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Telenor response to European Commission PUBLIC CONSULTATION on a Review of the functioning of Regulation (EC) No 544/2009 (the "Roaming Regulation")

Dear Sir/Madam, Group (Telenor herafter) welcomes the opportunity to respond to this consultation on a Review of the functioning of the Roaming Regulation.

Telenor is headquartered in Norway and has a wireless footprint in Nordic (i.e. Norway, Sweden and ), Central Europe (i.e Hungary within the European Community and the candidate/ accession countries Montenegro and Serbia) and in several markets in South East Asia. The single market for international roaming services and regulation thereof impact on our business, but in contrast to other mobile services market the roaming revenues has declined lately both in absolute figures and as proportion of total market (eg. our overall roaming revenues show a 14% decrease during the last two years even though data roaming is increasing). Telenor companies have been diligent in delivering new and attractive roaming offers according to regulatory requirements and competitive pressure.

Telenor appreciates the analysis of the international roaming market made by the advisory body BEREC which coincided with the launch of this consultation. Telenor supports the main findings of BEREC’s December 2010 report “International Mobile Roaming Regulation” and in particular the analysis relevant for the design of any Roaming Regulation post July 2012 (Page 30, point 128) if continued regulation should be the result of the review process.

“ ….It is appropriate therefore to put in place measures for the period July 2012 - June 2015 and review the situation again by (say) June 2014.

Very close alignment of roaming prices with domestic prices will cause disruption to the market (margin squeeze at retail level and/or requirement to sell below cost at wholesale level) unless 2 preconditions are satisfied: a. Wholesale prices are close to cost-oriented levels b. Average domestic retail prices are not significantly different throughout Europe

These preconditions will not be in place by 2012….

BEREC believes that, whatever form the wholesale and retail regulation takes in future, a “no losers” policy is desireable, so that all consumers benefit and none are worse off than under the current Regulation.”

In short ’ position is: • Facts and figures speak for itselves. The Roaming Regulations may have contributed positively to a single market for roaming services, have protected consumers, but have likely dampened competition in the roaming market somewhat. • Telenor accepts that there is a case for continous regulation of roaming services to protect consumer interest and the achievment of the single market objectives, but oppose the idea that there is a lack of mobile competition. • Structural solutions to increase competition within the single market for roaming services bring cost that would outweigh benefits by far. Adopting compex combinations of different regulatory solutions would add further burden and unintended consequences. • Any price regulation maintained to moderate prices must be based upon realistic and conservative assumptions about mobile operators’ underlying cost. Any new price regulation imposed on retail data must not compromise operators’ ability to innovate on packages and tarriffs. • Telenor believes that the fast growing mobile data market due to intra and inter platform competition and will deliver results also in the roaming market. We are committed to contribute to such a development. • The regulatory proposal should be accompanied by a cost benefit analysis. The internal market objective of lowering the difference between national and roaming charges to close to zero by 2015 must be balanced with other policy goals in Digital Agenda for Europe (DAE). Miniumum adverse impact on domestic mobile markets must be secured. A rigourous impact assessment (eg revenue loss, implemetation costs, dynamic welfare losses, etc) in line with the EU policy on better regulation must follow the proposal for legislation

Finally Telenor welcomes the open minded approach of the Commissioner and her desire to establish a strong partnership between the Commission and the Industry.

Developments since the commencement of the Regulation

Question 1: To what extent do you believe that the current regulation achieved its objectives in terms of: (a) Contributing to the single market for roaming services? (b) Ensuring consumer protection? (c) Promoting competition? Please explain and substantiate your responses with data where possible.

Telenor answer: Telenor is in general subscribing to the situation analysis of the Commission for the period under scrutiny (2007-2010). The facts and figures speak for itselves and are analysed in detail in several BEREC benchmark reports. 1

Telenor will, however, insist that it is the importance of the notion of a single European market for international roaming services in combination with consumer preferences (i.e. the value consumers in general give to attractive roaming offers relative to the full set of mobile services) that is the challenge, not lack of competition as such. However, when analysis is made of the the said international roaming market within the European Economic Area in isolation it seems as if effective competition for roaming services restrained by specific factors at both wholesale and retail level.

On a general note it should be mentioned that prices for roaming services was also declining under normal competitive pressures prior to 2007.

