MAKING THE TOUGH CALLS Annual Report 2014-15

P.O. Box 56067 – Minto Place RO, Ottawa, ON K1R 7Z1 www.ccts-cprst.ca [email protected] 1-888-221-1687 TTY: 1-877-782-2384 Fax: 1-877-782-2924 CONTENTS

2 CHAIR’S MESSAGE Suspensions Due to Non-Payment Top 25 Participating Service Providers Table 9: Suspensions Due Table 19: Top 25 Participating to Non-Payment Service Providers by COMMISSIONER’S MESSAGE 3 Bundling Discounts: A rising issue Complaints Accepted Table 10: Bundling Discounts Top 10 Participating Service Provider Profiles 4 WHO WE ARE & WHAT by Line of Business WE DO: OUR MANDATE Increase in Internet Complaints List of Participating Service Providers Table 11: Yearly Proportion of Internet Issues 5 OUR COMPLAINTS PROCESS: 34 STATISTICAL REPORTS HOW IT WORKS Table 12: Top 10 Internet Issues Contact Centre Activities The Wireless Code in Focus Out-of-Mandate Issues Additional Considerations Analysis of Closed Complaints 6 THE YEAR IN REVIEW for Future TWC Review Operations Compensation Analysis Regulatory Small Business Complaints CODE OF CONDUCT Governance Performance Standards 21 REPORTING Background 8 2014-15 COMPLAINTS How We Use TWC and the D&D Code 40 REGIONAL ANALYSIS Complaints Definitions The Wireless Code Complaints by Province/Territory Operational Statistics Terminology Complaint Categories by Province/Territory Summary of Leading Complaint Issues Table 13: Summary Table 1: Summary of Leading Issues of TWC Breaches Table 2: Line of Business Table 14: TWC Confirmed CUSTOMER SURVEY RESULTS Breaches by Section 43 Table 3: Categories What Customers Said About CCTS Table 15: TWC Confirmed What Customers Said About Service Breaches by Service Provider Provider Public Awareness Activities 11 TOPICS AND TRENDS The Deposit and Disconnection Code Table 4: Top 10 Issues Table 16: D&D Confirmed Raised in Complaints Breaches by Section 47 WHO WE ARE Non-Disclosure of Contract Terms Table 17: Summary of Board of Directors Table 5: Yearly Proportions D&D Code Breaches CCTS Organizational Chart of Non-Disclosure Table 18: D&D Confirmed Table 6: Non-Disclosure Breaches by Service Provider by Line of Business 50 APPENDIX A 30 days’ Notice to Cancel WORKING WITH PARTICIPATING Table 7: 30 Days’ Notice 26 SERVICE PROVIDERS APPENDIX B by Line of Business 57 Referrals to Investigations Material Change to Good Results from Many Contract without Notice Smaller Service Providers Table 8: Material Contract Change without Notice by Line of Business

CCTS ANNUAL REPORT 2014-15 1 Message from the Chair of the Board of Directors Mary Gusella

CHAIR’S MESSAGE

By the time this Annual Report is released, my term as director and Chair of the Board of CCTS will have come to an end. I was appointed to the Board in June 2008 and at that time was selected to be its first chair. I have been reappointed annually since 2008 and as prescribed by the CCTS By-laws for independent directors, my term of office comes to an end in October 2015.

Following a Canadian Radio-television and Telecommunications The mandate of CCTS has also grown beyond dispute Commission (CRTC) decision in 2007, CCTS was created resolution during recent years. The CRTC, the industry to be a stakeholder-led, industry-funded organization with regulator, asked CCTS to administer two industry codes of independent authority to resolve telecommunications conduct – the Deposit and Disconnection Code (D&D Code) complaints from consumers and small businesses in Canada. in 2012 and the Wireless Code (TWC) in 2013. Earlier this CCTS represents a unique dispute resolution model operating year, the CRTC announced that it intended to develop a in the public interest but outside government processes and Television Service Provider (TVSP) Code of Conduct and without government funding. that it viewed CCTS as the appropriate organization to administer that code as well. The chairing of a stakeholder board holds its special challenges because of the need to continuously balance multiple The CRTC recently completed a public proceeding to conduct interests brought to the table. I am pleased to say that my its second review of CCTS. Following the first review in 2010, Board colleagues and I have successfully established the the CRTC expressed satisfaction with the work done by infrastructure and policies that constitute the foundations for CCTS and expanded the mandate by requiring all telecom CCTS good governance and effective operations. The Board service providers to participate in CCTS. The review is an has developed and approved two strategic plans (2009-2014 accountability and transparency exercise through which all and 2015-2019) to provide CCTS with direction and set stakeholders, including members of the public, are offered the priorities. It has also developed and implemented accountability opportunity to provide their comments on the role, mandate, and oversight mechanisms, including service performance structure, governance and experience of working with CCTS. standards, a director code of conduct and multiple revisions to the By-laws, including major revisions to bring CCTS into In October 2014, the Board welcomed two new directors compliance with the Canada Not-for-profit Corporations Act. appointed by Canadian consumer groups, Jacques C.P. Bellemare and Marina Pavlovic, and conducted a search for In addition to this foundational work, the Board has overseen a new independent director, Catherine Boivie, who will assume the growth of CCTS from a little-known body with a few staff her position In October 2015. members borrowed from other organizations into a healthy and active consumer agency respected for its accomplishments As I leave the Board, I am confident that the organization in dispute resolution and known for its role in highlighting is well equipped to meet the challenges ahead. I thank my consumer issues in the telecom industry. As of July 31, 2015, director colleagues, CCTS management and staff, in particular CCTS had roughly 260 Participating Service Providers (PSPs) the Commissioner, for their support, dedication and hard and brands. In the five years concluding on July 31, 2015, work through the years. I trust that CCTS will continue to CCTS dealt with almost 54,000 complaints. Client feedback meet stakeholder needs for independent and impartial dispute surveys show very high rates of customer satisfaction with the resolution, code of conduct administration and for reporting to service received from CCTS. the public on the consumer issues placed within its mandate.

CCTS ANNUAL REPORT 2014-15 2 Message from the Commissioner Howard Maker

COMMISSIONER’S MESSAGE

I write this while we’re in the midst of the CRTC’s regular review of CCTS. It’s not often that every aspect of an organization is put under the microscope in a public forum. This close scrutiny is accompanied by an invitation for public comment on what we do and how we do it, as well as how we’re structured, how we’re funded, and how far our authority should extend. As a consumer agency with a public interest mandate, we understand the need for – and the benefits that can come from – such an exercise. It also presents an opportunity to do some navel-gazing of our own about our work and how we can do it better.

Looking back at 2014-15, one sees a tumult of activity. On With complaints down for two years in a row, we want to be the regulatory front, in addition to the current review, the certain that customers are aware of CCTS and their right to CRTC expressed an intention to expand our mandate to bring us complaints. We’ve surveyed our customers for years include complaints about television services, supported our to get their feedback on the quality of our service. In 2015-16, interpretation of the disconnection provisions of TWC, and we’ll conduct public polling to determine awareness levels prohibited the use of “30-day cancellation policies” for retail of CCTS, and to compile information about how consumers telecom services, a concern to which we’ve called attention find out about us. This year we took steps to increase our for many years. We also participated actively in a CRTC communications activities by activating our Twitter account proceeding to develop the TVSP Code of Conduct, which the and Facebook page and by holding the first of what we hope Commission plans to develop and wishes us to administer. will be many Twitter Town Hall sessions. And in order to make And in June 2015, when TWC became applicable to all us more accessible, we put in place a web chat service to wireless customers and many expressed interest in switching supplement our online, email and telephone presences. providers, in our role as code administrator we issued a detailed interpretation describing the limited circumstances The year also featured changes within our core. We want to be in which termination fees could be charged to customers an employer of choice, so we conducted our first staff survey taking the opportunity to switch providers, and how those and are in the process of making changes to address some fees should be calculated. of the issues our employees identified. We also conducted a compensation survey, and we made adjustments to ensure Operationally we saw some interesting results. For the our people are compensated fairly and appropriately. second year in a row, complaints declined somewhat. We’re cautiously optimistic that the effectiveness of our process I would be remiss if I failed to note that our founding Chair is helping customers and service providers resolve many and director, Mary Gusella, will be retiring from the Board complaints before they get to us. And for the first time in our in October 2015, after more than seven years’ dedicated history, we recorded a decline in the proportional number of service. I want to thank her for guiding us through sometimes issues arising from wireless complaints – over 60% for the rough waters in pursuit of our objective to make us a world- last four years to approximately 53% this year. Is this a result class provider of dispute resolution services. And I welcome of TWC clarifying rights and responsibilities? How does one Marie Bernard-Meunier, the new CCTS Chair for 2015-16. reconcile this with the large year-over-year increases in TWC I look forward to working closely with her as we continue violations? Those questions are difficult to answer right now, on our charted course. but we’ll keep a close eye on them.

CCTS ANNUAL REPORT 2014-15 3 Who We Are CCTS is an independent organization dedicated to working with & What We Do consumers, small business customers, and participating Canadian telecommunications service providers to resolve complaints relating to most retail telecom services. We strive to assist customers and service providers in an independent, fair, effective, and efficient manner, after direct communications between a customer and a service provider have proven ineffective.

OUR MANDATE

We are able to assist customers with a wide range We are able to assist with most types of of complaints about products and services offered problems that can arise between a customer in the telecommunications sector including: and his or her service provider, including:

CONTRACT DISPUTES LOCAL PHONE for example, disputes about whether there is a contract, what is included in a contract or how the contract should be interpreted, or whether the provider’s conduct meets its contractual obligations, or misunderstandings about the LONG DISTANCE particulars of a contract or term; (including prepaid calling cards) BILLING for example, complaints about customers having agreed to one price and subsequently being charged more, being overcharged due to either WIRELESS a billing system error or a price that is different (including voice, data, and text) than advertised, or about being billed for per-use services which they claim they did not use;

SERVICE DELIVERY for example, complaints about the installation, INTERNET repair or disconnection of service, including the quality of the service or unreasonable interruptions to service and transfers of service from one provider to another; and,

WHITE PAGE DIRECTORIES, DIRECTORY CREDIT MANAGEMENT ASSISTANCE, AND OPERATOR SERVICES for example, complaints about security deposits, payment arrangements and collections treatment of customer accounts.

Please see the Mandate page of our website for full details.

CCTS ANNUAL REPORT 2014-15 4 OUR COMPLAINTS PROCESS: HOW IT WORKS

INSUFFICIENT INFORMATION ASSESSMENT COMPLAINT OUT OF MANDATE Key information missing from CCTS determines whether Complaint outside of mandate complaint. File on hold until complaint is in mandate. and referred to appropriate customer responds. 1 organization when possible.

COMPLAINT RESOLVED COMPLAINT ACCEPTED SERVICE PROVIDER Complaint resolved between Complaint forwarded NOT A CCTS PARTICIPANT customer and provider after to provider, which has CCTS solicits membership CCTS involvement. 2 30 days to respond. within five days of determining the complaint is within mandate.

COMPLAINT RESOLVED RESOLUTION COMPLAINT CLOSED CCTS successfully mediates Complaint remains unresolved. Service provider made a reasonable an informal resolution. CCTS collects information offer or provider clearly met 3 from both parties and attempts its obligations to the customer. informal resolution.

COMPLAINT RESOLVED INVESTIGATION COMPLAINT CLOSED Analysis of evidence Complaint remains Analysis of evidence demonstrates facilitates resolution unresolved. CCTS analyzes provider met its obligation or of complaint. 4 evidence provided. reasonable offer is made.

RECOMMENDATION RECOMMENDATION ACCEPTED Complaint cannot be resolved Both customer and and no basis for closure. CCTS service provider 5 issues Recommendation accept Recommendation. to parties proposing resolution.

DECISION ACCEPTED DECISION DECISION REJECTED Customer accepts Decision One or both parties rejects Customer rejects Decision and is free and service provider is bound the Recommendation. to pursue other remedies. Service to implement its terms. 6 CCTS issues a Decision. provider released from Decision.

Please see the Complaints Process page of our website for full details.

CCTS ANNUAL REPORT 2014-15 5 THE YEAR IN REVIEW This section provides a brief summary of the highlights of 2014-15.

explained that in our view this was an impediment to the public Operations policy objective of allowing customers to switch providers easily, 1. FIRST MID-YEAR REPORT – our first-ever Mid-Year because it frequently required them to pay two companies for up to Report was released in April. The Report was designed to a month, when only one was actually providing service. We noted in provide more frequent reporting of data and greater transparency last year’s Report that some service providers had voluntarily done and insight into our operations; away with this practice. In November 2014, the CRTC prohibited this practice effective January 23, 2015, for local phone, internet 2. JUNE 3, 2015 – on this date TWC became fully and TV services. TWC already prohibited it for wireless services; applicable to all Canadian wireless customers. This meant an 4. CRTC SUPPORTS CCTS INTERPRETATION OF end to three-year contracts. But the Code didn’t specify how TWC DISCONNECTION PROVISIONS this change would impact customers seeking to cancel service. – TWC requires We issued detailed guidance to assist consumers and service wireless providers to give advance notice to customers they providers with this transition; intend to disconnect for non-payment. In many complaints, we saw wireless providers interrupt service but not provide notice. 3. WEB CHAT – in February 2015, we introduced a web chat They explained that in their view they didn’t have to give notice service in order to make us more accessible to Canadians, in because the customers’ service was not being “disconnected”, particular those who prefer to communicate online rather than by merely “suspended”. In our opinion, the notice obligation applied phone, email or mail/fax. A web chat can be initiated from almost to any interruption of service for non-payment, no matter how the any page on our website. service provider characterized it. In those cases we recorded these as breaches of TWC. Rogers filed an application with the CRTC, supported by a number of other wireless providers, to challenge our interpretation. The CRTC supported our decision, clarifying that Regulatory disconnection rules apply to service suspensions that are part of 1. CRTC FIVE YEAR REVIEW – Our accountability is the process possibly leading to disconnection for non-payment. ensured through periodic public reviews by the CRTC of our The CRTC clarified that the notice requirements “…apply in all governance, structure, mandate and operations. The first such instances before a disconnection, and in the first instance of a review took place in 2010. The CRTC launched the 2015 review in suspension in a disconnection cycle.” June. It included a public consultation and a hearing in November 2015. All documents filed in the proceeding are publicly available; Governance 2. CRTC TAPS CCTS AS OMBUDSMAN FOR TV SERVICE COMPLAINTS – in October 2013, the In October 2014, Canadian consumer groups appointed CRTC launched “Let’s Talk TV: A Conversation with Canadians”, Jacques C.P. Bellemare and Marina Pavlovic as their a public proceeding in which it reviewed all aspects of TV services two representatives on the CCTS Board. in Canada. In April 2014, it initiated Phase 3 of the proceeding, in which it examined numerous issues, including whether there In October 2015, the term of office of Mary Gusella expired. should be TVSP Code of Conduct and whether it would be Ms. Gusella was appointed to the Board in June 2008, and she desirable to put in place an industry ombudsman like CCTS to was appointed by her fellow directors as our first Board Chair. address complaints about TV services. In March 2015, the CRTC She was reappointed as Chair each year since. However, with the decided it would create a TVSP Code of Conduct and we would expiry of her term, she has left our Board. We owe her a debt of be the appropriate ombudsman and administrator of the Code; gratitude for her stewardship over the years.

