Code of Conduct – Sales and Marketing of Fixed-Line Business Telephone and Broadband Services Introduction
and Overview
The purpose of our Code of Conduct is to:
• Ensure that Synotio Business Communications Provider (‘our’, ‘us’ and we referred to throughout refers to Synotio Business Communications
Provider) implements responsible selling techniques when marketing its range of products and services;
• Help customers to understand the service levels and professionalism required of all our staff;
• Provide a clear framework which all our staff members are required to work within. This will ensure they act responsibly
throughout and adhere to our good practice policies when marketing and selling any of our products and services.
will always aim to avoid:
• Mis-selling
• Misrepresentation
It is important that our customers understand the services we offer and the Terms and Conditions of any Agreements they
may have entered in to. The code applies to the sales and marketing of our services to both business and domestic
customers (please note that ‘you’ and ‘your’ refer to our customers) and covers every aspect of the sales process.
We routinely monitor compliance with this code to ensure that all our sales and marketing staff, sub- contractors and
representatives are fully briefed and, where necessary, retraining or disciplinary action which may be required is instigated
in all cases.
For customers who feel that any representative of Synotio Business Communications Provider may have breached the terms of the
code we would urge you to contact us without delay to advise us of this. You may contact our Customer Services Team by
telephone on 0161 393 8884, Monday to Friday from 9am to 5pm, by email to or by letter to our head
office at Building 5, Crossford Court, Dane Road, Sale M33 7BZ
1. Status of the Code
1.1 Engaging in sales and marketing for fixed-line telecommunication and broadband services, we are required under the
Ofcom General Condition 14.3 to establish the code in accordance with these guidelines and to comply with the
provisions of the code.
1.2 Compliance with the code does not guarantee compliance with any legal requirement.
2. Sales, Marketing Advertising and Promotion
2.1 We will make customers aware of services and promote through a variety of methods. In all instances we will act
responsibly to ensure compliance with relevant legislation.
2.2 If a customer is registered with any of the available preference services, including mailing preference service, telephone
preference service etc. we will ensure their legal rights and wishes are respected at all times.
2.3 Our advertising and promotion complies with the British Codes of Advertising and Sales Promotion and all other
relevant advertising codes. In addition to this, advertising and promotional literature will always be clear, unambiguous,
accurate and fair. We will ensure our information is not misleading, false and we will we not denigrate any other companies
who supply the same or similar services.
3. Recruitment and Sales Training
3.1 We have strict and appropriate recruitment and selection policies in place, which are designed to ensure our staff
members are suitably qualified and fully trained, particularly in relation to sales and marketing activities and where their
role involves direct contact with our customers. Where third party agencies are involved we will always endeavour to
follow equivalent recruitment and selection practices and training procedures.
3.2 When recruiting field sales and other sales staff we will ensure that references and suitable background checks have
been carried out to confirm suitability for the position. We will never knowingly employ someone who has relevant
convictions, evidence of mis-selling or a lack of integrity in any previous employment.
3.3 We will always ensure that our sales staff members have provided us with details of the following when they are
• National Insurance Number
• Proof of address
• Two references from two separate, previous employers
Where any issues arise during the term of the employment we will record these and maintain records on file for a
minimum period of six months following termination/end of employment.
3.4 We will always take reasonable steps to ensure that all sales staff employed have sufficient training and understanding
of Synotio Business Communications Provider’s products and services and will be fully competent in their ability to explain these to
customers in a way that is not misleading.
Training will include:
• Arrangements for the competition in the supply of Telecommunications and Broadband within the UK;
• The variety of services we provide and how these compare to other companies in terms of price e.g.Line Rental and Calls;
• The process for ordering telephone and broadband services;
• The relevant principles of consumer protection law;
• Our tariffs, terms and conditions of the services, methods of payment, duration of contract andtermination fees;
• The nature and cost of any additional services we offer;
• The cancellation process during both the cooling-off period and following commencement of the service;
• The existence of the sales and marketing code of practice and benefits provided;
• Customer complaints procedure.
3.5 We ensure that we, any sub-contractors and agencies who work on our behalf are knowledgeable of relevant aspects
of consumer protection law, the content and interpretation of this code and understand the benefits this provides to the
3.6 Our remuneration systems for all sales and marketing personnel, sub-contractors and agencies are designed to
discourage misleading or exploitive sales practices.
4.0 Customer Contact
4.1 When contacting residential customers our sales staff members are issued with specific guidelines to follow.
Appointments will be made during the hours of 8am to 8pm. Telephone calls will only be made during the hours of 8am to
9pm. The only exception to this will be when a customer specifically requests an appointment or telephone call outside of
these hours
4.2 All of our representatives are issued with identity badges which clearly display our company name and a unique
identification number for that representative. The identity badge also displays the representative’s name, photograph and
an expiry date for the validity of the card. This information will be clear and visible. If requested, this information may be
presented in Braille.
4.3 When making contact our representatives will identify themselves immediately, stating the company name, purpose of
the call and the estimated duration. Identification badges will be available and will be shown upon request during face to
face visits.
