SPARK SYSTEMS USE IN OUR UFL

WHAT’S BEEN HAPPENING

Unfortunately, we recently discovered instances of members of our Spark teams misusing Spark Systems.
Upon further investigation this issue was found to be more widespread.

WHAT WE FOUND
The investigation uncovered several team members who were using Sparks systems (predominantly
SparkCRM) to action orders on their own accounts, their colleagues accounts, friends, and family members
accounts. We also found team members who had products and or services (including plans, offers, and
promotional credits) applied to accounts, that they were not eligible for (according to business rules).

IT’S FRAUDULENT BEHAVIOUR

Using Spark systems and or tools for personal gain constitutes as serious misuse and is grounds for the
termination of one’s employment with Spark.
Applying plans, offers, and promotional credits to customers who are not eligible for them (according to
Spark’s business rules) is considered fraudulent behaviour, and it carries a financial impact for Spark (a
credit on a customer’s account, or discounted products and or services have real value and impact on our
ability to achieve our fiscal goals).
Spark has obligations when it comes to the fair-trading act. We must be seen to be treating customers
fairly. When a plan, offer, or promotional credit, is applied to a customer who does not meet the business
rules, we can be seen to be discriminating against other customers, which can result in further implications
for Spark.
Lastly, and most importantly, misuse of Spark systems, and fraudulent behaviour is against our Code of
Ethics, and our Values here at Spark. It’s not who we are, it’s not how we work.

WHAT NOW
Misuse of Spark Systems, and fraudulent behaviour will not be allowed within Spark, and as leaders within
Spark you have obligations to play your part in protecting Spark, and your teams from these actions.

NEXT STEPS
There will be communications that will be shared with all our UFL team members, outlining the recent
investigation, re-establishing the expectations of systems use and our behaviour as outlined in ‘Our Spark
Code of Ethics’.
We have launched a new compliance module in Ako, and every team member within UFL will be expected
to complete. It includes a digital acknowledgement of their agreement to comply with Spark policies and
guidelines around systems use, and the potential consequences if they are found to have broken them.
We will hold a two week amnesty, where any team members who may have; offers, products or services, or
promotional credits – that they are not eligible for, can inform us of these and have them removed, without
facing any potential disciplinary action. The can inform us through filling in this Microsoft form.
If any instances of Spark systems misuse, or fraudulent behaviour are discovered beyond this point, then
we will be proceeding with investigations and acting in accordance with the findings.
You will be expected as a leader to have this conversation with your team members, establishing the
accepted behaviours going forward, and ensure that all your team members have completed the following
compliance modules.

• Systems access and use for our Unified Frontline (including the digital acknowledgement of their
understanding, and agreement to comply with Spark’s policies).
• Way we work 1 – People
• Way we work 2 - Legal
• Way we work 3 - Spark
• Way we work 4 - Security
• Enhancing our brand and reputation
• Privacy
• PCI DSS
• Customer Channels – Adjustment Levels and our Frontline
Please note: Except for the ‘Systems access and use for our Unified Frontline’, all these modules should
have been completed as part of onboarding when your team members joined Spark. If it has been more
than 12 months since you, or your team have completed any of these modules, it’s a good idea to re-do
them.
The systems access and use for our Unified Frontline module, and digital acknowledgement form, must be
completed by all of your team members by 29th October, there will be an audit report run to confirm this.

SUPPORT
If you have further questions, you can reach out to your Market Lead, or your People Partner.