Following a meeting before Easter with some
members of the WIA and two members of the National Fraud Intelligence Bureau,
here is in draft form (comments and suggestions are greatly welcomed) the
conditions that I think would make a call to a non-client call acceptable.
A cold call is one to a stranger who does not anticipate a call and has not expressed an interest in wine investment. Such calls are not acceptable for the purposes of investment and are a high-pressure sales technique.
Calls can be made to non-clients who have expressed an interest in wine investment and who are aware that having expressed such an interest they can reasonably expect a follow up call. Increasingly this interest is likely to be expressed through a website. Companies should keep records of these leads to show that they were properly established leads and be able to produce them if challenged. If adopted by the WIA, these records should form part of the annual monitoring process.
Obviously there have to be the
necessary safeguards in place to ensure that potential client is not subject to
inappropriate and high-pressure sales. At the start of the call the potential
client must be given the opportunity to end the call. If calls are monitored
then those called must be made aware that the calls are monitored. The
threshold of high-pressure sales should be lower for the elderly and vulnerable.
When a client places an order over the phone they must be made aware of their right to cancel as in line with the Distance Selling Regulations’ legislation.
This draft of acceptable conditions will have to take cognisance of any proposals and changes that are made by the new The Financial Conduct Authority (FCA), which has now taken over from the Financial Services Authority.
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Hugo Rose MW, chairman of the WIA, has called on the fine wine trade to support self-regulation and the WIA here in Harpers. A prerequisite of getting such support should be ruling out cold calls – ie those to strangers who have no reason to expect a call about wine wine investment.

