posted 25th January 2026
This article is written in the context of our work at Meridian Legal Services, where we represent businesses that allege they have been mis-sold telecommunications services and associated finance agreements.
We have received a substantial volume of complaints relating to 4Com, and the company has also been the subject of national media reporting, including coverage by the BBC . Those matters are a matter of public record.
We do not act as a regulator, and this article does not purport to determine liability. Instead, we examine 4Com’s published Code of Conduct as an example of how such documents can create reassurance while offering limited protection when disputes arise.
Where companies set out standards by which they claim to operate, it is legitimate and necessary to test whether those standards are capable of withstanding real-world scrutiny.
There is something quietly revealing about a company’s Code of Conduct.
On the surface, 4Com’s looks reassuring enough. It is long, polished, and densely packed with references to regulators, ombudsmen, and legislation. It talks warmly about customer satisfaction, corporate responsibility, and best practices. To a busy small business owner, it looks like exactly what a responsible telecoms provider should have.
But apply even modest pressure, and it snaps clean in two, like a KitKat.
This matters because Codes of Conduct are not decorative documents. They are public promises. Customers rely on them. Regulators expect them to mean something. And when a code collapses the moment it is tested by a real dispute, the problem is not the complaint; it is the code.
Compliance in Appearance, Not in Substance.
4Com’s Code of Conduct is presented as a response to Ofcom’s General Condition C4, which governs complaints handling and dispute resolution.
It carefully explains processes, escalation routes, and membership of an Alternative Dispute Resolution scheme. In procedural terms, it ticks the right boxes.
What it does not do, and this omission is striking, is set out any meaningful standards governing how 4Com behaves at the point of sale.
- There is no clear prohibition on aggressive or misleading sales tactics.
- No obligation to disclose total contract or lease cost in a simple, intelligible way.
- No requirement to explain the real financial consequences of early termination.
- No standard to ensure that customers actually understand what they are signing up to.
For a company operating in a sector known for long contracts, complex pricing, and equipment finance, this silence is not trivial. It is structural.
"This is not a Code of Conduct designed to prevent harm."
It is a document designed to manage complaints once harm has already occurred.
The Cancellation Illusion.
One sentence in the Code deserves particular attention. 4Com states that “Customers are entitled to cancel services in writing at any time.” Read quickly, that sounds fair, even generous. Read carefully, it is something else entirely.
What the Code does not clearly or prominently explain is that cancellation can trigger substantial early termination charges, often running into many thousands of pounds. A right that carries severe financial penalties is not a meaningful right unless those penalties are spelled out in plain terms.
Presenting cancellation as a simple entitlement while downplaying its true cost risks misleading by omission. Regulators have long been clear that consumer rights cannot be framed in a way that disguises their practical consequences. A Code of Conduct that does so does not build trust, it erodes it.
Investigating Itself: Why Should Any Customer Trust the Process?
Perhaps the most troubling feature of 4Com’s Code of Conduct is the degree to which it asks customers to rely on faith. When something goes wrong, the Code promises an internal investigation. Complaints are logged, escalated, reviewed, and corrective action is supposedly taken. On paper, the process looks orderly and controlled. What the Code does not explain is why any customer should have confidence in the outcome.
- There is no separation between those whose actions are complained about and those responsible for investigating them.
- No independent oversight of internal complaint decisions.
- No transparency about how conclusions are reached.
- No commitment to share investigation findings in full with the customer.
Instead, the same organisation that sold the contract, benefits financially from it, and may face liability is also responsible for deciding whether it has done anything wrong. Trust in this context cannot be assumed. It has to be earned.
And a Code of Conduct that contains no safeguards against bias, defensiveness, or conflict of interest gives customers no rational basis for confidence.
More concerning still, the Code explicitly allows account activity to be suspended while a complaint is under investigation. For a small business reliant on its communications, that is not a neutral administrative step, it is pressure.
A process that can disadvantage a customer while the company investigates itself is not impartial redress. It is leverage dressed up as procedure.
Complaints Handling That Discourages Complaints.
The Code devotes significant space to describing how complaints are recorded and monitored. What it does not include is just as telling.
There are no firm internal resolution deadlines. No guaranteed written outcomes within defined timescales. No clear commitment to issuing deadlock letters promptly.
A complaints process that customers fear using, because of delay, disruption, or the risk of retaliation is not an effective complaints process. Ofcom’s rules require fairness and effectiveness, not procedural theatre.
Finance by Confusion.
The Code also performs a familiar balancing act when it comes to equipment finance.
On the one hand, 4Com seeks to distance itself from third-party funders. On the other, it acknowledges that complaints relating to equipment and selling practices must be handled by the supplier.
This internal contradiction is revealing.
A company cannot both control the sale and disclaim responsibility for how it was sold. Where responsibility is blurred, it is the customer who bears the cost.
A Code of Conduct should clarify accountability. This one obscures it.
Why This Is a Regulatory Problem.
This is not a stylistic critique. It is a substantive one.
When a company publishes a Code of Conduct, it creates legitimate expectations. Customers are entitled to rely on it. Regulators are entitled to assess whether it meaningfully protects consumers.
4Com’s Code demonstrates that the company understands what it is required to reference — Ofcom, ADR, data protection — but not what it is required to embed: fairness, transparency, and restraint in its commercial behaviour.
This is compliance in form, not in substance. Regulators know the difference.
The KitKat Test.
A robust Code of Conduct should bend under pressure, not snap. It should protect customers at the point of sale, not merely catalogue complaints after the damage has been done.
4Com’s Code looks solid until you try to use it for the one thing that matters: holding the company to account when things go wrong. At that point, it breaks cleanly, revealing how little structural strength it ever had.
If a Code of Conduct cannot withstand light scrutiny, the question is not why customers complain, it is why anyone was reassured by it in the first place.
That is a question both consumers and regulators would be wise to consider carefully.
If you believe you or your business may have been mis-sold telecommunications services or finance agreements, we encourage you to get in touch. At Meridian Legal Services, we represent businesses facing exactly these issues, including those involving complex telecoms contracts and associated finance arrangements.
We offer a free, no-obligation legal review where we take the time to understand what you were sold, how it was presented to you, and whether the agreements you entered into reflect what you were led to believe. Following that review, we will explain your position in plain English, outline the options available to you, and provide clear guidance on the next best steps.
