Codes of Practice
Sales & Marketing
This code of practice (hereafter referred to as ‘the Code’) governs activity related to the selling and the marketing of the Sky Talk telephony service. The Code is designed to ensure that all individuals to which such selling or marketing is directed receive protection over and above that provided by the law, and to reinforce best practice and responsible selling by our representatives. The Code provides a clear framework to which all Sky Talk sales agents must adhere. Sky Talk Sales agents are referred to throughout the Code as ‘Agents’.
Compliance, or non-compliance, with the Code does not affect compliance with any legal requirement or the validity of any contract between Sky Talk and its customers, unless otherwise provided by law.
2 Sales, marketing advertising and promotion
2.1 At all times Agents should act responsibly and in compliance with the Code and all other applicable laws and regulations.
2.2 Prior to contacting customers, details should be checked for registration on relevant preference services, including the Mailing Preference Service, the Telephone Preference Service and the E Mail Preference Service.
2.3 All Sky Talk advertising and promotion should comply with the British Codes of Advertising and Sales Promotion. In particular it should be clear, unambiguous, accurate, fair, containing no false or misleading information about price, value or service and should not denigrate other telephony providers.
3 Recruitment and sales training
3.1 Agents involved in direct contact with customers for the purposes of selling or marketing the product will be recruited and trained in accordance with Ofcom guidelines and current employment legislation
In recruiting sales staff we have regard to:
• behaviour and appearance;
• security; and
• evidence of mis-selling or lack of integrity in any previous selling employment
In addition we require:
• Agents to provide proof of their NI number, proof of address and two references;
• A retention of a copy of the Agents sales records for a minimum of 6 months after they have left the company and the return of any identification badges.
Once Agents are recruited we endeavour to ensure that every such Agent is trained so as to have sufficient understanding that any relevant advice given by such Agent is not misleading. Topics covered in training include:
• how competition in telecommunications works in the UK;
• what telephone services Sky Talk provides and how these differ from other competitive telecoms products;
• the process of ordering the telephone service;
• the relevant principles of consumer protection law;
• Sky Talk’s prices and other terms and conditions of service and, in particular, methods of payment, duration of contract and any termination fees;
• the nature, and cost, of any additional services on offer;
• the process for cancelling the contract both during the cooling-off period and at any time following commencement of the service; and
• the procedure for handling customer complaints
3.2 The remuneration system for Agents is such as not to encourage misleading or exploitative sales practices. Further Sky Talk requires that agencies it employs for sales and marketing inform it of any incentive schemes they may from time to time introduce.
3.3 Responsibility for all Sky Talk representatives complying with the Code lies with Sky Talk. Our designated person responsible for ensuring we and our Agents observe the Code is:
Operational Compliance Manager
Telephone: 01383 814000
4 Customer Contact
4.1 No Agent should contact any customer outside the hours of 08:00 to 21:00, unless specifically asked to do so by the customer.
4.2 At the outset of a sales call, Agents should state their name, the fact they are calling on behalf of Sky Talk, the purpose of the call, and the approximate likely duration.
4.3 When engaging with the customer, all Agents should be courteous, use appropriate language and offer clear and straightforward explanations and convey information accurately. Agents should ensure that customers entering into contracts understand, and intend them.
4.4 Agents should end contact with any person who indicates that the contact is inconvenient, unwelcome, inappropriate or too long.
4.5 Sky Talk operates a vulnerable customer policy to ensure that the trust of vulnerable customers is not abused. During telephony contact, or on any other occasion where there is no face to face contact, Agents should not progress a sale where they believe that the particular customer was not capable, at the time of the contact, of making an informed decision as to whether or not to enter into the sale.
4.6 No sales activity should be undertaken to those who are under the legal age for entering into contracts.
4.7 Sales and marketing campaign records should be retained for six months to assist in dealing with any related complaint or query.
5 Entry into a contract
5.1 Agents will be instructed to take reasonable steps to ensure that on each occasion that a sales call is made, the customer has authority to enter into the Sky Talk contract, should they so wish.
5.2 Where an Agent has made a direct sales approach and a sale has been agreed, we will send you in writing clear information on:
• Sky Talk’s appropriate contact details including telephone, email address and Live Chat
• A full description of the telephone package chosen, how it works, costs involved and payment details
• The arrangements for the provisioning of Sky Talk, including the order process and the expected date of activation
• The right to cancel and the process for doing so
5.3 Customers may cancel their Sky Talk order or contract by telephone, in writing, by e-mail or by Live Chat.
5.4 Customers have the right to cancel their Sky Talk order, at no cost, between the time the order is submitted, and the time it becomes active on their account.
6 Consumer protection and other legal requirements
6.1 All Sky Talk sales and marketing procedures should comply with all applicable legislation.
7.1 Sky Talk will endeavour to carry out regular audits of systems, procedures and documentation to ensure compliance with all aspects of the Code.
8 Awareness of the Code
8.1 This Code is available free to customers upon request by post, and is also available on www.sky.com/skytalk
8.2 This Code is also available at the head office of the Citizens Advice Bureau, Myddleton House, 115-123 Pentonville Road, London N1 9LZ.
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