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The Consumer Protection Principles are the minimum standards of practice consumers should expect from an off-grid solar company. Making a Commitment to the Code signifies that the organisation is aligned to the Principles of the Code in spirit.
The CP Core is an entry point for Consumer Protection including 15 CP Indicators across 7 CP Principles and is applicable to smaller, early-stage companies to facilitate prioritization of good practices.
The Board or Senior Leadership reviews the company’s alignment with – and holds Management accountable to the company’s institutional management KPIs, including:
to ensure continued assessment, improvement and fulfillment of good consumer protection practices.
All relevant staff, including management, and (non-staff) sales agents are trained on the relevant Consumer Protection Principles and Indicators at onboarding and refresher trainings.
Consumers are informed of key terms and conditions of the contract including:
Customers are informed of the key information verbally and via a Key Facts Statement.
Consumers receive payment confirmation and updated remaining balance after making a payment, unless they opt out. Consumers are able to access their transaction history upon request.
Financial obligation depends on contract type, duration, amount, downpayment and other elements of the payment plan. Level of risk depends on the consumer’s income and its volatility, household composition and other family circumstances, vulnerability to (financial) shocks and other risks that may result in the financial obligation overburdening the consumer.
Assessment should be proportionate. For example, very low cost systems may present low risk to even the poorest households and thus require lower levels of assessment, whereas higher-cost systems may prove a burden even for households with moderate incomes and thus require more detailed assessments.
The assessment required may be conducted in a variety of ways, including: detailed credit processes in the field, call center verification calls, technology-driven decision making, collection of downpayment, as well as other models. Combining multiple approaches significantly strengthens the quality of the assessment.
Research has shown that credit scoring (tools and human centred) are often inherently bias agains women (who are more likely to repay but more likely to be rejected). Providers should test their systems for such bias and take actions to mitigate this.
This indicator is not applicable for cash sales.
Incentives can include (but are not limited to) commissions based on payment quality, requirements for customer quality threshold to maintain sales status, adherence to a credit checking policy. Monitoring can include monitoring of repayment quality and customer feedback by agent, internal audit of field operations. Sanctions can include loss of commission, firing, up to and including referal to criminal investigation for serious fraud and other criminal actions.
For staff with primary responsibility for assessing Ability to Pay and not sales (e.g. call center), if compensation is incentivised, such incentives should not be dependent on the outcome of those assessments.
Explanatory note: The provider recognises that calls with customers during and after the sales process, including verification, onboarding and other welcome calls, are a key control point for ensuring consumer protection. If the consumer cannot be reached for such calls, the provider retains a log of that attempt and takes all reasonable efforts to reach that consumer, including an in-person visit if necessary.
The company offers a warranty length of:
Explanatory note: The warranty entails timely repair or replacement in cases of a defect occurring which could reasonably be expected to be the responsibility of the manufacturer or provider. Refer to IEC 62257-13-1 for more detailed guidance.
In the event the payment period is longer than the warranty length (due to delinquency, rescheduling, or other reasons), consumers are given a reasonably priced option to purchase an extended service contract (including warranty) to cover the remaining payment period.
Assessment should be proportionate. For example, very low cost systems may present low risk to even the poorest households and thus require lower levels of assessment, whereas higher-cost systems may prove a burden even for households with moderate incomes and thus require more detailed assessments.
The assessment required may be conducted in a variety of ways, including: detailed credit processes in the field, call center verification calls, technology-driven decision making, collection of downpayment, as well as other models. Combining multiple approaches significantly strengthens the quality of the assessment.
Research has shown that credit scoring (tools and human centred) are often inherently bias agains women (who are more likely to repay but more likely to be rejected). Providers should test their systems for such bias and take actions to mitigate this.
This indicator is not applicable for cash sales.
Repairs shall be made in accordance with the designated timeline in the contract during the warranty period and for a reasonable period of time post-warranty.
The provider will endeavor to have sufficient inventory of spare parts.
Explanatory note: The de-facto industry standard for Pico-PV products up to 10W and plug-and-play Solar Home System Kits from 10W to 350 W is IEC 62257-9-5 and IEC 62257-9-8 (developed by Lighting Global/Verasol).
Component-based systems consist of certified components (where standard is applicable and available). The system has been appropriately designed, and installed by a qualified technician. Technicians can be deemed qualified if they have been appropriately trained and/or assessed by the provider or a recognized 3rd party organization.
Appliances are certified according to the appropriate IEC standard (or other).
Excluded: when an individual’s data is anonymized or aggregated in a manner that it cannot be traced back to the individual.
Legitimate interests cover any need to provide, develop and improve products and services to consumers. Financial vehicles that require non-anonymized consumer data (such as securitizations) constitute legitimate interests. However, monetizing consumer data through data sale, not linked to the company operations (for example, to 3rd party advertisers) is NOT considered legitimate interest.
Partners, service providers and sales agents may collect, use and store personal data to fulfil the consumer service and business needs; data privacy agreements should govern their data practices. A data register is recommended practice to help companies establish legitimate interest and data minimisations.
Fraud includes: engaging in bribery, extortion and other forms of corruption, misinforming or misleading consumers, coercing consumers, providing false information to the consumer or provider, changing consumer data after onboarding, and any other subversions of the sales process.
The provider may use a variety of mechanisms to address fraud, including: code of conduct, training, complaints handling procedures, random checks and controls, whistleblower policies and sanctions up to and including referral for criminal prosecution.
Full compensation includes refund of downpayment where appropriate.
Repossession can carry a social and emotional burden to the consumer and the household. As with many key household assets, forfeiture and repossession signals an irreparable failure in the company-consumer relationship and socially responsible companies must treat it as a rarely-deployed option reserved for a small minority of unresolvable cases.
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