Responsible Sales, Marketing & Mis-selling Code

1. Accurate and non-misleading information

Talk4 will market and sell services using information that is accurate, clear and not misleading. Material limitations, recurring prices, minimum terms, one-off charges, termination charges, roaming limits and network-dependent features must not be hidden or contradicted by headline claims.

2. Talk4 and underlying networks

Where Talk4 uses EE, O2, Vodafone, Three or another wholesale network, sales material must make clear that Talk4 is the contracting reseller/provider unless the customer is expressly told otherwise. Network branding must not create the impression that the customer is contracting directly with the underlying network.

3. Product claims

• “Unlimited data” must not conceal a domestic data-volume cap; any fair-use or traffic-management rule must be objective, relevant and disclosed.
• “EU roaming”, “global roaming” or similar claims must identify the actual included destinations and any data/fair-use allowance.
• 5G, Wi-Fi Calling, eSIM, speed and coverage claims must state relevant compatibility and coverage dependencies.
• Promotional savings must state eligibility, duration and what price applies afterwards.
• 12-month and 24-month Talk4 contracts must show that the core monthly subscription price has no annual increase during the Minimum Term.

4. Pre-contract documents and consent

Where Ofcom requires Contract Information and a Contract Summary, these must be given in a durable medium before the customer becomes bound and the Contract Summary must be provided before consent. Talk4 will not use pre-ticked acceptance for contract consent or disguise a contractual commitment as an enquiry.

5. Consumer sales conduct

Talk4 will comply with the unfair-commercial-practices provisions of the Digital Markets, Competition and Consumers Act 2024, including rules against misleading actions/omissions, aggressive practices, drip pricing and prohibited promotional practices.

6. Retailers, partners and sales records

Where a partner or retailer sells Talk4 mobile services on our behalf, we will impose appropriate contractual standards, monitoring and sanctions. Sales records will be retained for the periods required by Ofcom and other applicable law.

7. Complaints about sales

A customer who believes a service was mis-sold may use the Customer Complaints Code. Appropriate remedies will be considered, including correction or release where required by law or regulation.

Regulatory references

This code has been drafted by reference to current UK regulatory materials. These references do not replace the legislation or Ofcom conditions.

• Ofcom General Conditions C1, C2 and C8 - contract information, transparency and mobile sales/marketing requirements.

• Digital Markets, Competition and Consumers Act 2024, Part 4 - unfair commercial practices; and Ofcom in-contract price-rise rules. Talk4’s fixed 12/24-month policy is no annual increase to the core monthly subscription during the Minimum Term.