Consumer Code of Practice on Complaint Handling and Dispute Resolution and our Code of Practice for Premium Rate Services and NTS calls

PART 1: PremierTalk Ltd Code of Practice on Complaint Handling and Dispute Resolution for Domestic and Small Business Customers

Introduction to our company and services

PREMIERTALK LTD is an independent company that delivers communications services to domestic and business customers. While we may not provide all the component parts of our services ourselves we do take responsibility for the services delivered to you. So we will liaise with our suppliers to ensure that any problems with their services are resolved promptly.

Purpose of this Code of Practice

This Code informs you about our products, services, and customer care policies. Our code has been approved by Ofcom, the independent regulator for the UK communications industries for the purpose of section 52 of the Communications Act 2003. This Code of Practice is published on our website www.premiertalk.co.uk. Additional copies are available on request and free of charge to any domestic and small business customers. It is also available in larger print.

How to contact us

Please contact our Customer Service Team.

• By phone:From 9.00am until 5.00pm Monday-Friday.
• By e-mail: admin@premiertalk.co.uk
• By fax: 020 8200 4939
• By letter: PREMIERTALK LTD, EBC House, Townsend Lane, Kingsbury, London. NW9 8LL
• Or via our website www.premiertalk.co.uk

Our commitment to you

We are committed to giving you the highest quality of customer service. When we purchase our services from wholesale providers, we choose those providers carefully to ensure that you get a high quality service. We make every reasonable effort to supply services that satisfy your requirements. We work to all relevant laws and regulations.

Our products and services

• Landline calls
• CPS-Carrier Pre-Selection
• WLR -Wholesale Line Rental
• Broadband access

For more details on any of our products and services, or to place an order immediately, please contact our Customer Service Team on.

You may also purchase our services from local dealers and retailers around the UK. For more information, please contact the Customer Service Team on 020 8358 2574 or see our website www.premiertalk.co.uk

Marketing

We work to the principles within the British Code of Advertising, Sales Promotion and Direct Marketing, which may be found on the website, www.cap.org.uk

Terms and conditions

When you subscribe to a service from PREMIERTALK LTD, we will send you our Standard Terms and Conditions and ask you to sign a contract, if applicable. If you have any questions, please phone our Customer Service Team on. We may carry out a credit check as part of our assessment procedures.

Where applicable, the minimum contract term for our services is 12 months. We aim to provide services within fourteen working days of your original request, subject to the availability and installation of any equipment and, where appropriate lines to your premises. If we need to carry out a survey of your premises or lay additional cabling we will advise you of the revised timescales as soon as we can.

Cancellation

If you decide to cancel your order or agreement before we have provided the services, you may do so without charge within seven working days after your order is placed. After seven working days we will charge you an administration fee as set out in your contract. Should you wish to terminate your contract within the minimum term of 12 months we will charge a fee as set out in your contract.

Faults and repairs

Please call our Fault Service Team on 020 8358 2576 if you experience a fault with any of our services. We aim to have this investigated and repaired within two days.

Price lists

Our pricing structure is available from our Customer Service Team on and via our website www.premiertalk.co.uk. We will write to you in advance if we change the pricing structure on your products and services.

Billing

We will bill you monthly.

You can choose to pay us via a range of options including credit card, cheque and direct debit. These are agreed at the start of your contract. If you wish to change your method of payment at any time, please call our Customer Service Team on.

We provide statement bills as part of our service to you free of charge.

If you have difficulty paying your bill, please contact us on 020 8358 2574 and we will try to arrange a different method of payment. We will do all we can to help our residential and small business customers to manage their bills and avoid disconnection. Please refer to PREMIERTALK LTD�s company terms and conditions.

If you are moving home or office

Please call our Customer Service Team on 020 8358 2574 no later than 30 days before your move date. We will amend your account and billing requirements as necessary. We will endeavour to offer you the same telephone number to minimise disruption but please note that this is not always possible.

Number porting

PREMIERTALK LTD recognise that keeping your existing telephone numbers may be important to you. If you move your business to us and wish to keep the number that you have with your old provider, we will arrange it if you ask us. We will work with you to ensure that the services are switched over at a convenient and appropriate time. For more information, please call our Customer Service Team on 020 8358 2574.

Directory Entries

You are entitled to a Directory listing (including an entry in the phone book). If you do want your details included, please contact our customer service team on 020 8358 2574.

Complaints

We make every effort to ensure that our customers are happy with the level of service, and the products and service they receive from us. However, despite our best efforts, things can go wrong. We take customer complaints very seriously and aim to resolve them quickly and efficiently.

