TPI Code of Practice
RBE Technologies Limited trading as Tethera Energy
Introduction
This document sets out how Tethera Energy, the trading name of RBE Technologies Limited, conforms to the seven principles of the REC TPI Code of Practice (v2.0, last updated 1 September 2025) administered by RECCo. It is published as part of the voluntary signatory application ahead of first customer contracting and is available to energy suppliers, customers, and the public via the Tethera Energy website.
Tethera Energy is a technology-led business energy intermediary serving UK SME limited companies. The platform handles the customer journey end-to-end: bill upload, OCR extraction, eligibility and credit pre-screening, supplier quote orchestration, customer acceptance, e-signed LOA and contract, and submission to the chosen licensed energy supplier. Every step is timestamped, auditable, and retained for six years.
Tethera Energy operates a digital-only customer journey. There is no telesales, no verbal contracting, and no outbound consumer cold-calling. Commission is disclosed to the customer before contract acceptance. The platform does not rank suppliers by commission.
ADR & Regulatory Position
Tethera Energy is a member of the Energy Ombudsman ADR scheme, the Qualifying Dispute Settlement Scheme (QDSS) for energy brokers mandated by Ofgem's supply licence conditions.
Tethera Energy intends to be in the first cohort of registered TPIs when the Ofgem TPI registration regime opens (expected 2027). The compliance framework documented here and in the full Supplier Compliance Pack is designed to satisfy the anticipated registration requirements ahead of the regime opening.
Entity Details
| Field | Detail |
|---|---|
| Legal entity | RBE Technologies Limited |
| Trading name | Tethera Energy |
| Company number | 16918885 |
| Incorporated | 18 December 2025, England & Wales |
| Registered office | 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ |
| SIC codes | 35140 (Trade of electricity); 35230 (Trade of gas through mains) |
| Directors | Thomas George Regan (Commercial); Lee Christopher Baker (Technical) |
| ADR scheme | Energy Ombudsman (primary) |
| ICO registration | ZC142475 |
| Website | tetheraenergy.com |
| Complaints email | complaints@tetheraenergy.com |
Principle 1 - Transparency & Accuracy
Code purpose: to empower consumers to make informed purchasing decisions.
| Code requirement | Tethera Energy conformance |
|---|---|
| TPI must provide clarity from the outset that it is an intermediary and must not misrepresent itself | All customer-facing materials identify Tethera Energy as a Third Party Intermediary acting between the customer and licensed energy suppliers. The landing page, LOA, Customer Terms, and Commission Disclosure all open with this position. |
| TPI must provide clarity on how it is remunerated, before the customer enters into a contract | Commission Disclosure Statement is presented to the customer at LOA signature and again at quote acceptance, before the customer commits to any supply contract. The customer cannot proceed without acknowledging it. |
| Clarity that commission is included in the cost | The Commission Disclosure Statement explicitly states that the supplier recovers the cost of commission via the charges paid under the supply contract. This wording follows RECCo Appendix 2 and the EDF and Yu Energy Principal Terms format. |
| Clarity on how commission is determined | Commission per quote is presented as a pence-per-kWh uplift and/or standing-charge uplift, with the calculation visible on the quote document and again on the Principal Terms at contract acceptance. |
| TPI must maintain accurate consumer data and provide it as required by supplier | Bill upload via OCR captures structured fields (MPAN/MPRN, supplier, end date, consumption, address). Submission Accuracy is a tracked KPI with a target of 99% or above. |
| TPI must take reasonable steps to establish accurate EAC / AC / AQ data and maintain records of how it was calculated | EAC / AQ values are captured directly from the customer's bill where available, or derived by the platform from documented assumptions. The calculation method, source bill image, and timestamp are retained against the customer record for six years. |
| TPI must ensure consumer is aware of the EAC/AQ used when tendering for prices | EAC/AQ values are shown to the customer on the quote document. Where Tethera Energy has derived an EAC/AQ rather than read it from the bill, the derivation is flagged. |
| TPI must not misrepresent the supplier contract type or contract price | Quotes are presented exactly as received from the supplier API or quote response. No editing of supplier-provided terms, no overlay marketing language on the quote document itself. |
| References to suppliers, legislation, or industry news must be accurate and traceable | Marketing copy reviewed before publication. Regulatory references (REC, Ofgem, DESNZ) are versioned to the source document. |
| When customer enters a contract, TPI must ensure customer is aware it is legally binding | The contract acceptance step on the platform presents a clear binding-contract declaration that the customer must explicitly tick before submission. |
Principle 2 - Transparent TPI Pricing & Product Information
Code purpose: enable consumers to compare TPIs effectively, support competition, ensure visibility of TPI commission.
