Quick Summary

Bronson served as IESO’s independent retail compliance auditor across 8 successive saveONenergy Seasonal Coupon Campaign cycles, completing a combined 581 site visits throughout Ontario.

Each campaign cycle applied three audit components: mystery shopping, purchase transaction testing, and promotional display compliance, coordinated through field teams of 8 to 12 auditors.

The most recent cycle covered 97 retail locations spanning 9 retailers and 13 municipalities, with findings detailed in this case study as representative of the multi-year program.

All 29 Costco locations in Ontario were visited for focused free-ridership transaction testing, recording a 28% failure rate and a dramatic improvement over their 69% result from the preceding Spring campaign.

Staff knowledge scores averaged 3.2 out of 5 across all retailers, matching the Spring 2015 result and continuing a modest multi-year upward trend.

Project Overview

The Independent Electricity System Operator (IESO) is the Ontario crown agency responsible for managing the province’s electricity grid and administering demand-side management programs, including the saveONenergy initiative. The saveONenergy Coupon Event is a bi-annual retail promotion designed to drive consumer adoption of energy-efficient products through point-of-sale discount coupons and in-store displays at participating retailers across Ontario. Participating retailers commit to training their staff on the program, installing promotional displays consistent with their Retailer Participation Agreements, and correctly processing IESO coupons at checkout.

Bronson served as IESO’s independent retail compliance auditor across eight successive Seasonal Coupon Campaign cycles, completing a combined 581 site visits to retail locations throughout Ontario. Each cycle covered both Spring and Fall campaigns and required Bronson to plan, coordinate, and support field teams of between 8 and 12 auditors to carry out mystery shopping exercises, purchase transaction tests, and in-store display assessments against retailer-specific compliance criteria. Following each campaign, Bronson delivered a findings report and presented results and recommendations directly to key IESO stakeholders.

The most recent cycle of this engagement is detailed here as a representative illustration of the multi-year program. The audit sample covered 68 standard retail locations across 9 retailers and 13 municipalities, with an additional focused exercise covering all 29 Costco locations in Ontario for free-ridership transaction testing. Bronson engaged Crawford and Company, the designated insurance adjuster for the Province of Ontario, to support field execution, deploying a team of six auditors operating from Crawford’s network of 57 Ontario offices.

The engagement also marked the first campaign cycle in which Standard CFL products had been removed from the saveONenergy scope, a change that introduced new compliance risks related to staff awareness and coupon eligibility interpretation.

The Challenge

Verifying compliance across a geographically dispersed retail network of this scale, involving nine distinct retail chains with varying Retailer Participation Agreement terms, required a structured and defensible audit methodology applied consistently across diverse store formats and markets.

  • Geographic scale and coordination: The audit spanned 13 municipalities from Windsor to Ottawa, requiring coordinated deployment of multiple field auditors across distinct markets while maintaining consistent scoring standards.
  • Multi-retailer variability: Each of the nine participating retailers operated under different Retailer Participation Agreement terms, with varying product scopes, display requirements, and coupon processing obligations, requiring the audit framework to be calibrated retailer by retailer.
  • Four-scenario transaction testing: IESO required coupon acceptance to be tested under four distinct purchase scenarios (Two Coupons, Ineligible Product, Refund, and No Coupon) simultaneously, demanding precise auditor briefing and execution discipline.
  • Free-ridership detection at Costco: All 29 Costco locations required a separate, focused evaluation for potential free-ridership, a persistent concern from prior campaigns that had generated a 69% failure rate in the preceding Spring cycle.
  • Scope integrity: A number of locations included in IESO’s official list of participating stores were found, on arrival, to have no campaign materials whatsoever, requiring a principled approach to excluding invalid sites from reported results without undermining the integrity of the broader analysis.
  • Product eligibility confusion: The removal of Standard CFLs from the campaign scope for the first time introduced a known risk of misunderstanding among store staff, requiring the mystery shopping framework to specifically probe whether representatives correctly distinguished between Standard and Specialty CFL eligibility.
  • Sales terminal programming: Retailers increasingly rely on pre-programmed sales terminals rather than cashier judgment to determine coupon eligibility, creating a systemic risk that errors in terminal programming would produce false compliance failures or, more critically, wrongful rejection of valid coupons.What IESO needed was a rigorous, independently conducted compliance picture that could be acted upon at both the retailer and campaign-management level.

Our Solution

Bronson structured the engagement as a seven-workstream field audit, coordinating design, training, execution, and reporting across a province-wide network under a compressed campaign window.

1. Stakeholder Kick-off and Scope Alignment

Bronson opened the engagement with a structured kick-off meeting with IESO representatives to confirm audit objectives, finalize the sample of 68 locations, and align on the specific compliance criteria for each retailer. This session also addressed the Costco free-ridership scope and the campaign timing constraints that would govern field scheduling.

