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Customer Complaint Policy

This document provides guidelines for working with customer complaints.

Contents

1. POLICY STATEMENT

2. COMPANY PRINCIPLES

3. OUR PROCEDURE

4. REMEDIAL ACTION

5. SECTIONS 56 & 75 OF THE CONSUMER CREDIT ACT

6. MANAGEMENT INFORMATION

7. COMPLAINTS REPORTING

8. DATA PROTECTION

9. FINANCIAL OMBUDSMAN SERVICES

1. POLICY STATEMENT

This policy is to demonstrate how Eco Installations Scotland Ltd, also referred to in this policy as the Firm, will manage customer complaints. All complaints will be investigated competently, diligently, and impartially so we can be sure that we are able to treat our customers fairly.

DATE: March 2026

Contact: John Kelly

Company Name: Eco Installations Scotland Ltd

Address:  8 Deer Park Avenue, Livingston, EH54 8AF

Telephone: 0800 246 1900

Email: [email protected]

John will have oversight on the customers complaint and will be the person of responsibility in relation to the FCA.

The FCA complaint handling rules, classifies a complaint as an expression of dissatisfaction—either oral or written—regarding the provision or failure to provide a financial service. Such complaints may allege the following:

  • Financial Loss: The claimant asserts that they have incurred direct financial harm due to the actions or inactions of the firm.
  • Material Distress: Emotional or psychological distress arising from the financial service issued.
  • Material Inconvenience: An assertion that the service’s failings have caused significant disruption to the complainant’s life.

The Firm will comply with the FCA requirements as detailed in the Handbook DISP 1.3.

A customer can complain to us free of charge without any barriers. A complaint could be in relation to how our staff have managed their interactions, how the product was sold to them (this could be the retail product, or the finance brokered), the products, the installation or the after sales procedure.

If the customer complains to us about a third-party product, we will follow the complaint forwarding rules, these being informing our customers if we believe that their complaint may be solely or jointly the responsibility of another firm, person, a body, or regulator.  If we have reasonable grounds to be satisfied that another respondent may be solely or jointly responsible for the matter alleged in a complaint then we may forward the complaint, or the relevant part of it, in writing to that other respondent, which we will do so promptly, informing the customer in a final response of why the complaint has been forwarded, and of the other respondent’s contact details; and where jointly responsible for the fault alleged in the complaint, it complies with its own obligations in respect of that part of the complaint it has not forwarded. As a firm we may receive a complaint via complaint forwarding. Time limits will come into effect from the date we received the complaint.

All complaints will be dealt with as a priority and in a way that respects and values the person’s feedback. It can also help prevent further escalation of the complaint.  A responsive, efficient, and fair complaint management procedure will help us achieve this.

As part of Consumer Duty, we will assess, test, understand and evidence the outcomes that our customers are receiving; to ensure that our products and services are working as we and our customers would have expected and in a way that is consistent with the Duty.

By following this policy, we will manage complaints fairly, efficiently, and effectively and as a FCA Authorised firm, we will comply with the regulations and refer to DISP 1.3 Complaint handling rules.

2. COMPANY PRINCIPLES

The customer is at the heart of everything we do, we work hard to avoid customer dissatisfaction, and believe we have a robust customer journey with all customer touchpoints adequate to provide a good service. However, we are aware that sometimes customers may be disappointed in their purchase, and we will make it a priority to resolve their concerns. We monitor our pricing structure regularly to ensure we are offering our customers a fair and competitive price and that the purchase they wish to make is suitable for their needs. Our customers are given information to aid them in making an informed decision. This information is held on file, so should they need to review it at any time they can do without delay. We are easily approachable and have received excellent feedback on our customer service support.

When preparing this complaints policy we have reviewed the customers journey and evaluated our customer’s needs. This policy ensures the following for all customers; especially those that have a complaint:

Every customer has the right to:

  • Be treated fairly and sensitively.
  • be kept informed about what is happening with their complaint.
  • and be advised of the service standards they should expect.
  • the timescale for acknowledging and responding to a complaint
  • and any right of appeal.

All staff will:

  • Be sensitive to the needs of customers.
  • treat complaints as confidential, where possible and, 
  • be accessible.