1 The GSMA Response contains additional analysis of the market empirics and should be incorporated into the analysis going forward. Our answers regarding the impact of the current regulation in terms of achieving the objectives are the following:

a) Single market: Yes, the current regulation has contributed positively to the single market for roaming services, but market structure gives limitations. On the other hand, it can be argued that there is no such thing as a single market for roaming services in the absence of large scale deployment of pan European roaming services and more harmonised conditions across the member states.

b) Consumer protection : Yes, the current regulation has contributed positively to ensuring consumer protection by lowering tarrifs and due to transparency requirements has reduced the amounts of “bill shocks”.

c) Competition: No, the current regulation has contributed negatively to the promotion of competition. Telenor believes the wholesale regulation at first had a positive but over time a neutral effect, whereas the retail provisions dampen competition. As BEREC and Commission analysis show retail prices tend to cluster around the caps for the majority of customers. It should be noted that many operators are actually offering cheaper non-Eurotarriffs and Eurotarriffs. This indicates some competition (absent competition we would not see operators launching new tarriffs or promotions)

Question 2: Do you consider that regulatory intervention for roaming services is needed beyond June 2012? Please consider voice, SMS and data roaming services separately. In particular, if you consider that the Roaming Regulation should expire in June 2012, please explain why, and describe how you consider that the market for roaming services will evolve in the absence of regulation.

Telenor answer: Telenor would advocate a market solution over persistent regulation. We consider that only wholesale regulation is justified to support competition. Retail prices should not be regulated to foster competition. General economic theory prescribes that no regulation of retail prices gives better incentives to competition than regulated prices, but Telenor would support a high degree of transparency in price plans offering customers cost control.

We are confident that data prices will continue to decrease in the coming years at a faster pace than observed untill today, thus regulation of retail data prices is premature. Competition from alternative technologies (Wifi) will further drive prices down. Furthermore, mobile data subscriptions may be purchased independent of ordinary subscriptions for voice/SMS putting even more pressure on data retail prices.

Concerning voice we also expect that competition among mobile providers and providers of alternative technologies (mVoIP) will put pressure on voice retail prices. Use of alternative technologies like Facebook will to a certain extent substitute use of SMS.

The current conditions in the roaming market suggest that significant further regulatory intervention at retail level is necessary. Telenor asserts that there is no basis to assume that withdrawal of the pricing regulation would reverse the trend of tariff decreases.

However, as also underlined by BEREC, if European legislators upholds the same justification for intervention as for Roaming I and II the empirics suggests that problem is not yet solved. Telenor consider it as understandable that policy makers think that business people, turists and young people that are frequent travellers deserve better prices. As such prevention of excessive roaming prices, keeping a downward pressure in place and also safeguarding against roaming prices to rise is to be expected. Telenor also acknowledge that DAE objectives are legitimate arguments to maintain regulation in the short term (towards 2015) . BEREC puts it this way:

“Given that legislators considered there were sufficient objective reasons to impose regulation in the first place, little that has happened in the market subsequently provides evidence for a change of view”. (Page 4 , point 15)

Any legislative proposals following the present review should be subject to a thorough impact assessment in the light of the policy goals pursued by the measure. The Commission has expressed its belief that the policy objectives, such as protecting consumers and fostering the internal market, could best be reached by lowering the difference between national and roaming charges to close to zero by 2015. Such an approach risks creating severe market distortions and increases in regulatory costs.

Furthermore, any regulatory option for roaming has to remain compliant with the electronic communication framework and in particular with the principle of justification, necessity and proportionality. In that sense, Telenor considers that some of the options proposed by the Commission seems to go beyond the objectives of roaming regulation, raising issues in terms of proportionality. Data markets in particular are characterised by a strong dynamism, innovation and price decreases which should lead to a cautious approach.

Options for future regulation As outlined above in our reponse to question 1 and 2 we do not neccesarily agree with the need for regulation, and regret that many policy makers have lost patience with the mobile industry. In the following we give our input to the alternative regulatory solutions.

We think BEREC has done a useful analysis in evaluating the alternative options for future regulation and find it difficult to provide additional evidence to support a different overall recommendation. Our contribution is thus basically refering to the BEREC analysis and commenting upon areas where we think differently.

a) Maint ain current approach

Question 3: Do you consider that the current model of regulation would be effective in the future in light of the desired objectives? Will this approach ensure adequate consumer protection and help stimulate competition? Is it efficient and coherent with EU policies?