4.4 All company representatives are trained to be courteous, use appropriate language and offer clear and straightforward
information and explanations. All information is factual and accurate. Our training is also designed to prevent any
misrepresentation of our services or those of other companies.
4.5 Our representatives will discontinue the conversation if advised by anyone the conversation is inconvenient,
unwelcome, inappropriate or too long. If this is a face to face meeting, the representative will leave the premises immediately.
4.6 Our representatives will not abuse the trust of vulnerable people e.g. the elderly, those with special needs or does not
speak English as their first language.
4.7 In the event that a visit is made to sheltered housing, such as nursing homes or residential care facilities, contact will be
made with the warden/caretaker before approaching the customer.
4.8 We will never promote our services to anyone who is under the legal age to enter into a contract.
4.9 To ensure we maintain our standards and to assist in dealing with any complaints or queries, we will retain records of
our sales and marketing campaigns for a minimum of six months. We will also record details of the identity of the sales
person who made the call or visit and the date and estimated duration of contact.
5.0 Entering into a Contract – Information, Order Forms and Contracts
5.1 We will take all reasonable steps to ensure the person entering into a contract with our products and
services is authorised to do so.
5.2 Our order forms and contracts are designed to be very clear; they state the contractual obligations which are in no way
obscured or concealed and require signatures adjacent to this information to ensure this has been understood.
5.3 Where a direct approach is made with you, in all cases we will provide you with;
• Confirmation of our company’s identity, full contact details of our head office address, telephone and fax numbers and
e-mail address;
• A description of the product and/or service you have chosen, details of how this works and contractual information
including payment terms, key features of the call types etc.
• Arrangements for providing the service, including the order process and as accurately as possible the likely date of
provision. If there is to be any delay with the provider, you will be made aware of this;
• Your right to cancel and the conditions for cancelling;
• The period for which any charges remain valid;
• The minimum period of contract and the minimum contract charges, if any.
5.4 Our representatives have details of all tariffs which can be provided upon request and free of charge; these are also
available on our website at
5.5 When a representative meets you in person, they will provide all information in writing as well as a copy of the contract
or order form. The following details will also be provided in writing at the same time or within five working days:
• Information about after-sales services or guarantees; • Arrangements for the termination of the contract.
5.6 All orders placed by telephone, fax or internet, comply with distance-selling regulations. As with order forms, our
telephone scripts are designed to ensure that you understand you are entering into a contract and you will be sent the
information, as detailed above.
5.7 The Synotio Business Communications Provider website,, has a sign-posted hyperlink where this information
may be viewed. The information is prominently displayed and can also be downloaded and printed out if required.
5.8 During the switch over period, customers may cancel without incurring a cancellation cost up to 48 hours before the
order completion date. If you change your mind you may notify us by telephone, e-mail or in writing at:
• Customer Services Monday to Friday from 9am to 5pm – 0161 393 8884 • E-mail –
• By post to: Synotio Business Communications Provider, First Floor, Building 5, Crossford Court, Dane Road, Sale, M33 7BZ
5.9 We will send a mandatory letter, email, SMS or phone call in accordance with the industry-agreed guidelines informing
you of details of the transfer and clearly confirming;
Date of notification;
• CLI(s) affected;
• List of services affected/unaffected, for example call barring;
• Date of Switchover and engineer visits
• Our contact details for any queries.
5.10 Generally, notification will be by letter or SMS unless the order has been placed online and you have confirmed that
you wish all correspondence to be sent by email. In cases where this has not occurred, we are more than happy to correspond
by email so please let us know in writing if you would prefer this method of contact.
5.11 We will rigorously monitor and review our procedures and take appropriate steps to prevent recurrence of any
problems identified.
5.12 In all cases, we will contact you to confirm that you understand you have entered into an agreement, that you are
happy to proceed and are content with the way in which the sales and marketing activity was conducted.
5.13 If we discover that our contract has been misunderstood or the order was progressed before the expiry of the
switchover period, and you wish to cancel, we will terminate the contract without charge or any other penalty.
5.14 For consumer protection our procedures comply with all applicable legislation and appropriate amendments.
6.0 Audit
6.1 We regularly carry out audits of systems, procedures and documentation to ensure we are acting
compliantly with all aspects of the code.
7.0 Customer complaints procedure
7.1 Our internal procedures for handling customer complaints also include those relating to the sales and marketing
activities. We ensure that all staff and representatives who deal directly with customers are made aware of this procedure
and we will inform you of the existence of our complaints procedure in accordance with our current obligations. These can
also be accessed via our website at
7.2 Our complaints procedure sets out how you may complain about our sales and marketing activity and what further
steps are available if you believe the complaint has not been dealt with correctly. In addition, you will also be made aware
of any dispute resolution arrangements as recognised by Ofcom. Currently Ofcom has approved two schemes;
• The office of the Telecommunications Ombudsman (‘Otelo’)
• The Communications and Internet Services Adjudication Scheme (‘CISAS’)
7.3 We will liaise regularly with Ofcom and the relevant consumer groups to monitor the number and nature of complaints
under its code.
8.0 Distributing the Code: Creating Awareness
8.1 The code is available to you on request, free of charge and in a reasonable range of other formats. All our codes are also
accessible on our website at