If you have a complaint about any part of our service, please contact our Customer Service Team on 020 8358 2574. Our advisors will ask you about your complaint and seek to resolve the problem while you are on the line. During any discussions we will protect the privacy of the information that we hold on you. To do this we may have to ask you questions to confirm that we are speaking to the right person.

You may also send your complaint to us in writing at PREMIER TALK LTD, EBC House, Townsend Lane, Kingsbury, London. NW9 8LL

We will try to resolve your complaint quickly and efficiently, and to keep you informed at all times. If your complaint is not resolved to your satisfaction, you can take it further within our company, and ultimately to the Managing Director at the above address. If we cannot resolve the problem, we will write to you to say so.

If you remain unhappy and wish to pursue your complaint further, if your complaint has been outstanding for more than 8 weeks or you have received a letter from us saying that your complaint has reached �deadlock�, then you may ask for help from Otelo PO Box 730 Warrington, Cheshire, WA4 6WU - Tel: 0330 440 1614 - email: enquiries@os-communications.org - Website: www.os-communications.org

Otelo is an independent organisation which is approved by Ofcom to provide an alternative dispute resolution (ADR) service. Ofcom-approved ADR services sort out disputes between communications providers and their consumer and small business customers. Their job is to investigate complaints fairly by listening to both sides of the story. They look at the facts given to them before recommending any action that may be needed to put things right.

Nuisance calls

We take the problem of nuisance calls and malicious communications very seriously. We tackle it by working closely with the police and others in the communications industry. If you have been a victim of this activity, please call the Customer Service Team onto report the incident and for information on how to deal with it.

Services for people with special needs

We are committed to helping all our customers to communicate easily. We offer the following additional services for customer who are older or who may have a disability, including:

• Priority access to the Customer Service Team
• Priority fault repair and assistance
• Additional help and support if you have difficulty paying your bill

Copies of this Code are available in larger print and other formats on request

Data protection

We comply fully with our obligations under the Data Protection Act 1998.

PART 2: PremierTalk Ltd Code of Practice for Premium Rate Services and NTS calls

Purpose of this Code of Practice

This code informs you about our policies on providing information about Premium Rate Services (PRS) and on our call charging policy for call to NTS and PRS numbers.

Premium rate services

Premium rate services (PRS) are telephone numbers that offer some form of information or entertainment that is charged to your phone bill. UK-based PRS numbers are normally prefixed by "09". 0871 is now also designated as a Premium rate number and subject to PRS regulation Typical services include TV vote-lines, mobile ring-tone downloads, technical help-lines, charity fund-raising and adult entertainment.

Charges for these services are added to your telephone bill. Calling a PRS number generally costs between 10 pence and �1.50 per minute, per call or per text (incl. vat). Calling these services from, for example, mobile phones, cable networks or public payphones will generally cost more than the advertised rate but communication providers must publish calls to 0870 numbers where these are higher than calls to geographic numbers. Our charges for calling these services are shown in our price list, which is available on request from our Customer Services Team on and via our website www.premiertalk.co.uk.

If you have a problem with PRS, we can help. We can provide advice on checking the telephone number of any PRS charges that appear on your bill and will try to help you identify the premium rate service provider. We can use call barring to restrict access to �09� numbers. Please call our Customer Service Team onfor advice on this. We can give you a fact sheet on PRS.

You can also ask for help from PhonepayPlus (Formerly ICSTIS) which is the industry-funded regulatory body for Premium Rate Services. PhonepayPlus operates a code of practice that sets out standards for the operation of PRS. You can use the PhonepayPlus website at www.phonepayplus.org.uk to check PRS numbers direct or to download a complaint form. PhonepayPlus has legal powers to require a provider of PRS to amend its service or promotional material (or both) and can also impose penalties on content service providers. For other ways to contact PhonepayPlus, see the �Useful addresses� section below.

Number translation services

Number translation services (NTS) are based on numbers that are normally pre-fixed �08�. For example, 0800 and 0808 are used to provide freephone services (some freephone services are also provided on 0500 numbers). 0844 and 0845 numbers are used for dial-up pay-as-you-go Internet access and customer service helplines. 0870 and 0871 numbers are used for information services, technical helplines and telephone banking. They are also used by organisations to help them provide call-management features such as intelligent call routing and fax-to-email services.

Charges for calling services on NTS numbers are added to your telephone bill and prices range from free up to 10p per minute or per call (incl. vat). Calling these services from, for example, mobile phones, cable networks or public payphones will generally cost more than the advertised rate. Our charges for calling these services are shown in our price list, which is available on request from our Customer Services Team on 020 8358 2574 and via our website www.premiertalk.co.uk. We can also give you a factsheet on NTS.