Question 4: If this model is suitable in principle, what modifications may be required in order to achieve a well functioning single market for roaming services? Should this approach be combined with other options?

Telenor answer: In general Telenor supports the analysis made in BEREC report about practicality of pro-longing the current model of regulation:

”BEREC recommends continuation with the Eurotariff voice and Euro-SMS tariff for a further 3 years after June 2012 as the most practical measure for the next period.

BEREC believes that a wholesale price cap is the only realistic method currently available for controlling wholesale prices. The approach to wholesale regulation needs to be chosen to reflect the retail approach adopted. ” (page 30 and 31, point 128)

Some modifications to the current model of regulation to be considered in the review in light of challenges experienced:

Challenge: Local excange rates fluctuations The current roaming regulation which provides for maximum wholesale and retail prices has a different impact on countries within or outside the Euro zone. The situation is somewhat different to the standard currency risk of importing, where the retail price can be raised if local currency is weakening (the issue is also adressed in the BEREC report).

The regulated roaming rates are set in Euro, and in countries where the local currency is not Euro, operators exchange the Euro tariffs to their local currencies by using a fixed exchange rate on a defined date of the year cf. article 1 of the Roaming Regulation.

Telenor has already supported the proposal put forward by the EFTA Committee which permits more frequent adjustment of the exchange rates vis-a-vis the Euro.

“When the exchange rate to the euro deviates more than [e.g.10%] from the exchange rate determined at the last revision, the operator may, with approval from the NRA, every [four] months adjust to the prevailing exchange rate.

If the European Central Bank does not publish the relevant exchange rates the corresponding exchange rates published by the National Central Bank issuing the currency shall be used for reference.”

Challenge: Flexibility under the Eurotariff for voice (normalized call) If voice price cap regulation is to be continued in the future one should underpin competition by making allowance for operators to offer voice services with different combinations of set up prices and per minute prices in order to address different market segments. Such a regulation can be designed by setting the price cap as a maximum price for a normalized call of for instance two minutes. In order to make the regulation easy to implement a normalized call should for each operator be based upon its traffic statistics for call lengths from previous year.

b) Wh olesale and transparency measures only

Question 5: Would regulation of wholesale prices charged to MNOs, combined with transparency measures, be effective, efficient and coherent in light of the single market objective? Would the benefits of regulated wholesale rates be passed through to consumers?

Telenor answer: As outlined in answers above this is generally our preferred option. Still we acknowledge that absent sufficient evidence of pass through of cost reductions to consumers the answer to the first question about single market objectives is probably no. Based upon our experience benefits resulting from reduced wholesale prices are passed through to consumers, but not always to the roaming service. Telenor is committed to via provision of attractive offers to contribute to single market objectives in the near future.

c) Regulation of retail data roaming charges

Question 6: Do you consider that retail regulation of data roaming prices is necessary? If not, what are the likely market developments post-June 2012?

Question 7: If retail regulation of data roaming prices was necessary, what would be an appropriate model for such regulation?

Telenor answer : Telenor expects, as stated above, that data roaming prices will continue to decrease post June 2012. This is due to competition among mobile service providers and from the fact that data subscriptions can be obtained independently from ordinary subscriptions, and competition from alternative technologies. As observed by BEREC and further explained by the GSMA the data market is already evolving rapidly. Traffic is growing, retail prices are declining and innovation is ongoing so unnecessary regulation risks stifling the market development. Telenor prefers that market forces alone are allowed to shape the retail markets’ progress post June 2012

A future regulation (should be a very cautious regulatory approach) must be constructed such that alternative price models/offers are allowed. On balance, BEREC prefers the “Eurodata” tariff, for reasons of transparency and consistency with the approach to voice and SMS. BEREC concludes:

”We propose that the current price cap approach should be retained and a price regulation measure applied to retail data roaming, with the caps set at appropriate levels to reflect the pricing objective, taking account both of costs and of corresponding domestic prices”. (Point 96)

Telenor agrees that a modified Eurodata tariff, with a simple cap on the price per Mb would be the best option if retail regulation on data is imposed. The perils of the introduction of just a flat cap, applicable to all data services should however not be underestimated. The variety of data services and the fact that the bandwidth required by the different services does not reflect the value for the customers implies that even the imposition of a single price cap would have a negative impact on services innovation.

d) Approaches based on prices and conditions similar to those prevailing in the domestic markets (i) Roaming prices based on domestic prices in the home market (ii) Roaming prices based on domestic prices in the visited country

Question 8: Please indicate the advantages and disadvantages of these approaches, relative to each other and to the current model of price capping, considering also competition aspects such as the possibility of margin squeeze?

