TrustMark Continues to Represent Failure as Success

On Wed, 17 Dec 2025 at 10:40, Duncan Hayes <duncan.hayes> wrote:

Dear TrustMark (cc: DESNZ),

Before the Christmas break (and in any event prior to close of business Friday 19 December, given prior communications), I would be grateful if TrustMark could respond clearly and specifically to the following:

1. Fraud / misrepresentation handling (8 December submission)
   Please confirm precisely how my detailed allegations of potential RdSAP / ABS fraud and misrepresentation (shared on 8 December) are being handled by TrustMark, specifically.
2. Misrepresentation of insulated walls / property condition (Scottish Power / ECO4 eligibility)
   Please respond specifically to the further allegations (now established) of CES’ misrepresentation of uninsulated walls as insulated to Scottish Power, and misrepresentation of property condition for ECO4 — as evidenced by the attached call recording (further recordings available), the findings in TrustMark’s survey, and as first disclosed to TrustMark some time ago.
3. Systemic investigation approach / other victims
   Please confirm whether further cases reporting harm by CES will now be reviewed under systemic allegations. For context, I am now in receipt of documentation for at least one other CES customer, which contains elements raising further concerns as to potential data fraud (recognising that documentation can take months or years for victims to obtain).  I am also in contact with a further c.20 CES victims who want to know when they can get their homes and lives back on track.
4. Expert report — amendments and evidential scope
   Please confirm that TrustMark’s report is being updated in line with the factual clarifications and omissions shared yesterday prior to any final issue.

For avoidance of doubt, no full evidential record has been submitted by myself to TrustMark for consideration, and I have not received confirmation that any individual component of my evidence has been reviewed in full. Nor does the current report wording or photographic record indicate that such evidence has been considered.

5. Enforcement and remediation plan (including insolvency risk / Minister assurances)
   Please confirm what actions TrustMark is now taking to enforce compliance and ensure my home is remediated, in light of the evidence now available, the risk of insolvency, and the Minister’s assurances that TrustMark would ensure remediations to my home take place.
6. Scope of my complaint
   Please confirm that my complaint is being addressed in its entirety (per the attached document). If only in part, please specify which parts are being addressed, which parts are excluded, and the reasons.
7. “Pass” status / ongoing misrepresentation
   Please confirm that — given sufficient facts are now clear and unequivocal — my installation will no longer be represented as a “pass” until the PAS Objective has genuinely been achieved. If it continues to be presented as a “pass” in the meantime, I this must be considered to be ongoing misrepresentation, which I believe has systemic implications.
8. Insurance details (Feb 2023)
   Please confirm, at minimum (prior to Christmas), the professional indemnity and public liability insurance details for CES as at February 2023.
9. Why victims are left to fight for years — and what TrustMark will change now
   Please explain candidly (and without “political” phrasing) how it can be that ECO4 victims — often already suffering health and financial vulnerabilities — are left to fight for months or years with wrecked homes and without access to heat, in the absence of consumer protections in practice, standards enforcement, sufficient investigations, or temporary mitigations.
10. NICEIC refusal to investigate
    Please explain why, under the terms outlined in TrustMark’s Master Licence Agreement and given the extent and detail of the complaint attached, NICEIC have been able to refuse to investigate, and on what justifiable grounds. This is particularly concerning given that PAS standards, insulation, solar/roofing and enforcement (in any practical sense) were out of scope of HIES ADR (findings attached).
11. DESNZ / TrustMark position on victims bearing remediation costs
    Please explain how TrustMark / DESNZ considers it reasonable that ECO4 victims should bear the cost of remediation after prolonged suffering and scheme failure, and what actions are being taken in light of the assurances given during the Public Accounts Committee to ensure this is not the case — not only for EWI, but for all ECO4 measures.

Given the seriousness of the issues and the ongoing impact on my home and health (as well as many others affected), a clear and specific response is now needed without further delay.

Finally, I would respectfully note that whilst Christmas will no doubt provide a welcome pause for representatives of the various regulatory and assurance bodies involved, it will not offer respite to the many households whose homes and lives continue to be dominated by these issues over the festive period.

Kind regards,

Duncan Hayes