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Topics: Connected Continent
Organisations: Rewheel

rewheelconnected continentfinland

Rewheel Ltd. Finland

www.rewheel.fi

17 October 2013

Stakeholder input to the public consultation launched by the ITRE (Industry, Research and Energy) Committee of the European Parlament

regarding the European Commission’s

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

laying down measures concerning the European single market for electronic

communications and to achieve a Connected Continent, and amending Directives

2002/20/EC, 2002/21/EC and 2002/22/EC and Regulations (EC) No 1211/2009

and (EU)No 531/201

By Rewheel Ltd, Finland

Submitted: 4th November 2013

About Rewheel

Rewheel Ltd is a Helsinki, Finland based boutique strategy advisory firm specialising in mobile data. During the last 4 years Rewheel has advised over ten European mobile operators and several national regulatory authorities (NRA). Rewheel has industry leading insights and experience in both the technology and economics aspects of data-centric business models: Rewheel has been deeply involved in five European spectrum auctions (either from operator or from the regulator side), advised many EU mobile operators (independent challengers and members of Tier1 telco groups) on network deployment/upgrade (3G/4G) strategy, WiFi offload trategy, spectrum strategy, integrated mobile data investment, cost and profitability modelling, passive and active network sharing trategy, spectrum pooling, fixed-mobile convergence strategy. Rewheel has advised several EU mobile operators (independent challengers as well as members of Tier-1 telco groups) in sourcing state-of-the art mobile network infrastructure and negotiating commercially viable contracts with the mobile infrastructure suppliers.

Rewheel’s

views and reports have been cited by Mr. Joaquin

Almunia, the Competition Commissioner of the EU. Rewheel

’s industry insights are

often quoted by Reuters, Bloomberg, Financial

Times, The New York Times, Handelsblatt and telecom specific media.

Contact information

For further information regarding this contribution please contact Mr. Antonios Drossos, managing partner of Rewheel at +358442032339 or antonios.drossos@rewheel.fi

Motivation: mobile internet access will be the next big thing after energy

As Ericsson’s CTO has recently stated, Radio

spectrum will soon become scarcer

than oil. That is, after energy, the next big thing

will certainly be mobile internet access. Rewheel is deeply concerned that the Connected Continent package lays the foundation for an unprecedented level of concentration and control

in the hands of a few selected EU champions.

To make matters worse, in many countries there are only few network operators and the barriers to entry are high.

This is because the spectrum is limited and building a network expensive. This is the reality of mobile telephony markets in Europe today. And this is the context in which some operators keep asking us to favour consolidation in the industry. I fully share the call for a Single Market for telecommunications made this week in Barcelona by Neelie Kroes. The industry would do well to consolidate across national borders, if that meant lower prices and new and better services. But let us not forget that around 80% of mobile-phone subscriptions are with four leading European groups. This market structure has not brought us closer to a Single Market for cell-phones; one where we can actually buy and use mobile services freely across the EU. Instead, roaming fees remain high and prices vary a great deal.

Research shows

that users pay up to ten times more to use their smartphones in those Member States where there is no challenger to the big European operators.

Moreover, as long as markets remain fragmented along national borders, there is no evidence that operators will invest more if they scale up. So, the risk here is that some incumbents could play an asymmetric game in which they can move in the Single Market without restrictions whereas their users and business customers cannot escape from their national borders.

Joaquin Almunia

Rewheel

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Rewheel Ltd. Finland

www.rewheel.fi

17 October 2013

Related Rewheel contributions

During 2013 Rewheel has met and provided its input to a number of EU Commission officials:

DG COMP, COMP.C.1 and COMP.C.5 on three pre-scheduled occasions

DG CNECT, CNECT.DDG2.B.1, CNECT.DDG2.B.2, CNECT.DDG2.B.3, CNECT.DDG2.B.4, CNECT.DDG2.B.5 on three precheduled occasions

Vice President Kroes Cabinet on one unscheduled meeting, briefly touching upon the key issues: Ryan Heath Spokesman, Pearse O'Donohue Deputy head of cabinet

The reports and presentations used on these meetings are all available on-line at insights.rewheel.fi

Further to providing inputs to the European Commission, Rewheel has also submitted its reports to BEREC, as well as several EU Member State government representatives and MEPs.

In addition to the meetings and written submissions, d

uring the past month Rewheel’s partners have engaged into a public debate

on Twitter with the European Commission about the Connected Continent package, under the twitter names @AntoniosDrossos (Antonios Drossos) and @rewheelPZ (Pál Zarándy).

Disclosures

Rewheel is a boutique strategic advisory firm privately owned by its partners and earning its income from advising privately owned operators and investors as well as public institutions such as national regulatory authorities. Rewheel also earns income from elling premium reports. Rewheel has NOT been sponsored, supported or even encouraged in any way by any private or public organisations to contribute to the policy debate related to the Single EU Telecom Market.

Rewheel’s views covered in the press Selected articles from January

EU Decelerating transition to utility business models, Ericsson winning, EU losing

Telekommarkanden, Sweden, October 2013)

http://www.svenskanyhetsbrev.se/Telekommarknaden/Nyhetsarkivet/Telekommarknaden-Special/2013/10/25/EU- decelerating-transition-to-utility-business-models/

European regulator club challenges Kroes' consolidation fixation

TelecomTV, September

http://telecomtv.com/comspace_newsDetail.aspx?n=50420&id=e9381817-0593-417a-8639-c4c53e2a2a10

European smartphone users face huge price disparities –study,

Findings could affect debate in Brussels on telco reforms

(Reuters,

May 2013) http://www.reuters.com/article/2013/05/22/eu-mobile-pricing-idUSL6N0E34FM20130522

Mobile users pay price for digital divide

January

, Financial Times

http://www.ft.com/intl/cms/s/0/b6636c90-5a55-11e2-a02e-00144feab49a.html#axzz2jIsj3Yjp

This ITRE public consultation input is essentially a compilation of the most important Rewheel material already shared with the above mentioned policy/regulatory bodies.

Contents of the contribution

1)

Cover section (this document)

2)

Briefing note submitted to Member States ahead of the European Council (17 October 2013)

3)

LTE adoption

a wrong metric, chosen by DG Connect (new document, 4th November 2013)

4)

Debunking false claims that EU is lagging in 4G

5)

Rewheel impact assessment of the (anti-competitive) roaming provisions of the Connected Continent package

6)

What the Connected Continent is really about: bailout of indebted telcos

APPENDICES (highly relevant Rewheel reports from the last year)

7)

Executive preview: Rewheel Price benchmark EU28, US, Switzerland, Norway smartphone tariffs with unlimited minutes and SMS (October 2013)

8)

Rewheel Flash Report: Consolidation in Austria and Germany and

EU’s Telecom Single Market

mess (September

2013)

9)

Full report: Rewheel EU27 Mobile data cost competitiveness report (May 2013)

10)

Executive preview: Rewheel smartphone tariff competitiveness report (December 2012)

Telcogroups' protective pricing widens the digital divide between poor and wealthy EU member states

Part #2 Briefing note submitted to Member States ahead of the European Council (17 October 2013)

Rewheel Ltd. Finland

www.rewheel.fi

17 October 2013

Briefing note ahead of the European Council digital economy summit 24-25 October 2013

regarding the European Commission’s

Proposal for a

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

laying down measures concerning the European single market for electronic

communications and to achieve a Connected Continent, and amending Directives

2002/20/EC, 2002/21/EC and 2002/22/EC and Regulations (EC) No 1211/2009

and (EU)No 531/201

Introduction The 2013 spring European Council stressed the importance of the digital single market for growth and called for the Commission to present (in time for the October European Council) concrete measures to establish a Single Market in ICT as early as possible.

What is the Commission trying to achieve with this new regulation? The general objective of the proposal is to move towards a single market for electronic communications.

What is this action necessary according to the Commission? ... due to fragmented national markets, consumers in Europe face less choice, services which are less innovative and of lower quality...

What was

the Commission’s motivation?

Europe is falling behind the US in telecoms

Neelie Kroes Vice President of the European Commission in charge of the Digital Agenda: Europe, once an ICT leader, is now lagging behind. Japan, South Korea and the USA combined have around the same population as the EU

but over 8 times more fixed fibre

broadband, and almost 1 times more G.

and

For

mobile, average European data speeds are half of those of the US

DEBUNKING THE BIG TELCO LOBBY CLAIM THAT EUROPE IS FALLING BEHIND echoed by Commission officials Rewheel

’s

independent, factual research, cited by Joaquin Almunia Vice President of the European Commission in charge of

Competition Policy showed that European consumers pay 5 times less, use more mobile data and enjoy faster network speeds than US consumers.

So what is the Connected Continent package really about...? While telecom revenues have been flat or declining across Europe big EU telcos (Vodafone, Deutsche Telecom, Telefonica, Orange, Telecom Italia and KPN Netherlands) have been investing little while paying high dividends to their owners. Telefonica

’s,

Telecom

Italia

’s

and KPN

’s

net debt is 50 billion, 30 billion and 10 billion euros respectively. Most recently,

Telecom Italia’s bonds have been

downgraded to junk.

Vice President Neelie Kroes

The telecoms sector hasn't had its Lehman moment yet. But with declining revenues, rising debt, dated

business models, I worry about that happening

Telecom analyst Robin Bienenstock of

Bernstein

KPN took on incremental debt to pay out cash to its shareholders it couldn't afford

and

For years, the largest Dutch telecoms provider paid huge dividends and bought back shares rather than invest.

... it is a debt-loaded big telco bailout subsidized by Europeans through consolidation & higher consumer prices The Commission has put forward the Connected Continent regulatory framework to promote consolidation rather than competition across Member State national markets which will lead to higher consumer prices and more revenue concentration for big EU telcos. A part of the Commission is orchestrating a failed debt-loaded big EU telco bailout.

So how will the Connected Continent package achieve its goal to create pan-European operators that will control consumer prices and increase further their sector revenue share across the EU28 Member States?

Through a loss of Member State sovereignty in a number of areas. Namely;

The Single EU authorization in essence transfers the regulatory control of operators present in a Member State from the Host regulator to the so called Home regulator. The Home regulator means the regulator of the member state where the

operators’ main establishment is.

For example the Czech regulator will lose the power to suspend or withdraw the license

of Deutsche Telekom, Telefonica and Vodafone. That power will be transfered to the Home Member States being, Germany, Spain and UK respectively

Rewheel

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Rewheel Ltd. Finland

www.rewheel.fi

17 October 2013

The Spectrum harmonization provisions in essence transfer control from Member State governments and regulatory authorities to the Commission. The Commission grants itself the right to delay by one year spectrum auctions planned by Member States on various spectrum and assignment conditions harmonization grounds or simply because of unequal treatment of Pan-European operators (e.g. If Vodafone has gained access to the 800MHz band it shall do so in all Member States otherwise its ability to offer a Pan-European service could be compromised). Moreover, the Commission can overwrite by means of Implementing acts essential spectrum assignment conditions across the EU that could significantly lower government revenues from future spectrum auctions. So Member States will effectively shed control of domestic competition, domestic investments, prices, and spectrum revenues from the telecom sector

The net-neutrality rules while designed to ban throttling of popular (free) internet based applications such as Skype will introduce a two-tiered internet across the Member States whereby operators could provide prioritized higher quality or ervice for selected internet applications on a paid basis. This will limit the available bandwidth for all remaining applications leading to a lower quality service and a 2-tier internet. In a protected oligopoly where all operators agree on constraining Gigabyte allowances (like they do in many EU member states today), operators will be able to offer much higher data volumes to their own specialised services such as e.g. cloud computing or video streaming (note: Google reported that today 40% of youtube is consumed on mobile devices up from 6% two years ago). Alternatively operators, the gatekeepers of bit pipes, for extra compensation may offer the required cloud computing or video streaming capacity to their preferred partners, on a commercial basis

in this what crippling alternative streaming, cloud computing

providers or any other providers of new, innovative, bandwidth intensive services.