Telenor answer: Telenor concurr with BEREC analysis. “Roam like at home” (page 110) and “Roam like a local” (page 114) is not suitable for the 2012 regulatory solution. The main justification is that it will cause disruption to the market. BERECs conclusion is that:

3. Very close alignment of roaming prices with domestic prices will cause disruption to the market (margin squeeze at retail level and/or requirement to sell below cost at wholesale level) unless 2 preconditions are satisfied: a. Wholesale prices are close to cost-oriented levels b. Average domestic retail prices are not significantly different throughout Europe

4. These preconditions will not be in place by 2012. Wholesale regulation can address condition (a) by 2015 but it is not clear whether or when condition (b) will be satisfied. (page 30)

We also agree with BEREC that the current variation in domestic prices across Europe makes any attempt to link roaming and domestic prices unworkable. In some more detail:

In the presence of different price levels in EU communications markets, an approach based on domestic price levels in the home country i n particular would undermine competition, investment and consumer interests by leading to large-scale price arbitrage between mobile markets in Member States.

National price differences for mobile services result from fierce competition, macro-economic factors like labour costs, cost differences in network roll-out, etc . As these different conditions can be expected to persist, a “roam like home” approach would actually oppose the principles of the EU internal market and fair competition.

An approach to roaming based on domestic prices and conditions in the visited country appears impracticable, as consumers would have to pay a different tariff in each Member State. It would reduce transparency for consumers.

Finally, there are objective differences between roaming services and service on national markets when it comes to usage of the networks. A market-based approach would recognise these differences in usage patterns which demand suitable pricing schemes, differing from national pricing.

It is in Telenor’s opinion questionable if the DAE target of closely aligning roaming and domestic tariffs is an approapriate approach. As the target has been set without clarity about what it actually means it should not be pursued. The present review offers a chance to adjust or at least clarify the policy goal.

In general any linkage between domestic and roaming prices must include a sufficient margin to account for roaming specific costs as the provision of Roaming Services objectively differs from the provision of domestic services. Some elements of service provision are specific to roaming, such as implementation, management and operations of an international signalling network and international call termination using international carrier services; maintenance of the “network” of roaming partners, management and operations of the roaming billing chain including relationships to clearing houses; targeted network expansion in areas with massive visitor concentration etc.

BEREC has provided very rough cost estimates for the roaming services (section 5) but further cost analysis and verification is needed to dictate roaming tariffs at such low levels.

e) Separate sale of roaming services - decoupling of roaming from mobile services bundles (i) Carrier Pre-select (CPS) in the domestic market (ii) Carrier Pre-select (CPS) in the visited network (iii) Choose operator at the border (based on local retail price)

Question 9: In general, would these decoupling approaches be effective in terms of stimulating greater competition for roaming services? Would all customer segments be able to benefit? Would such increased competition be sufficient to give consumers an effective choice of roaming services at (near) domestic prices?

Question 10: Would such 'structural' approaches be efficient? What are the technical implementation issues associated with these approaches?

Telenor answer: All proposals are decoupling approaches that aim to increase competition (for originating traffic) rather than directly achieving the target via price regulation. At first glance they may appear attractive as the alternatives seems to target the source of the perceived market failure in roaming provision, a lack of buyer power by end-users (mass market consumers and small businesses). However, such apperent advantages assume the presence by new third parties (MNO/MVNOs) in the relevant country.

Telenor evaluates that all three proposals are of such a nature that they will entail technical implications that would imply heavy costs. We cannot foresee that the possible benefits can justify the costs of implementation effort and standardisation by industry or standardisation bodies.

Such unbundling would also negatively affect customer experience due to increased complexity. The user friendly, transparent and practical roaming service we know of would be challenged and consumers must take active choices under bounded information in the different situations.

Concerning option (iii) we cannot see how customers in an easy manner can be informed of local prices at border crossings. Use of SIM of visited network would be a better option, a possibility that exists today.