| Code requirement | Tethera Energy conformance |
|---|---|
| Customer-facing documentation must include the calculation that determines TPI commission | Customer Terms include the commission calculation methodology. Per-quote commission shown as pence per contract or pence per kWh uplift on the quote document. RECCo Appendix 1 illustrative format used. |
| Prior to the customer entering into a supply contract, TPI must clearly state the commission and how it is calculated | Commission for the specific contract is presented at quote acceptance, with the calculation shown (e.g. 'Commission: 0.8p/kWh x estimated annual consumption x contract term'). The customer cannot proceed without acknowledgement. |
| Commission figure must include any commission payable by the consumer | Tethera Energy does not charge the customer a separate procurement fee. Total commission disclosed is the supplier-funded amount only; if any direct customer fee were ever introduced, it would be added to this figure. |
| TPI must provide clarity on which suppliers were approached and the prices quoted | On the customer's quote presentation page, every supplier approached is listed with the response received (priced quote / declined / no response). The customer can see the full eligible market. |
| TPI must clearly state the products and services provided in writing, in plain English | Customer Terms clause 4 sets out the scope of services. Plain English; reading age targeted at GCSE level. |
Principle 3 - Treating Consumers Fairly
Code purpose: ensure TPIs treat consumers fairly, increase engagement and trust.
| Code requirement | Tethera Energy conformance |
|---|---|
| Recommended supply contract must be suitable for the consumer based on the information provided | Eligibility logic matches the customer's stated requirements (term length, renewable preference, payment method) and consumption profile against available supplier products. Where multiple eligible products exist, the customer chooses; commission does not influence ranking. |
| Material terms must be clearly and fairly explained, including separate commodity and non-commodity charges | Quote presentation breaks out unit rate, standing charge, contract term, exit fees (if any), and any pass-through cost element. Principal Terms summary presented before acceptance per EDF and Yu Energy format. |
| TPI must only represent a Change of Tenancy if there is reasonable evidence the consumer is a new occupier | Change of Tenancy claims require supporting evidence (lease agreement or solicitor's letter). The journey cannot proceed without uploaded evidence. Platform enforcement. |
| Consumers must not be subject to unreasonable pressure | Digital-only customer journey. No telesales. No outbound pressure tactics. Quote validity windows shown clearly; no fake urgency. Channel partner agreements prohibit pressure conduct. |
| TPI must obtain an LOA consistent with Appendix 2 of the Code | The Tethera Energy LOA template is drafted directly against RECCo Appendix 2 and updated to reflect the September 2025 review (which removed the use case allowing TPIs to sign supply contracts on the customer's behalf). Full LOA template is reproduced later in this document. |
| Where an LOA is revoked, TPI must promptly inform all suppliers with which the LOA had been registered | Revocation handling is automated: customer revokes via the platform, notification dispatched to all suppliers within 1 business day, confirmation logged. |
| TPI must bring contract termination fees to the customer's notice | Termination fee applicable to any quoted contract is shown on the quote document and again on the Principal Terms. Where a customer is exiting an existing contract, Tethera Energy flags any termination fee payable to the existing supplier before the new contract is signed. |
Principle 4 - Clear Route for Dispute Resolution
Code purpose: ensure consumers have a clear route to address TPI complaints.
| Code requirement | Tethera Energy conformance |
|---|---|
| Robust complaints procedure available via website and in hardcopy on request | Complaints Handling Procedure published on the Tethera Energy website. Hardcopy available on request to the registered office. |
| Procedure maintained and version-controlled; previous versions available | Document control register tracks every version. Old versions archived and available on request. |
| For Small or Micro Business consumers, TPI must be signed up to a qualifying ADR scheme | Tethera Energy is a member of the Energy Ombudsman ADR scheme. ADR scheme name and membership details are stated on the Customer Terms, the LOA, the website footer, and the customer-facing complaints procedure. |
| Consumers must be able to register complaints by phone, post, and email/electronic format | Complaints accepted by email (primary), post (registered office), web form, and telephone. All routes are equally weighted in the complaints procedure. |
| Complaints logged electronically with date, reason, action, outcome; held for at least 6 years | Complaint register held electronically, six-year retention enforced. KPI tracking on resolution time and upheld rate. |
| TPI must clearly signpost the consumer to the ADR scheme and other independent help | ADR signposting on website footer, customer email signatures, complaints procedure document, and final response letters. Citizens Advice and the Extra Help Unit also signposted for micro-business customers. |
Principle 5 - Appropriate Data Protection Arrangements
Code purpose: provide assurance that regulatory requirements for data protection are met; promote trust.
