Sales and Marketing Code of Practice

1. Bulldog Broadband - Introduction & Background

In September 2006 Bulldog’s services and the Bulldog brand became part of the Pipex Communications Group, one of the UK’s leading providers of integrated telecommunications and internet solutions. The Broadband and Voice Division of Pipex Group were acquired by Tiscali U.K. Holdings in July 2007.

Although Bulldog has changed ownership, the current business remains unaffected and continues its focus on the provision of quality broadband and residential telephone services.

The legal relationship is between you and Pipex Internet Limited.

Pipex Internet Limited is a company registered in England (Company No. 5306519)

2. Purpose of Code of Practice

This code of practice provides a summary of products and the standards which we are committed to delivering for our customers. This code contains useful information about how Bulldog provisions and supports it services, including our contact details, terms and conditions, cancellation policy, billing information, and internet usage.

This code of practice will be reviewed and updated if necessary, on a quarterly basis.

3. Our Services

Bulldog provides a comprehensive range of internet connectivity solutions and services to consumers and small businesses, from standard dial up internet access to high speed DSL connectivity. For the most up to date information, please refer to our website at http://www.bulldogbroadband.com/

To be eligible for our service, you must be aged 18 or over and pay by a UK residential bank account by Direct Debit, Debit or Credit Card (MasterCard or Visa).

The use of Bulldog residential accounts for business purposes is strictly prohibited. Business customers should consider Bulldog Business Broadband products.

We may without notice, examine monitor or record the use to which you put your services and the nature of the data/information you are transmitting or receiving via the service.

Bulldog Terms and Conditions contain minimum contract periods and cancellations fees. We therefore advise potential customers to read our Terms & Conditions, Acceptable use, Data Protection & Privacy policies carry, before signing, to avoid any confusion or dissatisfaction.

Ordering Bulldog Products and Services

• You can order our products and services online at http://www.bulldogbroadband.com,
• You can initiate an order on the telephone with our dedicated Sales Teams who are available to provide professional, friendly advice and information on all of our products

Dedicated Team - 0871 663 3300

Opening Hours - 9am - 5pm Monday to Friday

Technical Support - 8am - 9pm Monday to Friday & 9am - 6pm Saturday

Once you have selected your Bulldog product, which can be completed by following the on line order instructions. On the date you place your order, your contract begins. We will acknowledge receipt of your order, and may carry out credit checks on you using the information you provide. By placing an order you agree that we or third parties on our behalf may carry out credit checks on you using the information you have provided

We recommend that you read and print the Terms & Conditions shown on http://www.bulldogbroadband.com by clicking "I agree" on our web site; you agree to be bound by our Terms & Conditions

Installation

We (or other Companies employed on our behalf) may need to visit your premises to carry out test, provisioning or activation, and you agree to such visits and to provide cooperation that may be required in order to provide the required service. We will liase with you to arrange timing of these appointments. It is also possible that BT or another party may contact you in relation to the agreed appointment.

If your service cannot be fully activated, we will contact you. We may offer to provide you with an alternative service, unless you choose otherwise and your contract will end and any charges already collected will be refunded to you.

Equipment Supply

You may wish to purchase equipment, inclusive of hardware and associated software from us, the risk of this purchase shall pass to you upon delivery of such equipment.

If we supply you with equipment, this is subject to the limited manufacturers’ guarantee in accordance with the documentation received with your equipment. You should be aware that such guarantees, generally only provide replacement, repair or refund of equipment within a published specified period of 12 months, or in the case of software 30 days.

How long is your contract?

We will provide you with service from the date of activation as specified in your contract. If your order comprises multiple lines with different activation dates, then each line will be subject to an initial contract period.

The service may be ended by either party through the provision of 30 days notice to the other if the other party has materially breached the Terms & Conditions.

If the other party is deemed to be insolvent, bankrupt or unable to pay its debts, makes or proposes an arrangement of composition this may prevent continued provision of a service for more than 30 days

If you wish to end your contract otherwise than as set out above, you will still be liable to pay us all charges due to the end of the contract period

Pricing Information

The charges the provision of our service or supply of equipment are shown on the Bulldog website http://www.bulldogbroadband.com. You will be liable for all charges made from your phone line, you are also liable for the security of your service.

We do not provide written invoices, however you may review your invoice and account status online

All amounts due to us shall be paid in full without deduction or withholding, except as permitted by law. We may charge interest on any overdue amounts payable from the due date until payment of all sums including interest is received.

