Business, Innovation and SkillsWritten evidence submitted by Anglian Home Improvements

1. Summary

Anglian Home Improvements (AHI) welcomes the Draft Consumer Rights Bill. There was a clear need for legislation to be bought in to the digital age to prevent the exploitation of consumers. We feel that in some elements the bill does not go far enough to crack down on unscrupulous firms and protect consumers including:

Issue: The introduction of a section which covered items that were both good and services, such as the building of conservatories or laying of driveways

Position: We would suggest that the Government’s amends the Bill to give clarity to consumers and businesses where a sale involves both a good and a service.

Issue: Support for vulnerable customers

Position: AHI welcomes the moves to provide additional support to vulnerable customers and prevent them being exploited by unscrupulous individuals.

Issue: Clarification around the right to reject bespoke goods

Position: AHI believe that the right to refuse bespoke goods should not be extended to 30 days. Instead we would welcome steps to introduce guarantees for customers as we provide.

Issue: Trading standards enforcement

Position: We are opposed to moves that will reduce confidence in the enforcement of trading standards and are unconvinced that giving two days’ notice in writing of a visit—as outlined in the draft Bill would provide sufficient benefit to responsible businesses.

2. About Anglian Home Improvements

AHI began selling windows in 1966 and opened our first showroom in Ipswich in 1969. In the subsequent 40 years we have expanded and opened manufacturing facilities for making double glazed units, extruding our own uPVC and gas filling units to make them more energy-efficient. AHI prides itself on being at the front of product development in our field at all times, making sure our product is the best it can be—raising the standard.

Our headquarters are based in Norwich and we are responsible for the employment of over 4,000 people across the UK. We have worked hard to build an enviable and deserved reputation amongst our customers, many of whom come back to us time and time again and recommend our products to friends and neighbours. Others become aware of our products through marketing activity, we also find customers through house visits.

In addition, as a leading member of the Glass and Glazing Federation, AHI fully supports the steps they take to safeguard consumer confidence and protection. For example, when work is undertaken by a member of the Federation the purchasers deposit is place in an indemnity scheme. This affords on-going protection to the consumer, even if a firm ceases to exist—a similar principle that exists with travel agencies who are members of the Association of British Travel Agents.

3. A Mix of both Goods and Services

AHI provides services to its customers which are a mix of both goods and services. For example, when fitting a drive whilst the bricks used are standard the time spent on designing and fitting the drive would be a service. The same principle applies for home extensions or window replacements.

Currently the draft Bill refers to items that are either goods (Part 1 Chapter 2) or services (Part 1, Chapter 4) but does not cover sales which fall in to both camps. This means that the status of the law is not as clear as it could be. For example, would the 30 day right to refuse rule be in place for AHI’s services.

We would suggest that the Government amends the Bill to give clarity to consumers and businesses where a sale involves both a good and a service.

4. Vulnerable Customers

AHI and BIS both take the exploitation of vulnerable customers extremely seriously. AHI are member of the Glass and Glazing Federation who are currently seeking approval for a Code of Good Practice to the Trading Standards Consumer Codes approval scheme.

This scheme gives a clarity of protection around vulnerable customers saying that “companies will take the necessary effort and time to make sure that vulnerable consumers understand all aspects of signing a contract for goods and services.

Vulnerable customers are those whose circumstances put them at risk of making an incorrect or inappropriate decision, or who are at risk of receiving inferior goods or services. Vulnerable consumers include but are not limited to those:

With a physical disability or health problems

Who are older people

With poor literacy skills

With a lack of knowledge about a complex product or service

Who are purchasing something at a time of particular stress or distress

Whose first language is not English, and English is the only language in which material is available.”

AHI welcomes the moves to provide additional support to vulnerable customers and prevent them being exploited by unscrupulous individuals.

5. Bespoke Goods

Almost all of the products that AHI sells are bespoke goods. For example, conservatories will be designed differently for each property and whilst windows may appear to come in standard sizes in truth they are always individual due to design configurations.

In this context extending the right to refuse goods and services places an unfair and disproportionate burden on the business. In circumstances where goods are bespoke we would argue that the right to refuse should not be extended.

This approach would not affect customer’s right to redress as outlined in the Sales of Goods Act (1979) and reiterated in the draft legislation. In fact the right to return goods in those circumstances fall far short of the guarantees that AHI already offers to its customers. For example:

PVC is guaranteed for 10 years

Sealed units are guaranteed for 15 years

Driveways are guaranteed for five years

All locks are guaranteed for two years

AHI believe that the right to refuse bespoke goods should not be extended to 30 days. Instead we would welcome steps to introduce guarantees for customers as we provide.

6. Trading Standards Enforcement

Some sections of the Home Improvements industry have attracted considerable criticism over the years. Those who fail to pay tax, or honour agreements have reduced confidence in the industry. That is why AHI, alongside others in the Glass and Glazing Federation came together to submit the code of conduct to the Consumer Codes Approval Scheme. We are determined to make sure that the public appreciate and have available to them the extra protections that come from using reputable and responsible companies to improve their homes.

We are opposed to moves that will reduce confidence in the enforcement of trading standards and are unconvinced that giving two days’ notice in writing of a visit—as outlined in the draft Bill would provide sufficient benefit to responsible businesses.

27 August 2013

Prepared 20th December 2013