And what about abolishing roaming, the popular jewel of the Connected Continent package? The Commission is arguing that the Connected Continent package will abolish roaming. However, roaming has already been dealt with in an existing EU Regulation adopted in 2012. From 1 July 2014 consumers from all Member States will be free to choose a different roaming provider, and pay domestic rates while they roam, without the need to change their SIM cards i.e. decoupling. The measure in Regulation 531/2012 applies non-discriminatory to all MNOs operating in all EU Member States and across all Member States.

So why abolishing roaming again? Because this time big EU telcos get a preferential treatment The Commission decided this time around to grant a discriminatory exemption from decoupling to big EU telcos. Big telcos are given 2 years to eliminate roaming premiums in all their retail packages. Small operators, unable to join a roaming alliance, should eliminate roaming premiums in all of their retail packages by 1 July 2014, in any of the 28 Member States visited by any of their customers or risk lose their customers while roaming.

Member States most affected by the changes Smaller Member States protected markets where the big telcos dominate (e.g. Hungary, Czech, Slovakia, Greece, Portugal, etc.) and competitive markets where the big telocs are not present (e.g. Nordics, Austria, UK, Netherlands) have most to lose if the Commission proposal becomes EU law.

Ericsson and Huawei will also benefit from maintaining the protected markets status quo while challenger LTE vendors Nokia Solutions & Network, Alcatel Lucent as well as ZTE, Samsung, NEC would rather benefit from the intensifying infrastructure based competition.

Budgeted government revenues from the sale of spectrum will be in jeopardy already in 2014, big telco subsidiaries in protected markets will effectively cement their positions and kill competition, smaller independent operators in competitive markets will be weaken further and become easy prey for big telcos.

EU’s

newest, less developed Member States will no longer be able to control the price of fuel (i.e. mobile data cost) for their digital

economies and they will fall further behind in the digital divide. EU’s most

data progressive economies such as the Nordics, UK,

Austria and Netherlands will be jeopardising the future of their competitive markets and dynamic digital economies by weakening their domestic independent operators.

Head of a National Regulatory Authority on twitter: It’s a pity EC did not consult BEREC before adopting the package. Too

much nonsense inside.

Part #3 LTE adoption

a wrong metric,

chosen by DG Connect (new document, 4th November 2013)

Slide | 1

© Rewheel Ltd. All rights reserved.

Debunking the claim that Europe is lagging behind in LTE

Why the LTE adoption (subscriptions) metric is deceptive!

If big EU telcos (Deutsche Telekom, Vodafone, Telefonica, Orange, Telekom Italia and KPN) were to do the same, overnight the EU could count over 50 million LTE subs and surpass US, SKorea & Japan!

Rewheel estimate based on big telco footprint in DE, FR, IT, UK, ES and NL and assuming a similar mix of LTE subscribers as a share of total subscriptions with 3 UK

It has been widely reported that Europe is lagging behind in LTE adoption. According to

Informa’s

WCIS research by March 2013 only 4% of LTE

ubscribers were Europeans

However, the LTE subscriber metric is misleading

The metric greatly favours operators such as Verizon which do not differentiate their tariff pricing between 3G and 4G. So all new and existing customers with LTE terminals are reported as LTE subscriptions

On the contrary big telcos in Europe are selling LTE at a premium over 3G at price levels unaffordable to the mass market. So subscribers in Europe stick to 3G (HSPA) networks which work very well and are far superior than 3G in US

Note that Sweden has 14x, Austria has 4x higher LTE subscriber penetration than Germany (Deutsche Telekom, Vodafone, Telefonica, KPN) despite being some 10x smaller countries (i.e. the metric chosen by DG Connect does not support DG

Connect’s

scale argument behind favouring

large pan-EU mobile network operators)

source: Informa, March 2013

http://www.telecoms.com/wp-content/blogs.dir/1/files/2013/06/MCI180.pdf

3 UK will launch LTE on December 2013 and will offer LTE free of charge to all of its customers. Overnight 3 UK will become the operator in Europe with the largest LTE subscriber base (1.5 million)

http://www.telecoms.com/176812/ee-leads-europe-with-1-million-lte-subscribers/

Vice President Kroes and the European Commission (DG CONNECT) have repeatedly echoed ETNO claims that Europe is lagging behind.

Europe, once an ICT leader, is now lagging behind... Japan, South

Korea and the USA have... almost 1

times more

G. 11th

Sept 2013

Slide | 2

© Rewheel Ltd. All rights reserved.

Is Germany (Deutsche Telekom, Vodafone, Telefonica, KPN E-

Plus, 80m pop market) the template in EC’s mind for the

#Connected Continent?

Rewheel hopes not

Source: NRA websites

Source: Informa

a 1.3m pop market

Part #4 Debunking false claims that EU is lagging in 4G

Debunking GSMA & ETNO claims (echoed by some Commission officials) that EU is falling behind the US

Investments

fixed and mobile broadband

mobile data usage

network speeds

consumer prices

Brussels 17 October 2013 Presented to DG Competition, DG CNECT, submitted to BEREC, Member States governments & ECTA

Rewheel

© Rewheel Ltd. All rights reserved.

Rewheel

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t e p

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Slide | 2

© Rewheel Ltd. All rights reserved.

Genuine single European telecom market as envisaged by Vice President Almunia

Vice President Kroes’s Connected Continent proposal, as it stands, will without

any doubt, not bring us any closer to a genuine single European telecom market

“First, it would be a market where

customers can obtain services from any of the operators

present in the EU, regardless of location;

Second, operators from any Member State could offer their services competitively to end customers throughout the EU; and

Finally, in a genuine Single Market customers would not have to pay extra charges for intra-EU calls, or for roaming within the EU

which is one of the provisions included in the Regulation

approved this week.

Market participants should also resist the temptation to use their commercial behaviour to create artificial barriers to intra-EU trade. Some mobile operators, active across several Member States, do not behave as truly European operators. This needs to change.

But the risk is that the big incumbents may want to continue playing an asymmetric game in which they can move across the entire Single Market whereas their users and business customers cannot escape from their national borders.

Slide | 3

© Rewheel Ltd. All rights reserved.

Roaming aside, what are the commercial barriers and this asymmetric game that Almunia is referring to?

Big telcos price at competitive levels only in markets where they face challenger MNOs. In protected oligopolies they charge up to 266% more!

The full chart can be found in Rewheel’s latest premium report

- Price benchmark of smartphone tariffs with unlimited minutes & SMSs

in EU28, US, Switzerland and Norway

October 2013

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€90

Euro

Big European telco pricing in protected oligopolies and in competitive markets

2GB basket smartphone tariff with unlimited minutes & SMS

Challangers that the E4 face in competitive markets

+126%

+266%

+115%

+67%

The big EU telco groups price at competitive level only in markets where they face challanger MNOs. In protected oligopolies they charge up to 266% more

Source: Rewheel report October 2013 © All rights reserved

Slide | 4

© Rewheel Ltd. All rights reserved.

Vodafone MNOs charge up to 320% more per GB in 3 and 4 player protected oligopoly markets than what Vodafone UK charges in the UK's competitive market

The full chart can be found in Rewheel’s latest premium report

- Price benchmark of smartphone tariffs with unlimited minutes & SMSs

in EU28, US, Switzerland and Norway

October 2013

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GB included in smartphone tariffs with unlimited minute & SMS

Vodafone group MNO GB prices across 12 European markets where it is present

Smartphone tariffs with unlimited minutes and SMS

The trend line slope shows the approximate variable, GB volume dependent price while the crossing point on the Y axis marks the approximate data-traffic independent fixed tariff charge

Rewheel report October 2013 © All rights reserved

Vodafone MNOs charge up to 320% more per GB in 3 and 4 player protected oligopoly markets than what Vodafone UK charges in the UK's competitive market

The trend line slope shows the approximate variable, GB volume dependent price while the crossing point on the Y axis marks the approximate data-traffic independent fixed tariff charge

Rewheel report October 2013 © All rights reserved

Vodafone MNOs charge up to 320% more per GB in 3 and 4 player protected oligopoly markets than what Vodafone UK charges in the UK's competitive market

Roaming aside, what are the commercial barriers and this asymmetric game that Almunia is referring to?

Slide | 5

© Rewheel Ltd. All rights reserved.

Would consolidation and big telco dominance lead to higher investments as GSMA and ETNO claim? Lets put their claim to the test...

In protected oligopoly markets like the US and Switzerland where the revenue per capita is higher operators have invested higher absolute amounts in 2010-2011. However, this is also true for the very competitive data progressive, low price Nordic markets. Investments as a share of revenues are the same across EU and US.

0

150

300

450

600

750

900

1,050

1,200

annual telecom revenue per capita 2010-2011

Source EC digital scoreboard, OECD

Competitive market where a challenger is present Protected oligopoly where no challenger is present

€1,585

©Rewheel 2013. All rights reserved.

21%

13%

12%

10%

10%

13%

15%

13%

0

20

40

60

80

100

120

140

160

180

200

annual telecom investment per capita 2010-2011

% of annual telecom revenue per capita invested

Source EC digital scoreboard, OECD

Competitive market where a challenger is present Protected oligopoly where no challenger is present

€295

13%

©Rewheel 2013. All rights reserved.

Slide | 6

© Rewheel Ltd. All rights reserved.

Have investments in overpriced protected oligopolies yielded higher data usage, higher fixed and mobile broadband penetrations?

No. US mobile broadband penetration is similar to that of western European progressive markets. The EU28 average is lower because it includes many eastern European protected markets, e.g. Hungary, with very low penetration caused by the very high price of mobile data i.e.7 times the market ARPU

0% 5%

10% 15% 20% 25% 30% 35% 40% 45%

% of population with fixed broadband connection 2012

Competitive market where a challenger is present Protected oligopoly where no challenger is present

©Rewheel 2013. All rights reserved.

Source EC digital scoreboard, OECD

0%

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

100% 110%

% of population with mobile broadband connection 2012

it includes both smartphone and dedicated data only connections

Competitive market where a challenger is present Protected oligopoly where no challenger is present

©Rewheel 2013. All rights reserved.

Source EC digital scoreboard, OECD

Europeans use more data than Americans

We have serious doubts about the US figure which is an OECD estimate

0.0 0.2 0.4 0.6 0.8 1.0 1.2 1.4 1.6

monthly mobile data consumption per capita 2012 (GBs)

Competitive market where a challenger is present Protected oligopoly where no challenger is present

Source Rewheel anaylsis

©Rewheel 2013. All rights reserved.

Slide | 7

© Rewheel Ltd. All rights reserved.

No. Europeans enjoy faster overall mobile network speeds and 2x faster LTE speeds!

Have investments in overpriced protected oligopolies yielded better and faster mobile networks?

0 1 2 3 4 5 6 7 8 9

10

actual measured fixed network speeds 2012

Competitive market where a challenger is present Protected oligopoly where no challenger is present

©Rewheel 2013. All rights reserved.

Source Akamai report 1Q2013, Rewheel analysis

0 5

10 15 20 25 30 35 40

actual measured LTE network speeds 2011-2013

Competitive market where a challenger is present Protected oligopoly where no challenger is present

©Rewheel 2013. All rights reserved.

Source Rewheel Oct 2013 report

©Rewheel 2013. All rights reserved.

0 5

10 15 20 25 30 35 40

actual measured LTE network speeds 2011-2013

Competitive market where a challenger is present Protected oligopoly where no challenger is present

©Rewheel 2013. All rights reserved.