| Code requirement | Tethera Energy conformance |
|---|---|
| Handle consumer data per UK GDPR, Data Protection Act 2018, and PECR | Full data protection framework: Customer Privacy Notice, Record of Processing Activities (ROPA), Data Processing Agreement (full Article 28 text), Data Protection Impact Assessment, sub-processor register, and PECR / direct marketing compliance statement. All documented in the Tethera Energy Supplier Compliance Pack. |
| Register with ICO and pay the data protection fee | ICO registration: ZC142475 |
| Maintain an up-to-date data protection policy | Data Protection Policy reviewed annually; version-controlled. |
| Access controls to guard against unauthorised access to personal data | Role-based access; MFA on all privileged accounts (AWS, GitHub, banking, CreditSafe); audit logging on production data stores; quarterly access review. |
Principle 6 - Awareness Training
Code purpose: ensure TPIs and their representatives understand the requirements of the Code.
| Code requirement | Tethera Energy conformance |
|---|---|
| Representatives must regularly undertake training on Code principles | Training matrix includes a TPI Code of Practice module covering all seven principles. Mandatory at induction; annual refresher. |
| Training extended to all relevant staff, third parties, agents, or representatives | Channel partner agreements require partners to confirm awareness of Code principles in customer-facing interactions. Tethera Energy does not currently use sub-brokers or aggregators. |
| Maintain a detailed training log including next refresher dates | Training Completion Log holds per-individual, per-module records with refresher dates. Training Exception Register holds open exceptions. |
| TPI is responsible for ensuring all staff and representatives adhere to principles | Director - Commercial is the named accountable individual. Compliance with each principle tracked in this conformance review, repeated annually. |
Principle 7 - Compliance Processes
Code purpose: ensure TPIs maintain evidence of compliance and have processes to check sales and other activity against the Code.
| Code requirement | Tethera Energy conformance |
|---|---|
| Retain evidence of compliance, including telephone recordings (with consumer awareness) | Tethera Energy operates a digital-only customer journey with no telephone sales. All compliance evidence is platform telemetry: bill image, OCR-extracted fields, eligibility decision, quote payload, customer acceptance event, LOA signature, contract submission, supplier confirmation. Retained for six years. |
| Appropriate compliance processes to check sales and activities against the Code | Internal audit programme explicitly samples LOA execution, submission accuracy, commission calculation, complaint handling, and channel partner conduct against Code principles. Critical and High findings tracked to closure with verification by the director not responsible for the area. |
Commission Disclosure Statement
Tethera Energy may receive commission from the energy supplier when a business energy contract is placed through the platform. The supplier recovers the cost of any such commission via the charges the customer pays under their supply contract.
The amount and calculation of commission applicable to a specific quote is provided to the customer:
- At LOA signature - a general statement that commission may be payable and how it works.
- At quote presentation - the specific commission for each quoted product, shown as a pence-per-kWh uplift and/or standing-charge uplift, alongside the estimated annual cost and total contract cost.
- At contract acceptance - on the Principal Terms document presented before the customer signs, with the commission amount restated alongside the key contract terms.
Unless otherwise agreed in writing, the customer is not charged a separate Tethera Energy fee. Commission detail is available on request at any time.
Tethera Energy does not select suppliers solely on the basis of commission. Eligibility, the customer's stated preferences, supplier availability, and pricing determine which quotes are presented. The platform does not rank quotes by commission.
Complaints Handling Procedure - Summary
Tethera Energy takes complaints seriously. If something goes wrong, the customer has a clear, free, and fair route to resolution.
How to complain
By email: complaints@tetheraenergy.com
By post: Complaints, Tethera Energy, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
By telephone: via the contact number published on the Tethera Energy website
Online: via the complaints form at tetheraenergy.com/complaints
What happens next
Acknowledgement within 2 business days. Tethera Energy will investigate and aim to resolve within 10 business days. A final resolution, including any remedy, will be provided within 20 business days where possible.
If the complaint is not resolved
If the complaint remains unresolved after 8 weeks, or if Tethera Energy issues a deadlock letter before that point, the customer may escalate to the Energy Ombudsman - an independent Alternative Dispute Resolution service, free to use.
Energy Ombudsman: www.energyombudsman.org
The Energy Ombudsman can investigate the complaint and, where appropriate, require Tethera Energy to take action including an apology, a practical correction, or a financial remedy.
Complaints about the energy supplier
If the complaint relates to the energy supplier rather than Tethera Energy's role as intermediary, the customer should contact the supplier directly. Tethera Energy will assist with routing the complaint and providing any relevant evidence held on the platform.