3. CRTC PROHIBITS 30-DAY CANCELLATION Her role as Board Chair will be assumed by Marie Bernard-Meunier, FEES – In each CCTS Annual Report from 2009-10 to 2013-14, who also became a director in June 2008. In October 2015, we expressed concerns about many service providers requiring the Board appointed Catherine Boivie to assume the vacant their customers to provide 30 days’ notice to cancel a service. We director position. CCTS ANNUAL REPORT 2014-15 6 Highlights of 2014-15 The Year in Review

Resolution 582 7, 294 Rate TWC breaches up from 30 to 5821 Out of Scope issues related to TV up 87% from 3,496 Complaints down (109% increase) 12%

Decisions and Recommendations up from 8 44 (450% increase)

Contact Centre phone calls up by 6%

1 2013-14 numbers were from December to July; 2014-15 numbers include 422 breaches by one wireless service provider that had some systemic problems. CCTS ANNUAL REPORT 2014-15 7 2 0 1 4 - 1 5 COMPLAINTS In this section you will find our primary operational statistics, and the highlights of the main issues presented in the complaints we saw. Later in this Report you will find a section containing various detailed statistics.

Complaints Definitions

In order to fully understand the data being provided, familiarity with our terminology is essential.

COMPLAINT: In many cases, complaints are closed after the service provider A customer complaint that we have received, reviewed has corrected the problem and provided the customer with some and found to be within our mandate. form of compensation. See our Analysis of Closed Complaints report for further information. OUT OF MANDATE: RECOMMENDATION: Complaints about products, services or issues that we cannot investigate are considered to be “out of mandate.” See our The complaint was fully investigated. Often, the service Procedural Code for more details. provider has not made an offer to informally resolve the complaint, or the offer is not found to be reasonable in light of the specific circumstances of the complaint. We will make RESOLVED: a Recommendation requesting that the provider take specific The complaint was informally resolved with the assistance of actions to resolve the matter. a CCTS team member, to the satisfaction of both the customer and the participating service provider. DECISION: A Decision is issued if either the customer or the service CLOSED: provider rejects the Recommendation. The party rejecting The complaint was fully investigated and subsequently closed. the Recommendation must set out its reasons and the A complaint may be closed for different reasons, including: Commissioner will reconsider the Recommendation and issue a Decision. The Commissioner may confirm the original • The service provider has made an offer to resolve the Recommendation or, if the Commissioner concludes that there is complaint that we think is fair and reasonable in light of the substantial doubt as to the correctness of the Recommendation, specific circumstances of the complaint; the Commissioner may modify the Recommendation as • The complaint was found to be without merit; appropriate. A Decision is binding on the service provider, but not on the customer. The customer may reject it and • After filing the complaint, the customer either withdrew it pursue other remedies. or failed to provide the information we needed to conduct our investigation; or

• The complaint should more properly be brought before another agency, tribunal or court.

CCTS ANNUAL REPORT 2014-15 8 2014-15 Complaints

Operational Statistics

2014-15 2013-14 2012-13

Complaints 9,988 11,340 13,692 accepted

Complaints 10,238 11,196 14,036 concluded

TOTAL COMPLAINTS RESOLVED 8,894 9,754 12,723

Complaints resolved 6,952 7,440 8,690 at Pre-Investigation

Complaints resolved 1,942 2,314 4,033 at Investigation

TOTAL COMPLAINTS CLOSED 1,300 1,434 1,264

Complaints closed 534 610 539 at Pre-Investigation

Complaints closed 766 824 725 at Investigation

Recommendations accepted 36 7 41

Decisions issued 8 1 8

CCTS ANNUAL REPORT 2014-15 9 2014-15 Complaints

Summary of Leading Complaint Issues

In this section, you’ll find a snapshot of the broad categories into which complaints fell this year, as well as the lines of business that generated them. Once again, billing problems accounted for by far the largest number of issues raised in complaints, and customers complained about their wireless services more than any other. However, as mentioned in our Year in Review section, 2014-15 saw the first decrease in the proportion of issues raised by wireless service customers – they were down by seven per cent.

TABLE 1: SUMMARY OF LEADING ISSUES

Billing Contract dispute Service delivery Credit management Total Wireless 4,345 3,557 1,756 556 10,214 Internet 2,203 1,385 1,323 134 5,045 Local phone 1,510 947 938 126 3,521 Long distance 311 97 107 19 534 Directory assistance 6 – – – 6 White page directories 3 2 – – 5 Operator services 1 – – – 1 TOTAL 8,379 5,988 4,124 835 19,326

TABLE 2: LINE OF BUSINESS TABLE 3: CATEGORIES

60% 52.9% 60% 50% 50% 43.4%

40% 40% 31.0% 30% 26.1% 30% 21.3% 20% 18.2% 20%

10% 10% 4.3% 0% 2.8% 0% 0% 0% 0%

Wireless Directory assistance Billing Internet White page directories Contract dispute Local Phone Operator services Service delivery Long Distance Credit management

CCTS ANNUAL REPORT 2014-15 10 TOPICS AND TRENDS Each year, we write about some of the trends we saw while investigating complaints. Our goal is to highlight areas in which service providers could improve their practices and avoid complaints, and to inform and educate consumers about these trends.

SECTION CONTENT Non-Disclosure 12 Material Change to 14 Bundling Discounts: 17 The Wireless Code 18 of Contract Terms Contract without Notice A rising issue in Focus

30 Days’ Notice 14 Suspensions Due 15 Increase in 17 Additional Considerations 20 to Cancel to Non-Payment Internet Complaints for Future TWC Review

TABLE 4: TOP 10 ISSUES RAISED IN COMPLAINTS

2014-15 2013-14

Number % of total Number % of total % change Issues raised in complaints of issues issues of issues issues Y/Y 1 Non-disclosure of terms/ 2,475 12.8% 1,686 10.1% 46.8% Misleading information about terms

2 Incorrect charge 2,314 12.0% 1,854 11.1% 24.8%

3 Legitimacy and amount of ECF 1,284 6.6% 1,144 6.8% 12.2%

4 Intermittent/Inadequate quality of service 1,273 6.6% 1,250 7.5% 1.8%

5 30-day cancellation policy 963 5.0% 1,167 7.0 % -17.5%

6 Credit/Refund not received 932 4.8% 671 4.0% 38.9%

7 Credit reporting 704 3.6% 569 3.4% 23.7%

8 Data charges 679 3.5% 575 3.4% 18.1%

9 Breach of contract 515 2.7% 400 2.4% 28.8%

10 Material contract change without notice 487 2.5% 199 1.2% 144.7%

CCTS ANNUAL REPORT 2014-15 11 For the year 2014-15 Topics and Trends

This year, we discuss some of the issues that customers TABLE 5: YEARLY PROPORTIONS OF NON-DISCLOSURE raised most often, such as non-disclosure of contract terms, incorrect charges, and the amount and legitimacy of early 14.0% cancellation fees (ECFs). 12.0% 12.8% 10.0% Customers continue to raise some of these issues in spite of the 10.1% 8.0% fact that we urged the industry to develop a solution in previous Annual Reports. Other issues represent new or emerging 6.0% 4.0% 5.0% trends. Over the last couple of years, there’s been a number 4.7% of changes brought about by the industry regulator that, in our 2.0% view, potentially impacted these trends. These changes include 0.0% prohibiting service providers from requiring 30 days’ notice to cancel service, as well as the full application of TWC to all 2011-12 2012-13 2013-14 2014-15 consumers, regardless of when they entered into a contract.

Sometimes these changes can result in heightened consumer And since 2011, when we first began providing a detailed analysis awareness that leads to an increase in complaints raising certain of issues raised in complaints, non-disclosure of information or issues. Other times, they can result in increased awareness misleading contract terms has increased by 342%. Wireless among service providers, which may review their practices and is still the service about which this issue is raised most often. make positive changes that lead to a reduction in complaints. Interestingly, however, wireless complaints involving non-disclosure are actually decreasing – from 72% in 2013-14 to 60% in 2014-15. Below, we discuss some of these issues, including those that It’s hard to say what exactly is driving that change, but we’ll are recurring, those that are newly emerging and those in which continue to monitor the statistics. positive changes seem to be taking place. TABLE 6: NON-DISCLOSURE BY LINE OF BUSINESS

Non-Disclosure 2014-15 2013-14 % of Contract Terms Line of Number % of Number % of change business of issues issue of issues issue Y/Y Ensuring customers are well-informed about the services and products they agree to buy is vital in delivering a positive consumer Wireless 1,485 60.0% 1,220 72.4% 21.7% experience. To that end, we’ve discussed the importance of Internet 588 23.8% 235 13.9% 150.2% clearly and fully disclosing important information to customers in previous Annual Reports. Case studies often highlight the Local 352 14.2% 188 11.1% 87.2% impacts of not disclosing key information that might’ve avoided a phone complaint. Nonetheless, consumers raised concerns relating to the non-disclosure of information, or about “misleading Terms and Long 48 1.9% 42 2.5% 14.3% Conditions”, almost 2,500 times in 2014-15. Clearly, the problem distance persists. Whereas it accounted for just over 10% of all issues in 2013-14, it now represents almost 13%. White page 2 0.1% – – – directories

TOTAL 2,475 100% 1,685 100% 46.9%

CCTS ANNUAL REPORT 2014-15 12 For the year 2014-15 Topics and Trends

Case Study #1 – Disclosure Case Study #2 – No Limits of Terms and Conditions Related We received roughly 80 complaints from the customers of to Prepaid Balance a wireless service provider. These customers signed up for a plan We received 17 complaints from the customers of a service that included unlimited talk, text and data in Canada and unlimited provider offering prepaid mobile services. These customers roaming from anywhere in the U.S. for a flat monthly rate. Many of signed up for a prepaid account but soon decided to switch these customers travelled regularly to the U.S. and made frequent companies. Since they prepaid for a service that they weren’t use of their devices while travelling. Many of them suddenly found going to use, they asked their provider to refund the balance, themselves without service, having received no warning from the which, depending on the customer, was somewhere between provider. The company informed these customers that their service $25 and $40. The provider said its Terms and Conditions state had been suspended due to “excessive usage” in contravention of the circumstances under which prepaid balances would be its Fair Use Policy. Some customers were even charged “overage refunded, and moving to another provider wasn’t one of them. fees” for their use. Unsatisfied with the provider’s explanation, these customers complained to us, stating that they were never made Many of these customers told us they weren’t made aware of aware that the use of their service, advertised and sold to them this policy and weren’t satisfied with their provider’s response. as “unlimited”, actually had a limit. We found that the provider’s Terms and Conditions didn’t oblige a refund when customers move to a competitor. The provider told us its Fair Use Policy allowed it to suspend accounts if customers made excessive use of the service. TWC But the customers complained because they weren’t made doesn’t allow a provider to limit the use of a service purchased aware of this policy. Had they been aware, some of them on an unlimited basis, unless these limits are clearly explained wouldn’t have moved until making full use of their prepaid in the Fair Use Policy. Also, a customer’s contract must clearly balance. TWC requires service providers to inform the customer set out the services included, along with any limits that could of all conditions and fees that apply to the prepaid balance, but trigger overage charges. We reviewed the customers’ contracts when we asked the provider to demonstrate that it made its to see if there was a limit on service and found no such limit was customers aware of its Terms and Conditions, in particular those disclosed to customers who signed up for the service. Our review detailing refunds of prepaid balances, the provider was unable of the Fair Use Policy also didn’t find any mention of a limit. to do so. After our involvement, the company offered to refund each customer their prepaid account balance and the complaints While attempting to resolve these complaints, we reached out were resolved accordingly. to the provider a number of times. Initially, we got nowhere. Thirty-five complaints went to the Investigations stage of our process. Twenty-five went as far as Recommendation.

After sustained effort, however, we were able to connect with a senior representative of the company. This individual was receptive to our feedback, and we discussed at length a solution to the situation. As a result, the provider updated its Fair Use Policy to clearly disclose the limits. It also disclosed limits to data use directly in the Critical Information Summary given to customers both at the point of sale and on the company’s website.

The provider’s offering of unlimited service did in fact have limits – but they weren’t disclosed. What’s more, the limits fluctuated based on how much usage the network experienced at a given time. It was therefore impossible for customers to know the limit, plan for it, and avoid overage charges. TWC doesn’t prohibit limiting services. What it prohibits is the non-disclosure of such limits. This isn’t a new problem. In fact, we’ve discussed it in a previous Annual Report and are therefore surprised to see it persist. We strongly encourage the industry to review its practices and ensure they comply with TWC.

CCTS ANNUAL REPORT 2014-15 13 For the year 2014-15 Topics and Trends

30 Days’ Notice to Cancel Material Change to

Over the years, we’ve received many complaints about this issue. Contract without Notice It was a topic we identified, many times, as problematic and in need of an industry-driven solution. Last year, we were pleased In last year’s Annual Report, we talked about some of the to finally report that the number of times customers raised this complaints we received from customers who claimed that their issue decreased, and this year we’re reporting another decrease service provider had changed a material term in their contract of 17.5%. When it comes to wireless services in particular, we without providing notice. When it came to wireless services, we saw a 46% decrease, which isn’t surprising given that TWC saw a 72% increase of this issue in 2014-15. If we consider all bans the practice. lines of business, it was raised 145% more often than the year before. Regarding internet complaints only, the increase was Notwithstanding these positive gains, internet and home phone more than 400%. customers are raising this issue more often, as highlighted in the table below. This is surprising, given that the CRTC prohibited this TABLE 8: MATERIAL CONTRACT CHANGE practice for internet, home phone and cable services effective WITHOUT NOTICE BY LINE OF BUSINESS January 23, 2015. We’re cautiously optimistic that as time goes on, we’ll see industry practice conform to the prohibition. 2014-15 2013-14 % Line of Number % of Number % of change TABLE 7: 30 DAYS’ NOTICE BY LINE OF BUSINESS business of issues issue of issues issue Y/Y

2014-15 2013-14 Wireless 227 46.6% 132 66.3% 72.0% % Line of Number % of Number % of change Internet 192 39.4% 38 19.1% 405.3% business of issues issue of issues issue Y/Y Local 55 11.3% 23 11.6% 139.1% Wireless 451 46.8% 834 71.5% -45.9% phone

Internet 258 26.8% 165 14.1% 56.4% Long 13 2.7% 6 3.0% 116.7% distance Local 248 25.8% 163 14.0% 52.1% phone TOTAL 487 100% 199 100% 144.7% Long 6 0.6% 5 0.4% 20.0% distance Case Study #4 – Giving Proper Notice TOTAL 963 100% 1,167 100% -17.5% In April 2013, a home phone customer agreed to service for $49 per month, signing a three-year contract. A few months later, she noticed her monthly rate had increased slightly. When Case Study #3 – No Policy for 30 Days she complained to her service provider, it told her that her A customer subscribed to internet and home phone monthly rate plan had increased by 10% since she contracted service. She became dissatisfied and cancelled it, opting to do the service. Unsatisfied with the explanation, she complained to business with a competitor instead. The customer’s initial service us. After reviewing the provider’s Terms of Service, we found it provider billed her for an additional 30 days’ service, which later was permitted to change the price for home phone service so it told her was in accordance with its policy. After the customer long as it gave the customer advance notice. We found that such submitted her complaint, we discussed this matter with the notice was indeed given to this customer, but it didn’t contain provider, identifying the CRTC’s prohibition of this practice. The the correct information about the amount of the rate increase. complaint was informally resolved when the provider agreed to When we brought this to the attention of the provider, it credited credit the charges. the disputed amount. The customer was satisfied, and the complaint was resolved.

