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Private Corporate Services
  1. Aim and Status of the Code
  2. Sales, Marketing, Advertising and Promotion
  3. Sales and Marketing personnel
  4. Customer Contact
  5. Contracting
  6. Customer protection and other legal requirements
  7. Audit of Contracts
  8. Complaints Procedure
  9. Distribution

1. Aim and Status of the Code
The key objective of the Code of Practice for Sales and Marketing (below "the Code") is to ensure that Universal Telecom offers its Customers better standards of protection in regard of Sales and Marketing practices than those provided by the law.
Through the Code of Practice the Customer shall be ensured good practice regarding the Sales and Marketing. The Customer shall also be provided with reassurance as to what constitutes such good practice within Sales and Marketing. The Code shall help the Customer to understand the services provided by Universal Telecom and the Sales and Marketing behaviour to be expected from Universal Telecom.
The Code primarily deals with issues arising before, during and at the point of sale. In particular miss-selling and misrepresentation shall be avoided through the Code and the Customer is to be ensured understanding of the services offered and the key terms of the contracts that they enter into.
Universal Telecom has procedures for Sales and Marketing staff, in order to make sure that they are informed of the Code. Universal Telecom also has procedures for monitoring the compliance of its employees with the Code.
Universal Telecom's compliance with the Code does not guarantee compliance with any legal requirement.
Non-Compliance with the Code does not affect the validity of any contract between Universal Telecom and any of its Customers.
The Code will be provided to Customers upon request and free of charge. The Code is also available on the homepage of Universal Telecom, www.uvtc.co.uk .

The person responsible for Compliance with the Code is Susy Mendonça Her contact details are: E-mail: Top ^

2. Sales, Marketing, Advertising and Promotion
Universal Telecom has many ways of conducting its Sales and Marketing activities. Regardless of the way chosen, Universal Telecom will act responsibly and in compatibility with the British Code of Advertising and Sales Promotion and any other applicable advertising code.

If the Customer has registered with any relevant preference service (e.g. the Mailing Preference Service, the Telephone Preference Service, the Fax Preference Service and the E-mail Preference Service) Universal Telecom undertakes to respect the Customers legal rights and wishes. Top ^

3. Sales and Marketing personnel
In order to make sure that Universal Telecom has Sales and Marketing persons fit to comply with the Code and thus fit to avoid miss-selling and misrepresentation, Universal Telecom uses special procedures for the selection of staff involved in direct contact with Customers in Sales and Marketing activities. In those cases where Universal Telecom hires sub-contractors (third party agencies) Universal Telecom undertakes to make sure that it has applied equivalent selection procedures in the recruiting process. Resellers to whom telephony services are sold on a wholesale basis are not regarded as third party agencies. It is the responsibility of Universal Telecom to make sure that all its representatives, and any sales agency acting on their behalf, comply with the Code. Universal Telecom pays special attention to the following facts when hiring representatives, as long as it within the current legislation. - Behaviour and appearance
- References
- Evidence of previous mis-selling or lack of integrity in any selling employment

Universal Telecom also requires all its Sales and Marketing personnel in the UK to provide proof of National Insurance number, proof of address and two references from the same company and not related to the applicant. If a sales person leaves Universal Telecom, a copy of his/hers sales records will be retained for a minimum period of six months and in case the person takes its identification badge with him/her, reasonable efforts will be made to retrieve them. For personnel outside the UK equivalent standards are used.

After having employed a person Universal Telecom requires them to be trained so that they have a sufficient understanding that any relevant advice given by them is not misleading. Topics covered in the training include: - Arrangements for competition in the supply of telecommunications in the UK

- The different telephone options provided by Universal Telecom and how they differ from other products.
- The process for ordering the telephone service
- The relevant principles of consumer protection law
- The prices charged by Universal Telecom and other terms and conditions of service and, especially, 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
- The existence of the Sales and Marketing Code of Practice and the benefits provided
- The procedure for handling customer complaints

The responsibility for compliance with the Code lies with Universal Telecom.
Within Universal Telecom Henrik Sjostrand is responsible for ensuring that the code is observed by the company and its employees.
The person responsible for the Code is the person responsible for the business in the UK.
The remunerations systems are documented and are not such as to encourage misleading or exploitative sales practices.
In case Universal Telecom hires any third party agencies, it undertakes to be kept informed as to the remuneration systems in those companies.

The formal details of the general terms and conditions of our contractual relationship with customers can be found on our website www.uvtc.co.uk. Top ^

4. Customer Contact
In respect of privacy life Universal Telecom uses discretion in all customer interactions. Universal Telecom practises no visits to Customer's homes outside the hours of 08.00. to 20.00, and no telephone calls outside the hours of 08.00. to 21.00, unless at the Customer's request.

All customer Contacts are initiated with the Universal Telecom representatives identifying themselves, the company they represent and the purpose for their visit or call. In case of face-to-face sales and marketing all representatives have and show identity badges that, clearly display Universal Telecoms name, a unique identification number for the sales person, the name of the sales person, a photo of him/her and the expiry date of the card. The identity cards can, upon request, also be made available with key information in Braille.

Universal Telecom takes all reasonable steps to keep informed of local authority initiatives, such as the Local Distraction Burglary Initiative.

In order to comply with the Code, Universal Telecom has taken every reasonable step to ensure that all personnel involved in direct contact with Customers in Sales and Marketing activities are capable of delivering factual and accurate information. Moreover, the representatives are trained to avoid any miss-selling or misrepresentation by using appropriate language and offering clear and straightforward explanation in all Customer Contacts. The sales representatives shall also check that the customer entering into contracts understand, and intend, them.

