Where we receive a commission or referral fee from a third party, promote their services to consumers in return for cash or other benefits, or work with them to offer a commercial service, the following principles apply:
All of our relationships with third parties should offer a clear consumer benefit and contribute to the furthering of our mission, to make consumers more powerful. Where Which? is using a third party to provide data and information (rather than a service) to consumers, we will aim to give as much market coverage as possible. We will only enter into monopoly relationships if it is in the best interest of the consumer and will not cause any detriment. In these instances, we will apply a higher level of scrutiny to the relationship, both in terms of frequency and level of review of the arrangement.
The nature of each third-party relationship and the basis on which the relevant product or service is being endorsed should be clearly visible to people, for example on relevant pages of our website. This includes, as a minimum, the fact that there is a fee or commission earned.
It is mandatory for all third-party relationships to be subject to an internal due diligence process, details of which are available to all staff on the intranet. The results of such procedures must be recorded and retained for future reference and be repeated on renewal of contracts.
Quality assurance and ongoing monitoring
All third-party relationships should be subject to regular quality assurance activities, commensurate with the nature and size of the relationship. Such activities should incorporate an element of in-house monitoring (by the service provider) and monitoring by Which?, including mystery shopping where appropriate. All third-party relationships that generate material revenue should be subject to Which? audit rights (which should be reflected in contractual terms). Relevant third parties are required to demonstrate they take an approach to complaints handling that is in line with both Which? values and the agreed policies and procedures.
Which? has the right to terminate each contract within a reasonable time period (as appropriate to the market), or immediately in certain circumstances (such as a material breach of contract).
Establishing new relationships and ongoing oversight
All new third-party relationships are subject to the internal guidance. The formation of new third-party relationships and the renewal of existing third-party relationships should be subject to prior approval by the Which? Corporate Leadership Team when considered of high risk, or where significant revenue is involved.