Code of Practice

1. Who we are
Coms offers high quality VoIP, fixed, mobile and broadband services to business and residential customers throughout the UK, both directly to end-users and via selected resellers. Coms.Com Limited (referred to here as Coms) is wholly owned by Coms plc which is listed on the London Stock Exchange AIM market (LSE:COMS.L).

2. Our customers
Coms understands that customer satisfaction and service delivery are the most important part of its business. Our company values are based on this, which is why our team strives to ensure that you get what you want, when you want it. We will do our best to meet your requirements to your satisfaction. Coms values its customers and aims for the highest standards of account management and customer service. By investing in our people and in systems to support our customer care activity and by continually developing our services, we aim to deliver the best in customer care to stay ahead of our competitors.

3. Purpose of our Code of Practice
This Code of Practice (CoP) aims to give you, the client, a clear statement of how we conduct our business and to describe the relationship between you and us in all matters concerning your purchase of services from us. This CoP provides a statement of the services available from Coms to business and residential customers and those interested in finding out more about Coms. It explains how we provide these services and the key support services and company policies that underpin them. It describes your relationship with us and how you can and should contact us when you need help or want to change the services you have and how we will respond. It also describes what you should do in the unlikely event of something going wrong. The CoP has been approved by OFCOM, the UK communications regulator and ITSPA, The Internet Telephony Services Providers Association.

4. Coms services
Coms uses its resources of talent and expertise to continuously strive to find new ways to meet customers evolving communication needs. We offer governments, businesses and individual consumers a variety of superior solutions using a range of new, emerging and established technologies. All of these services are described in greater detail on our website at www.coms.com. The information on our website is available in English only.

We own and operate our own communications facilities, as well as sharing infrastructure with other carriers and distributing the services of other network operators. We offer our services through authorised resellers and have a direct sales force. The industries and sectors which use our services include but are not limited to broadcast and new media, oil and gas, Government / military, shipping, business services, transportation, manufacturing, aeronautical, energy, mining, cruise, engineering/consulting, yachting, rural communications, humanitarian/disaster relief, resource exploration and individual business users.

5. How to contact us
There are a number of ways that you can contact us and we will be happy to answer your questions and explain our services to you. Our contact details are also set out under Contact Us on our website.

Sales
Tel : 020 7148 3000
Fax: 020 7148 3001
E-mail : enquiries@coms.com

Customer services and general enquiries
Tel : 020 7148 3000
Fax: 020 7148 3001
E-mail: support@coms.com

Customer Support
Tel : 020 7148 3000
Fax: 020 7148 3001
E-mail: support@coms.com

Customer accounts and billing
Tel : 020 7148 3000
Fax: 020 7148 3001
E-mail: accounts@coms.com

For customer service enquiries, please call our customer service line on 020 7148 3000 which is open from 8.30am to 5.30pm Monday to Friday (excluding public holidays) or you can contact us via our website at www.coms.com.

If you would prefer to write to us instead, please address your letter to:
Head of Customer Service
Coms.Com Limited
46 Cannon Street
London
EC4N 6JJ

6. Our services
Coms provides a wide range of communications services falling into four broad categories:

VoIP - Voice over IP
Examples include our own hosted VoIP solution for business as well as IP-PBXs and associated hardware.

Fixed services
Examples of these services include direct and indirect phone line services, CPS, IDA, number translation services, premium rate services, private circuits, non-geographic numbers, and digital lines (ISDN).

Mobile services
Examples of these services include standard mobile services, messaging (SMS and MMS) mobile email solutions such as BlackBerry and other Mobile Data solutions and mobile virtual private networks.

Broadband and other services
Examples of these services include co-location, hosted and managed firewalls, internet connectivity including Ethernet and xDSL, leased line based services as well as private wide area network and other professional services.

7. Our obligations
Like all UK communications operators, Coms has a number of obligations laid down in UK legislation. These are aimed at providing individual clients and small businesses with less than 10 employees, with both choice and consumer protection. Coms takes these responsibilities very seriously, while aiming to deliver excellent service and a range of services to meet our customers communication needs. The formal details of the general terms and conditions of our contractual relationship for clients can be found in the section on our website found at www.coms.com

In addition to being available online, all service-specific terms and conditions are also detailed on each relevant order form.

Installation of services
We offer a wide range of services and our sales team can confirm the serviceability of your address for each of these services. Delivery timescales are agreed with customers in advance of installation.

Call barring
If you want to have a particular number barred so that it cannot be dialled from your phone, please contact our customer service team (please see contact details above under Section 3). Please note that this option may not be available with all Coms services.

Calling-Line and Called-Line Identity
Your phone number is by default displayed to the person whom you are calling. However, you can alter this by requesting that your phone number should not be displayed to the person whom you are calling on a call-by-call basis or for all calls. However, even if you request withholding of a phone number, we are legally obliged to pass it on in certain circumstances e.g. to the emergency services in case of an emergency. To request any of the above facilities, please contact our customer service team.