The amount of your credit limit is £150 or such sum as we may notify you

A PRS (Premium Rate Service) bar is automatically placed on your line, please contact 0800 4048151 should you require this bar to be removed

Service Provision & Information

e may end the contract with you before the service is provisioned for use in any of the following circumstances:->

• If you fail a credit check
• You are not within a geographic area covered by us
• Technical issues prevent, delay or degrade the activation or provision of service

You may end your contract before activation, we will refund any payments you have already made in respect of such contract within 7 working days from the order date if you have ordered online, or otherwise at distance or if 40 working days have passed since the order date

If you end your contract before activation as set out as shown above, we will refund you any payments you have already made in respect of such contract. If you want to end your contract before activation for any other reason, you may do so, but you agree to pay us the full activation/

Bulldog is committed to ensuring that the service you purchase is available for use as much as is reasonably possible.

We may from time to time make changes to our network or the technical specification of a service.

We may suspend provision of a service for operational or technical reasons; we will endeavour to contact you to ensure minimum impact. If we have reasonable grounds to believe that the service is being used fraudulently or illegally or you are in breach of your contract, the service being used by yourself or anyone else

We may immediately end or suspend the provision of your service if:-

• You are in breach or have breached the Acceptable Use Policy (as published on our website)
• You fail to pay any amounts due
• The unpaid charges are in excess of your credit limit

If you order voice services from us then some of the services you currently receive may be terminated. Such services include without limitation, BT Call Sign Number, Indirect Access,, Home Highway. For full information please view our website

4. Our Key Commitments

Commitment to Quality

Our service delivery ethos is about much more than providing you with a service and leaving it to manage itself. We have always been committed to delivering quality throughout every aspect of our operations - from initial phone contact to pre- and post-sales support. This continued commitment is reflected in Pipex achieving registration to ISO 9001:2000 by the British Standards Institute after an assessment visit in December 2003.

The purposes of these commitments are:

• To provide you with a standard of protection over and above that provided by law;
• To ensure that our sales and marketing activities are practiced in a responsible manner and deliver good practice;
• To help you understand more about our services and the quality of service you should expect in every contact with Bulldog;

Our commitments within these Codes deal with any concerns arising before, during and at the point of sale, with particular emphasis on the avoidance of mis-selling and misrepresentation. Our main aim is to ensure that you understand the services offered and the key terms of any contracts you are entering into.

Our Commitment to you

Bulldog, part of the Tiscali Group, believes in providing the highest levels of customer service and satisfaction. We are constantly reviewing our services and processes in order to provide our customers with the best internet service available today. Should a customer require any assistance,

Bulldog has dedicated Technical Support & Customer Service teams that are staffed by highly trained, friendly people who are there to help.

• Your wishes will be respected where 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
• Our advertising and promotions will comply with the British Codes of Advertising and Sales Promotion. All our advertising and promotional literature will be clear, unambiguous, accurate and fair, containing no false or misleading information about price, value or service. We will not denigrate other Providers.
• All our Sales representatives will be recruited and trained in a manner consistent with the procedures set out in this Code
• All our Sales representatives will comply with the Rules of Conduct described in this Code..
• We will comply fully with all applicable legislation of relevance with the Sales and Marketing of our services.
• We will retain all sales and marketing campaign records for six months, including the date and the approximate time of any contact, in order to deal with any complaints or queries that arise about our activities.
• Any agreement can only be made to persons aged 18 and over.
• Any agreement forms will be designed such that the contractual nature of the document is clear to you.
• We will carry out regular audits of systems, procedures and documentation to ensure that we are acting compliantly with all the commitments in this Code.

As a responsible Company, Pipex Internet follows the guidelines of the UK Communications Industry Regulator OFCOM. Please visit their site for more information

Office of Communication
Riverside House
2A Southwark Bridge Road
London
SE1 9HA

Website: http:/www.ofcom.org.uk
Telephone: 020 7981 3000
Fax: 020 7981 3333

In addition to the above, Pipex Internet is also a member of the Internet Service Providers Association (ISPA) and abides by their Code of Practice. Please visit their site for more information: http://www.ispa.org.uk

5. Our Commitments on Recruitment and Training of Sales Agents

• In recruiting sales agents involved in direct contact with you, we will ensure they have been carefully selected with due care having regard to the following:
• Behaviour and appearance, recognising that the sales person may be seen as the ‘public face’ of the industry;
• Security – references and relevant convictions for criminal offences to be checked and taken into account;
• Evidence of mis-selling or lack of integrity in any previous selling employment.

or UK sales employees the following requirements will need to be observed:

• the applicant must provide proof of NI number, proof of address and two references;
• referees cannot be related to the applicant;
• business referees must not both be from the same company;
• If a sales person transfers to another company, a copy of his or her records will be retained for a minimum period of three years. The identification badges of staff leaving the company should be returned.

