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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 Consumer Protection Code provides a comprehensive framework of 39 CP Indicators across 7 CP Principles to address the full range of consumer risks.
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.
The Consumer Protection Principles are widely visible and easily accessible to staff, including management, and consumers (e.g. in organization’s premises and intranet, external website, staff communication channels).
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.
In cases where the company works with partners or service providers, an agreement is in place to ensure compliance with the relevant Consumer Protection Principles and Indicators.
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.
Explanatory note: Disclosure of charges from unrelated 3rd party transactions (e.g. mobile money fees, phone credit for calls, etc.) are not required. However, if there are special charges levied as part of the product delivery itself (e.g. SIM card communication from the system), these must be disclosed.
Explanatory note: Provider seeks to ensure that prospective customers are presented with a range of appropriate products. For any multiple-payment contracts (PAYG, lease, and similar), the upfront cash value of the product (if offered) and the total cost of ownership (TCO) under the payment contract are presented side-by-side, to enable consumers to make well-informed decisions. If different payment options are offered, the consumer should be presented with representative scenarios (e.g. long-term and short-term, or high-energy usage and low-energy usage) and the TCO of each.
This can be demonstrated through compliance with IEC 62257-13-1 (specifically the Truth in Advertising requirements), or other relevant product quality standard. This applies equally to verbal and written statements to consumers.
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.
The company informs consumers (in a clear and simple way) which of their personal data is collected, stored and shared with Credit Reference Bureaus (for legitimate reasons only).
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.
• training on the specific consumer assessment tools employed by the provider;
• familiarisation with common vulnerabilities faced by target consumers;
• recognising and interpreting typical behaviours and responses of consumers to onboarding/assessment questions; and
• training on respect and sensitivity surrounding questions on income, expenditure and family contexts, including the risk of bias in decision making (e.g.,gender or other minority characteristics).
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.
Explanatory note: For companies that do NOT sell additional products or services with the original energy system as collateral, this should be marked as Not Applicable.
PURE companies consider the additional income potential (and risks) of the product in the ability-to-pay assessment to inform the cash flow analysis and suitable repayment plan.
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.
The company endeavors to design and manage its operations in a way that would enable the consumer to have continued service in the event of the failure of the company. This may entail take-over or transfer of operations to a back-up service provider, another company, unlocking the product, or other means. The company ensures that the agreements with hardware and keycode generation partners entitle them to continue to accept payments and issue tokens to consumers in the event of a dispute.
The company captures sex-disaggregated consumer feedback on its products and services and payment plan through satisfaction surveys and/or interactions with consumers (before, during and after sales, including through consumer support services). The provider uses this feedback to improve its existing or new products, services and payment plan.
The consumer is made aware of the disposal requirements of the product at end-of-life, with particular attention to the battery. The company implements a collection scheme or informs consumers about other collection options (e.g. from other agencies).
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).
Technicians may be trained by the provider or a recognized 3rd party. Support should be made available for consumers who may have difficulty installing a plug-and-play system (e.g., due to disability or other challenge).
Explanatory note: Refer to IEC 62257-9-8 (the Lighting Global standard) for more detailed guidance (specifically the consumer information requirements).
Technical specifications can be adjusted or verbally communicated to consumer groups with lower literacy levels and/or other limitations.
The user interface and payment process is appropriate for consumers (i.e. if relying on mobile network or mobile money agent this is readily accessible, and payment procedures are not unduly complicated).
PURE companies carry out a technical assessment to ensure that the product is suitable, the customer has access to inputs and markets to benefit from the product.
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.
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.
Consent is ‘meaningful’ if the provider has taken reasonable steps to be confident that the consumer genuinely understands the relevant information, and has conducted basic verification of this understanding by asking questions of the consumer.
Consent in the absence of choice (e.g., opt out) is meaningless. A person who declines such consent will not have their service impacted or in any way impaired.
Personal data (in both paper and electronic copies) is adequately protected /encrypted to minimise risk of data theft or misuse in all storage and transmission.
Prohibited behaviours include:
• using abusive language;
• using physical force;
• limiting physical freedom;
• shouting at the consumer,
• entering the consumer’s home uninvited;
• publicly humiliating the consumer;
• violating the consumer’s right to privacy;
• mistreating or discriminating consumers based on any protected categories (ethnicity, gender, age, disability, political affiliation, sexual orientation, caste, and religion);
• using intimidation or threats;
• engaging in sexual or moral harassment.
The provider may use a variety of mechanisms to mitigate and act on prohibited behaviours: code of conduct, training, complaints handling procedures, random checks and controls, whistleblower policies and sanctions up to and including referral for criminal prosecution.
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.
Explanatory note: Mechanism can be adhoc (such as discussion), structured process, and even an automated/algorithmic decision. This indicator can also be met if the payment plan has inherent flexibility that allows a consumer to miss some payments without risking repossession of their system.
If automated/algorithmic systems are in place, they should be tested for bias and mitigations put in place.
Providers who have a “catch-up” requirement (i.e. requiring customers to pay all past-due installments before energy is turned back on) should have special fall-back options to rectify the client’s contract situation and above all will avoid repossession for minimal delays (i.e. a week or less).
For consumers who die or are incapacitated during the course of the contract, the company shall strive to mitigate the financial burden on the consumer or his/her household of meeting the contract terms. This may be done by offering compulsory or optional credit-life insurance to consumers, or the provider taking a group insurance policy from an insurer.
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.
The company respects consumers’ privacy (and social norms such as gender dynamics). Whenever possible, any discussion relating to delayed payments, sanctions, or other socially awkward situations are conducted in private (including by phone).
In cases of claimed product complaint or claimed defect, there is a presumption of honest intentions on the part of the consumer. The company investigates the claim before making conclusions regarding misuse, fraud or deceit.
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