Finally, all three approaches should be categorized as access based approaches. The fundamental concerns outlined in the response to question g) apply.

f) Spot -trading of wholesale roaming

Question 11: How feasible/efficient is the establishment of a spot trading market for wholesale roaming? Would this approach lead to competitive wholesale rates? How effective would this approach be in terms of achieving competitive retail rates?

Telenor answer: A spot trading market for wholesale roaming will not lead to more competitive wholesale prices. This is so because the trading for wholesale prices in practice already entails the mechanisms and benefits that a spot market is sought to bring forward however with less fluctuations. It is Telenor`s experience that the increased competition for inbound roaming traffic leads to decreasing wholesale rates.

It could furthermore be argued that frequently changing of wholesale prices could impede the retail market. Retail prices should benefit from a predictable cost base. If spot trading is the basis wholesale prices would fluctuate continuously. Even the lowering wholesale price will not necessarily result in a lowering retail price.

g) Access -based approaches

(i) Wholesale access mandated for MVNOs, for roaming only, in visited networks. (ii) An obligation on the home MNO not to charge in excess of the regulated wholesale cap to any MVNOs using its network (iii) Mandating full wholesale access for MVNOs to mobile networks in the home market for all services (not just roaming)

Question 12: For each of options (i) to (iii) above please indicate whether such approaches can stimulate additional competition for roaming services. In order to achieve significant reductions in roaming prices do you consider that these 'access-based' approaches may need to be combined with other forms of wholesale price regulation (i.e. between MNOs) and/or retail price regulation? Please explain.

Telenor answer: We cannot see that these options would contribute much and it is very intrusive to force one or more of the options upon the market. Beneficial wholesale price levels are already obtained through the negotiation mechanisms presented to Question 11. On the downside unbundling may create unintended disturbances to domestic markets.

Adopting complex combinations of differerent regulatory approaches based upon the examples of access based, decoupling (ref question e) or any other solution would burden the industry with further implementation cost and impact on customer experience. A necessary condition for any discussion of the viablity of such access based approaches would be that there is no retail regulation and that the cost based MVNO access level must consider the actual cost.

Fundamentally we are concerned that such approaches to access obligations would represent a parallell regime to the telecoms regulatory framework in place (the three step procedure to impose access obligations) without fulfilling any of the requirements for imposing access obligations (relevant market, SMP, proportionate remedies). This would undermine legal certainty of the market players and circumvent the rules already in place.

Medium to long term view

(i) Wi fi networks (ii) All IP data networks

Question 13: In the medium to long term, markets and technologies will possibly evolve to the point where roaming services can be provided by different competing technologies. Such developments seem to be unlikely to be sufficient to eliminate or minimize roaming problems within 5 years. Do respondents share this view? Please explain.

Question 14: Do respondents think that the Commission should pursue measures to accelerate these developments (e.g. to encourage the massive deployment of interconnected Wifi networks? What other measures could be considered? What will the impact be of the transition to an 'all IP' environment on roaming services?

Telenor answer: In general we think technology developments and substitute product offerings will solve current competition problems in the international roaming market longer term. The Commission should of course not pick winners (e.g. support Wifi deployment), but let market decide on most cost efficient technology.

The time it will take Europe to get to a point where roaming services can be provided by different competing technologies depend on several factors including levels of investment in LTE and Wifi networks. In turn this may to some extent depend on the investment friendliness of the regulatory framework in Europe. Relevant examples of IP-based products that bypass the roaming service can already be found in the business segment.

We would also like to mention that in Telenor’s opinion the promise of new business opportunities coming from M2M applications will bring innovation and new deals in the wholesale area. Business models and necessary flexibility in wholesale arrangements (micro transactions, signaling, etc) will be solved in the market.

In general Telenor would welcome some patience on internal market objectives as a justification for intervention as long as policy makers see this development coming.

Inadvertent roaming

Question 15 : To what extent is the problem of inadvertent roaming still a concern for citizen's living close to borders? What measures could be taken to avoid the adverse effects of inadvertent roaming, whether by means of voluntary co-operation between operators or by means of regulatory or legislative action?

Question 16 : If you are an operator, what measures (technical or otherwise) have you taken to deal with the issue of inadvertent roaming, both to prevent it happening and to compensate for the adverse effects once it has been shown to have occurred? How do you raise awareness of the problem and the potential remedies on the part of your customers?