If you are unhappy with the help you have received from us on a problem with PRS or NTS, please email us at                                                 admin@premiertalk.co.uk , who has responsibility for compliance with our code of practice for PRS and NTS. You may also complain using the complaints procedure set out in this code including, ultimately, referring your complaint to Otelo PO Box 730, Warrington, Cheshire, WA4 6WU - Tel: 0330 440 1614 - email: enquiries@os-communications.org - Website:www.os-communications.org.uk

Internet diallers

If you use the Internet, it is possible for software to be placed on your computer without you knowing - using the same methods as for computer viruses. This type of software (known as Internet or rogue diallers) can then make calls to PRS and NTS numbers without your knowledge. Software is available to detect this activity and we can help you to access this - please contact our Customer Services Team on for details. PhonepayPlus has been given responsibility for policing this type of activity and you can contact them via www.phonepayplus.org.uk to ask for help or to report examples of this type of abuse. For other ways to contact PhonepayPlus, see the "Useful addresses" section below. We can also help by barring calls to 09 numbers.

The Telephone Preference Service

If you don�t want to get sales and marketing calls you have not requested,you can add your details to a list run by the Telephone Preference Service (TPS). If your number is on the list, it is illegal for a company to call you for marketing purposes. You can contact the Telephone Preference Service via www.tpsonline.co.uk or by telephoning 0845 0700707.

Useful addresses

OteloPO Box 730, Warrington, Cheshire, WA4 6WUTel: 0330 440 1614 - email: enquiries@os-communications.org - Website: www.os-communications.org

OfcomRiverside House, 2a Southwark Bridge Road, London SE1 9HATel: 0845 456 3040 or 020 7981 3040Email: contact@ofcom.org.ukWebsite: www.ofcom.org.uk

PhonepayPlusClove Building, 4 Maguire Street, London, SE1 2NQTel: 0207 940 7474Website: www.phonepayplus.org.uk

Telephone Preference ServiceDMA House, 70 Margaret Street, London W1W 8SSTel: 0845 070 0707Website: www.tpsonline.org.uk

Federation of Communication Services (FCS)Burnhill Business Centre, Provident House, Burrell Row, Beckenham, Kent BR3 1ATTel: 020 8249 6363Email: fcs@fcs.org.ukWebsite: www.fcs.org.uk

Code of Practice - Sales and marketing of fixed-line telephone services

Introduction and overview

The purpose of our Code of Practice is:

• to show that PremierTalk  Ltd. ("our", "us", and "we" refer to PremierTalk Ltd.) adopts responsible selling techniques when marketing our fixed line-telecommunications services ("services");
• to help our customers and potential customers understand our services and the behavior to be expected from our representatives;
• to show that we provide our customers with higher standards of protection than consumer law requires; and
• to set out clearly what is good practice in the sales and marketing of our services, as reassurance to our customers.

The code applies to the sales and marketing of our services to domestic and small business customers ("you" and "your" refer to customers) and covers all aspects of the sales process. We aim to avoid mis-selling and misrepresentation and to ensure that you fully understand the services and the terms of the contracts we offer you.

All our sales and marketing staff, sub-contractors and agents are briefed on this code and we routinely monitor compliance with it. If you feel that any representative of PremierTalk has breached the terms of the code, please report your concerns to our complaint�s department, who has responsibility for compliance with this code, and for handling associated complaints.

Compliance Manager

PremierTalk, EBC House, Townsend Lane, Kingsbury, London. NW9 8LL

Tel -

Email - admin@premiertalk.co.uk

For any queries about our Code of Practice do not hesitate to contact us

Copies of this code are available free of charge in various formats on request, including via our websitewww.premiertalk.co.uk. The code has been prepared in line with guidelines published by Ofcom, the industry regulator, on 13 April 2005.

Sales, marketing, advertising and promotional activity

We make customers aware of and promote our services by various methods. In all cases, we act responsibly and try to comply with relevant legislation.

We will respect your wishes if you have registered with any relevant preference service, including the Mailing Preference Service, the Telephone Preference Service, the Fax Preference Service and the E-mail Preference Service.

All our advertising and promotion activity keeps to the principles of the British Codes of Advertising and Sales Promotion. In addition, we ensure that advertising and promotional literature is clear, unambiguous, accurate and fair, does not contain false or misleading information about price, value or service and does not denigrate other companies.