Repair and maintenance
Coms carry out preventative and corrective maintenance over its networks and services. Our aim is to minimise inconvenience and correct faults through remote diagnostic tools used at our National Service Centre and/or with other technical support centres. However, should a network fault occur which is within our direct control, we aim to clear this type of fault (i.e. that does not require a customer visit) within 8 hours.

We encourage our customers to call us for technical support, via our telephone support number regardless of the nature of the problem. There is also a range of support documentation on our website at www.coms.com

The level of repair commitment, fault fixing and service availability depends on the type of service you purchase and the terms and conditions under which you obtain that particular service from us. If you subscribe to a service carrying a specific service level guarantee, we will credit you accordingly if we fall short of our guarantee. Unless otherwise stated in a separate contract between you and Coms, your repair and fault-fixing rights and obligations are set out in Coms Terms and Conditions, posted on our website at www.coms.com

Coms employee identification
All staff who visit customer’s premises carry official company identification e.g. a business card, which should be clearly displayed. Customers should request to be shown this identification if it is not immediately visible before allowing anyone into their premises.

Ceasing service
Customers are able to cease their service with us at any time in accordance with the terms and conditions of their service contract.

Billing and payment
We invoice our customers monthly, quarterly or annually on one combined bill. As part of the initial ordering procedure clients may need to pay a deposit in advance. This is calculated as part of a standard process and is determined by the customer’s credit status, past history with Coms (if any), and the type(s) of service requested. If a deposit is required it will be returned, by credit to your account upon request, after a satisfactory period.

We expect customers to settle their bills within their agreed credit terms. There may be a non-standard charge for late payment. As a client you are responsible for any charges incurred on your account. Customers are requested to pay their invoices by Direct Debit. Other options including Standing Order, credit card or cheque may be possible by prior agreement with our finance department. Full details of how to settle your bill are provided on the reverse of each of your Coms invoices.

Prices
Coms publishes its prices in electronic and paper form available from our sales and customer service teams. We may change these from time to time either permanently or for limited periods (offers and promotions) and will provide at least seven days public notification of such changes to our customers.
Our intention is to be competitive with other leading communication providers and to offer our customers excellent value for money.

Credit policy
We expect our clients to:
- pay their bills promptly
- inform us of any significant change in their circumstances, for example if you are going to be away for an extended period which may affect bill payment
- be straightforward with us when providing information
- If a customer experiences problems in paying their bill, Coms has a consistent policy designed to:
- help the customer manage their costs
- protect both Coms and clients in general
- help minimise debt, suspensions and disconnection
- promote good customer service

We offer a range of methods for customers to pay their bill (see above Billing and Payment), and have a number of ways of helping customers minimise the risk of large debts for their communications services. Where appropriate, if a customer needs support, a third party or a nominee can be appointed to help the customer with their bill payment, e.g. by ensuring the customer remembers to pay it by the due date, converting to Direct Debit payment, or dealing on the customers behalf if the customer is away for an extended period. The nominee will not have any legal responsibility to pay the bill although they may do this if they and the customer wish but simply to help the customer to manage their account. The respective responsibilities will be made clear to both parties that clients are required to pay their bills within their agreed credit terms. Where this does not happen, Coms may, according to its terms and conditions, chase payment by contacting the customer and / or sending reminders. If there is no response to the initial contact made and / or full payment of the arrears is not made, then the customers services may be restricted. The customer may be reminded that continued non-payment will lead to full disconnection of the service. We will follow this by debt recovery procedures, which would include disclosure of relevant customer information to the appropriate credit vetting agencies leading to a possible bad credit history. Any debt recovery procedures will be carried out professionally and in accordance with relevant UK legislation and best industry practice.

If a customer is in genuine dispute with Coms and makes this known to us, then the disconnection process may not be invoked, pending the outcome of the dispute resolution, any un-disputed portion must still be paid in full.

We are aware that some customers can get into financial difficulties unintentionally, and this is taken into account when dealing with instances of non-payment. We will advise the customer of our processes to minimise debt and help them manage their bills. Customers may of course wish to take advantage of help from external debt Counselling agencies. Coms reserves the right to disconnect any customer without notice if the company has reasonable grounds for suspecting that there is an unacceptable credit risk, for example through suspected illegal behaviour (e.g. fraud) or a breach of the contract with Coms. We will carry out a review of any such decision if the customer requests it. Any customer must settle any outstanding debts, and may be subject to credit checking and payment of any appropriate published reconnection charges, before new service can be re-provided. In the unlikely event that Coms were to disconnect a customer incorrectly the customer would be reconnected free of charge.

Resolution of complaints: What to do if you are not satisfied with our service

If you are unhappy with our service please contact us and let us know. It is through your feedback that we are able to review and improve the service we provide.

