1. What could be considered as gun jumping? (a) A practical indication of where the boundary lies between planning and implementation: AreaDoDon’t Potential JV customers Set up education and awareness presentations and meetings to explain the benefits of the JV and the services it might offer Hold principled high level discussions around potential ways in which the JV might typically charge for its services (e.g. set up fees; tenancy fees) Engage with sample customer panels to facilitate planning (i.e. open discussions around product needs) Always include caveats around clearance at the start of any discussions and make it clear that you are acting on behalf of the Shareholders in a clean team planning role and not on behalf of the JV Don’t negotiate or agree (in principle or otherwise) financial or non- financial terms Don’t represent to third parties that you are acting on behalf of the proposed JV or that the JV has been cleared Don’t in any way sell or promote the products or services of the JV Potential JV suppliers Set up education and awareness presentations and meetings (as above) Issue ‘Requests for Information’ (RFIs), including supplementary RFIs where further information is required. Responses can contain indicative fee quotes. Such RFIs will be designed to simply gather information to assess the available relevant resources Make decisions on preferred potential suppliers within the clean team Always include caveats around clearance at the start of any discussions (as above) Don’t negotiate or agree (in principle or otherwise) financial or non- financial terms. This includes entering into non-binding MOUs or letters of intent Don’t communicate decisions on preferred potential suppliers outside the clean team (including by reducing the number of suppliers you send supplementary RFIs to) Don’t represent to third parties that you are acting on behalf of the proposed JV or that the JV has been cleared Potential Service Users (MNOs & MVNOs) Set up education and awareness presentations and meetings (as above) Engage with the Service Users’ technical teams in order to plan how the JV’s systems could operate following clearance Don’t negotiate or agree (in principle or otherwise) the Service User Agreements Don’t permit Service Users to adapt their existing systems in anticipation of clearance 1 6

2. What could be considered as gun jumping? (b) A practical indication of where the boundary lies between planning and implementation (cont’d): AreaDoDon’t Potential Service Users (MNOs & MVNOs) (cont’d) Always include caveats around clearance at the start of any discussions (as above) Don’t permit Service Users to withdraw or align certain services to ensure minimal overlap with the JV’s activities (e.g. suspending competitive sales efforts for advertising; limiting or terminating existing research activities) Don’t represent to third parties that you are acting on behalf of the proposed JV or that the JV has been cleared PR/Branding Set up education and awareness presentations and meetings (as above) Engage a brand agency through one Shareholder to develop a B2B brand for the JV Register the brand and associated collateral (e.g. website) through that Shareholder Begin preparing draft branded websites, advertisements and other materials Always include caveats around clearance at the start of any discussions (as above) Don’t issue documentation (e.g. press releases) or engage with third parties (e.g. in correspondence; discussions) in the name of the JV or using the JV’s brand Don’t publish branded websites, advertisements or other materials Legal Engage an independent commercial lawyer through PwC to prepare first drafts of commercial documents on behalf of the JV (e.g. procurement agreements; Service User agreements) Don’t engage any of the commercial lawyers (internal or external) currently working for any of the Shareholders to prepare draft commercial documents on behalf of the JV Don’t allow the JV’s own lawyers to contact the legal representatives of third parties (including those acting for the Shareholders) 2 7