Recruitment and sales training

To ensure that our employees act responsibly at all times, we follow strict procedures in the selection and training of staff that have direct sales and marketing contact with customers. We also ensure, to the best of our ability, that all our sub-contractors and agencies use equivalent selection and training procedures and remuneration (payment) systems.

When recruiting new sales staff we take up references and carry out relevant background checks. We also consider whether applicants are suitable for this type of work, recognising that our sales people will be seen as the 'public face' of our company and the industry in general. We encourage our sub-contractors and agencies to do the same.

We train our sales and marketing employees, our sub-contractors and agencies to ensure they have a good understanding of our services and of industry practice generally and do not give our customers inaccurate or misleading advice.

We also ensure that our sales staff, our sub-contractors and agencies are familiar with the relevant aspects of consumer protection law, the content and interpretation of this code and the benefits it provides to customers.

Our remuneration systems for all sales and marketing personnel, sub-contractors and agencies are designed to discourage misleading or exploitative sales practices.

Customer contact

Our sales staffs are given clear guidelines on contacting residential customers at home, particularly during the hours of darkness. They must not visit you before 8am or after 8pm, and must not telephone before 8am or after 9pm, unless you ask them to.

Representatives involved in face-to-face sales and marketing have identity cards or badges that clearly display our company name and the representative's own identification number. The identity badge also displays the representative's name and photograph and a date showing the validity of the card. Information on the card is clear and easy to read without close examination.

On making contact, our representatives will immediately identify themselves, state our company name, the purpose of the call and how long it should take. If visiting or meeting in person, they will show you their identity card.

Our representatives are trained to be courteous, to use appropriate language and to offer clear and straightforward explanations. They must offer only factual and accurate information about our services and contracts and must not misrepresent our services or those of other companies. They must check that if you enter into a contract you fully understand the terms and are sure that this is what you want to do.

Our representatives will cease contact with anyone who indicates that the contact is inconvenient, unwelcome, inappropriate or too long. At your request, the discussion will be ended immediately and, if making a doorstep call, the representative will leave your premises immediately.

Our representatives will not abuse the trust of vulnerable customers, for example people who are elderly or who have special needs, or whose first language is not English.

When visiting sheltered housing, nursing homes or residential care facilities, our representatives will make contact with the warden or other person in authority before approaching a customer.

We will not aim sales or marketing activity at people who are under the legal age for entering into contracts.

To ensure we maintain these standards, we keep the records of our sales and marketing activity for at least six months. Records include the date of the contact with you. To help us deal with any complaints or queries, all such records clearly identify the salesperson(s) that made the call or visit.

Entering into a contract

We check that the person entering into a contract with us is authorised to sign a contract for services and be responsible for bills at the premises in question.

Our order forms and contract forms are designed to ensure that you understand that you are entering a contract, and each document states this immediately next to where you sign.

You have the right to change your mind during the switchover period and that there is no cost for cancellation during this period.

In all cases we will give you the following information:

• confirmation of our company's identity and full contact details;
• a description of the service you have chosen, the cost and payment terms;
• arrangements for providing the service, including how we deal with the order and, as accurately as possible, when it is likely to start;
• your right to cancel and how to use it;
• how long the charges will remain valid; and
• the minimum period of contract, and minimum contract charges, if any.

Our representatives have a full summary of our tariffs, which you can ask to see.

Where our representative meets you in person, they will give you the information in writing. When you sign an order form, or enter into a written contract, you will also get a copy of the order form or contract, as well as information about any after-sales services or guarantees and arrangements for ending the contract.

You will get this information at the same time as you sign, or within 5 working days, unless you received it in writing before signing the contract.

Orders placed with us by distance-selling methods (such as phone, fax or internet) comply with distance-selling regulations. As with order forms, our telephone scripts are designed to ensure that you understand that you are entering into a contract and will be sent the information detailed above.

In the case of internet orders, a well signposted and easy-to-see hyperlink to this information is prominently displayed and the information is readily available for downloading and printing.

Regardless of our method of selling, you may cancel orders and end contracts by telephone, in writing, by fax or by e-mail to:

• Tel � 020 8358 2576
• Fax � 020 8200 4939
• Email - sales@premiertalk.co.uk
• PREMIERTALK LTD, EBC House, Townsend Lane, Kingsbury, London. NW9 8LL

Contract review

Our standard procedures minimise the risk of errors or mis-selling on our part when taking orders or making contracts during face-to-face or telephone selling.

We confirm orders by sending a notification of transfer letter to the customer in accordance with the industry-agreed process. The letter, which is clearly dated, gives details of the transfer, including the date of transfer, and information on any services and features which may be affected by the transfer. The letter also provides contact details for any questions.