2. Audit Guidance and Training Material Development

Bronson prepared step-by-step field instructions covering all three audit components: mystery shopping scripts, purchase transaction testing protocols for each of the four scenarios, and promotional display observation criteria. Guidance was calibrated each cycle for campaign-specific context, including any changes to product eligibility scope and the updated compliance matrices provided by IESO.

3. Sample Selection and Geographic Weighting

Bronson was responsible for selecting which locations to include in the audit sample. Site selection weighted metropolitan centres more heavily based on historical coupon redemption volumes, and retailer weighting reflected prior audit findings and the relative scale of each chain’s participation in the program.

4. Crawford and Company Field Deployment

Bronson engaged Crawford and Company to execute field visits across all 13 municipalities, leveraging Crawford’s provincial network of 57 offices and 150 insurance adjusters to eliminate travel overhead and ensure local presence across all markets. Bronson delivered training and briefing to assigned Crawford personnel to ensure scoring consistency.

5. In-Store Audit Execution

Field audits were scheduled to begin one week after campaign launch to allow participating stores adequate time to set up their displays, and concluded before the final campaign weekend to avoid flagging retailers for premature display takedown. Auditors engaged store representatives in mystery shopping conversations, conducted live purchase transactions under each assigned scenario, and photographed and documented all promotional display observations.

6. Costco Free-Ridership Testing

Each of the 29 Costco locations in Ontario received a dedicated site visit focused exclusively on the No Coupon purchase transaction scenario. Results were analyzed separately from the broader retailer sample to provide IESO with a standalone view of free-ridership risk at this retailer.

7. Findings Report and Stakeholder Presentation

Bronson compiled all field data into a structured draft report covering mystery shopping results by retailer and product type, purchase transaction results by retailer, city, and scenario, and promotional material compliance rates broken down by retailer and store size. In addition to the written report, Bronson prepared and delivered a summary presentation of audit findings to key stakeholders at IESO Headquarters in Toronto.

Key Deliverables

  • Mystery Shopping Results Spreadsheet – A detailed tabulation of mystery shopping scores for each store, product, and knowledge category, provided to IESO alongside the main report.
  • Purchase Transaction Results Spreadsheet – A store-level summary of all purchase transaction test outcomes by scenario and retailer, including flagged instances of sales terminal miscoding.
  • Promotional Display Compliance Spreadsheet – A store-level record of display observations covering coupon pad presence, shelf talker placement, poster compliance, and dedicated display ratings for all 64 participating stores.
  • Coupon Pad Presence Analysis by Product Type – A product-level analysis of coupon display rates across all 64 locations, segmented by year-round and seasonal merchandise categories.

The Impact

Bronson’s audit delivered a structured, evidence-based compliance picture across IESO’s participating retailer network that IESO could use to target corrective action and guide future campaign design.

  • The overall purchase transaction failure rate of 29% across 62 stores represented a measurable improvement over both the preceding Spring campaign (32%) and the equivalent Fall campaign two cycles prior (49%), confirming a multi-year trend of compliance improvement across the network.
  • Home Depot’s refund processing failure rate fell from 100% in preceding campaigns to 0%, attributable to a targeted change the retailer made to its refund processing procedures following prior audit recommendations.
  • No Coupon failure rate dropped from 69% in the preceding Spring campaign to 28%, falling below the average for all other retailers subject to the same test scenario (45%), reflecting the impact of prior audit findings on retailer behaviour.
  • Bronson identified two locations at Canadian Tire and Lowe’s where sales terminals were incorrectly programmed to reject valid coupons for eligible products, a finding with direct implications for consumer access to IESO incentives.
  • The audit documented a newly emerging and more pervasive pattern of Annual Campaign coupon substitution at six locations, including multiple Home Depot and Lowe’s stores, flagging a practice that was inconsistent with how the Annual Campaign was designed to operate.
  • Auditors identified an unintended pricing distortion created by the flat $5 LED coupon value across both single-pack and multi-pack products, which was effectively incentivizing consumers to purchase multiple single packs over more sustainably packaged bulk formats.

Across eight campaign cycles, the engagement gave IESO a consistent, independently verified compliance baseline against which retailer performance could be tracked, participation agreement obligations enforced, and program design adjusted over time. The steady improvement in transaction failure rates across successive campaigns reflects the compounding effect of audit-informed retailer accountability. Bronson’s sustained presence as IESO’s compliance auditor over multiple years of bi-annual campaigns established a repeatable audit infrastructure that both documented program compliance and contributed directly to the improvement it was measuring.

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