ABTA; Ofwat; Ofcom; HSO; Ofsted; FSA; DMA; Otelo; IPCC; PCA – it sounds like a competition to list the worlds most confusing acronyms! If you have not yet worked it out, these are in fact acronyms for some of the regulatory bodies who represent and protect the consumer from organisations who provide things like travel services, water, media, schools and financial services in the UK. I wish my budget stretched to offering a prize for guessing all of the bodies listed above – regrettably I do not – but I will be very impressed with anyone that can name this lot!! The official definition of a ‘regulator’ according to the Oxford English Dictionary is as follows:

“a person or body that supervises a particular industry or business activity”

Regulatory bodies exist to ensure that organisations within their industry operate within the law and in the best interests of their customers. They exist to ensure that you and I – the great British consumer – are treated fairly. The FSA (Financial Services Authority) famously has a programme entitled ‘Treating Customers Fairly’. We can make our own judgement as to how well they have enforced it with the banks over the last few years!! In a document entitled ‘Treating Customers Fairly – Culture’ (http://www.fsa.gov.uk/pubs/other/tcf_culture.pdf), the FSA state:

Treating customers fairly (TCF) is a cultural issue. It is only through establishing the right culture that senior management can convert their good intentions into actual fair outcomes for consumers. In our July 2006 publicationwe included an outcome on culture which states that ‘Consumers can be confident that they are dealing with firms where the fair treatment of customers is central to the corporate culture.’  

As firms will be aware, TCF is one of our priorities and, to be effective, they should be making it an integral part of their business culture. While we identified in our May 2007 publication  that an encouraging number of firms were at the ‘implementing’ stage of their TCF strategy, further progress is needed to reach the embedding phase. We now expect to see firms taking action to ensure a consistent delivery of fair consumer outcomes – to do this, firms need to consider their culture. The culture of an organisation drives the behaviours of its management and staff and their actions, which in turn will determine the outcomes for consumers.

Sounds great doesn’t it? We are very lucky in a democratic society to have bodies like the FSA to guard against companies doing the wrong thing; taking advantage of the consumer; that we all get treated fairly. This blog is not going to assess how good the FSA or any other regulatory body is at doing that – we will all have our own opinions and judgements. However, what I do want to explore is whether or not the fact that these bodies exist, a help or a hindrance to us as consumers.

Let me explain what I mean. I am a strong believer in doing the right thing for the customer. As any true customer experience professional would agree – the best way of genuinely embedding a customer centric culture in an organisation is to treat the customer as we ourselves would like to be treated. Create a great product or service and deliver them to the customer in a journey designed to fully meet and exceed their expectations. Be honest and genuine at all times, and do everything you can to recover a situation when the journey has not gone as expected.

How many organisations do you deal with that feel like that? Not many in my own personal experience. To be truly customer centric; to honestly put the customer at the centre of everything you do; does indeed require something that the FSA have defined in their ‘TCF’ documentation – it requires the right kind of culture. However, I believe that to embed the right kind of culture in an organisation requires the right kind of leadership. In the case of the customer experience, the right leader needs to ‘believe’ in doing the right thing by the customer – above anything else. I am not sure that any regulatory body can make an organisation ‘believe’. They can strongly influence – and apply penalty and punishment, but does that really help us as consumers?

At this point, I will ask you to use the analogy of being a small child (easy for some of us!). If your parents ask you to clean your bedroom, you might do it (because you are well behaved), or you might procrastinate and ‘put it off’. You might wait to ‘get shouted at’, or even punished by having your pocket money deferred until it is done. t is not until you ‘believe’ that having a clean and tidy bedroom is the right thing to do, that actually performing the task of cleaning it feels right. It is, and should not be about the pocket money. My wife is always telling me that we should not ‘barter’ with the kids to get them to do things – they should ‘want’ to do it. The treat of ‘no sweets’ or the promise of a play on the ‘Wii’ usually gets them to do what I ask, but Naomi believes that they should do things because they ‘want’ to, and ‘believe’ it is the right thing to do. As always she is absolutely right.

So – coming back to regulatory bodies – is this analogy of parent/child a good one? How many organisations are ‘doing the right thing’ by customers just because they are being told to? How many organisations are ‘complying’ with instruction from the regulatory body to avoid penalties? How many of these organisations really ‘believe’ that doing the right things for customers is actually the right thing to do – and would have done it whether or not the regulatory body had asked them? It is difficult to answer this question factually, but it would be very interesting to know the truth. I would suggest that using the FSA as an example, and the fact that the financial services industry has spent the last two years having to compensate consumers for the misspelling of products, demonstrates that the organisations they govern could not really have ‘believed’ Treating Customers Fairly. If they had believed, they would not have done what they did.

Using a more current example, in the UK, we are all aware of the recent exposure given to the energy industry, and the current governments attempt to ensure that we are all offered ‘the best deal’ by our energy provider. Again, the fact that the government has to even discuss the issue is a demonstration that the organisations in this industry have not pro-actively thought about offering customers the best deal. So, due to the exposure, organisations in this industry are mobilising to act on what the government and regulator is asking them to do. One of the companies who has acted is e-on – one of the UKs largest energy suppliers. On their website they say “We want to be a company people can trust and are always looking at ways to make energy cleaner”. Can they be trusted? They have recently launched their ‘best deal’ – a way for all customers to find the best deal ‘in the time it takes to make a cuppa’.

They have sent a letter and marketing communication to all customers – I have been given a copy of one received by a friend in November. ‘Helping you find our best deal for you’ – says the headline in big orange letters. ‘We’re changing the way we do business..’ says the opening line. A nice glossy A3 leaflet is enclosed detailing their tariffs; rewards for staying with e-on; and information on how to find the best deal either online or by phone. It all sounds great – yes I could be pedantic and ask what has driven them to ‘change the way they do business’ – but you will know what my conclusion will be – it was probably not of their own making.

My friend decided to phone them to get more information – the number 0333 202 4680 is emblazoned on the letter and leaflet. They called the number 7 times at the beginning of December – on all 7 occasions, they were met with an automated message that said – ‘the other person has hung up’ – 7 times!! I have just tried to call the number – I was met with ‘due to a building evacuation, we are unable to connect your call’ – I kid you not!!! Are they really serious at helping customers find the right deal? Yes, I could go online, but I do not want to – I want to speak to someone – in e-on’s case, this is not possible.

Whether my friend and I chose a bad time to call e-on is irrelevant. If organisations want to do the right thing by their customers, they must proactively design and deliver a customer journey that meets and exceeds customer expectation – they should not have to wait to be shouted at by an industry regulator. The fact that regulators have been in the headlines so often highlights the fact that too many businesses are still not doing the right thing by themselves. Are regulators a help or a hindrance? Without them we would be in a bit of bother at the moment, so by that token, they are a help. What we desperately need though is for organisations to stop waiting for their regulator to spot them doing things wrong. In an ideal world we would have regulators showing us all what their businesses are doing right – now that would be quite something, wouldn’t it?

As always, your comments on my blogs are very welcome.