• Bespoke Telephony Solutions Limited

    Version 1.2 | Effective Date: 15 November 2025 | Next Review: 15 November 2027

    1. Policy Statement

    Bespoke Telephony Solutions Limited has a zero-tolerance approach to bribery and corruption. We are committed to conducting business in an ethical and transparent manner in accordance with the Bribery Act 2010.

    This policy applies to all employees, directors, contractors and associated persons acting on behalf of the Company.

    2. Prohibited Conduct

    The following are strictly prohibited:

    •       Offering, promising or giving a bribe (including facilitation payments).

    •       Requesting, agreeing to receive or accepting a bribe.

    •       Bribery of foreign public officials.

    •       Any other corrupt activity intended to obtain or retain business or a business advantage.

    3. Gifts, Hospitality and Expenses

    Modest gifts and hospitality that are reasonable, proportionate, transparent and not intended to influence business decisions may be acceptable. All gifts and hospitality above a modest threshold must be recorded and approved. Cash or cash equivalents are never acceptable.

    4. Third Parties and Due Diligence

    We will conduct proportionate due diligence on agents, suppliers, distributors and other third parties who act on our behalf, particularly where higher risk is identified. Contracts will include appropriate anti-bribery clauses where relevant.

    5. Reporting and Whistleblowing

    Suspected breaches must be reported immediately to the Director. Employees who raise concerns in good faith will be protected from retaliation. We will investigate all reports thoroughly.

    6. Training and Communication

    Relevant staff will receive training on this policy. It will be communicated to associated persons as appropriate.

    7. Monitoring and Review

    This policy forms part of our adequate procedures under the Bribery Act 2010. It will be reviewed annually or following any incident. Next review: 15 November 2027.

  • Bespoke Telephony Solutions Limited

    Version 2.2 | Effective Date: 24 June 2026 | Next Review: 24 June 2028

    1. Introduction and Scope

    Bespoke Telephony Solutions Limited is committed to protecting the personal data of its customers, employees, suppliers and other individuals in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

    This policy applies to all processing of personal data by the Company in the course of its business activities, including the provision of IoT SIMs, connectivity services, hardware for critical applications, and related customer support.

    2. Data Protection Principles

    The Company will process personal data in accordance with the following principles:

    •       Lawfulness, fairness and transparency

    •       Purpose limitation

    •       Data minimisation

    •       Accuracy

    •       Storage limitation

    •       Integrity and confidentiality (security)

    •       Accountability

    3. Lawful Bases for Processing

    The Company will identify and document a lawful basis for each processing activity. Common bases include:

    •       Contract: to deliver SIM connectivity, hardware and Device as a Service contracts.

    •       Legitimate interests: for business operations, security of critical systems, and limited marketing where appropriate.

    •       Legal obligation: for tax, accounting and regulatory compliance.

    •       Consent: where required for specific optional activities.

    4. Data Subject Rights

    Individuals have rights including access, rectification, erasure, restriction, portability and objection. Requests will be handled within one calendar month (extendable in complex cases). Contact: privacy@bespoketelephony.co.uk (or the designated contact).

    5. Security Measures

    Appropriate technical and organisational measures will be implemented to protect personal data, including access controls, encryption where appropriate for connectivity data, secure handling of SIM credentials, and staff training. Particular attention is paid to data relating to critical infrastructure applications.

    6. Data Breaches

    Any personal data breach will be assessed promptly. Breaches meeting the threshold will be reported to the ICO within 72 hours where feasible, and affected individuals notified where required.

    7. International Transfers

    Where personal data is transferred outside the UK, appropriate safeguards (such as adequacy regulations or standard contractual clauses) will be used.

    8. Retention

    Personal data will be retained only for as long as necessary for the purposes for which it was collected, or as required by law (e.g., financial records for HMRC).

    9. Responsibilities and Training

    All staff must comply with this policy. Training will be provided. The Director has overall responsibility for data protection compliance.

    10. Monitoring and Review

    This policy will be reviewed annually or following significant changes in law or processing activities. Next review: 24 June 2028.

  • Bespoke Telephony Solutions Limited

    Version 2.1 | Effective Date: 23 February 2026 | Next Review: 23 February 2028

    1. Policy Statement

    Bespoke Telephony Solutions Limited is committed to minimising the environmental impact of its activities and complying with applicable environmental legislation. We recognise our responsibility as a supplier of electronic connectivity products and services.

    2. Scope

    This policy covers all Company operations, including the design, supply and support of IoT SIMs, hardware for critical applications, packaging, energy use, waste, and business travel.

    3. Commitments

    •       Comply with relevant environmental laws, including the Waste Electrical and Electronic Equipment (WEEE) Regulations and packaging waste requirements.

    •       Promote the responsible use and end-of-life management of SIMs and hardware (e.g., encouraging return and recycling of equipment under Device as a Service arrangements).

    •       Reduce energy consumption and promote efficiency in operations and product selection where practicable.

    •       Minimise packaging and prefer recyclable or reduced materials.

    •       Consider environmental factors in supplier selection where feasible.

    •       Raise staff awareness of environmental issues relevant to our business.

    4. Continuous Improvement

    We will monitor our environmental performance and seek opportunities for improvement, proportionate to the size and nature of the business.

    5. Review

    This policy will be reviewed annually. Next review: 23 February 2028.

  • Bespoke Telephony Solutions Limited

    Version 3.0 | Effective Date: 17 April 2026 | Next Review: 17 April 2028

    1. Policy Statement

    Bespoke Telephony Solutions Limited is committed to promoting equality, diversity and inclusion, and to eliminating unlawful discrimination. We aim to create an environment where everyone is treated fairly and with respect.