Telenor answer: Telenor does not consider inadvertent rooming to constitute a large problem. In the Nordic region Telenor informs its subscribers via an “SMS Bon Voyage” message that they are outside their home network. For example in Norway this sms is sent to subscribers entering another EU/EEA country and also Russia. By including Russia we include all countries that border Norway.

In Hungary we are encouraging our customers living close to the border to: - use manual network selection on their handset / equipment - use roaming barring service to avoid any kind of roaming Also we send an SMS each time the customer is connected to any foreign network making them aware of the situation.

These solutions eliminate the above described problem. Still if a customer runs into unwanted roaming we are using individual customer complaint handling to resolve the situation.

Outermost regions

Question 17 : What has been the impact on mobile users and service providers of the implementation of the Regulation as far as roaming within, from or between the outermost regions is concerned?

Question 18 : What additional measures (if any) have been taken by the Member States or their NRAs to address roaming between the outermost regions and other parts of the EU?

Telenor answer: N/A

Impact on smaller operators

Question 19: What has been the financal impact (revenues, costs, profits, volums,etc) on smaller mobile telephony providers of the application of the Regulation since its entry into force on 30 June 2007 and amended in 2009? Please provide financial data and any other information in this respect wherever possible (which will be treated as confidential if so requested).

Question 20 : Has any operator encountered problems when seeking to agree a wholesale roaming agreement with an operator in another Member State? What kind of problems were these (e.g. for SMS interworking)? Were they resolved in the end? Was the issue referred to anTelenor NRA? answer: If so, what action has been taken or is in train to address those problems?

Telenor answer: N/A

Traffic steering

Question 21 : To what extent is the use of traffic steering accompanied by a lower retail price for the roaming customer? Where lower roaming prices are conditional upon the use of a preferred visited network, how effective is the traffic steering in practice in ensuring that the preferred network is used? Please provide detailed data where possible.

Question 22 : What techniques are applied to implement traffic steering in practice? Is the roaming customer informed in advance about the steering and does he have the possibility to override it?

Telenor answer: Telenor has implemented traffic steering. The retail prices offered customers are, however, independent of chosen network.

As an example in Hungary a special data tariff is offered. This tariff allows the user to roam into 9 different countries through the preferred operators at a reduced price. Traffic steering into those countries is very efficient: 94% of the GPRS traffic arise through the preferred operators.

Telenor Norway, Telenor Denmark, Telenor Sweden and basically applies two methods for steering of roaming traffic: 1. Preferred PLMN list on SIM/USIM (list of preferred operators on SIM/USIM applied when a phone searches for a roaming radio network) 2. SS7 based network traffic redirection (signaling based traffic redirection applied when a customer logs on to a roaming network)

In addition Telenor Denmark and Telenor Sweden applies network barring in HLR for some customer groups.

In general, the customers are not informed about traffic steering. The customers can in most cases override the traffic redirection manually.

Impact on domestic prices

Question 23 : Have you identified any significant effects on domestic prices or changes in an operator's tariff structure for domestic voice calls or other mobile services introduced after or shortly before the entry into force of the Regulation? If so, please explain providing details of the changes in terms of timing, scope and prices.

Telenor answer: No, relevant effects to provide in addition to BEREC analysis . Hypotetically waterbed effect may have had impact on how fast domestic tarrifs have decreased (i.e. less than potensial absent roaming regulation).

Impact on international roaming arrangements with operators in third countries

Question 24 : What, if any, has been the impact of the Regulation on reciprocal roaming arrangements between EU/EEA mobile operators and their counterparts in other third countries?

Question 25 : Have any Community-based providers of mobile roaming services negotiated agreements with third country operators concerning a reduction of wholesale roaming tariffs comparable to those set up in the Regulation?

Telenor answer: In general there has been a negative effect on standard wholesale prices to/from operators in third countries outside of EU/EEA. Many operators inside of EU/EEA increased their standard wholesale rates for operators in countries outside of EU/EEA to compensate for the decreasing inbound revenue due to the regulation. As a response these operators increased their standard wholesale rates towards the operators within EU/EEA. In Telenor for example our Swedish and Danish subsidiaries increased prices whereas Telenor Norway kept prices towards third countries.

Seen from a company outside of the community it could be mentioned that for example our Serbian subsidary since the start of EU Regulation was met with 25% increase in average IOT charged by EU operators. Additionally, our Serbian subsidiary was under pressure from EU operators to decrease wholesale prices substantially through discount negotiations in order to gain their traffic.