A) Overview & Principles
Everyone benefits from honest, ethical sales. With so many homes yet to install solar in the United States, there's enormous potential for all parties involved. Palmetto LightReach takes a measured, but clear-eyed approach to compliance.
The spirit of our compliance guidelines is simple, and summed up in 5 key points:
B) How We Approach Compliance
Our rules of engagement with partners follows a simple 1-2-3 sequence.
Intake: Intake the information or evidence of a compliance violation.
Investigate: Request additional information or counter-evidence from the Certified Installer. Installer has 48 hours to respond. Installers should take additional precautions, via verifications, on all sales (details below).
Action: Render a decision and take action.
Depending on the context of the situation, PLR reserves the right to take any appropriate action, including but not limited to:
Clawback of funds.
Termination of rep/state/org access.
Org/Rep reported to Recheck.
C) Standard Installer Verifications
Installers should take reasonable steps to protect their business against potential adverse customer claims. Rather than enforcing invasive compliance requirements on all sales, we advise installers to take precautionary actions that work best for their business. We do however reserve the right to request specific items to verify proper sales steps were taken. Having concrete counterevidence can safeguard installers against adverse customer claims. Examples of common Standard Installer Actions are listed, but not limited to, the below.
Installer Verification Call (Recommended)
| Installer verification/welcome calls are a great way to record key terms and details with the customer. While LightReach doesn't mandate a specific script, installers should reasonably cover at least our minimum criteria, listed further below.
Recorded video calls are also commonly used version. Creative 'homegrown' verions, such as selfie video recaps with the client, are also used among many of our partners.
Click for Example
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Written Recaps / Order Recaps | Simple written recaps such as emails or text messages that recap key Energy Plan and general solar terms/information.
Typically an easy way to ensure key information is put in writing. While homeowners do not necessarily have to reply, it is best practice to document an acknowledgement.
Click for Example
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Physical Documentation | Leave behinds, brochures, disclosures; many installers create their own disclosure documents for customer signoff; any & all forms of paper documentation recapping key terms/info.
Click for Example
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Family Involvement & Special Considerations | Ensuring any/all relevant family members or decision makers are involved with higher risk customer groups (particular elderly customers) and fully educated on the sale, and provided documented recaps of key details. Other higher risk factors include customers on subsidized rate plans (further details below), or customers for whom English may not be their primary language.
Click for Example
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PLR Right To Request
LightReach may require verification of precautionary steps from installers for accounts with higher-risk factors, at the discretion of our underwriters. Higher-risk factors include but are not limited to pricing, age, or market NPS scores. In such instances, installers are responsible for providing PLR with a reasonable copy of the installer's verification step(s).
LightReach typically samples a percentage of accounts as standard practice, via Administrative Stipulations placed on the accounts. Partners receive standard stip notification emails in the event of this happening.
At the discretion of our underwriters, LightReach may elect to halt or cancel a deal in the event no standard installer actions or precautions were taken. In general, if LightReach selects an account for verification, we're looking for reasonable coverage of our above minimum criteria. However, in unique or extreme circumstances, LightReach may also review secondary criteria.
If in review, there are clearcut red flags, we will respectfully decline the deal.
Standard Installer Verifications: Minimum Criteria
Regardless of the exact verification method used, Installers should reasonably cover core basics of the solar deal and common friction areas. In the event of an account being stipulated to review installer verification, LightReach will review for coverage of (but not limited to):
1) Contact Info: Customer contact information, and the names & contact information of any family members included in the sale process (if applicable).
Click for example Covering the customer's contact information can often be treated as a quick courtesy confirmation. Asking for any contact information of family members involved is a great way to ensure any relevant decision makers are included: "For your contact info, I have 123-456-7899 and [email protected], are those still the best contacts for you? Great--and are there any other family members involved whose contact info you want to keep on file?" |
2) System Basics: Including size, production
Click for example This criteria can generally checked off quickly, and can often be treated as a quick confirmation for accuracy: "Just to double check I have all of the system details right in my system, we've got you down for a 20 panel system, estimated to produce around 9000 kWh (or units of power) over the first year. Does that sound good to you?" |
3) Contract Basics: Including payment, escalator, term
Click for example This criteria can generally checked off quickly, and can often be treated as a continuation of a quick confirmation. "And as far as your contract terms, it looks like we've got you set on a 25 year agreement, with a $100 monthly payment and a 1.99% escalator. Does all of that sound familiar?" |
4) Utility Bill Basics: Including that the customer will always have a utility bill, and that any electricity used beyond solar production will come from their utility.
