PENNYCOM COMMUNICATIONS CODE OF PRACTICE

Including our Code of Practice on Complaint Handling and Dispute Resolution and our Code of Practice for Premium Rate Services and NTS Calls

Part 1 PENNYCOM COMMUNICATIONS - Code of Practice on Complaint Handling and Dispute resolution for Small Business Customers.

Introduction to our company and services

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

Purpose of this Code of Practice

The Code informs you about our products, services, and customer care policies. Our code of practice on complaint handling and dispute resolution 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 web site at www.pennycom.com . Additional copies are available on request and free of charge to any business customer. It is also available in larger print.

How to contact us

From 9am until 5pm Monday-Friday excluding Bank Holidays

Please call the appropriate number for your query below:

Please contact our Customer Service Team

By Phone: 0844 880 2121

By e-mail:

By fax: 0871 236 8010

By letter: PENNYCOM COMMUNICATIONS, 26-27 Downing Street , Farnham, Surrey GU9 7PD

Website: www.pennycom.com

Our commitment to you

We are committed to providing you with 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 using the BT Network
• CPS-Carrier Pre-Selection
• ISDN-digital telephone line and standard PSTN lines
• Broadband access
• Internet start-up packages with pop3 e-mail
• Mobile telephone and data services
• Non-geographic services

For more details on any of our products and services, or to place an order immediately, please contact our Customer Service Team on 0844 880 2121.

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 PENNYCOM COMMUNICATIONS, we will send you our Standard Terms and Conditions and ask you to sign a contract. You may also download our standard terms and conditions from our website. www.pennycom.com If you have any questions, please phone our Customer Service Team on 0844 880 2121. We may carry out a credit check as part of our assessment procedures.

The minimum contract term for our services is 12 months. We aim to provide services within ten 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 7 days after your order is placed. After 7 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 make a charge - please refer to your contract for details. After the minimum term you can cancel any service by writing to us at our address above giving us 1 months notice.

Faults and repairs

Please call our Fault Line on 0844 880 2131 if you experience a fault with any of our services. We aim to have this investigated and repaired within 1 day.

Compensation and refund policy

Our policy with regard to compensation is to review each case on its merits. As for refunds, if a customer has overpaid within the terms of our contract then this will be refunded.

Price lists

Our pricing structure is available from our Customer Service Team on 0844 880 2121. We will write to you in advance if we change the pricing structure on your products and services.

Billing

We will bill you monthly

Our payment terms are by direct debit and this is a fundamental term of your contract with us.

We provide itemised bills as part of our service to you.

If you have difficulty paying your bill, please contact us on 0844 880 2121 at the earliest opportunity. We will do all we can to help our small business customers to manage their bills and avoid disconnection.

If you are moving home or office

Please call our Customer Service Team on 0844 880 2121 no later than 28 days before your move date. We will amend your account and billing requirements as necessary.

Number porting

PENNYCOM COMMUNICATIONS recognise that keeping your existing telephone numbers may be important to you. If you move we will endeavour to offer you the same telephone number to minimise disruption. 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 0844 880 2121.

Directory Entries

You are entitled to a Directory Enquiry listing (including an entry in the Phone Book) for both your fixed and mobile telephone numbers. If you do want your details included, Please contact our Customer Service Team on 0844 880 2121

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 the quickly and efficiently.

If you have a complaint about any part of our service, please contact our customer service team on 0844 880 2121Our advisors will ask you about your complaint and see to resolve the problem while you are on the line. During any discussions we will protect the privacy of the information 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 Pennycom Communications, 26-27 Downing Street, Farnham, Surrey GU9 7PD .

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 your complaint has been outstanding for more than three months or if 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: 01925 430870 or 0845 050 1614 email: Website www.otelo.org.uk

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 communication providers and their business customers. Their job is to investigate complaints fairly by listening to both side of the story. They look at the facts given to them before recommending any action that maybe 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 on 0844 880 2121 to report the incident, and for information on how to deal with this situation.

We encourage parents to register the mobile phone of their children, and take responsibility for all customer care enquiries.

We are aware that mobile phones can provide access to premium services, including adult content through independent companies' text services. Our Customer Service Team can restrict the access to premium rate services. Please call them on 0844 880 2121 for advice on this service.

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 0844 880 2121

§ 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 - Pennycom - 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 Service (PRS) calls and on our charging policy for calls 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". Typical services

Include TV votelines, mobile ringtone downloads, technical helplines, 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. Our charges for calling these services are shown in our price list, which is available on request from our Customer Services Team 0844 880 2121.

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 on 0844 880 2121 for advice on this. We can give you a fact sheet on PRS.

You can also ask for help from PhonepayPlus 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 ww.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 0844 880 2121 and via our website: www.pennycom.com We can also give you a fact sheet on NTS.

If you are unhappy with the help you have received from us on a problem with PRS or NTS, please contact Karen Bull Tel: 0844 880 2121 or email , 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. www.otelo.org.uk 01925 430870 or 0845 050 1614

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 for details. 0844 880 2121 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.org.uk or by telephoning 0845 070 0707

Useful addresses

Otelo - PO Box 730 , Warrington , Cheshire , WA4 6WU . Tel: 01925 430870 or 0845 050 1614

email: Website: www.otelo.org.uk

Ofcom - Riverside House, 2a Southwark Bridge Road , London SE1 9HA . Tel: 020 7981 3040 or 0300 123 3333 email: Website: www.ofcom.org.uk

PhonepayPlus ( Formerly ICSTIS) - Clove Building , 4 Maguire Street , London , SE1 2NQ . Tel: 0800 500212 or 020 7940 7474 Website: www.phonepayplus.org.uk

Telephone Preference Service - DMA House, 70 Margaret Street , London W1W 8SS Tel: 0845 0700707 Website: www.tpsonline.org.uk

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

This code has been licensed by The Federation of Communication Services Limited 2008

Licence number 001395

Published January 2008. Correct at the time of printing. © The Federation of Communication Services Limited 2008