Our policy will:

  • Be open, easily accessible, and widely promoted to all our customers and those who represent them.
  • be easy to understand and use by all customers and employees and,
  • set out how to complain and how a complaint will be handled.

3. OUR PROCEDURE

We will confirm the complaint details to the customer in writing (this maybe email / text message or letter depending on the customer’s choice) within 3 working days of receipt.

If the complaint is not made by our customer, but is made on their behalf, the customers consent, preferably in writing, must be obtained in advance from the customer to deal with this third party on behalf of the customer.

Where we identify recurring problems, we will consider the scope and severity of the consumer detriment that might have arisen; and whether it is fair and reasonable undertake proactively a redress or remediation exercise, which may include contacting customers who have not complained.

Our first step is to assess whether the complaint points raised relate to us or a third-party, such as the lender who provides the loan to the customer and whether the complaint is eligible.

We will establish the nature and scope of the complaint having due regards to the FCA direction:

  • Deal with complaints promptly and fairly.
  • Give complainants clear replies and, where appropriate, fair redress.
  • If a third party is involved, liaise with them directly, ensuring our customer has given consent for us to share their data.   
  • We understand that we have 8 weeks to provide a resolution, in this time we will provide weekly updates, so the customer is aware we are working to resolve the complaint.

We will check with the customer that they are able to read our correspondence, we recognise that some oral complaints may be received in this form as the customer has a vulnerability when it comes to communication.

ELIGIBLE COMPLAINANTS

Eligible customers that have purchased goods and services using a lenders finance, are legally defined and have additional rights in law that we must acknowledge and adhere to.

The FCA rules apply to complaints that have been made by, or on behalf of an eligible complainant and relating to regulated activity that involve an allegation that the customer has suffered, or may suffer, financial loss, material distress or material inconvenience.

FINAL RESPONSE

This will set out clearly our decision and the reasons for it. If any compensation is offered a clear method of calculation will be shown. We must do this within 8-weeks of receipt of the complaint.

We will let the customer know if we:

  • Accept the complaint and, where appropriate, offers redress or remedial action; or
  • Reject the complaint and gives reasons for doing so.

We will explain to the customer that they must refer the matter to the Financial Ombudsman Service within six months of the date of the final response letter or the right to use this service is lost.

If in the event of not concluding the complaint we will explain why we are not in a position to make a final response and indicate when we expect to be able to provide one. We will inform the customer that they may now refer the complaint to the Financial Ombudsman Service; we will refer to guidance on DISP 2.8 if it becomes apparent that the complaint has been made or is referred outside those time limits; we will provide the customer with details on the Financial Ombudsman Service and how to contact them.

COMPLAINTS SETTLED WITHIN 3 WORKING DAYS

Complaints that can be settled to the customer’s satisfaction within three working days can be recorded and communicated differently.

Where we consider a complaint to be resolved to the customer’s satisfaction under this section, the firm will promptly send a ‘Summary Resolution Communication’, being a written communication from us which:

  • Refers to the fact that the customer has made a complaint and informs them that they now consider the complaint to have been resolved to the customers satisfaction.
  • The firm will tell the customer that if they subsequently decide that they are dissatisfied with the resolution of the complaint they may be able to refer the complaint back to the firm for further consideration or alternatively refer the complaint to the Financial Ombudsman Service (FOS).
  • Provide the website address of the FOS and refer to the availability of further information on FOS’s website.

In addition to sending a Summary Resolution Communication, we may also use other methods to communicate the information where:

  • We consider that doing so may better meet the customer’s needs; or
  • they have already been using another method to communicate about the complaint. This may include recorded calls, emails, or text messages.
  • All communication will be recorded on to the customer’s file.

CLOSING A COMPLAINT

We will consider a complaint closed when we have made our final response to the customer.

This does not prevent a customer from exercising any rights they may have to refer the matter to the Financial Ombudsman Service.

Our final response must include:

  • If we accept the complaint and, where appropriate, offers redress or remedial action.
  • Offers redress or remedial action without accepting the complaint.
  • Reject the complaint and we will give our reasons for doing so.
  • Provide our customers with details of the Financial Ombudsman Service and how to contact them.

