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International Inbound Services ForumAnnual
Meeting September 2005International Freephone
Premium Rate Services Vodafone perspective

• Claire Alexandre, Group Public Policy

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Content

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

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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.

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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.

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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?

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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.

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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?

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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.

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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.

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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