TPI Code of Practice
Third Party Intermediary (TPI) Code of Practice For Micro-Businesses. Setting the benchmark for responsible, transparent, and high-quality utility consultancy.
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What is the TPI Code of Practice?
The TPI Code of Practice is a set of standards that sets the benchmark for responsible, high quality TPIs acting as intermediaries between micro-business customers and suppliers.
By signing up to this Code of Practice, TPIs agree to:
- Be bound by it and by any decisions taken under the Code by the Code Manager.
- Make sure their people (including any third parties they use) understand and comply with it.
- Tell customers they're providing their service according to the Code and where they can find it.
- Uphold the public image and reputation of the energy industry.
1 Third Parties
1.1 Responsibility: If the TPI uses a third party, it's their responsibility to make sure that anyone working on their behalf understands and follows this Code. Any actions of the third party are deemed to be the action and responsibility of the TPI and this is relevant throughout all principles laid out in this Code.
1.2 Records: The TPI must keep details of any third parties they use. They must share them with suppliers, regulators, the Code Manager, the Independent Code Panel and their representatives, if asked. TPIs must issue any third parties they use with unique identifiers that they must share with suppliers and upon request with regulators, Code Manager and the Independent Code Panel. The TPI must have a robust, continuous screening and selection process in place.
2 Recruitment
2.1 Hiring: TPIs must be able to show that for each of their sales representatives they have gathered employment and training history, obtained professional references, and obtained Criminal Record Bureau checks (field-based representatives only) for any new staff and identify when appropriate action is required.
3 Training
3.1 Training: TPIs must have an effective training programme in place. They must show all representatives have gone through thorough induction and assessment before providing services, updated regularly in line with laws and market regulations.
3.2 Assessment: TPIs must assess representatives before providing services and at least once a year thereafter. Assessments confirm understanding of products, Change of Tenancy rules, identifying micro-businesses, treating vulnerable customers, Code compliance, Data Protection Act, and Ofgem Standards of Conduct (SLC 7a & 7b).
3.3 Records: TPIs must maintain comprehensive training and assessment records for each representative.
4 Staff Records
4.1 Records: TPIs must maintain records for each representative (name, address, DOB, employment period) making each sales contract traceable to an individual representative under the Document Retention Policy.
5 Sales Material
5.1 Honest, accurate and transparent: Sales materials and web-based tools must be written in a simple, accurate and transparent way with zero false or misleading information.
5.2 Quotes: Quotes must be based on up-to-date information obtained from suppliers and customers, explain calculations clearly, and include all principal contract terms.
5.3 Sample copies: Copies of sales materials must be shared with regulators, Code Manager, Independent Code Panel, and relevant suppliers upon request.
6 Responsible Selling
6.1 Identification: Representatives must clearly state their name, TPI business name, reason for contact, and that they work for a separate company, not the supplier.
6.2 Nuisance calls: Representatives must respect the customer's right to say no and immediately cease contact if requested.
6.3 Contact details: Full contact details including a direct phone number must always be provided.
6.5 Diversity & 6.6 No Pressure: Zero high-pressure sales tactics. No exploitation of customer inexperience or vulnerability.
6.7 Transparent terms: Clear explanation of contract length, standing charges, unit kWh prices (fixed/variable), payment methods, and supply start dates.
6.8 Records: Records of every quote and sale must be maintained for at least 12 months (or 12 months after contract end date).
7 Relevant Laws and Regulations
TPIs comply with Ofgem Supply Licence Conditions 7a & 7b, Data Protection Act, AUDDIS, Business Protection from Misleading Marketing Regulations 2008 (BPMMRs), Employment Law, MRA (Electricity) and SPAA (Gas) supplier transfer frameworks.
8 Data Protection
8.1 Data handling: Registration as a Data Controller with the Information Commissioner (ICO), secure handling and destruction of records, and accurate Direct Debit collation.
8.2 Marketing consent: Full screening of customer records against TPS, CTPS, MPS, and EC Directives.
9 Change of Tenancy (COT)
9.1 Genuine Verification: Ensuring genuine COT evidence is gathered and retained. COT must never be misused to circumvent binding contracts.
10 Supply Contracts and Submission
10.1 Fairness: Ensuring customer understands legal contract formation, supplier credit checks, and termination obligations.
10.2 Verbal contracts: Full unedited call recording of verification scripts retained for the entire contract duration.
10.3 to 10.5 Submissions & Rejections: Secure transmission protocols and immediate customer notification in case of contract rejection.
11 Customer Contracts and Consent
11.1 Content: Clear terms regarding agreement duration, fees, complaints process, and supplier commissions.
11.2 Letter of Authority (LOA): Clear, documented or recorded LOA explicitly defining the scope of authority granted by the customer.
12 Sales Commission
12.1 Transparent fees: If commission is received, services must not be marketed as "free". Upon request, TPIs explain commission structures (one-off, price uplift) and provide written disclosure within 7 days if requested prior to agreement.
13 Complaints Handling
TPIs maintain a published, transparent complaints process aiming for 24-hour resolution, logging all expressions of dissatisfaction, providing written updates, and informing customers of their right to escalate to the Energy Ombudsman after 8 weeks or deadlock.
14 Systems and Controls
TPIs maintain internal compliance monitoring systems, complete annual self-assessment questionnaires for suppliers, and cooperate with independent audits.
15 Roles and Responsibilities
Defines the governance framework involving the TPI, Energy Suppliers, Code Manager, Independent Code Panel, and Independent Auditors.
16 Breaches and Sanctions
Classification of minor and major breaches. Sanctions range from written warnings to temporary suspension and formal expulsion (minimum 12 months) from supplier panels.
17 Glossary of Terms
Definitions of key regulatory and commercial energy terms: