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Title: Vodafone template


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International Inbound Services ForumAnnual
Meeting September 2005International Freephone
Premium Rate Services Vodafone perspective
  • Claire Alexandre, Group Public Policy

3
Content
  • Background
  • International Freephone Services
  • Call Completion
  • Access to 00800
  • Price vs. Access
  • Transparency
  • International Premium Rate Services

4
Background
  • Vodafone is the world's largest mobile community
    with about 165 million proportionate customers,
    equity interests in 28 countries and Partner
    Networks in a further 14 countries.
  • We are pro-connectivity and wish to be able to
    offer our customers the widest possible choice of
    calling destinations
  • national freephone
  • national non-geographical services
  • international access to freephone services
  • international access to other non-geographical
    services (except premium rate).
  • Vodafone is determined to combat any fraud and
    abuses targeting its customers, at home or
    roaming
  • national premium rate services
  • international premium rate services
  • international pseudo-premium rate services.

5
International Freephone Services (00800)
  • The issues related to 00800 calls from mobile
  • Connectivity is poor they are not always
    completed
  • They are sometimes charged for they are not
    free to the caller.

6
Call completion
  • Vodafone is willing to offer its mobile customers
    access to 00800 services on suitable commercial
    terms and will handle calls originated to 00800.
    All major VF operators in the EU should be
    originating calls to these numbers on request.
  • In general, we advocate consistency of approach
    with national freephone. Low call volumes do not
    indicate to us that a second settlement regime is
    justified (however, this could be subject to
    review in future).
  • However, not all 00800 customers provide access
    to their services from mobiles as they are
    entitled to do. This is a commercial decision
    for them.
  • And there may also be holes in the transit chain
    are all international carriers accepting mobile
    calls to 00800?
  • International 00800 is complex. 00800 customers
    should advertise when they do not provide access
    from mobiles or when there may be charges.
  • Originating operators do not control other parts
    of the call. Terminating operators neither, but
    represent the demand side. How can we arrive at
    greater connectivity and price transparency?

7
Access to 00800 consistent with national 0800
regime
  • In Europe, 2 commercial models exist for mobile
    calls to 00800
  • receiving an appropriate mobile origination
    charge from 00800 providers based on mobile
    network costs uplifted appropriately to reflect
    the nature of the call carried, and offering
    retail customers access to these services
    free-of-charge or
  • receiving a lower (usually) fixed-network based
    interconnect rate and applying an appropriate
    retail charge to the calling party.
  • Vodafone offers access to 00800 on the same terms
    which we offer to national freephone in the
    relevant national market
  • calls to 00800 mainly free, charged in some
    national cases and
  • a mobile-specific in-payment is made to the
    Vodafone operator in most cases assuming a
    national point of call handover or standard 0800
    interconnect in others
  • advantages consistent customer experience
    pragmatic and low cost to implement.
  • Mobile operators must be free to price in a way
    which makes sense commercially in the market.
  • Connectivity is an EU issue, pricing approach
    should be a matter for subsidiarity.

8
There is a genuine trade off between price and
access
  • Free of charge access from mobiles has been
    presented by EC as the most attractive
    pro-consumer option.
  • National freephone experience suggests many
    European commercial freephone customers may be
    significantly less willing to pay for 00800
    mobile origination than the typical mobile
    customer for these numbers.
  • This may result in reduced availability of
    destinations and actual minutes carried if the
    free of charge access model is mandated
    throughout Europe.
  • Policy-makers cannot simply wish-away real
    differences in customer behavior.
  • The issue of different customers willingness to
    pay for these services should be subject to
    further study, before any substantial changes are
    made to national interconnection environments.
  • Has IISF considered undertaking such study among
    its customers?

9
Transparency
  • Services that are advertised for free should in
    principle be free() European Commission
    Document COCOM 05-08.
  • Calls to 00800 should not be zero priced because
    of how they are advertised. The advertising must
    take the originating operators prices into
    account and reflect if and how access is
    provided.
  • The principle should be similar to what applies
    to calls to other types of non-geographic
    numbers, such as local or national rates each
    originating operator should inform its customer
    about the actual rate and also about the
    possibility for some services not to be
    accessible, based on a decision of the
    terminating party.
  • Originating operators should be transparent in
    how they price calls to 00800, at zero or at
    another price.
  • This should be reflected by advertisers in their
    statements about pricing.

10
International Premium Rate Services Fraud
  • Vodafone is pro-connectivity, but one key
    exception is international premium rate services.
  • In general, we see these as too subject to
    customer abuse and fraud risks. We do not
    support further access to these services.
  • Risk would be that market operates as national
    premium rate (where conflicting business
    objectives result in customer abuse and fraud)
    but with fewer effective controls on abuse
    because it is transnational.
  • As an example we are now seeing significant fraud
    calling international PRS while roaming.
  • Phones in use by a Vodafone mobile operator are
    roaming on a second mobile operator and, from
    that visited network, are systematically calling
    international premium rate numbers.
  • International premium rate geographic or
    mobile numbers of a distant country (often
    Pacific Islands or a satellite code) which are
    being "short-stopped" - calls are terminated in a
    third country and the interconnection payment
    used as a form of premium rate payment.

11
For further information about Vodafone, please
visit the Vodafone Group Web site
www.vodafone.com.
  • For further details about International Freephone
    and Premium Rate Services
  • Rob.Borthwick_at_Vodafone.com 44 79 79 54 00 54
  • Claire.Alexandre_at_Vodafone.com 32 475 70 60 31
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