CCTS ANNUAL REPORT 2014-15 14 For the year 2014-15 Topics and Trends

Case Study #5 – Plans May Change, Suspensions Due but Customers Need to Know In another complaint, an internet customer asked her provider to Non-Payment to move her service to a new address effective January 1. She Compared to last year, the number of times that customers subsequently called to ask that the reconnection be postponed raised issues related to the suspension of their service due to until January 16. She confirmed that the service at her old home non-payment of invoices increased by over 60%. still needed to be cancelled, and her provider did as requested, reconnecting service at the new address on January 16. And, as demonstrated in the table below, wireless customers However, when the customer received her bill, she noticed that raised this issue the most. Overall, it was raised 428 times, 62.1% her monthly charge was about $10 more than it was prior to of the time by wireless customers. her move. Unable to obtain a satisfactory response from her provider, she complained to us. TABLE 9: SUSPENSIONS DUE TO NON-PAYMENT

The provider told us the customer previously had a 2014-15 2013-14 “grandfathered” plan, meaning it wasn’t available to new % customers. When it disconnected her service and reconnected Line of Number % of Number % of change it at the new location two weeks later, it technically activated a business of issues issue of issues issue Y/Y new service. Since the customer was starting a new service, her grandfathered plan couldn’t be put back onto her account, Wireless 266 62.1% 166 62.4% 60.2% because it was no longer available. The provider, which Internet 82 19.2% 52 19.5% 57.7% “resells” internet service to its customers, said it didn’t have the mechanism to simply postpone reconnection at the new location. Local 71 16.6% 45 16.9% 57.8 % It had no other choice but to completely cancel service at her phone old location, then reconnect a new service at the new address. However, it also explained that its policy is to inform customers Long 9 2.1% 3 1.1% 200.0% of this, so that they’re aware that they will not be able to continue distance with their grandfathered plan. In this case, the provider failed to do so. As such, it offered the customer two weeks of free service TOTAL 428 100% 266 100% 60.9% and an additional monthly credit of $10 for the next eight months. During 2014-15, we also received 209 complaints from wireless The customer rejected the offer, insisting the provider reinstate customers telling us that their service was disconnected without her old plan. We closed the complaint, as, in our opinion, notice. TWC requires that service providers give customers the provider offered a reasonable resolution. In our view, the notice at least 14 calendar days before disconnection and, in customer’s monthly plan, even when grandfathered, can be many cases, again 24 hours before. In many of the complaints increased upon notice, further to the provider’s Terms of Service. we investigated, we found that the provider hadn’t given the It’s not guaranteed the plan will remain unchanged for an customer the notice required by the Code. When we discussed indefinite period of time. this with a particular provider, it told us that, in its view, it wasn’t required to provide notice because it hadn’t disconnected the customers’ service. Rather, it had “suspended” it, which it claimed wasn’t the same as a disconnection. We advised the provider that the intent of TWC provisions surrounding notification before disconnection is to ensure that customers didn’t find themselves without service, without notice, without first being given an opportunity to redress their default. We provided our view that from the customers’ perspectives, the result is the same whether the service is technically “suspended” or “disconnected” – they don’t have service.

CCTS ANNUAL REPORT 2014-15 15 For the year 2014-15 Topics and Trends

One service provider didn’t agree with our interpretation and filed Case Study #8 – an application to the CRTC seeking clarification. On August 14, the Stick to the Payment Plan CRTC issued its Decision and confirmed that the disconnection Another customer made arrangements with his provider to pay rules apply before the first suspension in a disconnection cycle. down his overdue wireless account, which had been in arrears, That is, if the suspension of service is part of the “disconnection on and off, for roughly nine months. When he complained to us, cycle” (i.e. part of the process of potentially disconnecting a he claimed his provider disconnected his service without giving customer’s service) then the TWC notification requirements apply. notice. But when we looked into the matter, we found that notice Wireless customers, however, weren’t the only ones who had indeed been provided, which is what prompted the customer complained about a provider suspending/disconnecting their service. to commit to payment arrangements. When the customer didn’t make his payments, the provider didn’t issue another notice, Case Study #6 – “But I Paid the which the customer claimed it was required to do. We explained to the customer that TWC doesn’t require providers to give Undisputed Portion of My Bill.” customers additional notice prior to disconnection in the wake A small business local phone customer called his service provider of failed payment arrangements. Only the initial notice, prior to to dispute $3,000 in long distance charges, claiming he didn’t entering into the payment arrangement, is required. We therefore make the calls. The provider informed him that the calls came closed this complaint. from his office, but it didn’t give any evidence or documentation to support this assertion. The customer continued to dispute the Since then, the CRTC issued its Decision providing additional charges, but paid the undisputed portion of his bill. Nonetheless, clarification surrounding the notification before disconnection the provider disconnected his service without notice. This requirements in TWC, as discussed on page six. In it, the complaint is concerning because, in our view, it’s not appropriate CRTC explains that “a customer’s agreement to a promise-to-pay to disconnect a customer who’s disputing charges while still arrangement should be considered sufficient notice of further paying the undisputed portion of his bill. In this case, potential suspensions in a single disconnection cycle”. the provider reconnected the service without charge.

Had this been a residential customer, the D&D Code would’ve applied. It prohibits the disconnection of a residential customer’s service if that customer is paying the undisputed portion of his bill.

Although in some cases we found that service providers didn’t meet their obligations, we also saw cases in which they did. We discuss some of these complaints below.

Case Study #7 – Two Business Days to Process A home phone service provider notified its customer that her payment was overdue. The customer called and agreed to pay $100 immediately, with the remainder to come within one week. However, the customer waited until two days prior to the due date, despite the fact her bank said the transaction would take at least two business days to process. Consequently, the provider wasn’t paid on time, and it disconnected her service.

The provider and customer both supplied us with documentation demonstrating the customer knew, or should have known, when full payment was expected and that a processing delay would occur. The service provider therefore had grounds to disconnect the service for non-payment.

CCTS ANNUAL REPORT 2014-15 16 For the year 2014-15 Topics and Trends

changes to promotional discounts such as these. We reviewed Bundling Discounts: the provider’s terms and indeed they did permit it to change the A rising issue amount of a promotional discount without notice if the customer didn’t have a fixed-term contract, and with 30 days’ notice if a This year, we noticed a surge in complaints that took issue contract was in play. In this customer’s case, he’d agreed to a fixed- with bundling discounts, many of which were related to internet term contract, so we asked the service provider to demonstrate services. In our view, many of these complaints could’ve been that it provided the requisite 30 days’ notice. Our investigation avoided had they been properly addressed by the customer’s allowed us to conclude that the service provider did indeed give the provider. Overall, the issue was raised more than 200 times. customer 30 days’ notice, so we closed the complaint. Compared to last year, this is an increase of over 130%.

TABLE 10: BUNDLING DISCOUNTS Increase in Internet Complaints BY LINE OF BUSINESS Every year, customers contact us with complaints related to their 2014-15 2013-14 internet service. However, in 2014-15, customers raised concerns % about internet service 52% more often than the previous year. And Line of Number % of Number % of change the proportion of all issues raised that relate to internet is increasing of issues issue of issues issue business Y/Y year-over-year. It now accounts for 26% of all issues raised. Internet 109 47.0% 42 42.4% 159.5% TABLE 11: YEARLY PROPORTION OF INTERNET ISSUES Local 94 40.5% 43 43.4% 118.6% phone 30%

Wireless 28 12.1% 11 11.1% 154.5% 25% 26% Long 1 0.4% 3 3.0% -66.7% 20% distance 20% 19% 18% TOTAL 232 100% 99 100% 134.3% 15%

10%

Case Study #9 – Credits Not Applied 2011-12 2012-13 2013-14 2014-15 A customer signed up for home phone, internet and TV services and was supposed to pay approximately $100 per month for the bundle. He complained to us because his provider We analyzed some of these complaints to better understand failed to apply credits he was promised as a result of bundling what drove them. We found that most were about the billing of his services. We found that the service provider indeed failed to monthly internet plans. In many cases, customers complained apply the three months of credits. The complaint was informally because they felt they’d been overbilled. Others complained resolved when the provider agreed to apply them. because they believed their provider increased their monthly price either without notice or in contravention of an agreement. Case Study #10 – Clear Terms of Service In 2014-15, internet customers raised concerns about the Another customer signed up for home phone and monthly billing of their internet service over 900 times. In addition, internet service, and the provider promised an they raised concerns almost 600 times about non-disclosure of $8 monthly credit for bundling his services. A few months later, the terms/misleading information. customer noticed that his credit was reduced to $6 per month. He made a complaint because he was unsatisfied with his provider’s response, which was that its Terms of Service allowed it to make

CCTS ANNUAL REPORT 2014-15 17 For the year 2014-15 Topics and Trends

TABLE 12: TOP 10 INTERNET ISSUES Case Study #12 – A Quick Eight Years In 2014-15, we also received over 250 complaints from Number Proportion of all the customers of a particular provider that increased the price of Issue of issues internet issues its monthly internet plans, allegedly in contravention of its Terms and Conditions. These customers told us that they’d been offered Incorrect charge 918 18.2% an internet plan for $45 per month, including 300 GB of data and Non-disclosure of terms/ “price protection” that guaranteed the monthly price wouldn’t Misleading information 588 11.7% increase for eight years. Many of them complained to us when about terms they received their monthly invoices and noticed that their rate had increased by $3 per month. We discussed these concerns with the Intermittent/Inadequate 444 8.8% service provider, which informed us that this plan was supposed quality of service to include 200GB of data but that certain of its employees had mistakenly included 300 GB of data instead. As such, some 30-day cancellation policy 258 5.1% customers received an invoice for data usage over 200 GB. Credit/Refund not received 249 4.9% To resolve these complaints, the provider credited the equivalent Material contract change of the additional charges billed to those customers. Customers 192 3.8% without notice who required more than 200GB were allowed to cancel their service without penalty. Bandwidth usage 182 3.6% Unable to cancel 174 3.4% The Wireless Code in Focus Customer cancellation due 171 3.4% date not kept/delayed As we discussed in last year’s Annual Report, it’s not surprising that we encounter instances in which we must interpret how Legitimacy of ECF 163 3.2% provisions of TWC apply in the context of a specific complaint. This continued in 2014-15, as we saw more scenarios with Below we discuss some of the internet service complaints we implications related to TWC. saw this year. SO WHO’S THE CUSTOMER? Case Study #11 – Overbilling Section E of TWC requires wireless providers to cap a An internet customer obtained service for $66 per month, customer’s data overage charges once they reach $50, and with unlimited usage. A few months later the customer roaming charges at $100, in any bill cycle. TWC allows additional reviewed his bill and noticed that he’d actually been billed about data or roaming charges to be billed if “the customer expressly $140 per month. He contacted his provider, but the matter consents”. TWC defines “customers” as “individuals or small remained unresolved, so he complained to us. We obtained a businesses subscribing to retail mobile wireless services”. recording of the call between the customer and the provider during The purpose of this requirement is to prevent “bill shock”2. This which they discussed the monthly price plan. We found that the can be a concern for any wireless user, but is especially troubling service provider had indeed advised the customer that his internet for customers with plans in which multiple users share services service would cost him $66 per month. As such, we found that (particularly data, which is the most costly service). There are many the provider overbilled the customer by $74 per month for the last such plans in the marketplace, particularly “family share plans” three months, for a total of $222. When we discussed this with and plans for small business. These account holders need to be the provider, it offered to apply a credit of $250 to the customer’s able to manage and control the cost of their plans. Obviously the account, which we believed to be satisfactory. account holder can’t know what each and every user is doing on their device at all times. As we look at the way in which many wireless providers seek the customer’s consent to incur additional charges for multi-user plans, we are concerned that their approach doesn’t meet the objectives of TWC.

2 Telecom Regulatory Policy 2013-271, para.113: The Commission recognizes that bill shock is a serious problem for all consumers. When a consumer receives a bill that is unexpectedly many times greater than their normal monthly bill, it can be a source of considerable concern.

CCTS ANNUAL REPORT 2014-15 18 For the year 2014-15 Topics and Trends

Let’s say a family has two parents and two children sharing Case Study #13 – Calling for an allotment of data. It’s clear from TWC that the person(s) a Clear and Present Calculation subscribing to the service is the account holder, which in the The Code clearly requires disclosure of the subsidy, and it CRTC’s words, is the customer, the person who subscribed for also requires that the disclosure be made in plain language. the service and who’s ultimately responsible for paying the bill. As Notwithstanding that requirement, we still received a number of the users consume the pool of data and approach the limit, most complaints from the customers of one provider because they service providers send a text message (“the notice”) advising were billed an ECF, even though their contracts indicated that that the recipient is approaching or has reached the maximum, they’d received an “economic inducement” of $0 for their device. and asking if the recipient agrees to incur additional charges for They claimed their service provider insisted they pay these fees, the service. The problem with this approach is that the notice which ranged between $275 and $375, because they were goes to the device consuming the service at the time the limit is cancelling service early. But we found it nearly impossible for reached, not necessarily to the device of “the customer”, i.e. the customers to accurately determine if a device subsidy had been account holder, who this provision is supposed to protect. In the provided and what the amount might be. This is because the case of the family plan, the notice may go to one of the children, contracts were drafted in a manner that didn’t clearly identify who may not be of legal age and may have no authority on the these details. The contracts said that an “economic inducement” account. In a small business situation, the notice may go to one of of $0 had been provided. However, elsewhere, the contract the employees who, like the children, has no authority to give the stated that there had been “additional economic inducements”, provider instructions related to the account. which together with the “economic inducement” of $0 resulted We have concluded that we must interpret TWC as requiring that in the “total economic inducement”. The “total economic the notice be given to the account holder – the customer, the inducement”, the contract seems to suggest, would then be person who subscribed to the service. In our view this is the only reduced from the “no term pricing” in order to calculate the way to make sense of TWC’s intent (to prevent bill shock) in the hardware charge. We struggled to understand what this meant context of multi-user plans. We recognize that this interpretation in relation to the calculation of an ECF. The use of so many may pose significant inconvenience to those wireless providers different terms and how they impact each other was confusing that don’t follow this practice, as they may be required to make and difficult to understand. Adding to this confusion was that system changes. But this interpretation is necessary to ensure that none of these terms seemed to be defined. the implementation of the TWC requirement matches the intent of As a result, the customers could not possibly have known what the CRTC and satisfies the policy objective. their ECFs would have been, as they were not properly identified in their contracts, contrary to TWC requirements to clearly state HOW MUCH IS MY DEVICE SUBSIDY? this information. Subsequent to our intervention, the provider Many customers contact us because they want to understand offered to credit the fees. The customers were happy and the if they’ll have to pay an ECF to cancel their service. If an ECF is complaints were resolved. applicable, the amount owing depends on a number of factors, including whether a customer received a device subsidy and the value of that subsidy. We discuss this further in our May 27, 2015, news release found here. The lack of clarity created confusion as to whether or not there was an ECF and how much it should be. Service providers therefore need to ensure that they fully inform Because TWC requires contracts be written in plain their customers of whether a device subsidy is being provided, language, this lack of clarity put the service provider as well as the amount of the subsidy. Not only is this a TWC at risk of breaching its requirements under the Code. requirement, but it’s necessary to demonstrate that a device After we reached out to the service provider, it improved subsidy was indeed provided in order to calculate the resulting ECF the language in its contracts. the provider is entitled to recover should the customer cancel early.