For sales-staff not based in the UK, equivalent procedures are applied.

We will ensure that all Sales Agents in direct contact with consumers undertake training courses to ensure that any relevant advice given by such person about our services is not misleading. Topics covered will include:

• arrangements for competition in the supply of telecommunications in the UK;
• the services we offer and how these differ from other competitive telecoms products;
• the process for ordering our services;
• the relevant principles of consumer protection law;
• the prices charged for our services and our terms and conditions of service and, in particular, methods of payment, duration of contract and any termination fees;
• the nature, and cost, of any additional services on offer;
• the process for cancelling the contract both during the cooling-off period and at any time following commencement of the service
• our complaints process

All sales agents will be regularly monitored for quality purposes. In the case of call centre sales staff, a minimum of 1 call per month will be reviewed. Monitoring records must be maintained to record the results and corrective action, if any, arising from the process.

The way we pay our Sales Agents will not encourage poor sales practice and non-compliance with the commitments in this Code.

6. Our Rules of Conduct

General

• Sales Representatives must clearly identify the business (Bulldog) and the purpose of the contact at the beginning of the conversation.
• Sales Representatives must be courteous, use appropriate language and offer clear and straightforward explanations. Representatives must cease contact with any person who indicates that the contact is inconvenient, unwelcome, inappropriate or too long.
• Sales Representatives must take care to ensure that customers entering into contractual agreement understand all details and information provided to them.
• Sales representatives must not sell to vulnerable individuals. Calls to individuals who clearly do not understand or are confused by the call must be politely ended.
• Sales representatives must not direct sales to those who are under the legal age for entering into contracts, being under aged 18
• Sales representatives must ensure that the person agreeing to the sale is authorised to do so by being the account holder or confirming that they are an authorised decision maker for that household.
• Sales representatives must ensure they don’t give out false or misleading information about price, value or service or denigrate or make false allegation against other providers
• At the customers’ request, full written information about tariffs must be made available.

Rules specific to Telephone Sales

• No telephone to new customers should be made outside the hours of 08.00 to 21.00, unless this is specifically requested by the customer. Telephone calls at weekends must be limited to 09.00 to 17.00 on Saturday and should not be made on Sunday.
• Sales representatives must immediately identify themselves, the company they represent (Bulldog) their purpose and the expected duration of the call.

Rules specific to Web Based Sales

• The sign up process via the website must be through secure web pages.
• The website should provide a clear hyperlink to the Privacy Policy and to all relevant information about the service, including full terms and conditions.

7. The Transfer Process and your Rights to Cancel

If you order our services, we will send you a Welcome Pack and notice of transfer letter in accordance with the industry-agreed process. This will inform you of the full details of the transfer including:

• phone numbers affected;
• expected timing of switchover;
• our contact details

You have a 7 day ‘cooling-off’ period during which you can cancel your agreement with us before your services are transferred from your current supplier. We will not apply any charges for such cancellations.

We will review the procedures by which contracts are agreed and take appropriate steps to prevent recurrence of any problem identified.

8. If you have a Complaint

Although we pride ourselves on our standard of service, we may occasionally get it wrong. If you’re unhappy with the service you’ve received, please tell us and we will do all we can to resolve the matter quickly and satisfactorily.

We will always try to resolve the matter during your first telephone call but if we can’t; we will give you an approximate timescale and return your call.

If you’re not satisfied with the way we’ve handled your complaint, please ask to speak to the manager of the customer services team.

If you feel your complaint has not been resolved and you remain unhappy please refer to our Complaints Code of Practice.

Complaints about this Code

If you believe we have failed to meet our commitments regarding our Sales and Marketing activities, please contact

Lee Jones
Head of Legal
Pipex Communications
Christie Fields
Derwent Avenue
Christie Fields
Manchester M21 7QA

Telephone: 0871 663 3300

9. Disclaimer

Pipex Internet takes every care to ensure that the content of this document is correct at the date of publication, but accepts no liability for any error or omission therein. Bulldog products and services are continually under development, and for this reason published information may sometimes not be fully up to date.

Please therefore check the latest situation either by visiting our web site at http://www.bulldogbroadband.com.

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