Vulnerable Consumer - home phone

The 111 Contact Code came into effect on 1 February 2021.

The purpose of this code is to ensure “Vulnerable Consumers” of internet-based phone services have access to an appropriate means of calling 111 emergency service in the event of a power failure or broadband outage.

If you, or someone in your household, relies on a landline connection for medical, safety or disability reasons, you may be able to apply to be listed as a Vulnerable Consumer. Information on who can qualify as a Vulnerable Consumer and how to apply is set out further below.

Using your home phone during a power outage

Our home phone service uses Voice over Internet Protocol (VoIP) technology, which means you won’t be able to use your home phone to make 111 calls during a power or broadband outage.

Our broadband service will also not be available during a power outage, as your modem/router requires power to work.

We strongly recommend you maintain or have access to a mobile phone service and keep a charged mobile phone at your premises in case you need to call 111 during a power outage or service disruption.

For more information see the New Zealand Telecommunications Forum 111 fact sheet below.

Telecommunications Forum 111 fact sheetpdf | 246 kB

Using other devices during a power outage

Some of your existing or future telecommunication devices that require power to work, but which do not have an inbuilt battery, may also stop working during a power outage. These could include:

  • Medical alarms
  • Monitored security alarms
  • Landline phones using a copper connection that also require power to work (e.g. cordless DECT phones)

We strongly recommend you contact the person or company that supplied the device if you are unsure.

Are you a Vulnerable Consumer?

To be eligible for Vulnerable Consumer status under the 111 Contact Code, you must be a consumer of a “retail landline service” (i.e. our VoIP home phone service) who:

  1. is at particular risk of requiring the 111 emergency service; and
  2. does not have an alternative means to contact 111 (that can operate for 8 continuous hours) in the event of a power failure.
Who is at “particular risk” of requiring the 111 emergency service?

A person who is “at particular risk” of requiring the 111 emergency service means anyone who is more likely than others to require the 111 emergency service because of a specific circumstance applicable to that person – e.g. for reasons of health, safety or disability.

A person may be at “particular risk” now, or sometime in the near future, or on a temporary basis.

Do you already have an alternative means to contact 111?

If you’re “at particular risk” but you already have an alternative means for contacting 111, then you are not considered a Vulnerable Consumer under the Code.

You may already have an alternative means to contact 111 if any of the following apply:

  • you have unrestricted access to a mobile phone and the premises where you live has adequate mobile coverage; or
  • your premises receives a copper landline service; or
  • you have an uninterruptable power supply (e.g. a battery back-up or generator) that will allow our VoIP home phone service to continue to operate during a power failure.

To register as a Vulnerable Consumer

We understand that some customers of our VoIP home phone service may not have access to a mobile phone and could be at particular risk of needing to call emergency services for health, security or disability reasons.

If you, or anyone in your household, might be vulnerable, it’s really important that you let us know. We’ll record this against your account and work with you to provide appropriate extra support.

If you feel this applies to you, please let us know as soon as possible by following these steps:

  1. Download, and complete the Vulnerable Consumer Application Form.

111 Contact Code Vulnerable Consumer Applicationpdf | 219 kB

  1. Email your completed Application and supporting evidence to or post it back to:
    Nova Energy
    PO Box 404
    Whakatane 3158
  2. If you are unable to print and fill out the application form you can call us on 07 306 2700 (or 0800 668 236) and we’ll assist with filling out the form on your behalf. Please ensure you have all relevant information with you when you call, including your nominated person’s contact details.

We will not deny your application to become a home phone customer, nor will we cease to supply you with a home phone service, if we know or suspect that you or someone in your household is, or may become, a Vulnerable Consumer.

What happens next?

Once we receive your fully completed application, we’ll review your application and advise you of the outcome within 10 working days.

If you, or someone in your household, qualifies as a Vulnerable Consumer, we will work with you to determine an appropriate alternative means for you to contact the 111 emergency service that meets your particular needs.

This alternative means will be:

  • able to operate for 8 continuous hours in the event of a power failure at your premises;
  • provided to you at no cost on or after 1 August 2021 (as per the Code).

Complaints under the 111 Contact Code

While we will always do our utmost to ensure our service is of the highest standard, should you have any issues or concerns in relation to the 111 Contact Code, we have a free comprehensive complaint investigation process in place to ensure such issues or concerns are thoroughly reviewed.

You can raise a complaint by contacting our customer care team on 07 306 2700 (or 0800 668 236), or by writing to:
Tammy MacArthur
Manager Retail Services
Nova Energy
PO Box 404, Whakatane 3158
Fax: 0800 200 427

We will try to resolve your complaint as quickly as possible and will acknowledge your complaint within 2 working days of receiving it. If we aren’t able to resolve your complaint, we will respond to you within 7 working days to let you know of the steps that have been taken to resolve your complaint. We will attempt to resolve your complaint within 20 working days.

Please note that:

  • Where a dispute under the Code concerns a consumer who is not a Nova customer (i.e. they are a person who ordinarily resides at the customer’s premises), the Nova customer at the premises where the consumer resides may refer the dispute to the Telecommunications Dispute Resolution Scheme (detailed further below) on behalf of that consumer.
  • If you think we are not complying with the Code, you may also raise a complaint directly with the Commerce Commission at, or phone the Commission’s Enquiries team on 0800 943 600. However, the primary method for making a complaint is to refer the complaint to the Telecommunications Dispute Resolution Scheme (detailed further below).

Telecommunications Dispute Resolution

The Telecommunications Dispute Resolution Scheme (TDR) is a free and independent service to help consumers manage complaints about any product or service from their telecommunications provider.

You can refer your complaint to the TDR if:

  • we have not been able to agree on a resolution and the dispute is therefore deadlocked; or
  • it has been more than 5 working days since you complained and the issue remains unresolved; or
  • you are still unhappy with the solution.

The contact details for the TDR are:
Telecommunications Dispute Resolution
PO Box 5573
Wellington 6140
Freepost 214075
Phone: 0508 98 98 98