CCTS ANNUAL REPORT 2014-15 19 For the year 2014-15 Topics and Trends

As discussed earlier in this report, some customers complained Additional Considerations they didn’t receive disclosure of the Terms and Conditions related for Future TWC Review to their prepaid balance. In another complaint, the customer said he agreed to a monthly price plan, but the provider charged Over the course of the year, we processed a large number of him something else. The provider couldn’t demonstrate what complaints with issues related to TWC. We’ve underlined some the customer agreed to, claiming it doesn’t provide prepaid of the most significant issues elsewhere in this report. Here, account customers with a written contract – all they get are we’d like to draw attention to some emerging concerns of which Terms and Conditions. The problem is those Terms and stakeholders may want to take note. Conditions don’t specifically outline how much the customer has to pay on a monthly basis. PREPAID ACCOUNTS VERSUS PREPAID CARDS We don’t think it was the Commission’s intention to exclude prepaid-account customers from the benefit of full disclosure. When TWC first came out, the emphasis was on providing However, since TWC doesn’t explicitly state prepaid account protections for postpaid service customers because they’re customers must get a written contract or document outlining the ones most susceptible to bill shock. However, there are the terms of the agreement, some providers aren’t furnishing some provisions that apply to prepaid services, and the CRTC customers with that information. We think this is something that explained its logic and rationale in TRP 2013-271. should be considered in the CRTC’s review of TWC in 2016. We’ve seen service providers offer two types of prepaid services – prepaid accounts and prepaid cards. With prepaid REMINDER TO CONSUMERS cards, the customer knows how much is on the card and the ABOUT TRIAL PERIODS amount of time they have to use it. TWC requires providers to disclose to customers the limits and amount of usage permitted by their trial period (sometimes called But we’ve started to receive complaints about prepaid accounts. a buyer’s remorse policy). However, providers are at liberty to Prepaid accounts are different in that customers don’t have to determine the details of their policies, most of which restrict trial top up their cards, but rather prepay automatically for services usage to between 15 and 30 minutes, or seven and 15 days, on a monthly basis. We haven’t seen many complaints about this, whichever comes first. Our advice to customers is to make sure but it seems that some customers aren’t receiving disclosure of that they know and understand the limits of their provider’s the details they agreed to at the point of sale. buyer’s remorse policy and that they test their new devices thoroughly within those limits.

CCTS ANNUAL REPORT 2014-15 20 CODE OF CONDUCT REPORTING

SECTION CONTENT Background 21 How We Use TWC 21 The Wireless Code 22 The Deposit and 25 and the D&D Code Disconnection Code Terminology 22

Background How We Use TWC

We’re responsible for administering two codes of conduct and the D&D Code developed by the CRTC: All complaints go through the same complaint-handling process • TWC, which applies to consumer and small business described here. Our staff study complaints in which the customer wireless services; and alleges, or we suspect, issues of non-compliance with either Code (“alleged breaches”), and we track these according to the section • D&D Code, which applies only to residential home phone that may have been breached. We don’t investigate every alleged services. Our core mandate is to facilitate the resolution of breach of the Codes. Complaints that are resolved to the mutual complaints between consumers, including small businesses, satisfaction of the customer and the service provider don’t receive and their service providers. In attempting to resolve complaints, additional analysis to determine whether a breach occurred. and during the course of our investigations, we seek to This is because in most cases, the evidence required to make determine whether the service provider reasonably met its such a determination wasn’t obtained and examined, because it responsibilities towards its customer. We use the Codes as wasn’t necessary to do so in order to resolve the complaint. Only yardsticks against which we can measure service provider those complaints that require a full investigation are analyzed to conduct in the context of our complaint-resolution activities. determine whether a breach of either Code occurred. In cases We’re also tasked with reporting on our activities related to the where our investigation leads us to believe that a breach may have administration of these two Codes. Below, you’ll find our reports. occurred, we inform the service provider and offer it an opportunity to respond before we proceed to confirm the breach.

“I was very satisfied with how quickly CCTS handled my complaint, and was very satisfied with the result. Thank you.” – A.V., a wireless customer

CCTS ANNUAL REPORT 2014-15 21 2014-15 Code of Conduct Reporting

The Wireless Code Terminology

In its development of TWC, the CRTC sought to ensure that ALLEGED BREACH: consumers of retail voice and data services are better informed when a customer claims that the service provider failed to perform of the rights and obligations contained in their contracts with an obligation under TWC, or when a CCTS staff member identifies wireless service providers. TWC applies to individual and small a potential TWC breach based on the details of a complaint. Each business consumers, and all wireless service providers must breach references an individual section of the Code. Thus, more follow its guidelines. When it created TWC, the CRTC asked us than one alleged breach may be recorded in a complaint. to administer it and report our findings.

The report below details the number of times we dealt with CONFIRMED BREACH: complaints that raised potential breaches of TWC, as well as the when we can confirm, based on our investigation, that a provision number of times we were able to confirm whether a breach of of TWC has been breached. TWC did (or didn’t) occur. We identified the specific sections of TWC that were breached as well as the wireless service provider NO BREACH: involved. The results should be read in light of the process when we have investigated an alleged breach and concluded described above as well as the terminology described to the right. that the service provider didn’t breach TWC.

TABLE 13: SUMMARY OF TWC BREACHES 3,284 ALLEGED BREACHES 994 BREACHES INVESTIGATED

582 412 CONFIRMED NO BREACH BREACHES

CCTS ANNUAL REPORT 2014-15 22 2014-15 Code of Conduct Reporting

TABLE 14: TWC CONFIRMED BREACHES BY SECTION

Total confirmed Percent of Total Section breaches confirmed breaches3

A. Clarity 51 8.8%

A.1. Plain language 3 0.5% A.2. Prices 1 0.2% A.3. Unlimited services 47 8.1%

B. Contracts and related documents 148 25.4%

B.1(i-ii) Permanent copy of the contract and related documents 22 3.8% B.1(iv) a-e Key Terms and Conditions 63 10.8% B.1(iv) f-m Other aspects of the contracts 63 10.8%

C. Critical Information Summary 11 1.9%

C.1. Critical Information Summary 11 1.9%

D. Changes to contracts and related documents 162 2 7.8%

D.1. Changes to key contract terms and conditions 72 12.4% D.2. Changes to other contract terms and conditions or related documents 90 15.5%

E. Bill management 14 2.4%

E.1. International roaming notification 5 0.9% E.2. Cap on data roaming charges 2 0.3% E.3. Cap on data overage charges 5 0.9% E.4. Unsolicited wireless services 2 0.3%

F. Mobile device issues 4 0.7%

F.1. Unlocking 4 0.7%

G. Contract cancellation and extension 9 1.5%

G.1. Early cancellation fees – General 2 0.3% G.4. Trial period 3 0.5% G.5. Cancellation date 4 0.7%

H. Security deposits 1 0.2%

H.1. Requesting, reviewing, and returning a security deposit 1 0.2%

I. Disconnection 182 31.3%

I.1. When disconnection may occur 7 1.2% I.2. Notice before disconnection 173 29.7% I.3. Disputing disconnection charges 2 0.3%

TOTAL 582

3 Note that percentages may not add up to 100% due to rounding.

CCTS ANNUAL REPORT 2014-15 23 2014-15 Code of Conduct Reporting

TABLE 15: TWC CONFIRMED BREACHES BY SERVICE PROVIDER

Service tion C. Critical lated documentslated

provider Confirmed breaches Percent of confirmed breaches A. Clarity Section Section B. Contracts and re Sec Information Summary Section Changes D. to contracts documents related and Section E. Bill management issues device Mobile Section F. Section G. Contract extension and cancellation Section Security H. deposits Disconnection I. Section Total

Wind 422 72.5% 11.4% 19.2% 0.0% 37.2% 0.5% 0.5% 0.5% 0.0% 30.8% 100%

Bell 64 11.0 % 0.0% 39.1% 9.4% 6.3% 14.1% 0.0% 6.3% 0.0% 25.0% 100%

Virgin 51 8.8% 0.0% 47.1% 3.9% 0.0% 0.0% 0.0% 2.0% 2.0% 45.1% 100%

Fido 13 2.2% 7.7% 53.8% 0.0% 0.0% 0.0% 0.0% 7.7% 0.0% 30.8% 100%

8com 11 1.9% 9.1% 63.6% 18.2% 0.0% 0.0% 0.0% 9.1% 0.0% 0.0% 100%

Rogers 10 1.7% 10.0% 20.0% 10.0% 10.0% 20.0% 0.0% 0.0% 0.0% 30.0% 100%

Telus 7 1.2% 0.0% 28.6% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 71.4% 100%

Tbaytel 3 0.5% 0.0% 0.0% 0.0% 0.0% 33.3% 33.3% 0.0% 0.0% 33.3% 100%

Petro Canada 1 0.2% 0.0% 0.0% 0.0% 0.0% 0.0% 100% 0.0% 0.0% 0.0% 100% Mobility

TOTAL 582 100% – – – – – – – – – –

CCTS ANNUAL REPORT 2014-15 24 2014-15 Code of Conduct Reporting

The Deposit and TABLE 17: SUMMARY OF D&D CODE BREACHES Disconnection Code

The D&D Code was developed by the industry, approved by the ALLEGED CRTC, and came into effect in May 2012. It’s a mandatory code 118 BREACHES of conduct that provides residential home phone customers with certain protections in cases where they’re required to provide a deposit as a condition of obtaining home phone service, or when a service provider intends to disconnect the customer’s home phone service. BREACHES INVESTIGATED TABLE 16: D&D CONFIRMED BREACHES BY SECTION 41

% of Total Confirmed confirmed Section breaches breaches

2.1 Overcharge 19 22 1 5.3% of security deposit CONFIRMED NO BREACH BREACHES 3.2 Notice at least 14 days prior 7 36.8%

3.3 Advise customer 8 42.1% 24 hours prior “CCTS certainly is an agency that customers 3.5 Improper disconnection 2 10.5% can use to resolve issues and come up with fair solutions in an objective manner.” 3.6 Disconnection during dispute 1 5.3% – P.C., a home phone customer TOTAL 19 100%

TABLE 18: D&D CONFIRMED BREACHES BY SERVICE PROVIDER firmed breaches tion 3.3 east 14 dayseast prior 14 isconnection isconnection isconnection

Service provider Confirmed breaches Percent of con Section 2.1 Overcharge of security deposit Section 3.2 Notice at l Sec customer Advise hours24 prior Section 3.5 Improper d Section 3.6 D during dispute Total

Bell Canada 10 52.6% 10.0% 30.0% 40.0% 10.0% 10.0% 100%

Vonage 3 15.8% 0.0% 33.3% 33.3% 33.3% 0.0% 100%

Bell Aliant 2 10.5% 0.0% 50.0% 50.0% 0.0% 0.0% 100%

Telus 2 10.5% 0.0% 50.0% 50.0% 0.0% 0.0% 100%

Vbuzzer 2 10.5% 0.0% 50.0% 50.0% 0.0% 0.0% 100%

TOTAL 19 100% – – – – – –

CCTS ANNUAL REPORT 2014-15 25 2014-15 Working with Participating Service Providers WORKING WITH PARTICIPATING SERVICE PROVIDERS

response within 30 days of receiving the complaint. Nonetheless, Referrals to Investigations we’re pleased that providers have recognized the wastefulness In our process, complaints go to our Investigations staff only of not responding and the impact it has on them, their when the customer and service provider are unable to resolve customers, and us. their dispute, either directly or with our facilitation. But as we first described in our 2012-13 Annual Report, a large number of complaints have gone to our investigators simply because service Good Results from Many providers didn’t give us a proper response to a given complaint, Smaller Service Providers eliminating the opportunity to resolve complaints informally at an early stage. In 2012-13, 41% of referrals to investigations resulted The focus of our Annual Report often seems to be on the from the failure to observe this basic procedure. We worked results posted by the largest service providers. Maybe that’s hard with service providers to address this concern, as it causes understandable, considering that this year, the top 10 service unnecessary delays in resolving complaints and additional costs providers accounted for almost 86% of all complaints. But we to service providers. Last year, providers worked diligently to noted this year the significant improvement by some of our reduce the number of these files to 19% of all referrals. smaller providers in reducing the number of complaints from their customers. Each year we publish a table detailing all But there was still room for improvement, and we continued complaint activity for the year for every PSP and their brands. these efforts this year. We are pleased to report that in 2014-15 This year there are 262 in in all. We’re pleased to note that this number continued to trend downward – only 11% of cases 150 of them recorded no complaints from any of their customers. required investigation solely because the provider didn’t give Another 32 recorded just one complaint. These are very good a response to the complaint. It still seems excessive that in results and we think these providers should be congratulated. over one in 10 cases, the provider is unable to give a proper

“The service and attention I received was above all expectations. Extremely grateful a service like CCTS is there when all else fails.” – D.R., a wireless customer

CCTS ANNUAL REPORT 2014-15 26 2014-15 Working with Participating Service Providers

Top 25 Participating Service Providers

As of July 31, 2015, there were approximately 262 service providers and brands participating in CCTS. A complete analysis of the number of complaints concluded in 2014-15 for every service provider and brand can be found here. In this section you’ll find the 25 service providers about which we received the highest number of complaints in 2014-15.