Click for example The most common misinformation (or misunderstanding) that we see from homeowners is the notion that they will never receive a utility bill. Legal and regulatory scales are heavily weighted toward consumers in these instances, so it's crucial that installers protect your business by setting clear expectations: "To recap some expectations about your bill, once the system is operating, you'll receive one bill from your electric utility and one from Palmetto LightReach. You will still have a utility bill even in months when solar covers all of your electricity needs. Any extra electricity you use beyond solar will be billed from your utility. Did you have any questions on any of this?" |
5) No Incentives: That there were no incentives or material promises of any kind included in the contract.
Click for example A combination of statements and questions are often helpful to covering all bases on this point: Often times, it can be helpful to flush out this area of the sale simply to ensure more practical items, like referral bonuses, are accounted for. "There are no incentive or tax forms you need to worry about with this Energy Plan, and I've covered off everything that was included here. Was there anything else that you and your sales representative discussed that we did not cover?" |
Click to view additional tips & best practices
Click to view additional tips & best practices
Ask probing questions: Many partners wisely phrase certain questions on their verification steps to flush out any potential misunderstanding. This can also serve as a means to cover multiple topic areas with a single question. For example "Is there anything else you and your sales representative discussed what we did not cover here, or you would like to clarify more about?"-- This is a great example of a probing question which might help surface friction points such as incentives, notions of 'never having a bill', etc.
Know the common pain points: Customer escalations and poor NPS scores often focus around [1] A promise or misunderstanding of incentives and [2] Promises or misunderstanding around offset concepts (such as "I was told I would never have a utility bill"). Installers should consider these key areas when formulating a verification method.
Don't coach: We understand that a degree of guidance through verification may be necessary as part of a normal sale. But distinct signs of sales rep coaching (such as completing steps for, or otherwise directly answering for a customer, is grounds for the deal to be halted).
Avoid risks: Installers should take sensible steps to avoid high risk customers who may pose a threat to their business. Homeowners who appear or sound disoriented about their solar sale may require additional education to minimize risk of issues down the line. Homeowners who do not have an email cannot sign with LightReach, and while we do not expressly prohibit customers from creating emails for solar, they must belong solely to the customer and installers should document this in your verification. Ultimately, some homeowners simply may not be a good fit for our product, and installers are asked to use best judgement in proactively cancelling any customers who may not be a good fit for solar.
The More the Merrier: Installers are not limited to just one single verification step. Having multiple layers can go a long way to mitigating against adverse customer claims. Many installers execute variations of 'homegrown' compliance methods, such as short video recordings at point of sale, or wet signed disclosure documents. This builds on PLR's general compliance strategy, which emphasizes multiple layers of consumer education and disclosures to combat misinformation or misunderstanding.
In general, if LightReach selects an account for verification, we're looking for reasonable coverage of our above criteria. However, in unique or extreme circumstances, we may also review secondary criteria.
Click to view secondary criteria
Click to view secondary criteria
The verification was completed with the applicant themselves, and that the applicant is reasonably engaged.
There are no signs of sales rep coaching.
Key facts and details are articulated to the customer in a fully transparent manner, and the customer shows no signs of potential confusion.
Partner/Customer Transfer Policy
LightReach Policy
| LightReach takes the stance of an 'Open Market' Policy. |
LightReach Does Not... | Transfer customer agreements between partners. |
Action Required by Homeowners | Homeowners wishing to cancel With Certified Installer (A) and sign with a new Certified installer (B) must qualify and sign a new contract. This is in the interest of fairness to all of our Certified Installer partners. |
Subsidized Rate Plan Customer Policy
Details | Some electric utilities offer specialized rate discounts to certain customer groups, such as low income or medical assistance/disability discounts. These programs can vary widely in scope and details. Common utility subsidized rate programs include:
Click for Common Subsidized rate programs
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LightReach Policy
| LightReach does not expressly prohibit all subsidized rate plan customers. However, we do take reasonable precautions to ensure that applicable homeowners are aware of the potential impacts of solar on their rate plan.
In many cases, customers who pay the utility less will save less (or not at all) with solar, and may not be a good fit for our Energy Plan product. |
LightReach Does Not... | LightReach does not expressly prohibit all subsidized rate plan customers. |
Additional Precautions | All homeowners acknowledge our subsidized rate plan disclosure when they complete their standard Clear Facts Disclosure (NTP requirement).