Source Rewheel Oct 2013 report

©Rewheel 2013. All rights reserved.

Slide | 8

© Rewheel Ltd. All rights reserved.

No. EU28 is in parity with US and among the 19 member state markets where operators have launched LTE, Europe is ahead of US.

The full chart can be found in Rewheel’s latest premium report

- Price benchmark of smartphone tariffs with unlimited minutes & SMSs

in EU28, US, Switzerland and Norway

October 2013

Have investments in overpriced protected oligopolies yielded better and faster mobile networks?

0 1 2 3 4 5 6 7 8 9

10

Actual measured average mobile network speeds in September 2013

in EU28, US, Switzerland, Norway, South Korea and Japan

2G/3G/4G blended as end users experience

EU19 LTE: member state markets where LTE is launched and there were measurement data available at September 2013

©Rewheel 2013. All rights reserved.

Source: Actual enduser measured speeds by OpenSignal, Rewheel analysis

M b ps

GSMA&ETNO claims echoed by VP Kroes are false. Mobile networks are faster in EU than in the US

Slide | 9

© Rewheel Ltd. All rights reserved.

No, Europe is leading the world in superfast LTE speeds. More than 2 times faster than US and 50% higher than South Korea LTE speeds!

The full chart can be found in Rewheel’s latest premium report

- Price benchmark of smartphone tariffs with unlimited minutes & SMSs

in EU28, US, Switzerland and Norway

October 2013

Have investments in overpriced protected oligopolies yielded better and faster mobile networks?

0

5

10

15

20

25

30

35

40

Actual measured average LTE mobile network speeds: July 2011 - September 2013

in EU28, US, Switzerland, Norway, South Korea and Japan

EU19 LTE: member state markets where LTE is launched and there were measurement data available at September 2013

©Rewheel 2013. All rights reserved.

M b ps

Europe is leading the world in superfast LTE speeds. More than 2 times faster than US and 50% higher than

Source: Actual enduser measured speeds by OpenSignal, Rewheel analysis

Highly fragmented national

pectrum band plan in US

Harmonized "LTE" (800, 1800, 2600)

pectrum band plan accross EU28

Slide | 10

© Rewheel Ltd. All rights reserved.

So what would be the price paid for consolidation and big telco dominance?

Consumers in Europe’s competitive

markets pay 5 times less use more data and enjoy faster mobile network speeds than in the US!

The higher absolute investments in the US and Swiss protected oligopolies, which are funded by the very high prices, have not yielded better and faster network services!

The GSMA&ETNO claims, which are echoed by VP Kroes are simple not true.

€29

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Denmark

UK

Austria

EU14

Czech

Republic

Germany

Hungary

US

Switzerland

price of GBs in smartphone tariffs with unlimited minutes and SMS

bar labels: traffic independent fixed charge in smartphone tariffs

Competitive market where a challenger is present Protected oligopoly where no challenger is present

Source Rewheel premium report October 2013

©Rewheel 2013. All rights reserved.

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price of GBs in data only tariffs

bar labels: traffic independent fixed charge in data only tariffs

Competitive market where a challenger is present Protected oligopoly where no challenger is present

Source Rewheel premium report October 2013

©Rewheel 2013. All rights reserved.

Slide | 11

© Rewheel Ltd. All rights reserved.

So what would be the price paid for consolidation and big telco dominance?

Consumers in the German, US and Swiss protected oligopolies pay 500% higher GB prices

than consumers in UK’s competitive market

y = 5.7657x + 34.459

y = 5.8465x + 49.029

y = 5.7037x + 50.913

y = 1.051x + 29.495

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German, US and Swiss protected oligopoly GB prices versus the UK

Smartphone tariffs with unlimited minutes and SMS

UK

€1/GB

Consumers in the German, US and Swiss protected oligopolies pay 500%

higher GB prices than consumers in UK’s competitive market

The trend line slope shows the approximate variable, GB volume dependent price while the crossing point on the Y axis marks the approximate data-traffic independent fixed tariff charge

Rewheel report October 2013 © All rights reserved

Slide | 12

© Rewheel Ltd. All rights reserved.

So what would be the price paid for consolidation and big telco dominance?

Consumers in EU’s protected oligopolies e.g. Germany, Spain, Greece, (ungary pay up to

%

higher GB prices than in EU’s most competitive markets e.g. UK, Sweden, Finland, Denmark,

Austria)

€0

€20

€40

€60

€80

€100

€120

€140

€160

€180

0

20

GB included in smartphone tariffs with unlimited minute & SMS

Protected oligopoly GB prices versus competitive EU market prices

martphone

tariffs with unlimited minutes and SMS

German and US GB pricing resembles more 3 MNO protected olIgopolies such as Swizerland, and Portugal rather than competitive markets such as the UK, Denmark , Austria, Finland

FINLAND

Source: Rewheel report October 2013 © All rights reserved

Slide | 13

© Rewheel Ltd. All rights reserved.

So what would be the price paid for consolidation and big telco dominance?

Big European telco group (e.g. Vodafone and Deutsche Telekom) GB prices are 550% higher than prices from data progressive Nordic incumbents (e.g. TeliaSonera

and

5

% higher than prices from challenger operators’ e.g.

Hutchison)

€0

€10

€20

€30

€40

€50

€60

€70

€80

€90

€100

€110

€120

€130

€140

€150

€160

0

20

GB included in smartphone tariffs with unlimited minute & SMS

Big EU telco versus challenger operator GB prices accross their markets

Smartphone tariffs with unlimited minutes and SMS

Hutchison

Big telcos charge 1500% more

Source: Rewheel report October 2013 © All rights reserve

Slide | 14

© Rewheel Ltd. All rights reserved.

Challengers, beside charging 500% less per GB have faster networks too! So if big telcos swallow challengers EU consumers will start paying 500% more per GB and get lower network speeds

So what would be the price paid for consolidation and big telco dominance?

0

1

2

3

4

5

6

Big telco Telefonica Challenger groups

Hutcison, Tele2, BITE, DNA, Play,

TusMobil, Iliad

Incumbents KPN,

TIM, Telekom

Austria, Belgacom ,

Telenor

Big telco Deutsche

Telekom

Big telco Vodafone

Data progressive

incumbnet

TeliaSonera

Big telco Orange

Challenger

Hutchison

Group actual measured average mobile network speed in September 2013 in EU28

2G/3G/4G blended as end users experience

©Rewheel 2013. All rights reserved.

Source: Actual enduser measured speeds by OpenSignal, Rewheel analysis

Mbps

Hutchison average network speeds are are faster than big telco speeds in EU28!

Slide | 15

© Rewheel Ltd. All rights reserved.

GSMA and/or ETNO claims regarding US market superiority echoed by ome European Commission officials are simply NOT TRUE!

GSMA or ETNO claim

The factual reality

EU consumers pay less per month than U.S

Prices

Not just less, 5x less per GB in both data only and tariffs with unlimited minutes & SMS

U.S. consumers use 2x more data than European consumers

Investments

Usage

Not true, in many of EU’s progressive

(competitive) markets they use 3x more

Speeds

US investment growth is translating into 75% faster speeds

Not true, EU leads the world in fast LTE peeds (2x more US) and is in parity with US on the overall mobile connection speeds

LTE roll out

US operators invested more in recent years

True in absolute terms when compared to EU28. But as a % of revenue they invest the ame with EU operators

Higher investment has yielded faster LTE rollout in the US

Not true, slow legacy 3G networks forced US operators to earlier LTE investments

US consumers pay 5x more for using use less data at slower connections peeds than European consumers

Slide | 16

© Rewheel Ltd. All rights reserved.

Thank you

Contact us at rewheel@rewheel.fi / +358 44 203 2339

Rewheel

is

pecialised

into

being

in

the

forefront

of

the

mobile

data

transformation

Since 2009 we have advised over 10 European mobile operators, including independent players and Tier-1 OpCos, as well as several regulators and a number of private equity and institutional investors

and various mobile-date centric startups.

Since the onset of the mobile broadband centric 900, 1800 and 2100 MHz license renewal avalanche in 2011 in Europe we have been providing strategy, spectrum valuation and auction theory advice (together with our world class CCA/SMRA auction theorist partners) to five European award processes (operator or regulator side depending on country), including new entrants and acquisitions

as well as license renewals in multi-band (typically 800,900,1800,2100 and 2600 MHz) auctions. So

far our advisory support has been directly impacting over EUR 1bn of European spectrum investments/state proceeds.

Rewheel

o n e

t e p

a h e a d

Strategies for meeting mobile connectivity needs of EU’s

Generation Y and Y affordably and profitably

Part #5 Rewheel impact assessment of the (anti-competitive) roaming provisions of the Connected Continent package

Rewheel’s

impact assessment of

Connected Continent roaming provisions

This presentation is an executive preview of

Rewheel’s

upcoming report covering

the planned mobile consolidation in Germany and EC’s Connected Continent

proposal

Brussels 17 October 2013 Submitted to DG Competition, DG CNECT, BEREC, Member States governments & ECTA

Rewheel is a Finland based fully independent strategic advisory firm

© Rewheel Ltd. All rights reserved.

Rewheel

o n e

t e p

a h e a d

Slide | 2

© Rewheel Ltd. All rights reserved.

The existing EU regulatory framework, adopted in 2012, would have effectively abolished roaming in the whole EU!

The existing EU regulations ,Article

4 of EU regulation No 531/2012 effective as of 1 July 2014

,

adopted

in 2012, would have effectively abolished roaming in the whole EU!

The exisitng regulation i.e. decoupling would have applied equally for all EU operators accorss all EU member states!

The domestic service is disconnected from the roaming service and consumers will be free to choose any roaming provider (e.g. offering domestic rates ) without the need to change SIM cards

So why the Commission is granting in the Connected Continent proposal a discriminatory exemption from decoupling to big EU telcos?

Slide | 3

© Rewheel Ltd. All rights reserved.

The Commission grants a discriminatory excemption from decoupling to big EU telcos (Vodafone, Deutsche Telekom, Telefonica, Orange)

Small, ”ordinary” operators must either surrender to big telco demands

or face decoupling i.e. loosing control of their customers while roaming

General exemption from decoupling to any provider subject to two conditions

a)

rates for roaming shall be the same with domestic rates in all retail packages fro 1 July 2014 that include roaming services subject to reasonable use criterion

b)

available in all Member States

Double standard #1 for big telcos: Big telcos are allowed a phased, 2 year delayed adoption of free roaming retail packages

Enough to have only one retail package throughout the Union by 1 July 2014

Enough to have only 50% of customers on such retail packages by 1 July 2015

all retail packages by 1 July 2016

Doubles standard #2 for big telcos: Or they can even get an exemption in 2014 and 2015 by applying a free roaming zone only within their group or by extending the zone with another friendly E4 member

Only 10 Member States and 30% population by 1 July 2014

Only 14 Member States and 50% population by 1 July 2015

Only 17 Member States and 70% population by 1 July 2016

Exemption to apply free roaming across all Member States granted by 1 July 2016 to operator groups that could cover at least 10 Member States and 30% population and were refused access to other bigger roaming alliances

BUT ...

What is the logic?!

What is the logic?!

Slide | 4

© Rewheel Ltd. All rights reserved.

So in plain words the Commission uses double standards in abolishing roaming

Small operators should eliminate roaming premiums in all of their retail packages by 1 July 2014, in any of the 28 Member States visited by any of their customers

Big telcos are given 2 years to eliminate roaming premiums in all their retail packages get a default exemption in 1 July 2014 by simple offering free roaming inside the group

Does not make sense!

Slide | 5

© Rewheel Ltd. All rights reserved.