TABLE 19: TOP 25 PARTICIPATING SERVICE PROVIDERS BY COMPLAINTS ACCEPTED plaints plaints calation ratecalation hange of 2014-15 Accepted com 2013-14 Y/Y Percent c Service Provider of Percent complaints all 2014-15 Accepted com complaints accepted rateResolution (% of all resolved complaints concluded; all vs 87% overall) Es (% of all escalated complaints concluded; all vs 27% overall) Bell Canada 36.0% 3,599 3,651 -1.4% 84.0% 29.3% Rogers 18.2% 1,814 2,379 -23.7% 93.9% 12.7% Wind 7.0 % 702 510 37.6 % 87.8 % 53.9% Virgin 6.1% 608 815 -25.4% 84.5% 34.2% Fido 6.1% 607 905 -32.9% 91.8% 8.2% Telus 4.7% 466 653 -28.6% 75.7% 28.4% Videotron 3.1% 313 294 6.5% 88.7% 23.9% Koodo 1.8% 175 172 1.7% 83.0% 19.3% Comwave 1.4% 143 179 -20.1% 90.3% 10.3% Bell Aliant 1.4% 142 160 -11.3% 84.1% 27.6 % Primus 1.3% 125 95 31.6% 96.1% 17.2% Xplornet 1.0% 101 97 4.1% 84.5% 27.2% ACN Canada 0.8% 82 75 9.3% 93.8% 30.9% Cogeco 0.8% 80 79 1.3% 90.1% 11.1% Mobilicity 0.8% 78 58 34.5% 89.3% 38.7% Shaw 0.7% 74 96 -22.9% 92.2% 20.8% Acanac 0.6% 64 77 -16.9% 92.2% 40.6% MTS 0.6% 60 120 -50.0% 85.9% 17.2% Public Mobile 0.6% 55 128 - 57.0 % 89.3% 36.0% Vonage 0.5% 50 45 11.1% 91.7% 33.3% Sasktel 0.5% 48 91 - 47.3 % 89.3% 23.2% Brama Telecom 0.5% 45 8 462.5% 91.7% 63.9% Pulse Telecom 0.4% 44 1 4300.0% 71.4% 71.4% TekSavvy 0.4% 40 53 -24.5% 91.4% 22.9% Distributel 0.3% 32 76 - 57.9 % 77.1% 37.1%

CCTS ANNUAL REPORT 2014-15 27 2014-15 Working with Participating Service Providers

Top 10 Participating Service Provider Profiles

In the pages that follow, we profile the 10 service providers about which we received the most complaints. In each profile, we provide information regarding the number of complaints accepted and the proportion of the total complaints accepted that this represents, as well as what we believe to be other key indicators, such as the proportion of complaints that the provider resolves (resolution rate) or that require escalation to our Investigation stage (escalation rate). We also list the types of issues that are most often raised in the complaints associated with that service provider, as well as the number of confirmed breaches of TWC and the D&D Code we identified in complaints from its customers.

1. Bell Canada 2. Rogers

Resolution Resolution 84.0% rate 93.9% rate

3,599 36.0% 1,814 18.2% Number of accepted of all Number of accepted of all complaints 2014-15 complaints complaints 2014-15 complaints

-1.4% 29.3% -23.7% 12.7% Change of complaints Escalation Change of complaints Escalation accepted compared rate accepted compared rate to 2013-14 to 2013-14

CODE BREACHES CODE BREACHES 11.0% of all confirmed 52.6% of all 1.7% of all confirmed 0% of all confirmed TWC breaches confirmed D&D TWC breaches D&D breaches (64 breaches) breaches (10 breaches) (10 breaches) (0 breaches)

TOP 3 ISSUES RAISED IN COMPLAINTS TOP 3 ISSUES RAISED IN COMPLAINTS

Incorrect charge Non-disclosure of 1,183 terms/Misleading information about terms 534

Non-disclosure of terms/Misleading 945 Incorrect charge information about terms 499

30-day 30-day cancellation policy 439 cancellation policy 259

CCTS ANNUAL REPORT 2014-15 28 2014-15 Working with Participating Service Providers

3. Wind 4. Virgin

Resolution Resolution 87.8 % rate 84.5% rate

702 7.0 % 608 6.1% Number of accepted of all Number of accepted of all complaints 2014-15 complaints complaints 2014-15 complaints

37.6 % 53.9% -25.4% 34.2% Change of complaints Escalation Change of complaints Escalation accepted compared rate accepted compared rate to 2013-14 to 2013-14

CODE BREACHES CODE BREACHES 72.5% of all D&D Code 8.8% of all confirmed D&D Code confirmed TWC not applicable TWC breaches not applicable breaches (422 breaches) (51 breaches)

TOP 3 ISSUES RAISED IN COMPLAINTS TOP 3 ISSUES RAISED IN COMPLAINTS

Non-disclosure of Non-disclosure of terms/Misleading 225 terms/Misleading 153 information about terms information about terms

Intermittent/Inadequate Incorrect charge quality of service 174 84

Roaming charges 76 Data charges 68

CCTS ANNUAL REPORT 2014-15 29 2014-15 Working with Participating Service Providers

5. Fido 6. Telus

Resolution Resolution 91.8% rate 75.7% rate

607 6.1% 466 4.7% Number of accepted of all Number of accepted of all complaints 2014-15 complaints complaints 2014-15 complaints

-32.9% 8.2% -28.6% 28.4% Change of complaints Escalation Change of complaints Escalation accepted compared rate accepted compared rate to 2013-14 to 2013-14

CODE BREACHES CODE BREACHES 2.2% of all confirmed 0% of all confirmed 1.2% of all confirmed 10.5% of all confirmed TWC breaches D&D breaches TWC breaches D&D breaches (13 breaches) (7 breaches) (2 breaches)

TOP 3 ISSUES RAISED IN COMPLAINTS TOP 3 ISSUES RAISED IN COMPLAINTS

Non-disclosure of Credit reporting terms/Misleading 139 85 information about terms

Non-disclosure of Data charges terms/Misleading 82 103 information about terms

Credit/Refund not received Incorrect charge X 68 64

CCTS ANNUAL REPORT 2014-15 30 2014-15 Working with Participating Service Providers

7. Videotron 8. Koodo

Resolution Resolution 88.7% rate 83.0% rate

313 3.1% 175 1.8% Number of accepted of all Number of accepted of all complaints 2014-15 complaints complaints 2014-15 complaints

6.5% 23.9% 1.7% 19.3% Change of complaints Escalation Change of complaints Escalation accepted compared rate accepted compared rate to 2013-14 to 2013-14

CODE BREACHES CODE BREACHES 0% of all confirmed 0% of all confirmed 0% of all confirmed D&D Code TWC breaches D&D breaches TWC breaches not applicable (0 breaches) (0 breaches) (0 breaches)

TOP 3 ISSUES RAISED IN COMPLAINTS TOP 3 ISSUES RAISED IN COMPLAINTS

Incorrect charge Non-disclosure of 92 terms/Misleading information about terms 38

Non-disclosure of terms/Misleading 70 Credit reporting information about terms 30

Bandwidth usage 49 Incorrect charge 18

CCTS ANNUAL REPORT 2014-15 31 2014-15 Working with Participating Service Providers

9. Comwave 10. Bell Aliant

Resolution Resolution 90.3% rate 84.1% rate

143 1.4% 142 1.4% Number of accepted of all Number of accepted of all complaints 2014-15 complaints complaints 2014-15 complaints

-20.1% 10.3% -11.3% 27.6 % Change of complaints Escalation Change of complaints Escalation accepted compared rate accepted compared rate to 2013-14 to 2013-14

CODE BREACHES CODE BREACHES TWC not applicable 0% of all confirmed 0% of all confirmed 10.5% of all confirmed D&D breaches TWC breaches D&D breaches (0 breaches) (0 breaches) (2 breaches)

TOP 3 ISSUES RAISED IN COMPLAINTS TOP 3 ISSUES RAISED IN COMPLAINTS Legitimacy of ECF 39 Incorrect charge 67

Non-disclosure of Non-disclosure of terms/Misleading 37 terms/Misleading 35 information about terms information about terms

No consent provided 30-day 29 cancellation policy 30

CCTS ANNUAL REPORT 2014-15 32 2014-15 Working with Participating Service Providers

List of Participating Service Providers

The following is an alphabetical list of our PSPs and the many brand names by which they’re known. Services provided under any of these names are eligible for our complaint service. An asterisk (*) following a company name denotes a service provider that joined CCTS between August 1, 2014, and July 31, 2015.

#100 CCAP (Coopérative de Globalive Communications Ontera Talk Canada 1010100 Câblodistribution Corp. Opcom Hospitality Talk Wireless 1010580 de l`Arrière-pays) Globalstar Solutions Inc. Talkit.ca Inc. 1010620 CCAP Cable Gold Leaf Telecom Ltd. Orbitel Targo Communications Inc. 1010738 CCI Wireless Group of Gold Line Oricom Internet Tata Communications 1011295.com CDTel Hook Communications Inc. Owtel tbaytel 295.ca Cellfone Horizon Telecom PageNet TekSavvy Solutions Inc. 3Web Chatr Wireless HuronTel Pannu Phone Inc. (SSTV) Tel-Synergy 450Tel Cheepnet I-NetLink Wireless Parlez rabais Tele-Page 768812 Ontario Inc. Cheetah *Ilink Communications Pathway Communications Telehop 8COM Choice Tel InfoFortin Telecom PC Mobile Teliphone Corp A dimension humaine CIK Telecom Inc. InfoSat Communications People’s Tel GP Inc. Telizon Acanac Inc. Cityfone InnSys Persona Telnet Communications Achatplus Inc. Coast Cable Inter.net Canada Communications Corp. TELUS Communications ACN Canada Cogeco Interhop Petro Canada Mobility Company AEBC Internet Corporation Cogeco Câble Québec Internet LightSpeed Phone Factory TeraGo Networks Inc. AEI Internet Cogeco Data Services Inc. Communications Phone Power ThinkTel AIC Global Communications Cogent Canada iRoam Mobile Solutions Inc. Phonebox Tough Country Alberta High Speed Colba.Net italkBB Platinum Communications Allstream inc. ComparAction Juno *Porchlight.ca Transvision Cookshire Altima Telecom Compton Communications K-Right Communications Inc. PortalOne Télébec Americatel Compuxellence Kokanee Phone Premiere Conferencing Uniserve Amtelecom Telco GP Inc. Comwave Koodo Canada Ltd. Vancouver Telephone *Arrow Technology Group. Contact Internet Le pigeon voyageur Premiere Global Services Company Auracom Convergia Networks Inc. LooneyCall Primus Vbuzzer Avenue Cooptel LuckyCall Public Mobile Velcom Axess Communications Cybersurf Internet Magic Jack Tel Pulse Telecom Velocity Networks Inc. Axsit Access (CIA) Mastercall PWHR Solutions Verizon B2B2C Inc. DCI Telecom MCI Canada Questzones Vianet Internet Solutions Bell Aliant Regional Dell Voice Mobilicity Quinte Long Distance Vidéotron s.e.n.c./ Communications LP Delta Cable Mountain Cablevision Limited RadioActif Videotron GP Bell Canada Distributel Communications MTS Inc. Redden.on.ca VIF Internet BlueTone Canada Limited Mustang Technologies Inc. RevTel Virgin Mobile Canada BMI Internet DolphinTel MyConnexion Rocler Technologies *VMedia Bragg Communications Inc. DSLExtreme National Capital FreeNet Rogers Communications Inc. Voice Network Inc. Brama Telecom Inc. Eastlink National Teleconnect Sasktel Vois Inc. Bravo Phone Cards Easy Office Phone Navatalk Sears Connect Vonage Canada Corporation Bravo Telecom EasyVoice Telecom NCIC Operator Services Seaside Communications Westman Brightroam eFirehose *NECC (Seaside Cable) Communications Group Bruce Municipal Electronic Box *NECC CA SecureNet Information WestNet Wireless Telephone System Enhanced VOIP Neighborhood Wireless Services Inc. Wightman Telecom Bruce Telecom Communications Net For Less Selectcom Inc. WiMac Tel Bud Light Lime Phone Enter-net Net Reach Selectcom Telecom Win-tel Bud Light Phone ExaTEL Inc. *NetAccess Systems Inc. Sens-net Canada Inc. WIND Mobile Corp. Bud Phone Execulink Netfone Shaw World-Link Cable Axion Falcon Internet Services NetRevolution Simcoe County Long Distance Communications Inc. Cable VDN Fibernetics NetZero Simple Connection Worldline Cablevision du Fido NEWT Business Services *Skydata *WTC Communications Nord de Québec inc. Fongo Inc. Nobel Canada Telecom Sogetel Xittel Inc. Call Select Freedom Phone Lines Northern Tel Solo Xplornet Internet Services Can-net Telecom FreePhoneLine.ca Northwestel Source Cable Ltd. Yak Communications Corp. Canada Payphone G3 Telecom Nucleus Information Speak Out Wireless (7-11) Yesup Corporation Galilee Service Inc. Speak Telecom Yesupnet Canada Relink Gems Telecom NuEra Telecom Spectravoice Youmano Canopco Giantel OneConnect Services Inc. Startec *YourLink Inc. CaspianWave Global Crossing OnlineTel SureNet Zid Internet Caztel Te lecommunications Ontarioeast.net Switchworks Zoomer Canada Ltd Talk & Save

CCTS ANNUAL REPORT 2014-15 33 STATISTICAL REPORTS This section contains detailed statistical reports on our operations.

SECTION CONTENT Contact Centre Activities 34 Analysis of 36 Compensation Analysis 37 Performance Standards 39 Closed Complaints Out-of-Mandate Issues 35 Small Business Complaints 38 Regional Analysis 40

Contact Centre Activities Our Contact Centre received over 174,000 communications by telephone, in writing and by chat.

Total written correspondence4 35,598 Total phone calls 138,220

Written correspondence from customers Number of general inquiries 83,124 about new or existing complaints 26,860 Inquiries generated by PSP bill message 16,156 Written correspondence from service Number of consultations about complaints 42,205 providers about complaints 7,883 Number of out-of-mandate phone consultations 11,372 Written correspondence from customers with general inquiries about CCTS Inquiries about CRTC Wireless Code of Conduct 1,278 or their telecommunications services 855 Number of complaints accepted by phone 241

Total chat sessions answered5 472 100,000

80,000 83,124

60,000

40,000 26,860 42,205 20,000 7,883 855 0 11,372 16,156 1,278 241 472 Total written correspondence 4 Total phone calls 35,598 138,220 Total chat sessions

answered5 472

4 The amount of written correspondence handled this year is down by over 14,000 items. This is largely attributable to our introduction of an online portal for use by service providers. This electronic application allows providers to respond to complaints online. These responses are processed automatically by our case management system and thus don’t require manual handling by our agents.

5 Web chat service became available in November 2014. CCTS ANNUAL REPORT 2014-15 34 2014-15 Statistical Reports

Out-of-Mandate Issues

This table shows the number of issues raised by customers, in writing or by phone, that we couldn’t accept in 2014-15, broken down by reason.

