Marketing Codes of Practice

Overview

Vayu Limited (“Vayu”) is a supplier of natural gas and electricity to business Customers.  We offer businesses real alternative to other energy suppliers currently operating in the ROI.  The aim of any marketing campaigns undertaken by Vayu is to:

  • Win new Customers
  • Communicate clearly with our existing Customers
  • Promote awareness of the Vayu brand
  • Compete with other energy suppliers in Ireland

Set out in this code of practice on marketing and sign up (the “Code”) are the rules by which Vayu governs itself and its employees regarding any marketing procedures to protect our Customers against unwanted, unfair or misleading marketing methods.  Within the Code are the following conditions:

  • Vayu will adopt a transparent and fair approach to the marketing of our products and services. This includes printed material, information on websites, twitter and LinkedIn and in the manner in which we sign up Customers.  No Vayu representative shall provide misleading information nor shall we apply any undue pressure on any person in order to gain/retain business.
  • Vayu will prepare marketing material that is jargon free, easy to understand, accurate and clearly states the product on offer and the time period it covers.
  • Vayu does not currently offer tariffs to Customers, but if we did so in future the information on the comparison of these tariffs and charges to those of our competitors will be dated to show when all tariffs were in place. Any comparison made will be done on a like for like basis and Customers will also be made aware that competitor tariffs and charges are subject to change. If Vayu is aware that competitor tariffs are due to change within three months of the comparison, we will notify Customers of this.
  • If Vayu offers a Customer a discount on a tariff or on that of a competitor, those discounts will clearly set out any difference in all charges, including any standing charges the Customer will have to pay.
  • Vayu will highlight on any sales literature and make Customers aware that components of a fixed rate charge are, or could be, subject to change.
  • Vayu will ensure that our employees or agents employed on our behalf, do not misrepresent the company or portray competitors in a negative or inaccurate way. Furthermore, Vayu’s employees or agents will not exploit a person’s inexperience or vulnerability when sending marketing material to a potential/current Customer.

Marketing Information

Vayu will carry out marketing campaigns using one or more of the following channels:

  • Telesales
  • Face-to-face selling/contact
  • Email, SMS and social media (eg. twitter, facebook)
  • Direct mail campaigns
  • Print advertising
  • Online advertising

Telesales

Upon making a marketing related telephone call, the Vayu employee will clearly state as soon as practicably possible:

  1. His/her name
  2. Vayu’s name
  3. The purpose of the call
  4. Contact number (if requested by the Customer)

If, at any time during the call, the Customer does not wish to continue with the call, the caller will cease the phone call immediately without attempting to change the Customer’s mind.

If told that the Customer does not wish to be contacted again by Vayu for telesales, Vayu will adhere to this and place the Customer on their ‘not for contact list’.

We will use the Telephone Preference Service (“TPS”) to ensure we do not make any unsolicited sales or marketing calls to phone listed on the TPS register.

Vayu will exercise reasonable judgement outside the Customer’s normal business hours before contacting the Customer.  Vayu will follow up the telephone contact by providing a copy of our Customer Sign Up Checklist (for the Customer to keep) prior to the commencement of the sales pitch.  This is to give assurance to the Customer that Vayu has followed the correct procedure (see Appendix A);

Regardless of whether a Customer sign up has occurred or not, Vayu will maintain records for not less than 2 years including the date of contact with the Customer.

Face-to-Face Selling/Contact

Vayu will often engage a Customer in person or at a Customer’s premises, generally by appointment. However, if this occurs without a prearranged appointment and if the Vayu employee(s) in question has not previously visited the Customer’s premises, she/he will:

  1. Be courteous and professional at all times;
  2. Produce an identity card detailing their full name, photograph and Vayu’s name, address and contact details;
  3. Inform the Customer what is the purpose of the visit/contact and enquire if the Customer wishes to proceed with the visit;
  4. Leave the premises/cease contact with the Customer if he/she does not want to continue further with the visit/contact;
  5. Exercise judgement and common sense when it comes to contacting Customers outside of normal business hours (Vayu are aware that business hours do vary between business consumers); and
  6. Will take all reasonable steps to ensure the Customer receives written information by post or electronically within 7 days of entering into the energy supply agreement.

Email, On-line Advertising, SMS and Social Media

Vayu may market to Customers through online advertising, email, SMS, twitter and linkedIn for direct marketing purposes, which will be in line with appropriate data protection legislation and regulations.

Email

Where Vayu markets to a Customer via email, Vayu will provide the following information in the email:

  1. Vayu’s name and address;
  2. Vayu’s email address or any other form of electronic contact;
  3. Vayu’s contact phone number; and
  4. An easy and free method to be removed from any future marketing via email (unsubscribe link).

SMS

Where Vayu markets to a Customer via SMS, we will provide the following information in the SMS:

  1. Vayu’s name;
  2. An easy and free method of unsubscribing/removing the Customer’s mobile number from any future marketing via SMS at no cost to the Customer; and
  3. Vayu’s contact phone number.

Social Media

Where Vayu markets to a Customer via twitter or linkedIn, we will provide the following information:

  1. Vayu’s name and address; and
  2. Vayu’s twitter and linkedIn address.

If told that by the Customer they do not wish to be contacted again by Vayu through social media, we will adhere to this and place the Customer on our ‘not for contact list’.

Direct Mail Campaigns

  • Where Vayu markets to a Customer via direct post, we will ensure all marketing material and information is jargon free, easy to understand, accurate and clearly states the product on offer and the time period it covers.
  • Vayu does not usually offer tariffs to Customers, but if we did so in future the information on the comparison of these tariffs and charges to those of our competitors will be dated to show when all tariffs were in place. Any comparison made will be done on a like for like basis and Customers will also be made aware that competitor tariffs and charges are subject to change. If Vayu is aware that competitor tariffs are due to change within three months of the comparison, we will notify Customers of this.
  • If Vayu offers a Customer a discount on a tariff or on that of a competitor, those discounts will clearly set out any difference in all charges, including any standing charges the Customer will have to pay.
  • Vayu will highlight on any sales literature and make Customers aware that components of a fixed rate charge are, or could be, subject to change.
  • If told that by the Customer they do not wish to be contacted again by us through a direct mail campaign we will adhere to this and place the Customer on our ‘not for contact list’.

Privacy and Data Protection

Vayu respects the privacy of our Customers and potential Customers. If at any time a Customer or potential Customer indicates to us orally, in writing, via email or any other means that they no longer wish to be contacted for marketing purposes, we will log their request and remove the Customer from our marketing database. If requested by the Customer, we will also provide a Customer with written proof they have been removed from our marketing database.

Vayu, in accordance with the Data Protection Acts, 1988 and 2003 and the ePrivacy Regulations 2011, will treat in confidence any personal information collected for marketing purposes. Any information that is collected will not be made available to third parties except in accordance with applicable laws and regulations.

Special Promotions

Where Vayu offers special promotions on our products and services, we will make the current or potential Customers aware of any time limits that are associated with the promotion. We will also bring to the attention of our current or potential Customers of any changes in conditions that will occur once the period of the special promotion elapses or any additional terms, conditions or charges which may be associated with the promotion in advance of the Customer signing up for it.

Prior to signing up a Customer, we will make clear to the Customer if there are any intended changes in tariffs or terms and conditions, which will come into effect once the promotional period has ended. If charges are not known at the time of sign up, Vayu will notify the Customer in advance of any changes, no less than 30 days before the changes come into place or in line with terms and conditions set out in the supply agreement.

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