Big telco become the gate keepers of decoupling!

Member

States

covered

EU 28

Population

coverage

10 Member States 30%

pop. coverage

1 July 2014

14 Member States 50%

pop. coverage

1 July 2015

17 Member States 70%

pop. coverage

1 July 2016

17 Member States 70%

pop. coverage

1 July 2014

Vodafone

12

67%

A breath away

Need to team up with

another E4 member

Need to team up with

another E4 member

Deutsche

Telekom

11

54%

A breath away

Need to team up with

another E4 member

Need to team up with

another E4 member

Telefonica

6

54%

Need to team up with

another E4 member

Need to team up with

another E4 member

Need to team up with

another E4 member

Orange

7

50%

Need to team up with

another E4 member

Need to team up with

another E4 member

Need to team up with

another E4 member

E4

18

90%

Hutchison

6

30%

Others

<6

<5%

Hutchison

+ all others

26

≈71%

Complicated

Impossible

Impossible

Assumption: Telefonica acquires E-Plus in Germany and Vodafone or Orange acquires Yoigo in Spain

Whoever engineered the Connected Continent roaming provisions had well calculated inister objectives. While bigtelco customers are safe the rest of the MNOs shall either urrender to bigtelco demands, scrap roaming fees alltogether or face decoupling!

Slide | 6

© Rewheel Ltd. All rights reserved.

Reasonable use criterion; Backdoor for not really abolishing roaming?

T-Mobile tariffs in Germany that include roaming allowances

How much data under the reasonable use criterion an EU consumer who is in a 3GB domestic tariff can use while roaming abroad during a monthly billing cycle without incurring any additional charge?

In the event that this consumer uses 2GB in 5 days while travelling abroad will he be exceeding the reasonable use criterion and pay for roaming?

a)

€0

b)

€40

(200MB at

€0.2/MB)

c)

€340

(1700MB at

€0.2/MB)

d)

€380

(1900MB at

€0.2/MB)

a)

3GB and pay nothing extra (consumed during one day or during 30 days)

b)

No more than his domestic monthly average usage (e.g. 1.8GB)

c)

No more than his domestic daily average usage (60MB)

d)

No more than the EU average domestic daily average usage (20MB)

And what about speed limitations? Data roaming at slow speeds could be offered at domestic rates while fast speeds will be charged at the current punative rates, see T-

Mobile’s

US

8kbps misleading ”free” data roam

ing

And what about high end tariffs (e.g. T-Mobile DE) that already include small roaming minute and data allowances? Can big telcos fulfil the conditions with such tariffs and get a painless exemption from decoupling ?

Slide | 7

© Rewheel Ltd. All rights reserved.

General decoupling exemption

ʻArticle

4a

1. This Article shall apply to roaming providers which:

(a) apply, by default and in all their respective retail packages that include regulated roaming services, the applicable domestic service rate to both domestic services and regulated roaming services throughout the Union, as if the regulated roaming services were consumed on the home network; and (b) ensure, whether through their own networks or by virtue of bilateral or multilateral roaming agreements with other roaming providers, that the provisions of point (a) are complied with by at least one roaming provider in all Member States.

2. Paragraphs 1, 6 and 7 shall not preclude the limitation by a roaming provider of consumption of regulated retail roaming services at the applicable domestic service rate by reference to a reasonable use criterion. Any reasonable use criterion shall be applied in such a way that consumers availing of the roaming provider's various domestic retail packages are in a position to confidently replicate the typical domestic consumption pattern associated with their respective domestic retail packages while periodically travelling within the Union.

By 31 December 2014, BEREC shall, after consulting stakeholders and in close cooperation with the Commission, lay down general guidelines for the application of reasonable use criteria in the retail contracts provided by roaming providers availing of this Article. BEREC shall develop such guidelines by reference to the overall objective set out in the first subparagraph, and shall have regard in particular to the evolution of pricing and consumption patterns in the Member States, to the degree of convergence of domestic price levels across the Union, to any observable effect of roaming at domestic ervice rates on the evolution of such rates, and to the evolution of wholesale roaming rates for unbalanced traffic between roaming providers. The competent national regulatory authority shall monitor and supervise the application of reasonable use criteria, taking utmost account of the BEREC general guidelines once they are adopted, and shall ensure that unreasonable terms are not applied.

4. Regulated retail roaming charges laid down in Articles 8, 10 and 13 shall not apply to roaming services offered by a roaming provider availing of this Article to the extent that these are charged at the level of the applicable domestic service rate. Where a roaming provider availing of this Article applies charges which are different from the applicable domestic service rate for consumption of regulated roaming services going beyond reasonable use of such ervices in accordance with paragraph 2, or where an individual end user explicitly renounces the benefit of domestic service rates for regulated roaming ervices in accordance with paragraph 3, the charges for those regulated roaming services shall not exceed the retail roaming charges laid down in Articles 8, 10 and 13.

Slide | 8

© Rewheel Ltd. All rights reserved.

Retail package exemption

Not only big telcos get a discriminatory delay but they could keep charging 50% more than domestic rates till 1 July 2016

ʻArticle

4a

6. In the period from 1 July 2014 until 30 June 2016, this Article shall apply to roaming providers which do not fulfill the conditions set out in paragraph 1, when they respect the following conditions:

(a) the roaming provider notifies its own declarataion and any relevant bilateral or multilateral roaming agreements to the BEREC Office in accordance with paragraph 5, making specific reference to this paragraph; (b) the roaming provider ensures, whether through its own networks or by virtue of bilateral or multilateral roaming agreements with other roaming providers, that the conditions of points (c),(d) and (e) are complied with in at least 17 Member States representing 70% of the population of the Union; (c) the roaming provider and any contractual partners within the meaning of point (b) each undertakes to make available and actively offer, at the latest as from 1 July 2014, or as from the date of notification, whichever is the later, at least one retail package with a tariff option according to which the applicable domestic service rate applies to both domestic services and regulated roaming services throughout the Union, as if those regulated roaming ervices were consumed on the home network; (d) the roaming provider and any contractual partners within the meaning of point (b) each undertakes to make available and actively offer, at the latest as from 1 July 2015, or as from the date of notification, whichever is the later, such tariff options in retail packages which, on 1 January of that year, were used by at least 50% of their respective customer base; (e) the roaming provider and any contractual partners within the meaning of point (b) each undertakes to comply, at the latest as from 1 July 2016, with paragraph 1(b) in all of their respective retail packages.

The roaming provider availing of this Article and any contractual partners within the meaning of point (b) may, as an alternative to the undertaking referred to in point (d), undertake, as from 1 July 2015, or as from the date of notification, whichever is the later, that any roaming surcharges applied in addition to the applicable domestic service rate in its various retail packages are, in aggregate, no more than 50% of those applicable in those packages on 1 January 2015, irrespective of whether such surcharges are calculated on the basis of units such as voice minutes or megabytes, of periods such as days or weeks of roaming, or by any other means or combination thereof. Roaming providers invoking this point shall demonstrate compliance with the requirement of a 50% reduction to the national regulatory authority and shall supply all necessary supporting evidence requested of them.

Slide | 9

© Rewheel Ltd. All rights reserved.

Member State exemption

ʻArticle

4a

7. In the period from 1 July 2014 until 30 June 2016, this Article shall apply to roaming providers which do not fulfill the conditions set out in paragraph 1, when they respect the following conditions: (a) the roaming provider notifies its own declaration and any relevant bilateral or multilateral roaming agreements to the BEREC Office in accordance with paragraph 5, making specific reference to this paragraph; (b) the roaming provider ensures, whether through its own networks or by virtue of bilateral or multilateral roaming agreements with other roaming providers, that the conditions of paragraph 1(a) are complied with in at least 10 Member States representing 30% of the population of the Union, at the latest as from 1 July 2014, or as from the date of notification, whichever is the later; (c) the roaming provider ensures, whether through its own networks or by virtue of bilateral or multilateral roaming agreements with other roaming providers, that the conditions of paragraph 1(a) are complied with in at least 14 Member States representing 50% of the population of the Union, at the latest as from 1 July 2015, or as from the date of notification, whichever is the later; (d) the roaming provider ensures, whether through its own networks or by virtue of bilateral or multilateral roaming agreements with other roaming providers, that the conditions of paragraph 1(a) are complied with in at least 17 Member States representing 70% of the population of the Union, at the latest as from 1 July 2016.

Where a roaming provider availing of this Article notifies its own declaration and any relevant bilateral or multilateral roaming agreements to the BEREC Office pursuant to point (a) of the first subparagraph and thereby falls under this paragraph, the notifying roaming provider and any contractual partners within the meaning of point (b) shall each be bound to comply with their respective undertakings to comply with the conditions of paragraph 1(a), until at least 1 July 2018.

Slide | 10

© Rewheel Ltd. All rights reserved.

Exemption due to intentional exclusion from roaming alliances

ʻArticle

4a

8. Roaming providers shall negotiate in good faith the arrangements towards establishing bilateral or multilateral roaming agreements, on fair and reasonable terms having regard to the objective that such agreements with other roaming providers should allow the virtual extension of the home network coverage and the sustainable provision by each of the roaming providers availing of this Article of regulated retail roaming services at the same price level as their respective domestic mobile communications services.

9. By way of exception to paragraph 1, after 1 July 2016, this Article shall apply to roaming providers availing of this Article when those roaming providers demonstrate that they have sought in good faith to establish or extend a bilateral or multilateral roaming agreements on the basis of fair and reasonable terms in all Member States where they do not yet fulfill the requirements of 1 and have been unable to secure any bilateral or multilateral roaming agreement with a roaming provider in one or more Member States, provided they comply with the minimum coverage referred to in paragraph 6(b) and with all other relevant provisions of this Article. In those cases, roaming providers availing of this Article shall continue to seek to establish reasonable terms for conclusion of a roaming agreement with a roaming provider from any unrepresented Member State.

Slide | 11

© Rewheel Ltd. All rights reserved.

Thank you

Visit insights.rewheel.fi for more

Or contact us at rewheel@rewheel.fi / +358 44 203 2339

Rewheel

is

pecialising

into

trategies

to

meet

connectivity

needs

of

EU’s

generation Y and Z profitably and affordably.

Since 2009 we have advised over 10 European mobile operators, including independent players and Tier-1 OpCos, as well as several regulators and a number of private equity and institutional investors and various mobile-date centric startups.

Since the onset of the mobile broadband centric 900, 1800 and 2100 MHz license renewal avalanche

in 2011 in Europe we have been providing strategy, spectrum valuation and auction theory advice

(together with our world class CCA/SMRA auction theorist partners) to five European award processes (operator or regulator side depending on country), including new entrants and acquisitions as well as license renewals in multi-band (typically 800,900,1800,2100 and 2600 MHz) auctions. So far our advisory support has been directly impacting over EUR 1bn of European spectrum

investments/state proceeds.

Rewheel

o n e

t e p

a h e a d

Part #6 What the Connected Continent is really about: bailout of indebted telcos

Slide | 1

© Rewheel Ltd. All rights reserved.

Connected Continent package

What is it really about?

Is EU planning to bail out debt-loaded big telcos that paid high divident and invested little, by relaxing consolidation rules and turning a blind eye to consumer price hikes?

VP Kroes

The telecoms sector hasn't had its Lehman moment yet. But with declining revenues, rising debt, dated

business models, I worry about that happening

Speech 20 Sept 2013

Ryan Heath Spokesman of Neelie Kroes

Some

telcos have debt three times market value. Complacency is the real

killer in digital era. and we managed to rescue 50 banks in a month in 2008. Where there is a cooperative will and a good reason, there is a way

Twitter 25 Sept 2013

Robin Bienenstock Analyst Bernstein

KPN took on incremental debt to pay out cash to its shareholders it couldn't

afford. and For years, the largest Dutch telecoms provider paid huge dividends and bought back shares rather than invest.