Homeowners may at their discretion contact LightReach to review their bill rate plan for potential solar impacts.
In such situations, LightReach will provide homeowners with transparent information about the impact of solar on their rate plan. It is therefore imperative for sales representatives to be cognizant of subsidized customers during the sales process, and avoid customers who may be negatively impacted by solar.
Generally, LightReach will provide information to customers and assess their rate plan based on the impact of going solar:
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E) Reference: Full PLR Code of Conduct
Click to View Full Code of Conduct
Click to View Full Code of Conduct
LightReach maintains a professional Code of Conduct that is expected to be observed by all partners. This ensures that our mission and values are upheld, and serves as a cornerstone of our commitment to ethical business practices and operational excellence.
At LightReach, we and our Certified Installers share a commitment to ethical, compliant sales and high-quality customer experiences. Certified Installers are expected to adhere to their agreement with LightReach (“Applicable Agreement”) and comply with all relevant laws, regulations, and legal obligations, as well as identify and manage environmental, social, and governance (ESG) risks in procurement, sourcing, and supply chain activities. Beyond these legal requirements and the Applicable Agreement, this Code of Conduct (the “Code”) outlines fundamental rules governing LightReach’s business practices.
This Code ensures that the actions of our Certified Installers align with our shared expectations and values. Failure to adhere may result in immediate termination of the Applicable Agreement. Certified Installers agree to maintain proportionate policies and management systems to ensure compliance with this Code when providing goods or performing services on behalf of LightReach. Such policies shall include training to help employees understand risk identification, mitigation, and escalation procedures related to this Code.
This Code is not intended to be an exhaustive list of responsibilities or all applicable policies. LightReach is dedicated to fostering a transparent customer experience and forming alliances with firms that guide consumers toward well-informed decisions regarding LightReach’s offerings. Certified Installers and their employees, subcontractors, representatives, business partners, and suppliers shall conduct themselves ethically and professionally in all circumstances.
All EPCs will receive a copy of this Code Of Conduct for signature during the onboarding process.
We are on a mission to stop climate change before we reach an irreversible tipping point. This requires urgent and large-scale action, but technological advancements have made it achievable.
At LightReach, we are driving the rapid expansion of clean technologies. Our ethical and safe working practices are built on core values that we uphold. We encourage our Certified Installers to embrace and exemplify these values in all their activities.
1) Adherence and Culpability
Achieve high standards by operating consistently, sustainably, and legally. Partners must demonstrate both results and the methods used to achieve them.
2) Customer Mindfulness
Prioritize understanding and empathizing with customer needs. Ensure that every interaction reflects attentiveness and sensitivity. Continuously seek improvements to enhance the overall customer experience.
3) Innovativeness
Deliver lasting value through strategic, innovative, and financially sound approaches. By leveraging their strengths, partners can drive sustainable growth and prosperity for all stakeholders.
4) Communication & Teamwork
Actively listen, build consensus, and earn trust through dignity and respect in every interaction. Foster an inclusive environment where diverse perspectives are embraced and individual contributions are acknowledged.
Operating ethically and fairly is paramount. Certified Installers must comply with all applicable laws and regulations governing financial, consumer, and operational activities. Certified Installers are required to hold appropriate registrations, licenses, and expertise to operate in their chosen markets. They must prioritize safety and treat subcontractors, service providers, and customers fairly.
Certified Installers and their representatives should demonstrate professionalism and respect when interacting with potential and current customers, as well as competitors. Treating customers fairly is our primary objective.
LightReach will guide compliance through its Certified Installer Management Program. Any Certified Installer or representative found failing to uphold these standards will face appropriate disciplinary measures.
Key ethical and compliance considerations include:
Certified Installer must carry identification at all times, clearly visible to customers, displaying the individual’s name and photograph.
Certified Installer must not claim affiliation with LightReach beyond the terms of the Applicable Agreement.
Certified Installer must not misrepresent themselves as “the electric company” or claim they are merely “upgrading” or “updating” a customer’s existing system.
Certified Installer shall be properly licensed and registered, complying with all relevant laws and regulations.
Certified Installers shall not guarantee government or tax incentives.
Certified Installer shall discontinue a sales presentation and leave the premises upon a customer’s request.
Certified Installer shall not approach premises with posted “No Solicitation” or “No Trespassing” signs.
All customer contact shall be polite and conducted during reasonable hours.
