishes to complain about us; if in doubt we must proceed as if the complaint is about us initially. We then need to establish whether or not the complaint does relate to us or our services or the service or performance of the third party. If this is unclear, this must not delay investigation and we will proceed with our own investigation. The Complaints Manager will review this matter and take the complaint to the provider if appropriate and inform the client accordingly.

Investigation

The Complaints Manager needs to establish the nature and scope of a complaint having due regards to the Financial Conduct Authority’s direction:
• Deal with complaints promptly and fairly
• Give complainants clear replies and, where appropriate, fair redress

It is important that our Complaints Manager receives full cooperation from all staff in this investigation. The complaints manager may also contact the complainant to gain further clarification of information. This can be done via telephone, email or any other appropriate means of communication and the process can begin before the complainant receives the initial response letter.

At this point the complaint must be entered into the complaints log and a complaint record must be created.

Eligible complainants

It is the firm’s policy to treat all complainants the same, however, eligible complainants are legally defined and have additional rights in law that we must acknowledge and adhere to. We have elected to treat all complaints in the same way for simplicity. Sometimes we may not know if a complainant is ‘eligible’ in which case we must treat them as such and if it becomes necessary, the Financial Ombudsman Service will establish the status of the complainant, not us.

Eligible complainants refers to people or entities with potential entitlements to claim against a firm in circumstances where they have suffered a financial loss due to poor advice or services. In order to be treated as ‘Eligible Complainants’ the Complainants must be:
• Private Individuals or
• Companies within the EU definition of a microenterprise or
• Charities with an income of under £1,000,000 or
• Trustees of a trust with assets of under £1,000,000 AND
• Their complaint must fall under the jurisdiction of the FOS and must therefore arise out of one of several listed relationships in DISP 2.7.6

The Financial Conduct Authority complaints rules apply to complaints:
• made by, or on behalf of an eligible complainant;
• relating to regulated activity;
• involving an allegation that the complainant has suffered, or may suffer, financial loss, material distress or material inconvenience;
• not resolved by close of business on the day following receipt.
• The Rules give firms a maximum of 8 weeks to issue a final response to the complainant and we require that this practice is followed for all complaints. It is also important and courteous to keep complainants informed of progress and we will do this by writing to them after four weeks if we have not reached a decision using the holding letter template. More holding letters may be given at the discretion of the Complaints Manager

Timescales

Letter Timing
Initial response letter Promptly: by the next working day unless there are exceptional circumstances.
Holding letter Optional until the eighth week
Final response By end of the eighth week after the receipt of the complaint in all cases, but sooner whenever possible. If, exceptionally, a full response is not possible by this time we must send out a holding letter explaining why we have not been able to issue a decision within the above time frame and when we expect to be able to provide a decision. You should however note that it is a requirement that final responses are issued by the end of eight weeks after receipt of complaints.

Holding letter

When the investigation has not involved a continuous dialogue the complaints manager may issue a holding letter after four weeks if the complaint remains outstanding.

Final response

This must clearly set out, in writing, the following:
• whether we accept or reject the complaint
• where applicable, the reasons for rejecting any complaint
• where we accept the complaint, and intend to offer redress or remedial action, details of the redress to be offered, any compensation offered and a clear method of calculation has to be shown.

Additionally where the client is an ‘eligible counterparty’/potential ‘eligible counterparty’ we must:
• explain that where the complainant disagrees with the firm’s decision they must refer the matter to the ombudsman within six months of the date of this letter or the right to use this service is lost and
• enclose a copy of the Financial Ombudsman Service’s standard explanatory leaflet

The final response template should be used and the complaints log and complaint record must be updated with the final decision including details of the amount of any redress offered.

Closing a complaint

Where we receive confirmation from the complainant that he or she is satisfied with our final response, the complaint, subject to any redress payment being made or remedial action taken, will be marked as closed.

Where no confirmation has been received from the complainant within 8 weeks of the firm’s most recent letter, the complaint may also be considered closed. This is regardless of any subsequent communication via the Financial Ombudsman Service

Our commitment to you

We want to ensure that your experience with us is one that you will feel warm about for years to come.

Here are just some of the ways we will help to keep you warm inside

Informed
Just like you, we hate any nasty surprises. That’s why you should never have to call us for information, as we will have contacted you first. We will always endeavour to keep you in the loop about what is happening next at your home, and to hold your hand every step of the way.

Important
We value each and every one of our customers. That’s why we assign you your very own Resident Liaison Officer. No matter what the issue, they are here to help.

Respect
We promise to always treat you with kindness, dignity and respect. We will also listen to your needs and accommodate your personal circumstances in all that we do. In return, we ask that the same respect is also shown to our people.

Constant Improvement
Whilst other companies strive for perfection, we see it as being the bare minimum. We don’t stop there though; we are always seeking ways in which we can improve our services further for you.

Clarity
We only promise what we can realistically achieve, and aim to provide you with information that is both clear and concise. Our people will always carry ID badges.

Satisfaction
Your home is very important to you and your family, and we will respect that. We will ensure that work is carried out to the correct standards and check in with you frequently to get your feedback as to how it is going.

Safety
Protecting the health and safety of you, and anyone else at your home are our first priority and we will never compromise on that.

Responsible
Our approved contractors are responsible both to their commitment to our customers and to this charter. We will always work responsibly in everything we do and ensure anyone working on our behalf does so as well.

Our aim is to be recognized as the best at what we do by exceeding our customer expectations with innovative, reliable, value-added products and services when and where needed. To achieve this we have developed an integrated management system covering the requirements of ISO 9001, ISO 14001 and OHSAS 18001.

The organisation commits to the prevention of pollution, injury and ill health by complying with the requirements of the ISO and OHSAS standards and all applicable legislative and regulatory environmental, occupational health and safety and any other relevant requirements.

The organisation commits to continually improve the effectiveness of the integrated quality, environment and health and safety management systems and its on-going performance.

The organisation sets its objectives and targets annually and reviews these, and this policy, regularly to ensure they are still relevant and appropriate.

This policy has been shared and understood by all personnel working in the organisation and is communicated to all personnel working on behalf of or under the control of the organisation.

This policy is available to the public and any stakeholders or interested parties on the company website or by request.

Want to know more

Get in touch today
0161 672 5430