Reuters 18 Sept 2013

VP Kroes on competitive spectrum auctions

Was nothing learned from previous auctions for UMTS frequencies,

when the share price of KPN dropped substantially... Telecom companies paid high prices. KPN saw a further decline

in its credit rating. Het

Financieele Dagblad, Netherlands 11 January 2013

VP Kroes on consolidation

Having a few pan-European

operators that are strong in the cross-border market

would not necessarily be bad for competition

Reuters 11 June 2013

ETNO/Boston Consulting Group

Merges might result in short term price increases ...

Report Reforming Europe's

Telecoms Regulation to Enable the Digital Single Market

APPENDIX

Part #7 Executive preview: Rewheel Price benchmark EU28, US, Switzerland, Norway smartphone tariffs with unlimited minutes and SMS (October 2013)

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Executive Preview: Price benchmark of smartphone tariffs with unlimited minutes & SMSs in EU28, US, Switzerland and Norway

October 2013

Proliferation of all you can eat voice & SMS tariffs exposes non-competitive mobile internet pricing practices

Report highlights

Mobile internet access represents the fuel of the digital economies, the price of gigabytes is analogue to the price of energy (

€/kWh for traditional industries

Smartphone tariffs with unlimited minutes & SMS are directly comparable, allowing for the straightforward separation of a variable GB charge and a fixed, data traffic independent charge

Deutsche Telekom’s GB pricing

in the Greek mobile market, a protected oligopoly, is

x higher than TeliaSonera’s and

32x h

igher than (utchison’s GB pricing

in the competitive Danish mobile market

Big European telco group (e.g. Vodafone and Deutsche Telekom) GB prices are 550% higher than prices from data progressive Nordic incumbents (e.g. TeliaSonera) and 1500% higher than prices from challenger operators

(e.g.

Hutchison)

Verizon

’s

and AT&T

’s

US prices are even higher that

Vodafone’s and Deutsche Telekom’s European prices

Consumers

in EU’s protected oligopolies e.g. Germany, Spain,

Greece, Hungary) pay up to 2200% higher GB prices than in

EU’s

most competitive markets (e.g. UK, Sweden, Finland, Denmark, Austria)

Consumers in the German, US and Swiss protected oligopolies pay 500% higher GB prices than consumers in

UK’s

competitive market

The price of a 2 GB smartphone tariff with unlimited minutes and SMS vary 800% in EU28. The difference exceeds 1000% for tariffs with a 4 GB allowance

Big European telco groups (Vodafone, Deutsche Telekom, Telefonica and Orange) price at competitive levels only in competitive European markets where they face challenger operators. In protected oligopolies they charge up to 266% more

Mobile broadband penetration tends to be lower in protected oligopolies (e.g. Germany, Spain, Hungary, Greece) where the price of a 2GB smartphone tariff with unlimited minutes and SMS is close to or exceeds two times the monthly average pend per capita

y = 5.7657x + 34.459

y = 5.8465x + 49.029

y = 5.7037x + 50.913

y = 1.051x + 29.495

€0

€20€

40

€60€

80

€100 €120€

140

€160€

180

0

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

GB included in smartphone tariffs with unlimited minute & SMS

German, US and Swiss protected oligopoly GB prices versus the UK

Smartphone tariffs with unlimited minutes and SMS

UK

€1/GB

Consumers in the German, US and Swiss protected oligopolies pay 500%

higher GB prices than consumers in UK’s competitive market

The trend line slope shows the approximate variable, GB volume dependent price while the crossing point on the Y axis marks the approximate data-traffic independent fixed tariff charge

Rewheel report October 2013 © All rights reserved

Rewheel

o n e

t e p

a h e a d

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

2

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Example exhibits

€0€10

€20€30 €40€50 €60€70 €80€90

€100€110 €120€130 €140€150 €160

0

20

GB included in smartphone tariffs with unlimited minute & SMS

Big EU telco versus challenger operator GB prices accross their markets

Smartphone tariffs with unlimited minutes and SMS

Hutchison

Big telcos charge 1500% more

Source: Rewheel report October 2013 © All rights reserve

€0

€20 €40

€60

€80

€100 €120 €140 €160 €180

0

20

GB included in smartphone tariffs with unlimited minute & SMS

Protected oligopoly GB prices versus competitive EU market prices

martphone

tariffs with unlimited minutes and SMS

German and US GB pricing resembles more 3 MNO protected olIgopolies such as Swizerland, and Portugal rather than competitive markets such as the UK, Denmark , Austria, Finland

FINLAND

Source: Rewheel report October 2013 © All rights reserved

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

3

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

€0€1 €2€3 €4€5 €6€7 €8€9

€10€11 €12€13 €14€15

Variable GB charge in smartphone tariffs with unlimited data & SMS

EU28 member states

US, Switzerland or Norway

Source: Rewheel report October 2013 © All rights reserved

€0€

10

€20€

30

€40€

50

€60€

70

€80€

90

Fixed charge in smartphone tariffs with unlimited data & SMS

EU28 member states

US, Switzerland or Norway

Source: Rewheel report October 2013 © All rights reserved

€0€

10

€20€

30

€40€

50

€60€

70

€80€

90

Lowest price smartphone tariffs with at least 2 GB of data

and unlimited minutes & SMS

Duopoly

Competitive oligopoly where a challanger is present

Protected oligopoly where no challanger is present

US, Switzerland or Norway

Oligopoly that will soon face a challanger

Source: Rewheel report October 2013 © All rights reserved

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

4

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

y = 1000x + 1000

€0

€20 €40 €60 €80

€100 €120 €140 €160

0

20

GB included in smartphone tariffs with unlimited minute & SMS

German - MNO and selected MVNO GB pricing in smartphone tariffs

with unlimited minute and SMS

The trend line slope shows the approximate variable, GB volume dependent price while the crossing point on the Y axis marks the approximate data-traffic independent fixed tariff charge

Discounter MVNOs offer lower prices only for very small GB allowances (typically less than 1GB) appealing only to light users. Their GB variable charge is almost 200% higher than the rates that their parents charge!

Source: Rewheel report October 2013 © All rights reserved

€0€

10

€20€

30

€40€

50

€60€

70

€80€

90

Euro

Big European telco pricing in protected oligopolies and in competitive markets

2GB basket smartphone tariff with unlimited minutes & SMS

Challangers that the E4 face in competitive markets

+126%

+266%

+115%

+67%

The big EU telco groups price at competitive level only in markets where they face challanger MNOs. In protected oligopolie s they charge up to 266% more

Source: Rewheel report October 2013 © All rights reserved

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

5

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

€0€10

€20€30 €40€50 €60€70 €80€90

€100€110 €120€130 €140

0

10

GB included in smartphone tariffs with unlimited minute & SMS

Vodafone group MNO GB prices across 12 European markets where it is present

Smartphone tariffs with unlimited minutes and SMS

The trend line slope shows the approximate variable, GB volume dependent price while the crossing point on the Y axis marks the approximate data-traffic independent fixed tariff charge

Rewheel report October 2013 © All rights reserved

Vodafone MNOs charge up to 320% more per GB in 3 and 4 player protected oligopoly markets than what Vodafone UK charges in the UK's competitive market

The trend line slope shows the approximate variable, GB volume dependent price while the crossing point on the Y axis marks the approximate data-traffic independent fixed tariff charge

Rewheel report October 2013 © All rights reserved

Vodafone MNOs charge up to 320% more per GB in 3 and 4 player protected oligopoly markets than what Vodafone UK charges in the UK's competitive market

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

6

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Introduction

In May 2013 Rewheel released its EU27 mobile data cost competitiveness report1. The primary aim of the May 2013 report was to measure and document, for the first time, the mobile data cost competitiveness across the EU27 member states. Having established the mobile data retail price level in smartphones and data-only tariffs for a variety

of GB and € baskets we

then tried to assess and expose the underlining non-competitive practices and market drivers

that were causing huge price disparities on an MNO level, MNO group level as well as member state level.

In order to capture prices across a wide range of usage profiles and as well account for the non-consumer friendly commercial pricing practices of some MNOs, in our May 2013 report we defined six smartphone tariff GB baskets ranging from 0.1 GB of mobile data, 100 national minutes and 20 national SMSs to 4 GB of mobile data, 1,000 national minutes and 20 national SMSs.

Already back in May 2013 many European MNOs had launched smartphone tariffs that included unlimited national minutes and SMSs. This Europe-wide trend of launching smartphone tariffs with unlimited minutes and SMSs and tier the prices based on the GB allowances has continued throughout the summer months. By September 2013 when we collected the data for this latest report the overwhelming majority (94 out of 101) of EU28, US, Swiss and Norwegian MNOs had launched such tariffs.

Smartphone tariffs with unlimited minutes and SMSs are directly comparable, allowing for the traightforward separation of a variable GB charge and a fixed data traffic independent charge. The analysis of these simplified tariff structures in turn reveals information on the willingness of an MNO or an MNO group to compete by embracing the new mobile data centric era or conversely: protect its interests vested in the outdated voice era.

Our main objectives with this latest report were:

to measure

and start tracking the variable per GB and fixed charge of smartphone tariffs with unlimited

minutes and SMS on an MNO, MNO group and country level

to measure the price differences and start tracking the price convergence on member state and MNO group level

to verify our hypothesis that the huge differences that we presented in our May 2013 analysis and which could not be attributed to differences in cost level or other macro economical factors are also present in martphone tariffs with unlimited minutes and SMS

to provide further evidences that support our notion made in our May 2013 report that competition is

impaired in half of EU’s 8 protected oligopolies markets

uch as Germany, where there is no challenger

operator present)

to provide further evidences that support our notion made in our May 2013 report that big European telcos price competitively only when they face

challenger MNOs in EU’s competitive markets markets where a

challenger operator is present such as the UK)

1 http://rewheel.fi/insights_15.php

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

7

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Report contents

1

Introduction ...................................................................................................................................................................................................................................................... 4

2

Methodology ..................................................................................................................................................................................................................................................... 5

2.1

Mobile Network Operators and MVNO discounter brands ................................................................................................................................................ 5

2.2

Smartphone tariff eligibility rules ................................................................................................................................................................................................ 5

2.3

Treatment of tariffs with unlimited data ................................................................................................................................................................................... 6

2.4

VoIP, IM and tethering restrictions ............................................................................................................................................................................................. 6

2.5

Data collected from MNO websites .............................................................................................................................................................................................. 7

2.6

MNO group classification rules ..................................................................................................................................................................................................... 7

2.7

Member state market classification rules ................................................................................................................................................................................. 7

3

A closer look at the German, US and UK smartphone tariffs ......................................................................................................................................................... 8

3.1

German MNO and selected MVNO GB pricing in smartphone tariffs with unlimited minutes and SMS .......................................................... 8

3.2

Four biggest US MNO GB pricing in smartphone tariffs with unlimited minutes and SMS ................................................................................ 10

3.3

UK MNO GB pricing in smartpohne tariffs with unlimited minutes and SMS .......................................................................................................... 11

4

Country level analysis ................................................................................................................................................................................................................................ 13

4.1

Variable GB charge in smartphone tariffs with unlimited data & SMS ....................................................................................................................... 13

4.2

Fixed charge in smartphone tariffs with unlimited data & SMS .................................................................................................................................... 14

4.3

German, US and Swiss protected oligopoly GB prices versus UK's competitive market prices ....................................................................... 15

4.4

Protected oligopoly GB prices versus competitive EU market prices ......................................................................................................................... 16

