Customer Reviews Policy

  1. Policy Statement

1.1 Kennet Equipment Leasing Limited, Credo Capital Finance Limited, Ignition Credit PLC and First Capital Finance Limited form part of Star Asset Finance Limited and will be referred to as “The Group” within this policy. 

1.2 The Group’s policy is to conduct business in an open, honest, ethical and legal manner and to act professionally, fairly and with integrity in all business dealings and relationships.

1.3 The Group is committed to ensuring that customer reviews and ratings displayed or referenced by the Group are genuine, transparent and not misleading. The Group has a zero-tolerance approach to fake reviews and to practices that conceal, manipulate or misrepresent customer review information.

1.4 The Group does not offer incentives in exchange for reviews (including writing, changing or removing reviews), and will take active steps to monitor, report and address suspicious or non-compliant review activity.

1.5 This policy applies to reviews hosted by third-party platforms (including Trustpilot) and any reviews or ratings embedded or reproduced on the Group’s websites and other digital channels.

  1. Purpose

2.1 This policy sets out the Group’s approach, controls and procedures for:

  • requesting customer reviews in a fair and neutral way;
  • displaying customer review information (including star ratings) on websites and other channels;
  • preventing, detecting and addressing fake, misleading or incentivised reviews; and
  • maintaining appropriate oversight, governance and records.

2.2 This policy supports the Group’s obligations under applicable UK consumer protection rules and wider expectations around clear, fair and not misleading customer communications, including reputational and regulatory risk management.

  1. Review of Policy

3.1 This policy will be reviewed annually and amended as considered necessary by Senior Management and Compliance in the event of changing legislation, guidance, platform standards (e.g., Trustpilot policies) or changes to the Group’s processes. 

  1. Scope

4.1 This policy applies to:

  • all employees, contractors and representatives of the Group who request, manage, respond to or publish reviews;
  • Marketing, Sales, Customer Services, Operations and Compliance; and
  • all review-related communications and content, including:
    • Trustpilot reviews  (hosted on Trustpilot);
    • Trustpilot widgets and star ratings embedded on Group websites;
    • any internal or third-party review feeds shown on landing pages, product pages, and advertisements;
    • social media posts featuring reviews or ratings; and
    • email campaigns requesting reviews.

4.2 This policy applies to both regulated and unregulated products/services where reviews are used in customer communications.

  1. Definitions

5.1 Customer review: feedback, opinion or rating provided by an individual about a business, product or service.

5.2 Customer review information: information derived from reviews, including star ratings, averages, summaries, counts, excerpts, or “top reviews”.

5.3 Fake review: a review that is not based on a genuine experience, is posted by someone who has not used the service, or is otherwise manufactured, misleading or unauthentic.

5.4 Incentivised review: a review written, changed or removed in exchange for a benefit (discount, gift, voucher, cash, competition entry, preferential treatment, etc.), whether explicitly or implicitly, where this could influence content or star rating or is not transparently disclosed.

5.5 Selective solicitation (“review gating”): requesting reviews only from customers more likely to give positive feedback, or filtering who receives invitations in a way that could misrepresent overall customer sentiment.

5.6 Trustpilot: the third-party platform used by the Group (as applicable) to invite, collect, host and display reviews.

  1. Roles and Responsibilities

6.1 Compliance 

  • Owns this policy and approves all public-facing review-related policy wording.
  • Advises on compliance risks, banned practices, and remediation.
  • Oversees breach reporting and records related to review integrity.

6.2 Marketing

  • Ensures review widgets, ratings, excerpts and claims are presented fairly and not misleading. 
  • Maintains records of what is displayed, where, and when (including screenshots if needed).
  • Ensures review invitations are neutral and consistent with this policy.

6.3 All staff

  • Must not post, procure, request, edit, suppress, or encourage reviews in a way that breaches this policy.

  1. Policy Requirements

7.1 Prohibited practices

The Group prohibits:

  • creating, commissioning or facilitating fake reviews;
  • asking staff, associates, introducers, or third parties to post reviews that are not genuine;
  • offering incentives for reviews, or for changing/removing reviews;
  • exerting pressure on customers to remove or amend reviews;
  • selectively requesting reviews only from customers likely to be positive (review gating);
  • presenting review information in a way that could mislead (e.g., cherry-picked excerpts without context, or star ratings presented without clear source).

7.2 Neutral review invitations

  • Review invitation wording must be neutral (e.g., “Please share your honest feedback”).
  • Invitations must not indicate that only positive reviews are desired.
  • Where feasible, invitation triggers should be applied consistently across similar customer journeys.

7.3 Publishing reviews and ratings on the website

  • Where Trustpilot reviews/ratings are displayed, the Group will:
    • include a short disclosure explaining the source (Trustpilot) and linking to the public Reviews Policy;
    • avoid editing review text or star ratings;
  • Any marketing claim based on ratings (e.g., “Rated Excellent”) must be supportable and not misleading. 