Procedural Code Section 3

Section 3(a) Internet applications/content 333 Section 3(b) Broadcasting (television) 7,294 Section 3(b) Broadcasting (radio) 26 Section 3(c) Emergency services 30 Section 3(d) Payphones 50 Section 3(e) Customer owned equipment 232 Section 3(f) Inside wiring 35 Section 3(g) Yellow pages/Business directories 55 Section 3(h) Telemarketing/Unsolicited messages 913 Section 3(i) Security services 48 Section 3(j) Networking 25 Section 3(k) 900/976 calls 42 Section 3(l) Pricing 1,121 Section 3(m) Rights of way 44 Section 3(n) Plant/Poles/Towers 277 Section 3(o) False/Misleading advertising 193 Section 3(p) Privacy issues 390 Section 3 Other – Regulated services 181 Phone/Internet scams 269 TOTAL 11,558

Procedural Code Section 4

Section 4.1 Customer service Language barriers 57 Outsourcing 138 Rude representative 673 Transfers/IVR 134 Wait times 484 Total 1,486 Section 4.3 General operating practices and policies 3,103 TOTAL 4,589

Procedural Code Section 8: Duty to decline to take action Some complaints could not be accepted due to provisions of the Procedural Code. They break down as follows:

Section 8.1 Service provider not offered opportunity to resolve 137 Section 8.2 Matter previously or currently with another agency 166 Section 8.3(a) Complaint filed outside time limits 387 Section 8.3(b) Facts arose prior to effective date 12 TOTAL 702

CCTS ANNUAL REPORT 2014-15 35 2014-15 Statistical Reports

Analysis of Closed Complaints

Our operational statistics show that we closed 1,300 complaints in 2014-15. This table provides a breakdown of the reasons why those complaints were closed, with reference to the relevant section of the Procedural Code.

Number of Percent of closed Reason for Closure closed complaints complaints

Customer withdraws complaint 80 6.2% Out-of-mandate after further information obtained 276 21.2% Section 7.1(b) Customer does not have sufficient interest 6 0.5% Section 7.1(c) Complaint more appropriately handled by another agency 18 1.4% Section 7.1(d) Further investigation not warranted 423 32.5% Section 7.1(e) Customer not cooperative 216 16.6% Section 7.1(f) Service provider offer is reasonable 199 15.3% Section 8.1 Service provider not offered opportunity to resolve 3 0.2% Section 8.2 Matter previously or currently with another agency 41 3.2% Section 8.3(a) Complaint filed outside time limits 33 2.5% Section 8.3(b) Facts arose prior to effective date 5 0.4% TOTAL 1,300 100%

CLOSED COMPLAINTS

35%

32.5% 30%

25% 21.2% 20%

15% 16.6% 15.3% 10% 6.2%

5%

0.5% 1.4% 0% 3.2% 0.2% 2.5% 0.4%

CCTS ANNUAL REPORT 2014-15 36 2014-15 Statistical Reports

Compensation Analysis

In many complaints, customers receive compensation. This compensation can take many forms, including:

• Bill credits; • Bill adjustments; • Free or discounted products and services; and • Cash payments

We attempt to record the value of all compensation awarded to customers as a result of our process. In some cases we are not fully informed of the amount of compensation provided to the customer, and in others the amount of compensation must be estimated.

This report discloses the full value of compensation received by customers that has been reported to us.

In 2014-15 customers received compensation in 73% of complaints concluded, which is up 3% from last year.

Compensation range Number of complaints Percentage

< $100 2,956 39.6% $100 – $499 3,497 46.8% $500 – $999 694 9.3% $1,000 – $4,999 302 4.0% $5,000+ 22 0.3% TOTAL 7,471 100%

TOTAL COMPENSATION $ 2,144,171.69

“I am grateful for CCTS and their professional attitude and assistance.” – P.T., a home phone customer

CCTS ANNUAL REPORT 2014-15 37 2014-15 Statistical Reports

Issues about wireless services make up over half of our work. Small Business Complaints But small business customers raise significantly more concerns When we report our operational statistics, we include the data for with their local phone and internet services. all the complaints we dealt with during the year. However, not all complaints are alike. In particular, we know that complaints TOP FIVE COMPLAINT ISSUES from small business customers can be quite different from those of individual consumers. Top five issues for consumers Percentage 1 Non-disclosure of terms/Misleading In 2014-15, we had 761 complaints from small business 13.1% information about terms customers, or 7.4% of all concluded complaints. 2 Incorrect charge 12.2% An analysis of these complaints reveals some significant differences from complaints filed by individual consumers: 3 Intermittent/Inadequate quality of service 6.5% 4 Legitimacy and amount of ECF 6.0% BY CATEGORY 5 30-day cancellation policy 5.3% Small Subject Consumer business

Billing 44.5% 30.1% Top five issues for small business Percentage

Contract dispute 29.9% 43.9% 1 Legitimacy and amount of ECF 14.0%

Service delivery 21.2% 22.7% 2 Non-disclosure of terms/Misleading 9.9% Credit management 4.4% 3.3% information about terms

TOTAL 100% 100% 3 Incorrect charge 8.7% 4 Auto-renewal 8.4%

While consumers complain most about billing issues, small 5 Intermittent/Inadequate quality of service 7.3 % business customers are focused more on contractual issues between them and their service provider. The top five issues raised by consumers and small business BY LINE OF BUSINESS customers are very similar, although they’re raised in slightly different proportions by each group. The one unique concern Small raised frequently by small business customers is “auto-renewal”, the 6 Line of business Consumer business process by which some providers automatically renew a customer’s Wireless 55.0% 27.9 % contract unless the customer specifically cancels the contract.

Internet 25.6% 31.5%

Local phone 16.6% 37.4%

Long distance 2.7% 3.2%

Directory assistance < 0.1% 0%

White page directories < 0.1% 0%

Operator services < 0.1% 0%

TOTAL 100% 100%

6 Note that percentages may not add up to 100% due to rounding.

CCTS ANNUAL REPORT 2014-15 38 2014-15 Statistical Reports

Performance Standards

Each year, we set ourselves a goal of great customer service. To ensure that we’re meeting that goal, we track our performance across various benchmarks. In 2014-15, as in the year before, we exceeded all of our performance standards, often considerably. The table below shows that breakdown.

PERFORMANCE STANDARDS

100% 92.7% 96.4% 80% 89.6% 80% 80% 80% 86.7% 80%

60%

40%

TARGET

RESULT TARGET 20% RESULT TARGET

RESULT TARGET

RESULT

0%

Answered phone calls within Processed written 120 seconds communications Complaints within concluded at Complaints 3 calendar days Pre-Investigation concluded at stage within Investigation 40 days stage within of acceptance 60 days of referral to Investigation

“I would HIGHLY recommend this service to anyone with complaints or concerns about their service provider. EXCELLENT!” – D.M., a wireless customer

CCTS ANNUAL REPORT 2014-15 39 2014-15 Statistical Reports

Regional Analysis

We receive complaints from customers throughout Canada. In this section, we identify the number of complaints and leading complaint issues raised by Province/Territory.

COMPLAINTS BY PROVINCE/TERRITORY

Complaints Population7

Alberta 623 6.1% 4,121.7 11.6%

British Columbia 965 9.4% 4,631.3 13.0%

Manitoba 180 1.8% 1,282.0 3.6%

New Brunswick 156 1.5% 753.9 2.1%

Newfoundland and Labrador 72 0.7% 527.0 1.5%

Northwest Territories 5 0.0% 43.6 0.1%

Nova Scotia 191 1.9% 942.7 2.7%

Nunavut 11 0.1% 36.6 0.1%

Ontario 5,493 53.7% 13,678.7 38.5%

Prince Edward Island 27 0.3% 146.3 0.4%

Québec 2,381 23.3% 8,214.7 23.1%

Saskatchewan 126 1.2% 1,125.4 3.2%

Yukon 8 0.1% 36.5 0.1%

TOTAL 10,238 100% 35,540.4 100%

7 2014 Canadian population according to Statistics Canada as of July 1, 2014. Numbers are measured in thousands of persons. Canada, Statistics Canada, Population by year, by province and territory (Ottawa, CANSIM, 2014) at http://www.statcan.gc.ca/tables-tableaux/sum-som/l01/cst01/demo02a-eng.htm

CCTS ANNUAL REPORT 2014-15 40 2014-15 Statistical Reports

Complaint Categories by Province/Territory

CONTRACT DISPUTE

36.4%

30.7% 32.4% 29.8% 25.0% 31.0% 32.7% 30.4% 33.2% 26.9% 32.6% 16.7% 25.5%

YUKON

BRITISH

ALBERTA COLUMBIA

NUNAVUT NORTHWEST

TERRITORIES ONTARIO QUÉBEC

MANITOBA

ISLAND

SASKATCHEWAN

NOVA SCOTIA NOVA

NEW BRUNSWICK

PRINCE EDWARD AND LABRADOR

NEWFOUNDLAND

BILLING

58.3%

44.9%

39.6% 39.1% 48.7% 27.3% 39.7% 41.5% 33.3% 42.6% 42.7% 43.0% 32.7%

YUKON

BRITISH

ALBERTA COLUMBIA

NUNAVUT NORTHWEST

TERRITORIES ONTARIO QUÉBEC

MANITOBA

ISLAND

SASKATCHEWAN

NOVA SCOTIA NOVA

NEW BRUNSWICK

PRINCE EDWARD AND LABRADOR

NEWFOUNDLAND

Note that percentages may not add up to 100% due to rounding.

CCTS ANNUAL REPORT 2014-15 41 2014-15 Statistical Reports

SERVICE DELIVERY

38.9%

25.5% 38.2% 18.2% 19.4% 21.4% 16.7% 25.3% 21.7% 20.7% 20.1% 19.0% 19.3%

YUKON

BRITISH

ALBERTA COLUMBIA

NUNAVUT NORTHWEST

TERRITORIES ONTARIO QUÉBEC

MANITOBA

ISLAND

SASKATCHEWAN

NOVA SCOTIA NOVA

NEW BRUNSWICK

PRINCE EDWARD AND LABRADOR

NEWFOUNDLAND

CREDIT MANAGEMENT

18.2%

5.0% 6.7% 11.1% 5.5% 0.0% 4.0% 4.1% 6.9% 3.6% 5.0% 3.6% 5.2%

YUKON

BRITISH

ALBERTA COLUMBIA

NUNAVUT NORTHWEST

TERRITORIES ONTARIO QUÉBEC

MANITOBA

ISLAND

SASKATCHEWAN

NOVA SCOTIA NOVA

NEW BRUNSWICK

PRINCE EDWARD AND LABRADOR

NEWFOUNDLAND

Note that percentages may not add up to 100% due to rounding.

CCTS ANNUAL REPORT 2014-15 42 CUSTOMER SURVEY RESULTS

We surveyed customers who used our service, with two main goals in mind:

1. To get their impressions of the work we do, so that we 2. To attempt to measure the success of the public can focus our efforts for improvement; and awareness initiatives we undertake with PSPs.

These results are based on approximately 1,800 responses. We thank the customers who took the time to participate in the survey and share their views.

What Customers Said About CCTS

1. We asked our customers: Was it easy to file your 2. We asked our customers to provide feedback on whether complaint with CCTS? the service they received from our Contact Centre agents met expectations in certain important respects. 82.8% 89.5% 14.4% Polite and 6.1% 2.8% professional 4.4% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

81.9% Yes Somewhat No 10.3% Helpful

7.8%

83.0%

10.3% Knowledgeable 6.7%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Yes Somewhat No

CCTS ANNUAL REPORT 2014-15 43 2014-15 Customer Survey Results

3. We also asked our customers about important elements of 4. Finally, we asked our customers about their overall sense of the service they received from our Complaints Resolution satisfaction with various aspects of our process. Officers and Investigators.

90.2% 90.5%

Polite and 6.7% 7.8% Accessibility professional 3.1% 1.7%

82.9% 85.2%

10.6% 9.2% Knowledgeable Timelines 6.5% 5.6%

75.4% 90.1%

10.6% 6.5% Impartial Professionalism 14.0% 3.4%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 82.3%

6.3% Yes Somewhat No Impartiality

11.4%

78.4%

9.6% Process fairness

12.0%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Yes Somewhat No

The feedback received from our customers this year was, once again, extremely positive. This applies to the quality of the service that our staff provides, as well as to the ease of use of our process. These high levels of satisfaction are very gratifying.

CCTS ANNUAL REPORT 2014-15 44 2014-15 Customer Survey Results

What Customers Said About Service Provider Public Awareness Activities

1. We asked our customers how they first found out about CCTS. BREAKDOWN OF “OTHER”

Our customers said: 1.5% 1.8% 32.6% 35.3% 4.1% 4.8% 19.2% 5.1% 15.2% 5.5% 14.0%

9.9% 8.2% 21.7% 10.3% 7.0% Service Provider Social Media / Public Forums 3.8% Government Agency Other TSP

0% 10% 20% 30% 40% 50% Credit Card Web Search Provider or Bank Better Business Bureau Web search A friend, colleague or family member General knowledge Phone Book The CRTC Learned about it from the media Legal Other Notice on your bill A Consumer group

“I am very happy that there is such an organization like CCTS. The representative was very helpful and resolved my issue in no time.” – S.T., a wireless customer

CCTS ANNUAL REPORT 2014-15 45 2014-15 Customer Survey Results

2. PSPs have committed to notify customers about CCTS 4. PSPs have committed to placing a prescribed notice about during their internal complaint-handling process. We asked CCTS in a reasonably prominent place on their web sites, our customers whether their service provider told them about and to include a link to our web site. We asked our customers CCTS during that process. whether they’d seen it.

Our customers said: Our customers said:

10.0% 14.7%

90.0% 85.3%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Yes No Yes No

3. PSPs are required to print a prescribed message about CCTS The main methods for customers to learn about us continue to on customer bills four times a year. We asked our customers be an internet search, referrals from the CRTC, and information whether they’ve ever seen the notice on any of their bills. obtained from friends and family members. Approximately seven per cent of customers initially found us from their service Our customers said: provider’s bill message, and roughly five per cent were first told about us by their service provider. 13.5% Customer responses to the other questions in this section 86.5% are essentially consistent with the responses from previous years’ surveys. 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Yes No

CCTS ANNUAL REPORT 2014-15 46 WHO WE ARE

BOARD OF DIRECTORS Our Board is structured to provide for the participation of all stakeholders while remaining independent from the telecommunications industry. It consists of seven directors: • Four Independent Directors, two of whom are nominees of consumer groups; and, • Three Industry Directors, one each to represent the Incumbent Local Exchange Carriers (ILECs), the Cable Companies, and the Other PSPs.

DIRECTOR BIOGRAPHIES A lawyer by training, Mary was awarded the Prime Minister’s Independent Directors Outstanding Achievement Award, the Public Service’s highest award, for her “Outstanding contribution to the Public Service The Independent Directors are intended to represent a diversity of Canada”. She received the Queen’s Jubilee Medal and has of experience and interests, being individuals known and been inducted into the Honour Society of the University of respected on a regional and national basis and representative Ottawa Law School. of the Canadian population, including gender, linguistic, minority and geographic representation. Marie Bernard-Meunier Mary M. Gusella (Chair) A career diplomat, Marie served in Ottawa as Assistant Deputy Minister for Global Issues and abroad as Canada’s Ambassador After a 36 year career in the federal public service, Mary retired to UNESCO, to the Netherlands and to Germany. She left the in 2006 from the position of Chief Commissioner of the Canadian Foreign Service in 2005 and has since published extensively on Human Rights Commission where she led the transformation various public policy issues. She currently serves on the Boards of the organization, eliminating a chronic backlog, drastically of many public institutions, including the Audit Committee of reducing wait times, developing new tools and partnerships the Canadian Space Agency. She holds a Master’s Degree for human rights prevention, and maximizing the use of conflict in Political Science from the Université de Montréal. resolution techniques to resolve complaints in a timely and effective manner.