We are committed to addressing any complaints as fairly as possible and within a reasonable time. If you are dissatisfied with any aspect of our service, please contact us and we shall do our best to resolve the problem as quickly as possible. We operate a complaints procedure to help ensure that any complaints are dealt with to your satisfaction:

- you can phone us on 020 7148 3000 and our customer service team will do all they can to resolve any problems while you are on the phone. If your problem cannot be resolved during the phone call we will agree a course of action with you.

- you can contact us by email at support@coms.com. We aim to reply to you as quickly as possible.

As soon as we become aware of your complaint we give it a complaint reference number. If you are unhappy with the way in which your complaint has been handled you can ask for it to be escalated. Escalation may happen immediately if you are on the phone or we shall arrange for a manager to contact you.

In the unlikely event that your complaint has not been resolved by us to your satisfaction within a period of eight weeks, or if during the process of investigating your complaint a deadlock situation is reached, you have the option of referring your complaint to OTELO for independent consideration.

The contact details for OTELO being:

Office of the Telecommunications Ombudsman (OTELO)
Wilderspool Park
Greenalls Avenue
Warrington
WA4 6HL
Tel: 0845 050 1614
Fax: 01925 430059
E-mail: enquiries@otelo.org.uk
Website: www.otelo.org.uk

Otelo resolves disputes between member operators and their residential and small business customers. Coms is a member of OTELO.

Special needs
At Coms we take our responsibility towards disabled customers very seriously. We are aware of the requirements of the current regulations (Telecommunications Services for Disabled Persons Regulations and the Disability Discrimination Act 1995) and have been working hard to accommodate their requirements.

We offer a number of different services for our customers with special needs. These services are designed to not only meet the demands of the current regulations, but to also enable us to offer the best possible service to these customers.

Coms literature
If you would like to request any of our literature, including this code, in large print or audio format, please contact Customer Services with your full name, address and telephone number so that we can send it to you or contact you in the unlikely event of a problem.

Priority fault repair
In the event of a fault, where any client or special needs client has a need of urgent repair, and where the product or service is supported for it, priority is given to restoring such a customer’s service. Please note that priority fault repair is only available for some products and services and may also incur a separate charge.

In order to take advantage of our priority fault repair service, customers with special needs must pre-register their requirements with us. In order to register please call our customer service team on 020 7148 3000.

Bill payment and protected service
Disabled customers who are dependent upon the internet may nominate somebody who can help them deal with Coms bills, and their account in general. Specifically, this nominee can:
- be the person to whom the customer’s bill is sent.
- be the person to whom any enquiry will be made by Coms in the event of a bill not being paid.
- pay the bill on behalf of the customer - but will not be held legally liable for the bill

In order to take advantage of any or all of the elements of our Protected Service Scheme, customers with special needs must register their requirements with us. In order to register please call our customer service team.

Contracts
Clients who have problems reading the terms and conditions of their contract should ask for their Coms salesperson to explain them or for an audio copy.

Confidentiality of customer information
We will treat any information we have about you in confidence and will not disclose it to anyone except you, or in accordance with any instructions you have given us. However, there are circumstances in which we may be required by law to disclose information. Such requests normally come from Statutory Authorities, for example, Police Forces, Customs and Excise etc. Any such disclosure will be strictly controlled and will be made fully in accordance with current UK legislation, in particular the Data Protection Act

Communication with customers
We believe in effective communications with our customers. Customers can contact us by phone on the numbers specified above (How to contact us ), or at any time by e-mail.

We will also promote our services, including special offers, through a variety of media. In doing this we will abide by the industry-accepted standards, in particular by:
- following the UK Direct Marketing Association guidelines on when to ring customers (only between 8.00 am and 9.00pm, unless specifically requested to call outside these hours)
- stopping specified promotional contact with individual customers if requested to do so by the customer and according to their wishes, in accordance with the Data Protection Act, Telephone Preference Service (TPS), Mailing Preference Scheme (MPS), and the Facsimile Preference Scheme (FPS)
- following the rules of relevant regulatory bodies such as the Independent Television Commission (ITC), Independent Committee for the Supervision of Standards of Telephone Information Services (ICSTIS), Advertising Standards Authority (ASA), and Broadcasting Standards Commission (BSC)
- abiding by the Distance and Doorstep Selling, and other relevant UK and EU regulations. The existence of this code will be brought to customer’s attention in appropriate ways.

Social responsibility
Coms takes its role within society and its responsibilities to its employees seriously. Coms is committed to developing and maintaining good environmental standards. Coms monitors areas such as waste management, energy and water usage, and transport. For further information on our social responsibility statement, see www.coms.com

Review of this Code
Coms will review this Code of Practice annually, or more frequently should events require such a review.

Approval of this Code
OFCOM has approved this Code of Practice, in accordance with criteria agreed with the UK telecommunications industry.

ITSPA has approved this Code of Practice, in accordance with criteria agreed with the UK Internet Service Providers Association.

All information is correct at the time of going to print.
E & OE Coms.Com Limited, October 2009