Records
All complaints are logged electronically with date received, nature, actions taken, and outcome. Records are retained for six years. Complaint volumes, resolution times, and outcomes are tracked as KPIs and reviewed at director level.
Letter of Authority - Template
This Letter of Authority is drafted to align with the minimum requirements set out in Appendix 2 of the REC TPI Code of Practice (v2.0, September 2025). It authorises RBE Technologies Limited, trading as Tethera Energy, to act as the customer's Third Party Intermediary in the procurement of business electricity and gas supply contracts.
Customers execute the LOA electronically via the Tethera Energy platform. The platform captures signatory name and role, IP address, timestamp, version of the LOA accepted, and explicit confirmation of intent.
1. Customer details
Customer's legal business name; Companies House registration number; registered address; trading address (if different); authorised contact name; role / position; email address; telephone number.
2. Authorised actions
By signing this LOA, the customer authorises Tethera Energy to: (a) Obtain confirmation of energy supply contract end dates. (b) Obtain confirmation of annual energy consumption (EAC / AQ) and provide updated values. (c) Obtain half-hourly or daily metering data where applicable. (d) Obtain meter details (MPAN / MPRN, profile class, meter type). (e) Obtain tariff details. (f) Obtain copy invoices. (g) Serve termination notices under gas and/or electricity supply contracts. (h) Request quotes for new gas and/or electricity supply contracts. (i) Notify a change of occupier at the customer's premises (Change of Tenancy). (j) Receive and respond to supply transfer objections, including account balance information where relevant.
3. What this LOA does NOT do
Following the September 2025 RECCo TPI CoP review, the use case allowing a TPI to sign and enter into supply contracts on the customer's behalf has been removed. Tethera Energy does not sign supply contracts on behalf of the customer. The customer signs the supply contract directly via the Tethera Energy platform after reviewing and accepting the final terms, including Principal Terms and TPI commission disclosure.
4. Sub-brokers and partners
Where the customer has been introduced to Tethera Energy via a channel partner, the introducing party is identified to the customer in writing at the point of LOA. Tethera Energy does not currently delegate switching responsibility to sub-brokers.
5. Duration and revocation
This LOA is valid for twelve (12) months from the date of signature. If the customer enters into a supply contract via Tethera Energy during that period, the LOA continues to apply until the end of that supply contract unless the customer revokes it in writing. The customer may revoke this LOA at any time by giving written notice.
6. Terms, conditions, and complaints
By signing, the customer confirms they have been pointed to the Tethera Energy Terms and Conditions and the Tethera Energy Complaints Handling Procedure, and that the customer has been signposted to the ADR scheme of which Tethera Energy is a member (Energy Ombudsman).
7. Commission acknowledgement
The customer acknowledges that Tethera Energy may be paid a commission by the energy supplier and understands that the supplier will recover the cost of any such commission via the charges the customer pays under their supply contract. The amount and calculation of any commission applicable to a specific quote is provided to the customer with that quote and again on the Principal Terms before the customer accepts.
8. Data protection
Personal and business data is processed in accordance with the UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003. The Tethera Energy Customer Privacy Notice describes the categories of personal data processed, the lawful bases relied on, retention periods, and the customer's rights.
9. Customer declarations
By signing, the customer confirms: (a) the signatory has authority to bind the business; (b) the information provided is accurate and complete to the best of their knowledge; (c) the LOA has been read and understood in full; (d) the customer understands that proceeding to a supply contract will create a legally binding obligation between the customer and the supplier.
10. Governing law
This LOA is governed by the laws of England and Wales.
11. Signature block
Customer's authorised signatory: [name]. Position: [role]. Date: [auto-captured]. Plus: IP address; user agent; LOA template version reference; explicit tick-box confirmation of intent.
This LOA template aligns with Appendix 2 of the REC TPI Code of Practice (v2.0, September 2025) and is compatible with the LOA validation criteria operated by EDF Small Business, British Gas Business, Yu Energy, Valda Energy, and other Tier 1 SME energy suppliers.
Signatory Declaration
RBE Technologies Limited, trading as Tethera Energy, confirms that it will adhere to all seven principles of the REC TPI Code of Practice in the conduct of its business as a Third Party Intermediary in the non-domestic energy market.
This conformance statement, together with the supporting LOA template, Commission Disclosure Statement, and Complaints Handling Procedure, constitutes the evidence for the signatory application.
The conformance position documented above is operational today. Full Supplier Compliance Pack is available by request.
| Director - Commercial | Director - Technical | |
|---|---|---|
| Name | Thomas George Regan | Lee Christopher Baker |
| Companies House ID verified | Yes | Yes |
Approved by the directors of RBE Technologies Limited, May 2026
Document version: 1.0 - May 2026