4. REMEDIAL ACTION

Remedial action is intended to correct something that is wrong or to improve a bad situation. This may include the replacement of faulty products, incorrectly fitted products or a change of product that may be suitable to the customers home, and that we have supplied according to the original sales customer contract, or it could be about the finance product, in the way it was presented, the credit agreement or the lenders terms.

We endeavour to make our remedial actions a ‘one off’ event driven corrective measure.

We document all our remedial action plans on their customer file and our management system.  This system provides the firm with management information to identify regular occurrences of complaints by product, installations, finance, or staff.

John will be responsible for sign off on the remedial action; this may involve one or more of the following:

Apology – A heartfelt apology maybe sufficient and may go a lot further than offering a monetary payment.

Redress – There may be a financial compensation required, which John will agree.

Distress – It is important that we recognise and acknowledge the possibility of emotional impact caused to the customer by something going wrong. FOS defines distress as including upset, embarrassment, anxiety,

disappointment, loss of expectation and stress. We will consider how our actions have affected the customer and respond accordingly.

Inconvenience – The time it has taken the customer trying to right something that has gone wrong.

Considering the nature, scale, and complexity we will ensure that lessons learned as a result of determinations by the Ombudsman and are effectively applied in future complaint handling.

We will

  • Relay a determination by the Financial Ombudsman Service to the individuals who handled the complaint and use it in their training and development.
  • Analyse any patterns in determinations received by the Financial Ombudsman Service and use this in training and development; and
  • Analyse guidance produced by the FCA, other relevant regulators and the Financial Ombudsman Service and communicating it to the individuals dealing with the complaint.

5. SECTIONS 56 & 75 OF THE CONSUMER CREDIT ACT

For customers using the funding option have extra protection through the Consumer Credit Act. All complaints registered under either of these two acts will be managed by the lender. We are aware of the information that is required to be supplied to the customer and will work with the customer and the lender should the situation arise.

Under Section 56 of the Consumer Credit Act, customers can make a claim against us and/or the lender if they believe that the finance was mis-sold or misrepresented. We will provide clear, fair, and not misleading information regarding the finance products to our customers, and we understand failure to do so could result in a Section 56 claim.

Under Section 75, customers can make a claim to the lender if they are not satisfied with the products and services provided on finance if the cash price of the goods or service was more than £100 but less than £30,000. If the cash price was more than £30,000 and the loan or credit amount is less than £60,260, customers can only make a claim against the lender if the retailer is not able to settle the customer’s claim.

Section 75 of the Consumer Credit Act 1974 is there for customers that have purchased using funding brokered through us.  If the customer under a debtor-creditor-supplier agreement falling within section 12(b) or (c) has, in relation to a transaction financed by the agreement, any claim against us in respect of a misrepresentation or breach of contract, shall have a like claim against the lender, who, with us, shall accordingly be jointly and severally liable to the customer. Subject to any agreement between them, the lender shall be entitled to be indemnified by the supplier for loss suffered by the customer in satisfying their liability, including costs reasonably incurred by the customer in defending proceedings.

6. MANAGEMENT INFORMATION

The firm is able to report back to the FCA information on complaints such as complaints upheld, not upheld, steps taken, complaint resolution type, regulated or unregulated.

As part of Consumer Duty, we will assess, test, understand and evidence the outcomes that our customers are receiving; to ensure that our products and services are working as we and our customers would have expected and in a way that is consistent with the Duty.

We use some core principles that help us to provide effective management data, helps us analyse the information and enhances the service we provide our customers:

  • Focus on correcting and remedying root causes rather than just symptoms.
  • Do not ignore the importance of treating symptoms for short term relief.
  • Realise there can be, and often are, multiple root cause.
  • Focus on HOW and WHY something happened, not WHO was responsible.
  • Be methodical and find concrete cause-effect evidence to back up root cause claims.
  • Provide enough information to inform a corrective course of action.
  • Analysing guidance produced by agencies such as the FCA, regulators And Financial Ombudsman Service, and communicating it to the individuals dealing with complaints.
  • Consider how a root cause can be prevented (or replicated) in the future.