We contact all customers entering into a new contract to confirm that you understand that you have entered into a contract, are happy to proceed with the contract and are content with the way in which we conducted the sales and marketing.

This check is generally incorporated into the order confirmation letter but is always completed no more than 5 working days after a contract is agreed. Where we contact you directly, this is done by a person not involved with our sales and marketing activities, who will tell you who they are.

The letter may be sent electronically if you have applied online and have confirmed online that you wish future correspondence to be sent electronically.

We will terminate the contract without charge or other penalty to you if we find that you did not understand the contract or it was not what you intended or if it was finalised before the expiry of the switchover period, and you wish to cancel.

We keep our contract procedures under review and take steps to prevent the recurrence of any problem identified through audit (see below).

Audit

We carry out regular audits of the systems, procedures and documents we use in all our sales and marketing activities.

Customer complaints procedure

Complaints about sales and marketing are dealt with under the procedures set out in our Consumer Code of Practice.

Our complaints procedure sets out how you may complain, and this includes complaints about PremierTalk�s sales and marketing activities. It specifies what to do next if you believe the complaint has not been dealt with satisfactorily.

You should first direct your complaint to PremierTalk. If we cannot resolve the complaint to your satisfaction, you may contact OTELO or Ofcom. You can also ask for advice from your local Trading Standards Department or Citizens Advice Bureau.

Status of this code

By law, all companies marketing services to customers must issue a code of practice for sales and marketing.

Compliance with this code does not guarantee that it complies with any other legal requirement.

Non-compliance with this code does not affect the validity of any contract between the company and the consumer, unless the law states otherwise.

Useful addresses

Approved Alternative Dispute Resolution Providers:

OTELOPO Box 730, Warrington, Cheshire, WA4 6WUTel: 0330 440 1614 - email: enquiries@os-communications.org - Website: www.os-communications.org

OfcomRiverside House, 2a Southwark Bridge Road, London SE1 9HATel: 020 7981 3040 / 0845 456 3000Email: contact@ofcom.org.ukWebsite: www.ofcom.org.uk

Direct Marketing AssociationDMA House, 70 Margaret Street, London W1W 8SSTel: 020 7291 3308Website: www.dma.org.uk

Federation of Communication Services (FCS)Burnhill Business Centre, Provident House, Burrell Row, Beckenham, Kent BR3 1ATTel: 020 8249 6363Website: www.fcs.org.uk

If you wish to find details of your nearest Citizens Advice Bureau or Trading Standards department you can search on the following websites:

Citizens Advice - www.citizensadvice.org.uk

Institute of Trading Standards Administration - www.tradingstandards.gov.uk

The Office of the Telecommunications Ombudsman (Otelo):

PO Box 730, Warrington, Cheshire, WA4 6WUTel: 0330 440 1614 - email: enquiries@os-communications.org - Website: www.os-communications.org

OTELO is an independent organisation which is approved by Ofcom to provide an alternative dispute resolution (ADR) service. Ofcom-approved ADR services sort out disputes between communications providers and their consumer and small business customers. Their job is to investigate complaints fairly by listening to both sides of the story. They look at the facts given to them before recommending any action that may be needed to put things right.

Alternatively, if at any time you are not satisfied with the progress of your complaint you can ask us to agree an early referral to ADR (i.e. that we issue a deadlock letter). However, we may decline to do so if we do believe we will shortly resolve your complaint and are taking active steps to do so.

Useful addresses

OteloPO Box 730, Warrington, Cheshire, WA4 6WUTel: 0330 440 1614 - email: enquiries@os-communications.org - Website: www.os-communications.org

OfcomRiverside House, 2a Southwark Bridge Road, London SE1 9HATel: 020 7981 3040 or 0300 123 3333Email: contact@ofcom.org.ukWebsite: www.ofcom.org.uk

PhonepayPlus (formerly Icstis)Clove Building, 4 Maguire Street, London, SE1 2NQTel: 0800 500 212 or 020 7940 7474Email: info@phonepayplus.org.ukWebsite: www.phonepayplus.org.uk

Telephone Preference ServiceDMA House 70 Margaret Street, London, W1W 8SSTel: 0845 070 0707Website: www.tpsonline.org.uk

Federation of Communication Services (FCS)Burnhill Business Centre, Provident House, Burrell Row, Beckenham, Kent BR3 1ATTel: 020 8249 6363Email: fcs@fcs.org.ukWebsite: www.fcs.org.uk

This code has been licensed by The Federation of Communication Services Limited 2011