7.4 Handling suspicious reviews

  • The Group will actively monitor for indicators of suspicious reviews and flag concerns to the relevant platform (e.g., Trustpilot) using available reporting mechanisms.
  • The Group will keep records of actions taken (see Section 9).

  1. Procedures

8.1 Requesting reviews (invitation process)

Permitted approach:

  • Invite customers to leave an honest review after a defined event (e.g., completion, resolution of query).
  • Use standard, neutral invitation templates approved by Marketing and Compliance.

Mandatory wording principles:

  • “honest feedback” / “share your experience”
  • no mention of incentives
  • no promise of benefit for leaving a review
  • no wording implying only 5-star reviews are requested

8.2 Responding to reviews

  • Responses must be professional, factual and not disclose personal data.
  • Where a review indicates dissatisfaction, responders should:
    • acknowledge the issue,
    • invite offline contact to resolve it, and
    • avoid arguing about subjective experiences in public.
  • Staff must not ask reviewers to delete or amend reviews.

8.3 Handling disputes and suspected fake reviews

Triggers:

  • review contains factual claims that appear incorrect;
  • reviewer cannot be matched to any customer record (where appropriate to check);
  • multiple reviews posted unusually quickly;
  • reviews suggest coercion, incentives, or third-party posting.

Process:

  1. Marketing/Operations logs the concern and evidence.
  2. Marketing/Compliance assesses and decides action:
    • flag/report to Trustpilot; and/or
    • post a neutral response requesting the reviewer to contact the Group; and/or
    • take no action if insufficient grounds.
  3. Record action and outcome 

  1. Monitoring, Reporting and Record Keeping

9.1 Monitoring frequency

  • Marketing to review Trustpilot activity at least monthly (or more frequently during campaigns).
  • Compliance to perform periodic oversight checks at least quarterly, or ad hoc where risk increases.

9.2 Record keeping

Marketing to maintain a Review Integrity Log containing:

  • dates of monitoring activity,
  • suspicious review references and evidence,
  • actions taken (flagged/responded/escalated),
  • outcomes (removed/retained/pending).

9.3 Retention

Records relating to review publishing decisions, monitoring and sign-offs must be retained for at least 5 years, or longer where required by law/regulatory expectations or ongoing investigations. 

  1. Breaches and Escalation

10.1 Any breaches of this policy must be reported immediately to Compliance and recorded in the Group’s breach log in line with the Group’s breach procedures. 

10.2 Examples of breaches:

  • incentivising reviews;
  • staff posting reviews about the Group;
  • selective review solicitation designed to improve ratings;
  • misleading use of reviews or ratings in customer communications.

10.3 Marketing/Compliance will determine corrective actions, which may include:

  • removal or amendment of misleading website content;
  • reconfiguration of widgets;
  • training refreshers;
  • disciplinary action (as appropriate);
  • external reporting/escalation where required.

  1. Training and Awareness

Relevant staff will be made aware of this policy and the prohibited practices. Refresher communications will be issued when material changes occur.

Appendix A: Website Reviews Policy 

Reviews Policy

Last updated: [20/08/2026]

Contents

  1. Purpose
  2. How we collect reviews
  3. Incentives
  4. Displaying reviews on our website
  5. How we tackle fake or misleading reviews
  6. Responding to reviews
  7. Reporting concerns
  8. Company information and contact
  1. Purpose

We value transparent, reliable feedback. This policy explains how we collect, display and manage reviews and ratings, including Trustpilot reviews shown on our website.

  1. How we collect reviews

We use Trustpilot as an independent platform to collect and host reviews. We may invite customers to leave a review after they have used our services. Invitations are intended to be neutral and to encourage honest feedback.

  1. Incentives

We do not offer incentives (such as discounts, gifts, vouchers, cashback, competition entry or other benefits) in exchange for writing, changing or removing a review.

  1. Displaying reviews on our website

Where reviews or star ratings are displayed on our website via Trustpilot:

  • the reviews are collected and hosted by Trustpilot; and
  • we do not edit the text or star ratings shown.

We aim to present review information in a clear and non-misleading way.

  1. How we tackle fake or misleading reviews

We actively monitor reviews and will flag suspected fake or incentivised reviews to Trustpilot for investigation using the tools available on the platform.

  1. Responding to reviews

We may respond publicly to reviews to thank customers, clarify factual points where appropriate, and invite customers to contact us so we can address any issues. We will not pressure reviewers to remove or amend reviews.

  1. Reporting concerns

If you believe a review relating to our services is fake, misleading, or incentivised, you can:

  • report/flag the review via Trustpilot; and/or
  • contact us using the details below.

    In writing: The Complaints Department, Kennet House, Temple Court, Temple Way, Coleshill, B46 1HH

    Email: [email protected]

    By phone: 01675 469 275