The BT Audit and Risk Committee is responsible for monitoring and reporting on BT Group’s compliance with the Commitments and Governance Protocol. Part of its role is to review:

a) BT Group’s compliance with the Commitments and the Governance Protocol as set out in section 19.4 of the Commitments and sections 7.13 – 7.15 of Part A of the Governance Protocol, and may be amended from time to time;

b) whether the culture in BT Group and the behaviours of BT Group people in relation to the Commitments and Governance Protocol are conducive to BT Group’s compliance with them and to delivery of the Digital Communications Review (DCR) objectives; and

c) the extent to which metrics published by Ofcom in relation to the DCR are being achieved and the objectives identified by Ofcom in the DCR Final Statement are being met.

On behalf of the Audit and Risk Committee, the CAO monitors BT Group’s performance in each of these areas, by means of a programme which includes:

  • Ongoing compliance with the Commitments and Governance Protocol
  • Behavioural measures and other measures relating to the culture of BT Group people, to provide assurance that they are living up to the commitments
  • Reviews of consumer and industry outcomes
  • Investigation and resolution of complaints and informal issues raised by CPs or other stakeholders.

The CAO reports on these areas in detail to the Audit and Risk Committee three times per year.

Ongoing compliance

The CAO’s focus is on monitoring BT Group’s ongoing compliance in areas such as information sharing, financial planning and BT Group’s fulfilment of its Parent Company role. The CAO’s monitoring activities include a rolling annual programme of compliance checks, working with Group Regulatory Compliance and Internal Audit, together with more detailed, targeted reviews of key risk areas.

Behavioural measures

The CAO monitors a dashboard of behavioural measures relating to the Commitments which includes training and education, organisational separation, breach and complaint trends. These measures are regularly reported to the Audit and Risk Committee.

Complaints and informal issues

As well as investigating formal compliance complaints about the actions of BT Group people received direct, the CAO will engage with CPs via industry fora or as a result of direct contacts. The CAO will conduct informal reviews of issues and concerns raised as a result of such contacts. These reviews take place on a confidential basis when requested, and the CAO will advise both the CP and BT Group of the outcome of the review as appropriate.