Compliance

It is O2's policy to be fully compliant with its Business Principles and local and regulatory requirements. During the year, the Board approved a detailed updated compliance policy. Online training and team briefing material is available to ensure that all employees are aware of our Business Principles and how they should be applied. We have increased the uptake of our mandatory training in this area and issued a new compliance leaflet for our employees. We have a network of compliance officers to monitor the progress of this activity.

Executive Committee members are required to confirm compliance with our Business Principles as part of the Corporate Governance Certification process.

In 2004/05 we received one complaint from Ofcom, the regulation and competition authority for the UK communications industries, concerning unfair consumer terms. We agreed to clarify and amend some terms and communicated this information to our customers in April 2005.

ICSTIS, the regulatory body for UK's premium rate telecommunications industry, upheld three complaints and issued a fine against our online portal. An external information provider had breached the regulatory code whilst using O2's premium text platform. As a result O2 terminated its contract.

The UK Information Commissioner brought 11 adverse assessments against our operations in the UK with claims of failure to comply with the Data Protection Act.

We aim to comply with voluntary advertising standards and guidelines, such as the recommendation by the Stewart Report (2000) of not marketing directly to children. We also aim to withdraw any advertising that is found misleading or inaccurate. In 2004/05 advertising standards authorities brought two complaints against our operations in the UK, two in Ireland and one in Germany. We aim to ensure that every regulatory complaint we receive is investigated in accordance with our compliance procedures.