4.5

Price of virtually unlimited smartphone use in the German, US and Swiss protected oligopolies versus EU's competitive

markets (UK, Sweden, Finland, Denmark, Austria) .............................................................................................................................................................................. 16

4.6

Lowest price smartphone tariff per market with at least 1 GB of data and unlimited minutes and SMS ..................................................... 18

4.7

Lowest price smartphone tariff per market with at least 2 GB of data and unlimited minutes and SMS ..................................................... 20

4.8

Lowest price smartphone tariff per market with at least 3 GB of data and unlimited minutes and SMS ..................................................... 21

4.9

Lowest price smartphone tariff per market with at least 4 GB of data and unlimited minutes and SMS ..................................................... 22

4.10

Lowest price smartphone tariff per market with unlimited data, minutes and SMS ............................................................................................ 23

4.11

Average price per market of smartphone tariffs with at least 2 GB of data and unlimited minutes & SMS ................................................ 24

4.12

Amount of GBs consumers can buy with a maximum monthly spend of €

......................................................................................................... 26

5

Operator group level analysis ................................................................................................................................................................................................................. 27

5.1

Big European telco versus challenger operator GB prices across their EU28 markets ....................................................................................... 27

5.2

Big European telco versus challenger group 2 and 4 GB basket average price across their markets ............................................................ 28

5.3

Big European telco pricing in protected oligopolies and in competitive markets ................................................................................................. 29

5.4

The effect of challenger MNO presence on big European telco pricing ...................................................................................................................... 30

6

Impact of high prices on mobile broadband penetration ............................................................................................................................................................ 31

6.1

ARPU across EU28, US, Switzerland and Norway ............................................................................................................................................................... 31

6.2

Mobile monthly revenue per capita across EU28, US, Switzerland and Norway ................................................................................................... 32

6.3

Smartphone tariff affordability across EU28, US, Switzerland and Norway ............................................................................................................ 32

6.4

Impact of high prices on mobile broadband penetration in EU's protected oligopolies ..................................................................................... 33

7

List of exhibits ............................................................................................................................................................................................................................................... 35

Annex 1

EU28, US, Switzerland and Norway detailed country charts ............................................................................................................................................ 36

Annex 2

MNO tariff details ............................................................................................................................................................................................................................... 52

About Rewheel ......................................................................................................................................................................................................................................................... 60

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

8

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List of exhibits

Exhibit 1 German MNO and selected MVNO GB pricing of smartphone tariffs with unlimited minute and SMS ................................................................. 9

Exhibit 2 US MNO GB pricing in smartphone tariffs with unlimited minute and SMS ................................................................................................................. 10

Exhibit 3 UK MNO GB pricing in smartphone tariffs with unlimited minute and SMS ................................................................................................................ 11 Exhibit 4 Variable GB charge in smartphone tariffs with unlimited data & SMS across EU28, US, Switzerland, and Norway .................................... 13 Exhibit 5 Fixed charge of smartphone tariffs with unlimited data & SMS across EU28, US, Switzerland and Norway .................................................. 14 Exhibit 6 German, US and Swiss protected oligopoly GB prices versus UK's competitive market prices ............................................................................ 15 Exhibit 7 Protected oligopoly GB prices versus competitive EU market prices ............................................................................................................................. 16 Exhibit 8 Price of virtually unlimited smartphone use in the German, US and Swiss protected oligopolies versus EU's competitive markets (UK, Sweden, Finland, Denmark, Austria) ................................................................................................................................................................................... 17

Exhibit 9 Lowest price smartphone tariff per market with at least 1 GB data and unlimited minutes & SMS

ǀ

MNO view .......................................... 18

Exhibit 10 Lowest price smartphone tariff per market with at least 1 GB of data and unlimited minutes & SMS

ǀ

Country view............................. 19

Exhibit 11 Lowest price smartphone tariff per market with at least 2 GB of data and unlimited minutes & SMS

ǀ

MNO view ................................... 20

Exhibit 12 Lowest price smartphone tariff per market with at least 2 GB of data and unlimited minutes & SMS

ǀ

Country view............................. 21

Exhibit 13 Lowest price smartphone tariff per market with at least 3 GB of data and unlimited minutes & SMS

ǀ

MNO view ................................... 21

Exhibit 14 Lowest price smartphone tariff per market with at least 3 GB of data and unlimited minutes & SMS

ǀ

Country view............................. 22

Exhibit 15 Lowest price smartphone tariff per market with at least 4 GB of data and unlimited minutes & SMS

ǀ

MNO view ................................... 22

Exhibit 16 Lowest price smartphone tariff per market with at least 4 GB of data and unlimited minutes & SMS

ǀ

Country view............................. 23

Exhibit 17 Lowest price smartphone tariff per market with unlimited data, minutes & SMS

ǀ

MNO view .......................................................................... 23

Exhibit 18 Lowest price smartphone tariff per market with unlimited data, minutes & SMS

ǀ

Country view ................................................................... 24

Exhibit 19 Average price per market of smartphone tariffs with at least 2 GB of data and unlimited minutes & SMS .................................................. 25

Exhibit 20

Amount of GBs consumers can buy with a maximum monthly spend of €

........................................................................................................... 26

Exhibit 21 Big European telco versus challenger operator GB prices across their EU28 markets ......................................................................................... 27 Exhibit 22 Big European telco versus challenger group 2 and 4 GB basket average price across their markets ............................................................. 28 Exhibit 23 Big European telco pricing in protected oligopolies and in competitive markets ................................................................................................... 29 Exhibit 24 The effect of challenger MNO presence on big European telco pricing........................................................................................................................ 30 Exhibit 25 ARPU across EU28, US, Switzerland and Norway ................................................................................................................................................................. 31 Exhibit 26 Mobile monthly revenue per capita across EU28, US, Switzerland and Norway ..................................................................................................... 32 Exhibit 27 Average price per market of smartphone tariffs with at least 2 GB of data and unlimited minutes and SMS as a % of mobile monthly spend per capita..................................................................................................................................................................................................................................... 33

Exhibit 28 Impact of high prices on mobile broadband penetration in EU's protected oligopolies ....................................................................................... 33

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

9

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Disclosures

The comparative analysis carried out by Rewheel Ltd. during the third quarter of 2013, solely on its own initiative, does not constitute an investment, legal or tax advice and is not intended in any way to give any direct or indirect recommendations regarding current or future stock transactions that any party might undertake after reading this report. Rewheel Ltd. and/or its affiliates, and their respective officers, directors and employees accept no liability whatsoever for any direct, indirect or consequential loss arising from their use of this report or its content. The authors of the report make no buy, sell or hold recommendations regarding the stock of the companies mentioned in this report. Rewheel Ltd. is not a certified financial advisory and is not currently regulated by any financial investment authority. The viewers of this report should consider this publication as only a single factor in making business, regulatory or competition enforcement decisions.

This report does not make, imply or suggest direct or indirect claims of unlawful anti-competitive actions undertaken from any of the mobile network operators or operator groups covered herein. The non-competitive practices that our analyses exposed are based solely on our views on what market behaviors promote rather than demote competition. The term non-competitive practices shall not be associated, interpreted or confused with unlawful anti-competitive actions under national and European competition law.

The data used in this comparative analysis are based solely on public information posted on mobile network operator websites. We believe the tariff information posted on mobile network operator web sites to be reliable but no representation is made by us that the row data used are complete, accurate, fully representative, fully fit for purpose, or were up to date at the time of collection. The data collection team made subjective judgments when translating, interpreting and screening for tariff interdependencies in the mobile network operator web sites. Such subjective interpretations and judgments of tariff conditions, Google translations and of our qualification rules were the sole discretion of the data collection team and of the report authors. Rewheel Ltd. accepts no liability for omissions, errors or simply for not being able to discover on the mobile network operator website a tariff with lower price that met the qualification criteria. We welcome feedback and suggestions from mobile network operators for existing or newly launched tariffs that meet our qualification criteria and which were not considered in our analysis. The findings, conclusions and correlations that the authors of this comparative analysis have reached are solely attributable to their ubjective interpretations of Google translations, tariff conditions, qualification rule interpretations and mobile network operator classification & clustering rules.

Executive preview: Price benchmark of smartphone tariffs with unlimited minute & SMS in EU28, US, Switzerland and Norway

October 2013

10

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About Rewheel

Rewheel is an independent strategic advisory specializing in data-centric transformation of mobile operators and markets.

We are headquartered in Helsinki, Finland and our main operating footprint is Europe.

Since 2009 we have advised over 10 European mobile operators, including independent challengers as well as Tier-1 OpCos, regulators, competition authorities, a number of private equity and institutional investors and various mobiledata centric start-ups.

Since the onset of the mobile broadband centric 900, 1800 and 2100 MHz license renewal avalanche in 2011 in Europe we have been providing strategy, spectrum valuation and auction theory advice (together with our world class CCA/SMRA auction theorist partners) to five European spectrum authorisation processes (operator or regulator side depending on country), including new entrants and acquisitions as well as license renewals in multi-band (typically 800, 900, 1800, 2100 and 2600 MHz) auctions.

Our advisors’ knowledge, experience and insights cover all important

aspects of successful data-centric mobile

operator business models. Our typical advisory engagements are:

Mobile-data centric operator business planning end-to-end

Mobile data pricing strategies

3G/LTE mobile infrastructure development strategy and investment planning

3G/LTE mobile infrastructure procurement strategy, network infrastructure cost structure competitiveness benchmarking and optimisation (Rewheel is truly network vendor independent)

Spectrum acquisition strategy and NPV valuation

Industry expert advisory to policy makers, regulators and competition authorities

Contact information

For further information regarding the full version of this report or Rewheel please e-mail rewheel@rewheel.fi or call

Rewheel’s

managing partner, co-author of this report, Antonios Drossos at +358 44 203 2339.

APPENDIX

Part #8 Rewheel Flash Report: Consolidation in Austria and Germany

and EU’s Telecom Single Market mess

(September 2013)

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Rewheel flash report, September 2013

MNO consolidation in Austria, Germany and

EU’s single telecom

market mess

Summary

In this flash report we follow up on our latest EU27 mobile data cost competitiveness report May 20131 by reflecting on three recent major market developments;

Consolidation in Austria: On August 19th

, seven months after the approval of Orange Austria’s acquisition,

Hutchison 3G Austria launched new smartphone tariffs which are substantially more expensive than the premerger prices. We quantify and benchmark the post-merger smartphone tariff price hike: on average 60%.

Planned consolidation in Germany: We discuss the implications of the proposed takeover of E-Plus by Telefonica O2 and propose a set of antitrust remedies (i.e. O2 should hand back its 800MHz spectrum) to afeguard competition, incentivise efficient use of spectrum, prevent price hikes and drive mobile broadband penetration growth in Germany.

EU single telecom market regulation: We reiterate our May 2013 recommendation for introducing an EU single market tariff with the aim of improving tariff transparency, price convergence across EU28 and abolishing roaming

Source: Rewheel EU27 mobile data cost competitiveness report May 2013, www.drei.at 21 August 2013

1

http://rewheel.fi/insights_15.php

€0 €5

€10 €15 €20 €25

0.1GB-basket

0.5GB-basket

1GB-basket

2GB-basket

3GB-basket

4GB-basket

Average all

baskets

Post-consolidation price hike in Austrian mobile market

Hutchison 3G Austria lowest price smartphone tariff per basket before and after Orange's aqcuisition

Pre-consolidation Post-consolidation

+89%

+60%

+89%

+89%

+93%

+28%

+28%

Rewheel

o n e

t e p

a h e a d

MNO consolidation in Austria, Germany and EU’s single telecom market mess

2

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1

Consolidation in Austria

Hutchison 3G Austria has completed the acquisition of Orange Austria on the 3rd of January 2013, following a conditional approval granted by the European Commission on the 12th of December 2012. Hutchison 3G Austria offered significant remedies to the European Commission (spectrum divestments, MVNO access obligation and national roaming for a potential fourth entrant) for securing merger clearance. The European Commission wrote on the 12th of December that

In the end, our

analysis, supported by thorough economic assessment, showed that the merger would have led to substantial price increases for Austrian consumers 2.

