Ms Karen Kavanagh:

The suppliers have to make sure that customers are aware. The handbook requires that they have processes and procedures in place to ensure that at the sign-up they make customers aware of how the product works, what the consequences are if they fall behind, in that they will lose energy, and also why it may or may not be suitable for them. Following on from that and in terms of the oversight of that, we audit regularly and we do it on a risk-based approach. We would look at different areas at different times based on input from our consumer stakeholder group, the complaints that we receive or other own-initiative investigations. In doing that we are not just looking for a reassurance that they have done it, but we will look in detail at the requirements on each of the suppliers. In the case of electricity suppliers in terms of pay-as-you-go, we would require detailed information such as showing us their processes, showing us the training they have provided to their customer service representatives and showing us how they check to make sure that they have not missed a notification of a vulnerable customer. We will look in detail at those processes and we publish the reports on those audits. They are available and we can provide a list of the audits we have done over the last number of years. There is very detailed oversight.

There is also a feedback loop where we identify issues. We get the supplier to make sure that it remedies it, but we also notice if there are areas of good practice and we will incorporate that into the next iteration of the handbook. The customer protection framework is evolving. It is learning from the lived experience of customers and, ultimately, improving as we move along, taking account of new services and smart services as discussed earlier.