Kingfisher Utilities – Code of Practice for TPIs

Forward by Ian Sinclair, Director of Kingfisher Utilities.

The importance of good governance is key to earning this trust and enhancing the reputation of Kingfisher Utilities within the TPI market. That’s why I am delighted to support this Employee Code of Practice, which focuses on the key principles that our staff should follow and why. This document provides clear information about what those principles imply in practice.

I require all employees at all levels of the business to read, understand and follow these principles based on our core values. Therefore, the document should be signed by each employee, witnessed by a senior member of staff and then kept on the desk to remind all staff of their obligations and commitment.

Development of TEC Employee Code of Practice

Kingfisher Utilities operating as a Third-P arty Intermediary (“TPI”) as defined by Ofgem, the energy regulator, play a vital role in procuring energy and energy solutions for many B2B customers in the UK energy market.

With increased scrutiny from regulators and industry bodies, along with increasing customer expectations, TPIs carry an important responsibility to manage their organisations and deliver on their objectives in a way that enhances their customers’ trust and support.

This Code has been drafted based on similar best practice codes from energy suppliers, with input from consultations with key business partners. This Code of Practice will help ensure that we deliver to our customers a compliant, consistent customer experience which enhances the reputation of our business and the sector.

Our Core Values

Our core values have guided and formed our organization throughout the years, and we strive every day to maintain these qualities consistently throughout the business. We do everything possible to execute them in our work, our associations with our partners, customers, and service providers.

Honesty – Whenever we talk, or write to our customers, we must identify ourselves as working for Kingfisher Utilities. As energy saving experts, we will make sure all information is factually correct and presented clearly and always ask for permission to liaise with any other party on our customers’ behalf if necessary.

Respect – We’ll make sure we respect the thoughts and wishes of our colleagues, suppliers, and those of our customers.

Accuracy – We will always check our facts and present our offers and services to businesses in the most accurate way possible.

Transparency – We’ll provide transparent information to our customers, making sure they’re fully aware of the benefits of our service for their business.

Professionalism – We have been trained to deal with our customers professionally. We all abide by our Employee Code of Conduct which provides us with guidance in the standards which are the minimum expected of an energy saving expert.

Customer Focused – Customers are at the very centre of what we do. It’s important we all make sure they always receive the highest standards of services.


The objective of this Code is to demonstrate how Kingfisher Utilities protects the interests of customers when selling non-domestic energy products and other services. To help with this, we have developed four principles to ensure that sales of non-domestic energy products to customers are conducted in a fair, honest, and transparent way:

These principles are:

Principle 1: Accurate and Complete.
Principle 2: Presented in a full and professional manner
Principle 3: Understood by our Customers
Principle 4: Proposal must be appropriate for that Customer

Under each principle we have identified the standards that each of our customers may expect from Kingfisher Utilities.

We require all our sales agents, account managers and TPIs who make sales on behalf of Kingfisher Utilities to take all reasonable steps to interpret and apply the contents of the Code in a manner consistent with the objective and above four principles.

Kingfisher Utilities compliance team, which sits separately to our sales function, will carry out monitoring and assurance activity for the sales team internally and for TPIs in order to give assurance that the principles are being consistently complied with.

Principle 1 – Accurate and Complete

During the sales process, all non-domestic customers can expect to receive accurate and complete information to help them make an informed decision. Kingfisher Utilities expects its sales agents, account managers and TPIs to provide information about the non-domestic energy product being offered in a way that is not misleading, before the contract is entered into by the Customer.

Why? The impacts of not doing so could mean that the customer decides based on incorrect information in transferring their gas or electricity to the new Energy Supplier

This includes:
What does this mean?


Ensuring that an accurate annual consumption has been established for the customer.

Other additional charges

Explaining any additional charges that may apply, e.g. Meter Operator charges for when a half-hourly meter is required.

Credit checks

Informing the customer that a credit check will be performed and who/when it will be performed on (where applicable).

Security deposit

Explaining any requirement for a security deposit (including amount) following a failed credit check.

Price events or payment method changes

Explaining that variable prices may change at any time and where customer can find latest prices. That elements of the variable ma y increase over a fix ed resulting in higher bills.


Requirement for the customer to pay charges through a prepayment meter (where applicable).