Universal Telecom representatives cease contact with any person who indicates that the contact is inconvenient, unwelcome, inappropriate or too long. Upon request of the Customer, the discussion it to be ended immediately and, if making a doorstep call, the premises are to be left immediately.

No Sales and Marketing activity will be directed to persons who are under the age for entering into contracts. Where there is sheltered housing, nursing homes or residential care facilities contact is made with the warden or other person in authority, before any approach is made to the customer.

To assist in dealing with any complaint or query that may arise from a Customer Contact, Universal Telecom undertakes to maintain all Sales and Marketing records for at least six months. The records kept shall be such as to allow identification of the salesperson involved and to assist in dealing with any complaints or query. Top ^

5. Contracting
Whenever an individual enters into a contract with Universal Telecom, it will take all reasonable steps to make certain that the person entering the contract is authorised to do so.

To ensure that the contractual nature of the document is clear to the Customer, all contracts are designed in a clear and comprehensive language. The contract provided to the Customer shall contain a statement of the contractual nature of the document. This statement is to be placed next to where the Customer signs the contract. This is to avoid that the Customer is unaware that he is signing a contract.

Where a direct approach to the Customer takes place the Customer is given the following information in writing;

- The identity of the company, its address, telephone, fax, and e-mail contact details
- A description of how the telephone service that the Customer has chosen works
- Information about the major elements of the service, including the cost of any standing charges, the payment terms, line rental, key call types and details of "protected or special support" arrangements
- The arrangements for provision of the service, including the order process and, as accurately as possible, the likely date of provision. Where there may be significant delay in the likely date of the provision, the Customer is informed of this
- The existence of the right of cancellation and the process for exercising it
- The period for which the charges remain valid
- The minimum period of contract, and minimum contract charges, if any In case of contracting on distance, either by telephone, in writing, by fax or by e-mail, the Customer is provided the information stated above by letter within the next five working days. However, the information may be sent electronically where Customers have requested such correspondence. When a Customer signs an order form following a face-to-face contact, or enters into a written contract, the Customer is to be given a copy of the order form or contract, as well as the following details in writing either at the same time or within 5 working days, unless previously supplied in writing prior to the contract;
- Information about any after-sales services or guarantees
- Arrangements for the termination of the contract

After contracting, Universal Telecom always confirm that the Customer understands that they have entered into an agreement, are happy to proceed with the agreement and are content with the way in which the Sales and marketing activity was conducted. If it is found that the Customer had not understood or intended the Contract, or if the order matured before the expiry of the switchover period, and the Customer wishes to cancel, Universal Telecom will terminate the contract without charge or penalty to the Customer. At the Customer's request, full written information about our tariffs will be made available. During the switchover period there is a "no cost" cancellation for Customers when they change their mind. Customers are to be made aware of this fact when entering into the contract. Orders can be cancelled by telephone, in writing, by fax or by e-mail. By orders placed by distance selling, Universal Telecom provides the means to comply with the Distance Selling Regulations. Universal Telecom will, after the transfer, send a letter, also when the order is made by e-mail, unless the Customer has requested information to be send to him exclusively via e-mail, to the Customer of the details of the transfer clearly communicating the following.

- date of notification
- CLI (s) affected - List of services affected/unaffected,e.g. IA call barring - Date of switchover
- The sender's contact details for any queries

To ensure the awareness of the Code and to help the Customer to understand the services provided by Universal Telecom, the Customers will be informed of the existence of the Code and upon request be provided with a copy of it, free of charge. In the case of internet ordering, a well signed-posted and easily visible hyperlink to this Code is displayed and the Code can be easily downloaded and printed. Top ^

6. Customer protection and other legal requirements
Universal Telecom ensures that all procedures comply with all applicable legislation and appropriate amendments. Top ^

7. Audit of Contracts
Universal Telecom provides to carry out regular audits of systems, procedures and documentation to ensure that they are acting compliantly with all aspects of the Code. Top ^

8. Complaints Procedure
Universal Telecom will do everything it can to follow the Code. However, despite its best efforts, things can sometimes go wrong - and if they do, Universal Telecom wants to know so it can put them right as quickly as possible. If a Customer is unhappy in any aspect of our products, our services or our sales and marketing activities, Universal Telecom exercises an accessible and easy Complaints Procedure. We take all complaints seriously and will do what we reasonably can to resolve the issue speedily and to the satisfaction of the customer concerned. If you have an issue with any aspect of our service, please contact us and we will do our best to resolve it. If at the end of this procedure you feel your complaint has not been addressed properly, you can contact Otelo, our independent dispute resolution Service.

Otelo
PO Box 730
Warrington
WA4 6WU
Website: www.otelo.org.uk
Email: enquires@otelo.org.uk
Telephone: 0845 050 1614.

Otelo is an independent approved dispute resolution service and is empowered to resolve customer disputes; we are committed to this process. The communications regulator Ofcom approves Otelo. If your complaint has not been resolved by us or our dispute resolution agency, or you require further information on the role of Ofcom see www.ofcom.org.uk or call them on 0845 456 3000 or 020 7981 3040. Universal Telecom ensures that all Marketing and Sales personnel are aware of the Complaints Procedure and that the personnel inform Customers on first contact of the existence of the procedure. Top ^

9. Distribution
To create awareness of the Code, it will be available to all Universal Telecom Customers on request.

The Code is distributed free of charge and in a reasonable range of formats. Top ^

Universal Telecom - May 2006

 
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