Triggered by the recent launch, 19th August 2013, of new tariffs by Hutchison 3G Austria we updated our smartphone tariff database and present the findings below.

Exhibit 1: Post-consolidation price hike in Austrian mobile market

Source: Rewheel EU27 mobile data cost competitiveness report May 2013, www.drei.at 21 August 2013

In

Exhibit 1

above we present Hutchison 3G Austria

’s

pre and post-consolidation smartphone tariff prices across the six

baskets defined in our previous report. The columns on the right hand side depict the average prices across the six baskets. The post-consolidation prices (in grey) are based on the new tariffs launched on the 19th of August 2013 and the preconsolidation prices (in orange) are based on the tariffs which were available during the fourth quarter of 2012 until the 18th of August 2013. So has Hutchison 3G Austria raised prices? On average prices went up by 60%. The price of the most relevant basket, the 2GB-basket, has almost doubled. According to our experience in 2013 the 2GB-basket is the most relevant basket for the mass consumer market because it is comfortably accommodating normal data and speech usage. The price hikes appear to be

an attempt by (utchison G Austria to shift the mass market from the previously €

monthly

pend level

to the €

-20 range. Previously Hutchison 3G Austria offered five SIM-only packages (1GB, 2GB, 4GB, 6GB and

GB for €, €

, €

, €

and €

respectively while now

it offers only two SIM-

only packages

GB and GB for €. and

respectively.

That is, any new customer that is seeking a package with more than 1GB (the overwhelming majority of

2 http://europa.eu/rapid/press-release_IP-13-776_en.htm

€0 €5

€10 €15 €20 €25

0.1GB-basket

0.5GB-basket

1GB-basket

2GB-basket

3GB-basket

4GB-basket

Average all

baskets

Post-consolidation price hike in Austrian mobile market

Hutchison 3G Austria lowest price smartphone tariff per basket before and after Orange's aqcuisition

Pre-consolidation Post-consolidation

+89%

+60%

+89%

+89%

+93%

+28%

+28%

MNO consolidation in Austria, Germany and EU’s single telecom market mess

3

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

post-paid customers) will now need to spend

-

€20

compared to

-

that

it was required to spend with the old

tariffs. Early post-consolidation reactions of competition Note that during the first half of 2013 Telek

om’s Austria’s

mobile arm A1 launched a new portfolio of unlimited minutes &

SMS smartphone tariffs. The tariffs are tiered based on the amount of data volume and maximum speeds on offer. The pricing points of the new portfolio did not introduce any significant changes in the overall price level. The new smartphone tariffs of A1 have been captured in our May 2013 report. During the summer of 2013 T-Mobile Austria has also made some minor changes in their tariff portfolio (particularly in the post-paid data add-ons) yielding a 13% average price hike across the six smartphone tariff baskets we defined and benchmarked in our EU27 mobile data cost competitiveness report May 2013. The price hikes from Hutchison 3G Austria and T-Mobile Austria, have so far yielded an increase of 43% and 15% respectively in the lowest available and average price across the six smartphone baskets. It remains to be seen if T-Mobile Austria which now

, after (utchision G Austria’s latest move,

has the lowest prices in the market will stay put or trigger

another price hike round. Post-consolidation Hutchison 3G Austria prices in EU perspective In order to put the recent Austrian smartphone tariff price hikes into a European perspective we benchmarked the Hutchison 3G Austria price of a 2GB-basket against selected member state average 2GB-basket prices. The benchmark is presented in

Exhibit 2

below.

Exhibit 2: Even after the price hike Hutchison 3G Austria smartphone tariff prices are very competitive

Source: Rewheel EU27 mobile data cost competitiveness report May 2013, 3 Austria & German MNOs websites August 2013

As it can be seen from

Exhibit 2

Hutchison 3G Austria

’s

new smartphone tariff pricing remains highly competitive even after

the recent price hike. In our view the post-consolidation smartphone tariff price correction in the Austrian mobile market from the ultra competitive leve

l of €

to the healthier € 5-€

range for normal usage

is a positive development both for the

incumbent mobile operators and more importantly for the prospective new entrants. Nevertheless,

(utchison G Austria’s new

smartphone tariff portfolio proves that the antitrust officials of the European

Commission were right on their assessment that the merger could lead to substantial price increases for the Austrian

€0€5

€10€15 €20€25 €30€35 €40€45 €50

Finland

Hutchison 3G

Austria

France

UK

EU27

Ireland

Spain

Germany

Even after the price hike Hutchison 3G Austria prices are very competitive

Price of 2GB-basket for Hutchison 3G Austria and selected member state average 2GB-basket price

Pre-consolidation Post-consolidation

+93%

2GB-basket: 2GB, 200 offnet minutes and 20SMSs

MNO consolidation in Austria, Germany and EU’s single telecom market mess

4

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consumers. However, the remedies (e.g. MVNO wholesale access obligation) for approving the merger has so far failed to live up to the expectations to prevent such price hikes. We believe that the Commission should look carefully into this matter when examining future cases where consolidation will reduce the number of mobile network operators from four to three, notably Germany and Ireland.

MNO consolidation in Austria, Germany and EU’s single telecom market mess

5

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2

Planned consolidation in Germany

On 23rd July 2013 Telefonica agreed to buy the E-Plus German wireless unit of KPN in a cash-and-stock deal valuing the unit at 8.1 billion Euros

to become the country’s biggest mobile-phone

operator by customers3. On the 24th July 2013 Andreas

Mundt the President of the German Cartel Office (Bundeskartellamt

said that

The planned takeover of German mobile

operator E-Plus by Spanish Telefonica subsidiary O2 was definitely a case to be dealt with by German anti-trust regulators rather than by Brussels

4

and

he was concerned about the merger as it would create a new German market leader and reduce

competition to just three major mobile phone operators. It's obvious that such a tie-up will have substantial repercussion in Germany which will require an in-depth look at all of its nuances

. Beside the German Cartel Office, the German Federal

Network Agency (Bundesnetzagentur) must also approve the acquisition. In a letter wrote to the E-Plus CEO Thorsten Dirks on the 25th of July the Vice President of the Federal Network Agency, Mrs. Henseler-Unger

wrote

As a rule, the Federal

Network Agency must guard the competitive independence of owners of frequency rights in an area of scarce resources,... Ultimately, the Federal Network Agency can enforce this by withdrawing the frequency assignment.

5

The current four mobile network operators in the German market are all controlled by fixed and mobile European incumbent champions (Deutsche Telekom, Vodafone, Telefonica and KPN). Even though Germany has four mobile network operators competition is very weak mainly due to the absence of an independent challenger mobile-only MNO as it was hown in

Rewheel’s EU

mobile data cost competitiveness May

report.

As a consequence of the weak competition in

the mobile space the mobile broadband penetration of all active users in Germany is substantially lagging behind the EU average and it is less than half than that of the UK or Finland (41% vs. 54% vs. 84% vs. 107%) according to the latest EU Commission digital scoreboard data6. But more importantly the current four mobile operators are severely underutilizing

Germany’s scarce radio spectrum resources.

As it can be seen in

Exhibit 3

below, the annual cellular mobile data

consumption per capita in Germany is ten times smaller than in Finland and Sweden despite the fact that German MNOs had access to LTE 800MHz frequencies years ahead.

Exhibit 3: Annual cellular mobile data consumption per capita in Germany is ten times smaller than in Finland

Source: Rewheel EU27 mobile data cost competitiveness report May 2013, Regulator websites, Rewheel analysis

3

http://www.bloomberg.com/news/2013-07-23/telefonica-deutschland-to-acquire-kpn-s-e-plus-for-cash-stock.html

4 http://www.faz.net/aktuell/wirtschaft/unternehmen/o2-und-e-plus-kartellamt-sieht-handy-uebernahme-kritisch-12294266.html 5

http://www.bloomberg.com/news/2013-08-05/germany-opens-airwave-review-on-telefonica-kpn-wireless-merger.html

6 https://ec.europa.eu/digital-agenda/sites/digital-agenda/files/DAE%20SCOREBOARD%202013%20-%202-BROADBAND%20MARKETS%20.pdf

1.2GB

1.8GB

5.2GB

10.7GB

11.3GB

1.7GB

3.8GB (e)

7.4GB (e)

16.7GB (e)

17.9 GB

0

2

4

6

8

10

12

14

16

18

20

Germany

UK

Denmark

Sweden

Finland

GB

German vs UK and Nordic annual cellular mobile data consumption per capita

2011

2012

LTE

800 MHz

2600 MHz

LTE

800 MHz

2600 MHz

LTE

800 MHz

2600 MHz

LTE

800 MHz

2600 MHz

LTE

800 MHz

2600 MHz

MNO consolidation in Austria, Germany and EU’s single telecom market mess

6

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In

Exhibit 4

below we benchmarked the latest German smartphone tariff prices and GB allowances against the Finnish and

the Hutchsion

G Austria’s

post-consolidation prices (new tariffs launched on August 19th 2013).

Exhibit 4:

Finns and Austrians enjoy practically unli

mited voice and data communication with €

. )n Germany €

will only buy an entry level smartphone package of 300MB

Source: Rewheel EU27 mobile data cost competitiveness report May 2013, MNO websites, Rewheel analysis

In our EU27 mobile data cost competitiveness May 2013 report we had shown that Germany had the highest average price

€9.

across EU27 for the most important 2GB smartphone tariff basket (2GB, 200 off-net minutes and 20SMSs). Our May

2013 report came out days before T-Mobile Germany launched a new portfolio of tariffs with lower prices. We have now updated our smartphone tariff database and included the latest offers from all four German MNOs. As we have shown earlier in Exhibit 2 the latest average price for the 2GB-basket in Gemrany is

€9.

which is more than three times higher than the

Finnish average price of the 2GB-basket. While Finns

and Austrians enjoy practically unlimited voice and data communication with €

, in Germany €

will

only buy an entry level smartphone package of 300MB. Is the merger of O2 and E-Plus about extracting cost synergies or rather about the protection of mobile price levels and the incumbent

vested interested in maintaining the oligo- or monopolistic positions traditionally enjoyed in

their fixed infra centric businesses? Telefonica said the combination of O2 Germany with E-Plus would generate savings of 5 billion euros to 5.5 billion euros

through combined distribution, customer service and network services, after deducting unspecified integration costs.

While Telefonica was quick to disclose the merger cost savings to the market they said very little regarding their outlook for the post-merger price levels. Price (income) is equally or even more important to profitability than costs. The latest round of

price cuts in the German smartphone postpaid market, according to Rewheel’s database, reduced the average price

of the

2GB-basket from

€9.

to €9.12.

Obviously the 24 month long customer contracts will restrict the speed at which the

customer base can migrate to the lower tariffs so the 18% price drop will take its time to eat into the market revenues. However, if the price pressure on the lucrative smartphone data postpaid market that was triggered in 2013 by E-Plus

’s

determination to exit the German market was to maintain or even intensify (the EU average of the 2GB-

basket is €

.9

so

there is still plenty of room to further lowering the prices) the four German mobile operators could be faced with a medium

0 2 4 6 8

10 12 14 16 18 20

€9

€20

€31

€42

€53

€64

€75

€86

€97

€108

€119

€130

€141

€152

GB

Finns and Austrians enjoy practically unlimited voice and data

martphone communication with

€20

Finland market average Hutchison 3G Austria, post-consolidation Germany market average

MNO consolidation in Austria, Germany and EU’s single telecom market mess

7

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term annual revenue leakage of billions of Euros. These revenue-side considerations strongly suggest that the very generous premium (over 9.0xEBITDA)7 offered by Telefonica for E-Plus does not appear to be based on cost savings alone.