CCTS ANNUAL REPORT 2014-15 47 2014-15 Who We Are

Marina Pavlovic´ Industry Directors Marina is an Assistant Professor at the University of Ottawa’s The Industry Directors represent each of the ILEC, Cableco Faculty of Law, Common Law Section, where she is a member of and Other PSP categories. The current appointed Industry the Center for Law, Technology, and Society and the International Directors are Marten Burns (ILEC), Dennis Béland (Cableco) Law Group. Marina has research and teaching experience in and Jill Schatz (Other). consumer protection, telecommunications, law & technology policy, and dispute resolution. She holds a law degree from the Dennis Béland University of Belgrade (Serbia) and a LLM in Law & Technology Dennis is Vice-President, Regulatory Affairs, from the University of Ottawa. Telecommunications, Quebecor Media Inc. Dennis has a Bachelor’s Degree in Engineering and Management and a Jacques C.P. Bellemare Master’s Degree in Public Policy from the John F. Kennedy Jacques graduated in Engineering Physics at École School of Government at Harvard University. He is a Member Polytechnique in Montreal (1961) and later obtained an MBA of the Board of Directors of the Canadian LNP Consortium Inc., from Laval University in Quebec (1973). the Canadian Numbering Administration Consortium Inc. and a former Member of the Board of Directors of the Canadian In the private sector, he has worked in telephony with Bell Wireless Telecommunications Association. Canada, in Cable TV with Cablevision Nationale (acquired by Videotron), in consulting with Raymond, Chabot, Martin, Paré, Marten Burns and in regulation with Teleglobe Canada after its privatization. Marten is Senior Regulatory Legal Counsel with TELUS Communications Company and is based in Ottawa. He has a Since 1994, with his own firm STEM Consultants Inc, he offers broad range of regulatory experience with telecom issues, and independent expertise in economic regulation of public utility was previously involved with the CCTS during its inception in 2007 companies, mostly in the energy sector. when he served as a Provisional Director of the organization. In the public sector, from 1982 to 1988, Jacques served as a Marten is a respected public policy practitioner, and prior to Member of the Quebec Public Service Board then assuming joining TELUS, he served as a Senior Policy Advisor to the regulatory jurisdiction over certain telephone companies located Minister of Finance, the Minister of Public Works and Government in Quebec, including Quebec-Telephone and Telebec. Services, and the Minister of Natural Resources.

Marten has a private sector corporate law background, and has acted as Corporate Counsel and Secretary for two public companies.

Jill Schatz Jill joined Primus Canada in 2008 as General Counsel and VP Law and has overall responsibility for the legal requirements of the company. She has extensive in-house experience in various public and private corporations and has held senior legal, corporate secretarial and executive roles in the IT and Telecommunications industries since 2000 with Momentum Advanced Solutions Inc. (formerly OnX Enterprise Solutions Inc.) and Cybersurf Corp. Prior to 2000 she held in-house positions with ICI Canada Inc. (formerly C-I-L Inc.) and TransCanada PipeLines Limited. Jill holds a Juris Doctorate (J.D.) and MBA (Finance Major), both from the University of Toronto as well as a Masters in Law (International Trade & Competition Law) from Osgoode Hall Law School.

CCTS ANNUAL REPORT 2014-15 48 2014-15 Who We Are

CCTS Organizational Chart

Our employees bring diverse backgrounds and experience to their work. They’ve worked in the telecommunications industry, with consumer associations, and as regulators or lawyers. The chart below describes how our organization is structured and the names of the individuals in those roles.

COMMISSIONER Howard Maker

ADMINISTRATIVE ASSISTANT FINANCE ASSISTANT COMMISSIONER CONSULTANT Aby Noel Josée Thibault Kevin Byrne

MANAGER, MANAGER, MANAGER, CUSTOMER CARE INFORMATION INVESTIGATIONS Sylvie Laframboise TECHNOLOGY Marco Lanoue Al Villeneuve

TEAM LEADS, TECHNICAL TEAM LEAD, COMMUNICATIONS TEAM LEADS, CUSTOMER CARE SUPPORT COMPLAINTS OFFICER INVESTIGATIONS Patrick ANALYST ANALYSIS Paul Carlucci Danny Raymond Bisson‐Fields Vadim Tamar Palandjian‐ Erin Reid Eric Mayer Dombrovskii Toufayan

CUSTOMER SERVICE COMPLAINTS COMPLAINTS REPRESENTATIVES ANALYSTS RESOLUTION Daniel Brisson Nicolae Irina OFFICERS Felicia Brown Mauricio Pérez Philippe Mercorio Serge Cardinal (Investigator) Julie Chénier Federica Anaya Louis Desjardins Yves Chauvin Stefan Desmarais Chantal Daugherty Jean‐Pierre Friquin Jean‐Claude Lizé Tamara Holland Jason Mahon Nicholas Jodoin‐Brazeau José Fanie Saint‐Fleur Eric Levesque Karen Sanghera Sébastien Pigeon Marc‐André Savoie Hinda Seth Kelsey Tapp Michelle Wilson

New this year, we’re proud to begin a relationship with LiveWorkPlay and welcome Frances Laube to our team.

CCTS ANNUAL REPORT 2014-15 49 Appendix A ‐ Complaints by Service Provider Complaints

Change

all

%

of

% Accepted Y/Y Concluded Resolved Closed Resolved Closed Accepted Issued Accepted Rejected Provider Accepted and Concluded Complaints Pre‐Investigation Investigation Recommendation Decision

#100 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 1010100 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 1010580 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 1010620 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 1010738 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 1011295.com 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 295.ca 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 3Web 0.0% 0 ‐100.0% 0 0 0 0 0 0 0 0 0 450Tel 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 768812 Ontario Inc. 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 8COM 0.1% 8 ‐88.4% 10 2 0 8 0 0 0 0 0 A dimension humaine 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Acanac Inc. 0.6% 64 ‐16.9% 64 37 1224 0 0 0 0 Access Communications Inc. 0.0% 1 0.0% 1 0 1 0 0 0 0 0 0 Achatplus Inc. 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 ACN Canada 0.8% 82 9.3% 81 54 2 22 3 0 0 0 0 AEBC Internet Corporation 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 AEI Internet 0.0% 3 ‐40.0% 5 0 0 41 0 0 0 0 AIC Global Communications 0.0% 1 0.0% 1 0 0 1 0 0 0 0 0 Alberta High Speed 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Allstream Inc. 0.1% 11 175.0% 10 4 0 24 0 0 0 0 Altima Telecom 0.0% 3 50.0% 3 2 0 0 1 0 0 0 0 Americatel 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Amtelecom Telco GP Inc. 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Arrow Technology Group 0.0% 1 ‐ 1 0 0 0 1 0 0 0 0 Auracom 0.0% 0 ‐100.0% 0 0 0 0 0 0 0 0 0 Avenue 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Axess Communications 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Axsit 0.0% 0 ‐100.0% 0 0 0 0 0 0 0 0 0 B2B2C Inc. 0.1% 5 150.0% 4 3 0 0 1 0 0 0 0 Bell Aliant Regional Communications LP 1.4% 142 ‐11.3% 145 98 7 24 14 0 220 Bell Canada 36.0% 3,599 ‐1.4% 3,739 2,385 257 755 338 1330 BlueTone Canada 0.0% 0 ‐100.0% 1 0 0 1 0 0 0 0 0 BMI Internet 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Bragg Communications Inc. 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Brama Telecom Inc. 0.5% 45 462.5% 36 13 0 20 0 210 0 Bravo Phone Cards 0.0% 0 0.0% 0 0 0 0 0 0 0 0 0 Bravo Telecom 0.0% 1 ‐ 1 0 0 1 0 0 0 0 0 Brightroam 0.0% 1 0.0% 0 0 0 0 0 0 0 0 0 Colba.Net Bruce Municipal Cheepnet ComparAction Canada Cheetah Bruce Telecom Compton Bud Canopco Compuxellence Choice Tel Bud CaspianWave CIK Telecom Comwave Contact Cityfone Bud Caztel Convergia Networks Inc. Coast CCAP Cable Axion Cooptel Cogeco Cable VDN Cybersurf CCAP Cogeco CâbleQuébec Cogeco DataServices Cablevision DCI Telecom CCI Wireless CDTel Cogent Canada Dell Voice Call Can‐net Telecom Cellfone Canada Chatr Wireless Select Light Light Phone (Coopérative Cable Cable Relink Payphone Internet Communications LimePhone Phone InternetAccess du Inc. NorddeQuébec TelephoneSystem Corporation deCâblodistribution Inc. (CIA) Provider Inc. del`Arrière ‐pays) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 1.4% 0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.8% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.2% 0.0% 0.0% 0.1% 0.0% Accepted % of all Complaints opansPre andConcludedComplaints 143 25 80 16 0 0 1 3 4 0 1 0 0 0 0 5 0 0 1 1 3 0 3 0 0 0 1 0 9 0 0 0 0 6 2 0 0 0 0 0 8 0 Accepted ‐100.0% ‐100.0% ‐100.0% ‐100.0% 100.0% 200.0% 700.0% ‐50.0% ‐61.5% ‐20.1% ‐40.0% ‐66.7% ‐40.0% ‐50.0% ‐10.0% ‐38.5% 38.9% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Y/Y % Change 145 22 11 81 15 2 0 0 0 0 3 3 0 1 0 6 0 0 0 0 2 0 1 1 0 3 0 0 1 0 0 0 0 0 1 4 3 0 0 0 0 8 Concluded 118 10 65 13 1 0 0 0 0 3 0 10 0 0 0 2 0 0 0 0 0 1 0 0 1 0 0 0 0 6 0 0 0 0 0 0 2 0 0 0 0 5 netgto netgto Recommendation Investigation ‐Investigation Resolved 12 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 7 0 0 0 0 0 0 0 0 0 7 320 0 0 0 0 0 0 0 0 0 1 0 0 0 Closed 13 1 0 0 0 0 0 1 0 0 0 4 0 0 0 1 41 0 0 1 0 1 0 0 1 0 81 0 0 0 0 0 31 0 0 0 1 0 0 3 Resolved 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 1 0 0 0 0 0 Closed 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Issued Decision 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Rejected I‐NetLink Delta Cable Gems ExaTEL Inc. Ilink Giantel Distributel Execulink DolphinTel Falcon InfoFortin Global DSLExtreme Fibernetics InfoSat Fido InnSys Globalive Eastlink Fongo Inter.net Canada Easy Freedom Globalstar FreePhoneLine.ca Interhop Gold EasyVoice Galilee G3 Telecom eFirehose Internet LightSpeed Group ofGold Electronic Box iRoam Hook Enhanced italkBB Horizon Enter‐net Juno HuronTel Communications Office LeafTelecom Communications Telecom Inc. Mobile InternetServices CrossingTelecommunications Communications Telecom PhoneLines Wireless Communications VOIPCommunications Telecom Telecom Communications Phone Solutions Line

Ltd. Communications Inc. Inc. Corp. Limited Provider Canada Ltd. 0.0% 0.0% 0.0% 0.0% 0.0% 0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 6.1% 0.0% 0.0% 0.2% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% Accepted % of all Complaints opansPre andConcludedComplaints 607 32 22 10 1 0 0 0 0 4 0 0 0 0 0 0 1 0 0 0 0 0 0 2 0 1 0 4 0 3 0 0 1 1 0 0 2 0 0 8 1 0 Accepted ‐100.0% 300.0% 100.0% 100.0% ‐75.0% ‐57.9% ‐32.9% ‐33.3% 46.7% 14.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% ‐ ‐ ‐ ‐ Y/Y % Change 625 35 20 0 1 0 0 0 0 0 0 0 3 0 0 0 0 1 0 0 0 2 0 0 0 0 1 0 5 0 0 0 0 1 1 9 0 0 0 3 6 1 Concluded 547 20 15 0 0 0 0 0 0 0 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 210 0 0 0 1 4 0 0 0 0 3 0 netgto netgto Recommendation Investigation ‐Investigation Resolved 27 0 0 0 1 0 2 0 0 0 0 0 0 0 0 0 0 0 0 0 3 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Closed 27 0 0 0 0 0 7 0 0 0 0 0 0 0 0 1 0 0 0 0 2 0 2 0 0 0 0 0 0 0 0 0 1 0 41 0 0 0 2 12 1 Resolved 24 0 0 0 0 0 0 6 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Closed 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Issued Decision 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Rejected Nucleus K‐Right Net ForLess NuEra MTS Inc. Kokanee Phone OneConnect Services Mustang Net Reach NetAccess Koodo OnlineTel MyConnexion Le pigeon Ontarioeast.net Netfone National LooneyCall Ontera National NetRevolution LuckyCall Opcom Hospitality Navatalk NetZero Magic JackTel Orbitel NCIC OperatorServices NEWT Business Mastercall Oricom NECC Nobel Owtel NECC CA MCI Canada PageNet Neighborhood Northern Tel Mobilicity Northwestel Mountain Canada Telecom Communications Internet Information Capital Teleconnect Technologies voyageur Cablevision SystemsInc.

