• Rule SLC 0 Standard of Conduct
    The domestic Standards of Conduct contain, amongst other things, a broad vulnerability principle that clarifies to suppliers that to uphold their obligation ti treat all domestic customers fairly, they need to make an extra effort to identify and respond to the needs of those in vulnerable situtations.
    The domestic Standards apply to all activities of the license and any representative which involve, or otherwise relate to, dealings with a domestic customer
  • Consumers on low incomes and those in other vulnerable situations often feel the impact of high energy bills the most. Being unable to afford an accepted level of thermal comfort may have serious health and psychological consequences. We are aware of these affordability issues and are working to help those consumers struggling to manage their bills.
  • Suppliers must take ’all reasonable steps’ to ascertain a customer’s ability to pay and must take this into account when calculating debt repayment installations or agree debt repayment plans that are affordable for the customer.
  • In carrying out our duties we must have regard to the interests of consumers who are:
    of pensionable age
    chronically sick
    on low incomes
    living in rural areas.
  • Vulnerable characteristics – risk factors In practice there may be a range of characteristics that put a consumer or member of a household at greater risk of detriment, and/or impact in different ways their ability to represent their interests. These include, but are not limited to:
    living with physical health issues or mental illness
    cognitive impairment
    literacy or numeracy difficulties
    having a speech impairment
    not speaking English as a first language
    being a child
    low confidence
  • The extent to which an individual is aware of their vulnerability may also impact the depth and likelihood of any detriment they suffer, and their ability to limit that impact.

TellJO Benefits

  • TellJO assesses the underlying reasons for fuel poverty and refers to support organisation to help resolve. TellJO will assess income/benefit levels and recommend ways to increase income to enable payment of fuel bills
  • TellJO is a neutral brand that is designed to engage with hard to reach groups allowing energy companies maximise reach in challenging areas
  • TellJO is designed to identify vulnerable groups and offer support specifically for them. TellJO will communicate with the customers explicit consent the level of vulnerability, affordability and capability of the customer allowing the energy company to give dedicated support
  • TellJO will assess if the customer needs free advice and will automatically refer them to the appropriate agency, and evidence the referral to the energy company.
  • TellJO is the 1 st Digital Vulnerability Support tool to market and contains the latest in machine learning.
  • Following completion of the digital self-assessment TellJO with the explicit consent of the customer will inform the energy company with the level of vulnerability, capability and vulnerability via a company specific dashboard and give best advice on how to support the customer and their level of vulnerability


  • PR19 Proposal: Enhanced customer engagement; customer participation; engaging customers on long-term issues including resilience.
  • PR19 Proposal: Affordability and vulnerability: affordability key areas, principles and sources of information, vulnerability tests
  • PR19 Proposal: Stretching performance commitments, including new customer experience measures; powerful outcome delivery incentives
  • PR19 Proposal: We also want to see companies creating business plans that demonstrate how well companies support customers who are in circumstances that make them vulnerable. (This includes customers who may be about to be in circumstances that make them vulnerable).
  • PR19 Proposal: Customers who are struggling or at risk of struggling to pay their bills need easy access to assistance. Companies need to be more proactive both in getting this assistance to customers and in communicating to raise awareness of the support
  • PR19 Proposal: Our thinking and proposals on vulnerability We propose to use qualitative information to assess how companies’ business plans support customers in circumstances that make them vulnerable. This is based on the challenges we set in our 2016 Vulnerability focus report. We will assess:
    how well companies use good-quality available data to understand their customers and identify those in circumstances that make them vulnerable.
    how well companies engage with other utilities and third-party organisations to identify vulnerability and best support those who are in vulnerable circumstances; and
    how targeted, efficient and effective companies’ measures to address vulnerability are. Reports from the CCGs will provide an independent assessment to us on the quality of companies’ planned support for customers who are in circumstances that make them vulnerable, and the quality of the engagement that supports their plan on vulnerability. We propose to require companies to include bespoke performance commitments for addressing vulnerability in their business plans after engagement with customers and challenge from their CCGs. We propose to require companies to develop common measures for addressing
    vulnerability, and to report on the data
  • We want to see companies demonstrating in their plans how they provide sensitive, well-designed and flexible support and services for customers in circumstances that make them vulnerable.

How TellJO can help overcome these problem areas

  • TellJO is designed as a neutral brand to get the maximum customer engagement, particularly from hard to reach groups. TellJO will identify the underlying reasons for water bill arrears and put steps in place to resolve them.
  • TellJO is a digital tool that identifies levels of vulnerability, affordability and capability and communicate that to the Water Company via their own unique dashboard
  • TellJO will clearly articulate what support has been given by referral to agencies and the recommendations to the water company. The outcomes can be cross referenced against the arrears performance
  • Using TellJO water companies can clearly demonstrate, evidence and provide outcomes as to how they have supported their vulnerable customers.
  • TellJO will automatically refer customers who are struggling to pay their bills to free support, this is evidenced via the Water Companies unique dashboard and outcomes created.
  • TellJO will maintain a robust database on how the Water Company has supported vulnerable customers and provide evidence of interventions and outcomes TellJO will automatically refer to specific support organisations as identified by the self-assessment TellJO will allow evidence based measurement to demonstrate how Water Companies have supported their vulnerable customers
  • TellJO gives individual dedicated support and will provide evidence of support from the Water Company


  • The needs of vulnerable consumers, and the interventions needed to support them, are changing As consumers’ needs and the market changes, there may be implications for our rules and our approaches to address consumer vulnerability.
  • Ofcom carries out research designed to increase our understanding of consumer vulnerability, and we also engage with a range of stakeholder organisations to understand these issues better and to identify areas for possible intervention.
  • The water, energy and landline telephone industries offer discounted prices for customers on low incomes, but these do not necessarily reach the people who need them most

How TellJO can help overcome these problem areas

  • TellJO is the UK’s 1 st Digital Support tool for vulnerability, this will allow communications companies to enhance their vulnerability ahead of further OFCOM regulation
  • TellJO will allow communications companies to evidence support and interventions given to vulnerable groups, giving evidence based on real outcomes
  • TellJO will discover which customers have low affordability and could qualify for lower tariffs