Sales (Ethics and Compliance)
Certified Installers must evaluate potential customers to ensure suitability for the products and services offered. Within the Certified Installer’s organization, no individual shall harass, threaten, pressure, or engage in aggressive, abusive, or deceptive sales tactics. Certified Installers must not offer products to customers unable to fully understand contractual terms due to language, health, or other factors.
Certified Installers must also:
Refrain from deceptive, misleading, unlawful, or unethical business practices.
Present any proposals or agreements exactly as generated by LightReach.
Accurately and transparently disclose additional costs that may affect a customer’s overall savings or total cost (e.g., structural repairs, property modifications, financing fees).
Ensure the customer has sufficient time to read and understand all materials, contracts, and related documents.
Reasonably ensure the customer is capable of understanding the contractual obligations.
Certified Installer shall not:
Misrepresent product or service capabilities.
Present false or misleading statistics, cost savings, or other unsubstantiated information.
Write or assist a customer in canceling their existing service.
Lead customers to believe they will not receive any ongoing bills, charges, or invoices.
Provide signatures or consents on behalf of a customer.
Sell products to a customer using a Power of Attorney.
Modify, alter, or change any proposals or documentation generated by LightReach.
Promise any specific tax incentives, rebates, credits, or money-back guarantees.
Make any guarantee or promise regarding savings to a customer.
Certified Installer shall provide accurate information about:
Price
Term of the agreement
Product and service performance
Credit and other qualifying requirements
Terms of payment
Cooling-off or right of rescission periods
After-sales service
Scheduling
When making comparisons with another company’s products or services, only use truthful, fact-based information that can be substantiated. Certified Installers must protect private information and obtain customer consent before requesting any credit authorization. They must answer customer questions accurately and honestly.
If telemarketing is employed, the Certified Installer must maintain policies, procedures, and documentation to comply with local, state, and federal laws and regulations, including DNC (Do Not Call) policies, training, and adherence to calling restrictions. They must keep records of lists, scripts, training materials, and registration evidence, ensuring calls are conducted lawfully and respectfully.
Certified Installers must follow all licensing and permitting regulations governing their operations. This includes obtaining any necessary licenses, registrations, and approvals required by law.
All advertising and customer-facing materials must comply with jurisdictional requirements. Certified Installers must notify LightReach promptly of any changes in license numbers, business names, status updates, or qualifying agents.
As a Certified Installer, you must:
Comply with all applicable environmental laws, including those concerning waste, hazardous materials, emissions, biodiversity, resource consumption, and more.
Report accidents, injuries, or adverse environmental impacts promptly.
Seek to reduce resource consumption, improve energy efficiency, and mitigate environmental risks.
Treat and reduce hazardous emissions, wastewater, and other operational byproducts where feasible or legally required.
Incorporate recycling and reusing practices where possible or mandated by law.
Forced Labor and Modern Slavery:
Certified Installers must not engage in forced labor, human trafficking, child labor, or any form of modern slavery. Employment must be voluntary.
Certified Installers must not employ workers under the minimum legal working age or involve underage workers in hazardous tasks.
Discrimination:
Promote equal opportunity without regard to legally protected characteristics.
Treat all workers with dignity and respect; protect them from discrimination, harassment, bullying, or other inappropriate behavior.
Freedom of Association and Collective Bargaining:
Respect workers’ rights to form or join associations and bargain collectively.
Do not discriminate or retaliate against workers for union-related activities.
Remuneration and Working Hours:
Comply with applicable wage and hour laws, ensuring regular and timely payment.
Health and Safety:
Comply with all health and safety laws.
Maintain a safe work environment through adequate training, policies, and procedures.
In essence, we require our Certified Installers to adhere strictly to legal requirements and the guidelines outlined in this code. All Certified installers have a responsibility to monitor compliance with this Code and are expected to cooperate with LightReach and notify LightReach, including with respect to their own suppliers, business partners, contractors, and subcontractors.
Business Partners may be asked to take reasonable steps to address such breaches, including undertaking audits and risk assessments, providing LightReach with records and information and/or developing corrective action plans. Violations of this Code may result in termination of the contract between LightReach and Certified Installer
How to Report
Contact your LightReach Relationship Manager
Send an email to: [email protected]
Write to: LightReach
1616 Camden Rd Suite 300
Charlotte, NC 28203
Attn: Legal and Compliance
All reported violations that include specific information will be investigated and appropriate action will be taken.
LightReach reserves the right to request an audit to verify compliance with these expectations, and LightReach expects Certified Installers to comply with reasonable requests for information, certifications, and/or audit access.