    This policy applies to all employees, job applicants, contractors and others who come into contact with the Company. It is based on the Equality Act 2010.

    2. Protected Characteristics

    We will not unlawfully discriminate on the grounds of:

    •       Age

    •       Disability

    •       Gender reassignment

    •       Marriage and civil partnership

    •       Pregnancy and maternity

    •       Race (including colour, nationality, and ethnic or national origin)

    •       Religion or belief

    •       Sex

    •       Sexual orientation

    3. Commitments

    •       Provide equality of opportunity in recruitment, training, promotion and other employment practices.

    •       Create a working environment free from harassment, bullying and victimisation.

    •       Make reasonable adjustments for disabled employees and applicants where required.

    •       Ensure decisions are based on merit and objective criteria.

    •       Encourage reporting of concerns and handle them promptly and confidentially.

    4. Responsibilities

    All staff are responsible for upholding this policy. The Director has overall responsibility for its implementation and for ensuring training and awareness.

    5. Monitoring and Review

    This policy will be reviewed annually or following changes in legislation. Next review: 17 April 2028

  • Bespoke Telephony Solutions Limited

    Version 2.0 | Effective Date: 15 May 2026 | Next Review: 15 May 2028

    1. Statement of Intent

    Bespoke Telephony Solutions Limited (the “Company”) is committed to ensuring the health, safety and welfare of its employees, contractors, visitors and anyone else who may be affected by its activities, so far as is reasonably practicable.

    This policy applies to all Company activities, including the supply of 4/5G multi-network IoT SIMs, hardware for critical applications (such as lifts, alarms and remote assets), Device as a Service offerings, and related support and installation activities.

    The Company recognises its responsibilities under the Health and Safety at Work etc. Act 1974 and associated regulations. We will provide adequate resources, information, instruction, training and supervision to achieve this commitment.

    2. Responsibilities

    2.1 Director / Senior Management

    •       Overall responsibility for health and safety and ensuring this policy is implemented and reviewed.

    •       Appoint a competent person (or external advisor) to assist with health and safety duties.

    •       Ensure risk assessments are carried out and significant findings recorded where required.

    •       Provide adequate resources for health and safety.

    2.2 Employees and Contractors

    •       Take reasonable care of their own health and safety and that of others.

    •       Cooperate with the Company on health and safety matters.

    •       Report hazards, near misses and accidents promptly.

    •       Follow safe systems of work, including when handling, installing or supporting hardware and SIM-related equipment.

    3. Arrangements

    3.1 Risk Assessment

    Risk assessments will be carried out for significant hazards, including office/homeworking environments, manual handling of equipment, electrical safety, and any on-site installation or maintenance work related to critical infrastructure systems.

    3.2 Information, Instruction and Training

    All staff will receive appropriate induction and ongoing training relevant to their role, including awareness of risks associated with IoT hardware, SIM cards and remote asset monitoring equipment.

    3.3 Accidents and Incidents

    All accidents, near misses and work-related ill health will be recorded. Serious incidents will be reported in accordance with RIDDOR where applicable. Investigations will be conducted to prevent recurrence.

    3.4 Welfare and First Aid

    Adequate welfare facilities will be provided. First aid arrangements appropriate to the size and nature of the business will be maintained.

    3.5 Remote and Hybrid Working

    Where employees work remotely, suitable DSE assessments and advice on safe working environments will be provided.

    4. Monitoring and Review

    This policy will be reviewed at least annually or following any significant change in activities, legislation or incidents. The next scheduled review is 15 May 2028.

    Approved by:

    Andrew Moody

    Director, Bespoke Telephony Solutions Limited

    Date: 15 May 2026

  • Bespoke Telephony Solutions Limited

    Version 1.0 | Effective Date: 16 December 2025 | Next Review: 16 December 2027

    1. Policy Statement

    Bespoke Telephony Solutions Limited has a zero-tolerance approach to modern slavery and human trafficking in all its forms. We are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to ensure slavery and human trafficking is not taking place in our business or supply chains.

    This policy reflects our obligations under the Modern Slavery Act 2015 and applies to all employees, contractors, suppliers and business partners.

    2. Our Business and Supply Chains

    The Company supplies 4/5G multi-network IoT SIMs, hardware for critical applications (including lifts, alarms and remote assets), and related services. Our supply chains include manufacturers and distributors of SIMs, routers, antennas and other connectivity hardware, as well as logistics and support providers. We recognise that certain stages of electronics and telecommunications hardware supply chains can present elevated risks.

    3. Due Diligence and Risk Assessment

    We will:

    •       Assess modern slavery risks in our operations and supply chains, particularly for hardware components.

    •       Conduct proportionate due diligence on key suppliers, including contractual requirements to comply with applicable laws.

    •       Encourage suppliers to cascade these expectations through their own supply chains.

    4. Reporting Concerns

    Employees and others are encouraged to report any concerns about modern slavery or human trafficking. Reports can be made confidentially to the Director. Whistleblowing protections apply where relevant. We will investigate all concerns appropriately.

    5. Training and Awareness

    Relevant staff will receive awareness training on modern slavery risks relevant to our sector.

    6. Monitoring and Review

    This policy will be reviewed annually. We will continuously improve our approach based on emerging risks and best practice. Next review: 16 December 2027.

    Note: An annual Modern Slavery Statement under section 54 of the Modern Slavery Act 2015 is required only for organisations with turnover of £36 million or more. This policy applies regardless of turnover.