Consequences of non-payment

Explaining the consequences if the customer fails to pay, e.g. supplier rights to object to them switching supplier if they have an outstanding balance and pursuing them for the outstanding debt.

Contract term

Providing the duration of the contract term including an explanation that the supplier contracts are continuous, any initial fix ed term periods which apply as well as an explanation as to what happens when the customer terminates the contract and the charges that will apply if the customer continues to take supply following the initial fix ed term period.

Contract renewals

Explaining the process for renewing or extending a contract (including that variable price may apply after the expiry of a fixed term plan).

Termination fees

Where applicable, explaining that termination fees may apply (including the amount or the calculation) if the contract is terminated early i.e. within the fix ed term period.

Termination rights

Providing an explanation of the customer’s rights to end the contract, including whether a termination notice is required, when the contract can be terminated and when such termination will take effect.

Advanced meters

Explanation of the requirement for an AMR meter (where applicable and if one is not installed) and if they don’t allow access to change the meter, we may take action including terminating the customer’s plan and switching them to prices that are different from those agreed in the contract.

Hardwiring billing

management systems

Advising the customer that where half hourly settlement is required, and they have a hardwiring billing management system, they need to notify the Supplier of this system and that they may lose functionality.

Relevant discounts / benefits

Providing details of an y relevant discounts / benefits which apply (e.g. Direct Debit discount if applicable).

TPI services and commission

Making the customer aware of the services the TPI provides and how the customer will pay (directly or indirectly) for those services.

Principle 2 – Presented In a Full and Professional Manner

During the sales process, all non-domestic customers can expect to be treated in a way that is fair, honest, transparent, appropriate, and professional.

Kingfisher Utilities expects its sales agents, account managers and TPIs to behave and act in a way that is fair and professional and present information about the non-domestic energy products in a clear and fair way.

Why? The impacts of not doing so may mislead the customer or cause them to feel pressured into agreeing the sale.

This Includes
What does this mean?


Identifying yourself clearly and obtaining the customer’s consent before the sales conversation begins. For TPIs this means identifying your name and trading name of the organisation you represent (directly or indirectly) and obtaining the customer’s consent before providing any sale or marketing information.


Respecting the customer’s wishes, including ceasing the current contact and avoid future contact if the customer requests.

Providing information that is not misleading

Providing accurate and complete information, including not making unsubstantiated claims and including correcting any customer misunderstanding.

Personal opinions

Ensuring that personal opinions and/or advice are not expressed or used as a wa y to influence the customer’s decision.


Ensuring staff are appropriately trained for dealing with customers, adhere to, and act in a professional manner in line with these principles.

Principle 3 – Understood by our Customers

Kingfisher Utilities expects its sales agents, account managers and TPIs to provide appropriate information so that the customer fully understands the contract that they are entering into, including that it is legally binding, and to confirm that the customer agrees to do so.

Why? The impacts or not doing so are the customer may enter into a contract on the basis of incomplete of misleading information or without realising that they have done so.

This includes
What does this mean?

Principal terms

Ensuring the customer understands all the information they have been given before proceeding with the sale.

Industry Jargon

To fully explain industry jargon, to tell a customer that the prices are ‘locked-in’ should be explained as they are now committed to a new supply contract.

Legally binding

Ensuring the customer understands that he or she is entering into a legally binding contract (and has confirmed they agree to do so and have the authority to do so).

Authority to enter into a contract

Ensuring the customer representative has the necessary authority to enter into a contract.

Principle 4 – Proposal Must Be Appropriate for That Customer

During the sales process, all non-domestic customers can expect to be offered products or services that are appropriate for their individual and business requirements.

Kingfisher Utilities expects its sales agents, account managers and TPIs to offer products or services that are appropriate for the customer’s individual and business requirements. Only those products or services that are appropriate for the customer will be discussed or sold.

Why? The impacts of not doing so are that the customer may enter into a contract that is not appropriate for their individual and business requirements. All non-domestic customers can expect that they will be offered only products or services that are appropriate for their individual circumstances and business.

This includes
What does this mean?


Confirmation that the product or service is appropriate for that customer.

Customer data

Confirmation that calls are recorded and what the data will be used for (where applicable).


Obtaining and evidencing consent from the customer for retaining their data for GDPR and before discussing a customer’s account with a third party.