Telecom Wireless Services FreeNet Solutions Service Inc. Limited Inc. Inc. Inc. Inc. Provider 0.0% 0.0% 0.1% 0.0% 0.6% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1.8% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.8% Accepted % of all Complaints opansPre andConcludedComplaints 175 60 12 12 78 0 0 9 0 0 0 0 0 1 0 0 0 0 0 0 0 2 0 0 0 1 0 0 4 0 0 0 1 0 0 0 0 0 0 0 2 0 Accepted ‐100.0% ‐100.0% ‐100.0% ‐100.0% ‐40.0% ‐50.0% ‐20.0% ‐50.0% ‐14.3% ‐71.4% 34.5% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1.7% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% ‐ ‐ ‐ ‐ ‐ Y/Y % Change 176 10 64 12 75 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 2 0 0 0 4 0 1 0 0 0 0 1 0 0 0 0 0 0 0 2 Concluded 126 47 43 0 0 0 0 5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 0 0 0 1 0 0 0 0 0 0 9 0 10 netgto netgto Recommendation Investigation ‐Investigation Resolved 16 0 0 0 0 0 0 6 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 Closed 20 24 0 0 0 0 5 0 83 0 0 0 0 0 0 0 0 0 0 0 0 2 0 1 0 0 0 0 2 0 0 0 0 0 0 0 0 0 0 3 0 Resolved 14 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 5 Closed 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Issued Decision 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Rejected Pannu Parlez Pathway PC Mobile PortalOne People's TelGPInc. Premiere Persona Communications Redden.on.ca Petro Canada Premiere RevTel Phone Factory Primus Rocler Technologies Public Rogers Communications Pulse Telecom Phone Power Shaw Simcoe County Sasktel PWHR Solutions Phonebox Simple Sears Connect Questzones Platinum Skydata Seaside Porchlight.ca SecureNet Quinte Sogetel RadioActif Selectcom Solo Selectcom Source CableLtd. Sens‐ Speak Speak net Canada OutWireless(7 Telecom rabais Mobile PhoneInc.(SSTV) Connection Long Communications Communications Conferencing Global Inc. Telecom Information Distance Mobility Long Services Inc. Distanc ‐11) Services Canada Inc. (Seaside Corp. e Provider Ltd. Inc. Cable) 18.2% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1.3% 0.0% 0.0% 0.4% 0.6% 0.0% 0.0% 0.7% 0.1% 0.5% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.2% 0.0% 0.0% 0.0% 0.1% 0.0% Accepted % of all Complaints opansPre andConcludedComplaints 1,814 125 12 44 55 74 48 23 11 0 0 1 0 0 0 0 0 0 4 0 0 0 1 0 5 6 0 0 0 0 4 0 0 1 0 3 2 0 4 0 0 0 Accepted 4,300.0% ‐100.0% ‐100.0% 400.0% 200.0% 100.0% ‐20.0% ‐69.2% ‐57.0% ‐22.9% ‐ ‐47.3% ‐25.0% ‐55.8% ‐56.0% 31.6% 33.3% 23.7% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% ‐ ‐ ‐ ‐ ‐ ‐ Y/Y % Change 1,903 128 15 75 77 56 23 12 0 0 1 0 0 0 5 0 0 0 0 0 0 7 0 0 3 0 6 0 0 0 0 1 4 0 0 3 2 0 0 4 0 0 Concluded 1,612 105 46 59 42 16 0 0 0 81 0 0 0 0 0 3 0 0 0 0 0 0 0 0 0 1 0 0 2 0 0 0 0 0 0 0 1 0 0 1 2 0 netgto netgto Recommendation Investigation ‐Investigation Resolved 50 0 0 0 0 0 0 0 0 0 0 0 0 1 0 221 0 0 250 2 0 0 185 0 0 0 0 0 0 0 0 0 0 0 0 13 3 0 0 0 0 Closed 175 1 12 0 0 1 0 6 0 0 0 0 0 2 0 0 0 0 0 0 0 0 2 0 6 2 0 0 0 0 0 2 10 0 21 0 7 0 8 Resolved 66 0 0 0 1 0 0 0 0 0 0 0 0 0 4 6 0 0 0 4 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 3 0 Closed 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Issued Decision 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Rejected Spectravoice TekSavvy Solutions tbaytel Tata Talkit.ca Talk Talk Talk Switchworks SureNet Startec Tel Teliphone Telehop Télébec Tele Targo Communications Telnet Telizon TELUS TeraGo Networks Vancouver Uniserve Transvision Tough ThinkTel Vianet Verizon VIF Vidéotron Velcom Vbuzzer Virgin Mobile Velocity VMedia Voice Network Westman WiMac Tel Wightman Vonage Canada WestNet Wireless Vois ‐Synergy Internet

Canada

‐Page Inc. Communications Wireless & Save Communications

Communications Internet Country Networks

Inc. Communications Corp

Telecom s.e.n.c. TelephoneCompany Cookshire Canada Communication Inc. Solutions Corporation Inc. / Inc. Inc. Videotron Inc.

Company Group Provider

GP s 0.0% 0.0% 0.3% 0.0% 0.0% 0.2% 0.4% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.2% 0.0% 0.0% 4.7% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 3.1% 6.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.5% Accepted % of all Complaints opansPre andConcludedComplaints 466 313 608 26 16 40 13 16 11 50 0 0 1 0 0 0 0 1 0 3 0 0 2 1 0 3 3 0 0 3 1 0 0 1 2 0 1 1 0 2 0 1 Accepted ‐100.0% ‐100.0% ‐ 200.0% ‐24.5% ‐ ‐28.6% ‐25.4% ‐ ‐71.4% 100.0% 44.4% 23.1% 50.0% 44.4% 50.0% 11.1% ‐8.3% 50.0% 85.7% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 6.7% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 6.5% 0.0% 0.0% ‐ ‐ ‐ ‐ ‐ ‐ Y/Y % Change 482 293 614 35 29 15 13 20 14 48 0 0 0 1 1 1 0 0 0 0 3 0 0 2 1 1 2 2 3 0 0 0 4 1 1 0 0 0 1 1 0 1 Concluded 286 217 381 26 16 32 0 9 0 0 0 0 1 0 0 9 7 0 0 0 1 0 0 0 0 0 0 1 0 0 1 0 1 1 3 0 0 0 0 0 1 1 netgto netgto Recommendation Investigation ‐Investigation Resolved 59 23 420 0 36 0 0 0 0 0 0 0 1 0 2 0 0 0 10 0 0 0 0 0 0 0 0 0 0 0 0 6 0 0 0 0 0 0 0 0 0 Closed 138 79 43 12 0 51 0 0 0 0 0 0 0 6 7 0 0 0 10 2 1 0 0 0 21 1 0 1 0 0 0 7 0 0 0 0 1 0 0 Resolved 5 27 71 1 0 0 0 0 0 0 0 0 2 4 0 1 1 0 1 0 0 0 0 0 1 0 0 2 0 0 4 0 0 0 0 0 8 Closed 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 2 0 0 0 0 0 0 0 0 Accepted 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Issued Decision 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Rejected Win World WIND Worldline WTC Zid Xittel Zoomer Xplornet Total Yak Yesup Yesupnet Youmano YourLink Internet Communications ‐tel Communications Inc. ‐Link Mobile InternetServices Inc. Communications Corp. Corp. Inc. Provider 100.0% 7.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 1.0% 0.1% 0.0% 0.0% 0.0% 0.0% Accepted % of all Complaints opansPre andConcludedComplaints 9,988 702 101 11 0 4 7 0 1 0 3 0 0 1 0 Accepted ‐ 600.0% 100.0% 37.6% 50.0% 37.5% 0.0% 0.0% 4.1% 0.0% 0.0% 0.0% ‐ ‐ ‐ ‐ Y/Y % Change 10,238 722 103 11 0 3 4 1 0 0 2 0 0 1 0 Concluded 6,952 329 67 0 1 1 1 0 0 0 423 0 0 0 1 netgto netgto Recommendation Investigation ‐Investigation Resolved 534 0 4 0 0 0 0 0 0 0 82 0 0 0 Closed 1,942 305 0 2 3 0 0 0 1 0 0 0 0 0 Resolved 766 57 0 0 0 0 0 0 0 0 8 0 0 0 Closed 27 36 0 0 0 0 0 0 1 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 852 0 0 0 0 Issued Decision 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Accepted 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Rejected Appendix B: Detailed Analysis of Issues Raised in Complaints from August 01 2014 to July 31 2015 This table details the issues raised in the complaints that we concluded between August 01 2014 and July 31 2015. The total number of issues exceeds the number of complaints concluded because some complaints raised more than one issue. s stance stance Total Internet Wireless and VoIP and Directory directorie assi White page page White Long Distance Distance Long Local Exchange Exchange Local Operator services Operator Billing 1,510 311 4,345 2,203 3 6 1 8,379 30-day cancellation policy 248 6 451 258 0 0 0 963 3rd party charges 2016 60 0 0 0 096 Airtime 0 0147 0 0 0 0147 Bandwidth usage 0 0 0 182 0 0 0 182 Bill delivery 57 9 216 89 0 0 0 371 Fees for paper billing 7 3 12 10 0 0 0 32 Invoices not received 50 6 204 79 0 0 0 339 Bundling discounts 94 1 28 109 0 0 0 232 Calling Cards 0 4 0 0 0 0 04 Balance clearing 0 1 0 0 0 0 0 1 Fees not disclosed 0 1 0 0 0 0 0 1 Wrong rate 0 2 0 0 0 0 0 2 Chargeable messages 0118 154 0 0 0 0272 Detailed Analysis of Issues Raised in Complaints from August 01 2014 to July 31 2015 Total Internet Wireless and VoIP and Directory assistance directories White page page White Long Distance Long Local Exchange Exchange Local Operator services Operator Billing 1,510 311 4,345 2,203 3 6 1 8,379 Credit/refund not received 161 24 497 249 1 0 0 932 Data charges 0 0679 0 0 0 0679 Long distance toll fraud 026 0 0 0 0 026 Misapplied payments 36 3 126 45 0 0 0 210 Monthly price plan 613 82 708 919 2 0 0 2,324 Government and regulatory fees 1 0 8 1 0 0 0 10 Incorrect Charge 612 82 700 918 2 0 0 2,314 One-time fees 132 6 419 207 0 0 0 764 Activation/reactivation charges 51 2 96 69 0 0 0 218 Deactivation charges 30 0 54 17 0 0 0 101 Equipment charges 32 0 195 93 0 0 0 320 Late-payment fees 19 4 74 28 0 0 0 125 Payper use services 11 024 0 0 6 142 Payment arrangement dispute 23 2 66 19 0 0 0 110 Pre-authorized payments 81 13 134 74 0 0 0 302 Incorrect amount 22 1 43 15 0 0 0 81 Incorrect bank account/credit card 3 0 7 2 0 0 0 12 Not authorized 56 12 84 57 0 0 0 209 Pre-paid service 0 090 0 0 0 090 Balance clearing 0 0 35 0 0 0 0 35 Fees not disclosed 0 0 8 0 0 0 0 8 No invoice 0 0 1 0 0 0 0 1 Top-up 0 0 36 0 0 0 0 36 Wrong rate 0 0 10 0 0 0 0 10 Premium text messaging charges 0 014 0 0 0 014 Rental equipment 1 0 0 14 0 0 0 15 Modem 0 0 0 14 0 0 0 14 VoIP hub 1 0 0 0 0 0 0 1 Detailed Analysis of Issues Raised in Complaints from August 01 2014 to July 31 2015 Total Internet Wireless and VoIP and Directory assistance directories White page page White Long Distance Long Local Exchange Exchange Local Operator services Operator Billing 1,510 311 4,345 2,203 3 6 1 8,379 Repair charges 5 0 0 13 0 0 0 18 Charges incorrect 1 0 0 5 0 0 0 6 Charges not disclosed 2 0 0 7 0 0 0 9 Inside wiring 2 0 0 1 0 0 0 3 Roaming charges 0 0322 0 0 0 0322 Text messagingcharges (not premium) 0 087 0 0 0 087 Transfer of Responsibility 10 1 41 12 0 0 0 64 Value-add services 18 0 82 13 0 0 0 113 Detailed Analysis of Issues Raised in Complaints from August 01 2014 to July 31 2015 Total Internet Wireless and VoIP and Directory assistance directories White page page White Long Distance Long Local Exchange Exchange Local Operator services Operator Contract dispute 947 97 3,557 1,385 2 0 0 5,988 Compliance with Terms of Service/Contract 152 21 630 421 0 0 0 1,224 Breach of Contract 73 6 302 134 0 0 0 515 Material contract change 24 2 101 95 0 0 0 222 Material contract change without notice 55 13 227 192 0 0 0 487 Contract duration/Length of Term 21 1 76 14 0 0 0 112 Contract renewal 117 5 36 63 0 0 0 221 Auto-renewal 84 4 8 53 0 0 0 149 No consent 33 1 28 10 0 0 0 72 Early Termination Fees (ETF) 230 10 832 212 0 0 0 1,284 Amount of ETF 57 3 309 49 0 0 0 418 Legitimacy of ETF 173 7 523 163 0 0 0 866 Incentive/Hardware plans 0 021 4 0 0 025 No consent provided 74 12 165 82 0 0 0 333 Non-disclosure of terms/Misleading information about terms 352 48 1,485 588 2 0 0 2,475 Warranties 1 0312 1 0 0 0314 Extended warranty purchased from service provider 0 0 95 0 0 0 0 95 Manufacturer`s Warranty 1 0 217 1 0 0 0 219 Detailed Analysis of Issues Raised in Complaints from August 01 2014 to July 31 2015 Total Internet Wireless and VoIP and Directory assistance directories White page page White Long Distance Long Local Exchange Exchange Local Operator services Operator Service delivery 938 107 1,756 1,323 0 0 0 4,124 Customer-initiated cancellations 292 47 340 345 0 0 0 1,024 Cx cancellation due date not kept/delayed 120 16 130 171 0 0 0 437 Unable to cancel 101 29 165 174 0 0 0 469 Unable to port 71 2 45 0 0 0 0 118 Device placedon blacklist 0 0 5 0 0 0 05 Disconnection/Suspension of service 100 11 425 118 0 0 0 654 Acceptable use policy 3 1 79 4 0 0 0 87 Bandwidth/Data over-consumption 0 0 15 3 0 0 0 18 Fraud 2 1 10 5 0 0 0 18 Non-payment/collections 71 9 266 82 0 0 0 428 Partial payment 9 0 16 8 0 0 0 33 Seasonal suspension 15 0 39 16 0 0 0 70 Installation/Activation 137 4 86 216 0 0 0 443 Damage to property 7 0 1 8 0 0 0 16 Install/activate due date not kept/delayed 86 3 44 156 0 0 0 289 Installation error 44 1 41 52 0 0 0 138 Repair/Loss of service 368 22 856 634 0 0 0 1,880 Complete loss of service* 124 10 180 120 0 0 0 434 Damage to property 1 0 0 4 0 0 0 5 Inside wiring 0 0 0 2 0 0 0 2 Intermittent/Inadequate quality of service 189 12 628 444 0 0 0 1,273 Outside wiring 5 0 0 7 0 0 0 12 Service repair/loss due date not kept/delayed 49 0 48 57 0 0 0 154 Service provider/Account sold 3 2 3 1 0 0 09 Transferred wrong number or service 12 113 1 0 0 027 Unauthorized transfer of service 2620 28 8 0 0 082 Further to inquiry 18 11 21 5 0 0 0 55 Further to solicitation 8 9 7 3 0 0 0 27 Detailed Analysis of Issues Raised in Complaints from August 01 2014 to July 31 2015 Total Internet Wireless and VoIP and Directory assistance directories White page page White Long Distance Long Local Exchange Exchange Local Operator services Operator Credit management 126 19 556 134 0 0 0 835 Credit limit 1 130 1 0 0 033 Disputes limit amount 0 0 4 0 0 0 0 4 Exceeded limit 1 1 17 1 0 0 0 20 Spending limit/other details not disclosed 0 0 9 0 0 0 0 9 Credit reporting 109 12 460 123 0 0 0 704 Security deposit 16 6 66 10 0 0 0 98 Disputes deposit amount 1 0 6 0 0 0 0 7 Disputes requirement for deposit 3 0 10 2 0 0 0 15 Interest 0 0 1 0 0 0 0 1 Not refunded 12 6 49 8 0 0 0 75

TOTAL 3,521 534 10,214 5,045 5 6 1 19,326