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Part of How to compare appointment setting agencies fairly
Appointment setting agencies: bribery and claims checks
Compliance checks before you select an appointment setting agency: Bribery Act 2010 procedures, evidence for claims and a written opt-out path.
What to take away
Compliance answers decide whether an appointment setting agency is safe to put in front of your customers. Ask for each one in writing and score it against your own brief.
- Fix your definition of a qualified appointment first, so every answer is scored against it.
- Ask for the evidence behind every headline number and every guarantee.
- Ask for the anti-bribery position in writing, not in a pitch deck.
- Test how an opt-out reaches every list the agency touches.
- Put liability for prospect complaints and the data exit into the contract.
Write the scoring key before you ask
Start with the meeting itself. Write down who counts as a decision maker, what budget signal qualifies them and how many no-shows you will tolerate. That single page becomes the scoring key for every compliance answer that follows. The weighting method sits in reviews and comparison methods.
Stage One Brief Checklist
- Define decision maker criteria
- Set budget signal threshold
- Set no-show tolerance
- Decide in-house sales cycle parts
- Assign follow-up ownership
- Create scoring key
Ask how the list was built and how an opt-out travels
Ask how the prospect list is built. Legitimate interest and consent behave differently once a regulator asks questions, so get the answer in writing with a worked example. A supplier that cannot show the build is asking you to carry the risk.
Evidence and Data Checks
- Prospect list build method
- Lawful basislegitimate interest, consent, suppression
- LinkedIn targeting logic explained
- Two anonymised call recordings
- One sample email sequence
- Written opt-out process and owner
Then test the opt-out path. Ask how a suppression request reaches every list the agency touches, including third-party data it buys. A verbal promise is not a process, so ask for the written version and the name of the person who runs it.
The ICO's business-to-business marketing guidance says that after an objection, opt-out or withdrawal of consent, you should add the contact to a suppression list instead of simply deleting all record of them. Ask the agency to confirm that it works this way. Settle the data protection steps before any prospect data is shared.
Test the claims before you trust the numbers
Any promise of guaranteed meetings or fixed conversion rates is a marketing claim, and B2B communications fall under the CAP non-broadcast advertising rules. Ask the supplier to show the evidence behind its headline numbers. Read the advertising rules for the detail.
Request two anonymised call recordings and one sample email sequence. Listen for pressure language and unverifiable claims, because those transfer risk to your brand. A claim you cannot verify should lower the supplier's score, however good the pitch sounds. Score each recording against the brief from the first step.
Ask how the agency prevents bribery
Anti-bribery controls matter where introductions, hospitality or referral fees appear. The Bribery Act 2010 makes it an offence for a commercial organisation to fail to prevent bribery committed by its associated persons to obtain or retain business.
An agency booking meetings on your behalf may count as an associated person, so its procedures matter to you. An organisation that can prove it has adequate procedures in place to prevent persons associated with it from bribing has a defence to the section 7 offence.
Ask for proportionate written procedures, not just a policy PDF, and for a named owner. Ask what the agency does when it offers or accepts hospitality or referral fees on your behalf. Record the answers beside the brief so they can be scored.
Name who answers for complaints
Check who is liable if a prospect complains. The commercial contract should name the responsible party and the timescale for notifying you. Without that clause, a complaint about the agency's calls reaches your brand before you know it exists.
Turn the answers into an evidence table
| Question | Written evidence to ask for | Answer that should worry you |
|---|---|---|
| How was the prospect list built? | Named source and lawful basis, with a worked example | "Proprietary database" |
| How does an opt-out reach every list? | A written process and the name of its owner | A verbal promise |
| What backs the headline numbers? | The data behind each claim | Guaranteed meetings or fixed conversion rates |
| What anti-bribery procedures exist? | Written procedures and a named owner | A policy mentioned only verbally |
| Who is liable for complaints? | A contract clause naming the party and notice timescale | Silence on liability |
Settle the exit in writing
Ask when your data is deleted, who confirms deletion and what happens to meetings already booked. Keep objections already received on a suppression list so they are still honoured after the contract ends. A supplier that resists a written exit clause is telling you something.
A broader due diligence checklist covers the rest of the supplier file.
Before you sign
- Write the definition of a qualified appointment and use it as the scoring key.
- Get the list build and the opt-out process in writing.
- Ask for the evidence behind every headline number and guarantee.
- Ask for written anti-bribery procedures and the name of their owner.
- Name the party liable for prospect complaints and the notice timescale.
- Agree the data deletion date, who confirms it and what happens to booked meetings.
Common questions
Does the Bribery Act matter for a small business?
The government guidance is intended for commercial organisations of all sizes and sectors. Whether a particular supplier relationship raises a risk depends on the facts, so ask the agency for its procedures and take advice if you are unsure.
Is a verbal assurance enough on opt-outs?
No. A verbal promise is not a process. Ask for the written version and the name of the person who runs it.
How should I treat a guaranteed-meetings promise?
As a marketing claim. Ask for the evidence behind it, and remember that B2B communications fall under the CAP non-broadcast advertising rules.
Who is liable if a prospect complains?
The contract should say. Name the responsible party and the timescale for notifying you.