Our root cause analysis will include:

  1. Identify the problem. The problem could be as a result of something we have done, a problem with a product or a problem with a third party.
  1. Gather information. Once we have identified the problem, we will prepare a clear problem statement which will include the impact it’s had on the customer, on the business and any third parties i.e. the lender / manufacturer. This is a vital part of the process as good data is critical to find the root causes and contributing factors to help prevent further complaints. We will speak to all staff involved in the customers journey and revert back to information used at the time of the sale.
  1. Determine possible factors. We will review all aspects of the customers journey, we will look at how the lead was generated, how the complaint has come about, has any other customer experienced this same problem etc.
  1. Identify the root cause. We will put our findings on a timeline so we can visualise the complaint. This might help when we are working with our customers also and help us to implement changes to our processes.
  1. Recommend & implement solutions. At this stage we have identified the root cause and we have developed corrective actions to make sure the problem is resolved. The plan will be updated including who is responsible for executing tasks and the risks of implementing said corrective actions.

All customer reviews will be acknowledged, including.

  1. Address the customer by the name that is visible on their review.
  2. Thank the customer. If the feedback is positive, we will express our appreciation and if the feedback is negative, we will apologise and will take responsibility.
  3. Acknowledge the feedback. For a positive review our response will be in relation to their positive comments and for a negative review, we will address the issue directly and let them know about plans to implement changes or make improvements to demonstrate we have listened to their feedback. We will comment that we have tried to make contact on, giving details of date and time and provide our contact details for the customer to reach out at time that is convenient to them. In our conclusion, we will include actionable steps for customers to take.
  4. Internal Review. All reviews made by our customers will be evaluated and an action plan for resolving negative feedback agreed. 
  5. Implementing Change. We are able to have fluid policies and procedures that can be adapted to the customer’s journey ensuring we are always delivering the best outcomes.

7. COMPLAINTS REPORTING

We understand as an authorised and regulated firm of the FCA we will have to report to the FCA annually. We will need to report on all relevant complaints received in relation to credit related regulated activities.

We can easily identify customers that have used the unsecured consumer credit and can provide this information to the FCA.

We are aware that any complaints made under sections 56 and 75 are reportable under the FCA’s regime but in the majority of cases, these complaints are raised directly to the lender therefore it is their responsibility to report these as part of their REGDATA return.

If a complaint is raised directly to us, i.e., the customer was dissatisfied with how the finance was brokered, then we will include it in our annual REGDATA return.

8. DATA PROTECTION

We will always obtain customer permission for us to store their personal details they have given us in connection to a sale and provide their details to the lender if we are brokering finance and or provide their details to the product manufacturer for their warranty. 

To process a complaint, we will hold personal data about the customer, provided to us by them and others in relation to the complaint. This data will be secure and only use it to help process the complaint.

The identity of the customer will only be made known to those who need to consider the complaint and will not be revealed to any other person or be made public by us. However, it may not be possible to preserve confidentiality in some circumstances, for example, where relevant legislation applies, or allegations are made which involve the conduct of any third parties, for example delivery of the goods from a manufacturer. Under the Freedom of Information Act 2000, customers have a right to obtain a copy of their personal data. However, there are exceptions to this right.

We normally destroy our complaint files six years after the complaint has been closed. We will maintain records for finance customers for a maximum of ten years.

9. FINANCIAL OMBUDSMAN SERVICES

We will co-operate fully with the Ombudsman in resolving any complaints made against us and agree to be bound by any awards made by the Ombudsman. The firm undertakes to pay promptly any fees levied by the Ombudsman. 

The customer will be informed that they have the right to refer their complaint to the Financial Ombudsman Service, free of charge but that they must do so within six months of the date of our final response letter. If they do not refer their complaint in time, the Ombudsman will not have our permission to consider the complaint and so will only be able to do so in very limited circumstances. For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.

Contact details for the Financial Ombudsman Service, The Financial Ombudsman Service, Exchange Tower

London.  Tel:  0800 023 4567 (free for most people ringing from a fixed line) or 0300 123 9123 (cheaper for those calling using a mobile) or 020 7964 0500 (if calling from abroad). 

Email:  [email protected]  Website:  www.financial-ombudsman.org.uk