If the German and the European antitrust authorities approved the takeover of E-Plus by Telefonica and at the same time approved the takeover of Kabel Deutschland by Vodafone then the German market would end up with three converged fixed and mobile operators with no incentive to compete in the mobile broadband market (smartphone data connections and data only MBB connections) and cannibalize the valuation of their fixed broadband assets. If all three players could keep mobile data allowances low and tariffs at the current very high levels they could delay the fixed to mobile broadband substitution (evident in the Nordics) and lock the consumers in their

fixed broadband leg

at home. Unsurprisingly, investors tend to

favour incumbents with both fixed and mobile assets over mobile-only operators because the former in many (most) geographical areas enjoy a network infra monopoly or at best an oligopoly (i.e. only a single copper, coaxial or fibre line is rolled out per household). In contrast, mobile only operators are riskier assets where investors have to actually face two or often three friendly and from time to time independent infrastructure competitors.

To further support our assertion for the strong preference of European incumbents on creating markets where there are no mobile-only operators in order to protect fixed broadband assets we point to the recent strategic asset portfolio review initiated by Deutsche Telekom. The Wall Street Journal reported on the 30th

of August

In any case, a cornerstone of the

review is the question whether Deutsche Telekom should exit Eastern European markets in which it has mobile-only activities or buy fixed-line and broadband assets to strengthen its position, the people say.

8

Clearly, from the investors’ point of view it makes perfect sense to set a convergent corporate strategy going

forward, and lobby, both on member state and EU Commission level, for policies that favour convergent players against pure-mobile-only challengers. Not because of cost efficiency reasons, meaning lowering the cost of offloading cellular data to fixed networks (recall that the mobile networks and radio spectrum in many EU markets, including Germany, are nearly empty compared to Nordic networks, Exhibit 3) but simply because this appears to be the only way to cement the monopolistic/oligopolistic positions telecom investors are historically used to. In fact, in

Rewheel’s opinion

the seismic technological shift witnessed in the space of mobile broadband infrastructure (LTE,

LTE-advanced, small cells, All-IP, high capacity microwave backhaul and rapidly falling mobile network equipment prices) does indeed pose a major, if not existential threat to the valuation of the fixed broadband businesses.

So should the merger be blocked?

In our view antitrust authorities must block outright any in-market consolidation whereby the number of mobile network operators is reduced after the merger and the operators in question fail to demonstrate that the financial benefits from the merger are primarily derived from cost, sales or product synergies and not from price level protection. In other words antitrust officials must test the merged operator

’s

appetite to complete the merger even

under the assumption that a new mobile network operator entrant will maintain or even intensify the price pressure in the short and medium term. So what should be the conditions for approving E-Plus

’s

takeover by O2 in Germany if the antitrust authorities were

not to block outright the transaction? Below we outline a number of remedies that in our opinion the antitrust remedies should strongly consider:

7

SHAREHOLDERS' CIRCULAR dated 21 August 2013 for the purpose of the Extraordinary General Meeting of Shareholders of KONINKLIJKE KPN N.V.

to be held on 2 October 2013

8

http://online.wsj.com/article/SB10001424127887323324904579043023358294120.html

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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Make space for a new entrant MNO: O2 and E-Plus should agree to hand back low and high frequency LTE uitable spectrum that could facilitate the immediate (early 2014) market entry of a new fourth credible challenger mobile operator. A viable fourth entrant must be equipped to build timely a nationwide high capacity LTE broadband network and serve the mass German consumer market. For that it will need as a minimum 2x10MHz of 800MHz and 2x20MHz of 1800MHz spectrum. O2 and E-Plus shall hand back to the Federal Network Agency their 800MHz holdings, some of their 1800MHz holdings and possibly some of their 2100MHz holdings and the package should be auctioned as soon as possible to new entrants. Reserved prices should be set to levels adequate for new entrants (e.g. Netherlands) but also tight coverage obligations and licence transfer conditions hould be set.

Support the business case of the new entrant: O2 and E-Plus should agree to temporarily open all (where EMF limits allow) of their sites for collocation and provide mandatory temporary national 2G, 3G and 4G roaming to the new entrant at competitive wholesale rates of

€-€ per GB

. cent to .

cent per MB) as shown in our EU27

mobile data cost competitiveness May 2013 report9.

Stay mobile-only after the merger: O2 and E-Plus should agree to divest their fixed broadband business and restrain for a period of 5 years from making acquisitions of fixed broadband assets (with the exception of backhaul and backbone infrastructure).

Provide reassurances that there will be no post-merger price hikes: O2 and E-Plus should commit not to raise the prices of their smartphone or data only tariffs directly (by increasing the charges on existing contracts) or indirectly (by launching a new portfolio of tariffs where the allowances are different but which result in a ignificant price hike for the majority of normal users).

While in principle we support the remedy of MVNO wholesale access obligation at competitive wholesale rates10 we believe that in the end the only effective measure for safeguarding competition, preventing price hikes and avoiding tacit collusion is ufficient competition at the mobile network infrastructure level. The overwhelming majority of MVNOs in Europe today are neither truly independent nor commercially free to compete head-on with their host networks in the business critical martphone data market.

A side note on the planned consolidation in Ireland: Three Ireland to acquire O2 from Telefonica In our view the review of the planned consolidation in the Irish market by Irish and European competition and regulatory authorities must also cover the areas we raised above for Germany even though there are some differences between the two mergers. In Ireland 3 Hutchison an independent challenger mobile-only no.4 MNO is taking over the no.2 mobile operator O2 owned by Telefonica. We are concerned for a post-consolidation price increase from 3 similar with the one we witnessed in Austria. Now while we viewed the price correction in the Austrian market as a positive development given the ultracompetitive pre-consolidation price levels the same will not be true for Ireland. Ireland is the ninth most expensive member tate with smartphone tariff prices significantly higher than the average EU27 price. If prices remain at the current levels or raise further mobile broadband penetration and mobile data consumption growth could slow or even stagnate.

9

http://rewheel.fi/insights_15.php

10

http://ec.europa.eu/competition/mergers/cases/decisions/m6497_20121212_20600_3210969_EN.pdf

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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3

EU single telecom market initiative

Vice President Kroes announced on the 9th of July 2013 a legislative initiative11 to fast forward her plans to complete a European single telecoms market. The College of Commissioners is due to adopt a final proposal on the 10th of September 2013 laying down measures to complete the European single market for electronic communications and to achieve a Connected Continent. On the 11th of July European Digital Rights (EDRi) published12 what appears to be a leaked early draft

of the Commission’s legislative proposal for EU’s single telecom market. On August

th the Financial Times reported13 that

the office of Vice President Almunia had expressed unusually frank criticism about Ms.

Kroes’ proposals to create a single

European telecoms market, arguing

that while the aim is laudable the plans are too unambitious

. DG COMP (Directorate

General Competition) expressed a number of reservations on DG CON

NECT’s Directorate General Communications,

Networks Content and Technology) draft proposal. It criticized Ms. Kroes

’s

plan as

uboptimal

and

lacking ambition

for

not suggesting to replace the 28 national regulators with one single European regulatory authority, it expressed concerns that the draft proposals could damage some competition rules and raised objections on the way that DG CONNECT choose to abolish roaming by regulating wholesale access levels and allowing roaming alliances among operators. The European Commission has played down the reports about friction between its commissioners. Commission spokesman Jonathan Todd told FierceWireless:Europe14 that the document referred to in the report appeared to be an earlier draft, temming from DG COMP and "forms

part of the normal preparatory process for any policy or legislative initiative being

prepared by the Commission."

Todd added that the ideas proposed for a single telecoms market by Neelie Kroes in June had

o far received strong support from the EU commissioners. He noted that Kroes's team was finalising the draft legal instrument, taking into account the inputs received. "We

cannot therefore comment on the substance of the arguments in the

article, which apparently refers to an earlier draft," Tod

d said.

Ms. Kroes

’s

leaked draft proposal attempted to address a wide range of industry and regulatory practices that according to

the Commission posed obstacles to the completion of EU single telecom market:

an EU passport for European electronic communications providers;

the further convergence of regulatory conditions as regards remedies imposed by national regulatory authorities on European electronic communications providers;

the harmonised provision of wholesale products for broadband consisting of wholesale virtual access and assured ervice quality connectivity;

the achievement of a European wireless space, through a coordinated European framework for the assignment of harmonised spectrum for wireless broadband communications services;

the achievement of a European consumer space through harmonisation of rules relative to the rights of end-users and the promotion of effective competition in retail markets;

the elimination of surcharges for international and roaming traffic not justified by underlying costs

11

http://europa.eu/rapid/press-release_SPEECH-13-622_en.htm

12 http://www.edri.org/files/consolidateddraft-ISC070713.pdf 13

http://www.ft.com/intl/cms/s/0/d85da03c-042c-11e3-8aab-00144feab7de.html#axzz2d9ygXPRw

14 http://www.fiercewireless.com/europe/story/european-commission-denies-split-over-single-telecoms-regulator/2013-08-14

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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Below we examine the regulatory measures proposed by DG CONNECT in order to meet the objectives covered by the last two bullets, namely;

How to promote competition in retail markets, achieve price transparency and promote price convergence across the EU28 member states;

How to eliminate international and roaming surcharges without resorting to a heavy handed regulatory intervention (wholesale access regulation) that could devastate the industry and harm competition;

How to promote competition in retail markets, achieve price transparency and promote price convergence across the EU28 member states European consumers (i.e. smartphone users) and European regulatory and antitrust officials both are faced with a common challenge. Consumers are primarily concerned for the monthly spend and quality of mobile service they receive while authorities need to track the overall market price trends. For consumers the motive for paying less or receiving more is traight forward. For regulatory and antitrust officials accurately tracking market price movements and service quality serve as a key indicator of competition intensity and a bellwether for dysfunctional markets. As we shown in Austria the European Commission antitrust officials were right to be concerned about post-merger price increases. Hutchison 3G Austria did raise prices, albeit not in a straight forward and easily traceable manner. When MNOs decide to raise prices they do so elegantly by launching a new portfolio of tariffs with different allowances (and possible new services included) in order to prevent the average consumer to compare and track the price hikes. MNOs being well aware of the average usage habits of normal users tend to carefully select the bundles of their tariffs in order to push consumers to packages with higher monthly fees as we explained earlier. On the 6th of August, Ms. Kroes

’s

office published a flash comparison of phone call prices across EU -

774% difference in phone

call prices across the EU15.

GSMA was highly critical of Ms. Kroes.

The Commissioner compares the different prices of domestic

mobile phone calls in EU countries to the price of a litre of milk

a point that reveals a fundamental misunderstanding of

market conditions. 16

. While we agree with GSMA’s criticism on the dubious back on the envelope methodology used by the

Commission in the particular comparison (dividing total voice revenues with total voice minutes to derive an average retail cost per minute bluntly ignores tariffs with unlimited minutes, handset subsidies, cheap or unlimited corporate minutes, allocation of flat tariff fees as

voice revenue, etc. we would like to draw GSMA’s attention to Rewheel’s

in-depth basket price

analysis, shown in

Exhibit 5

below, which confirms a 600% price difference for the 2GB smartphone basket across the EU27

member states. Note that the 600% price difference for the 2GB smartphone basket among the EU27 member states does not include netneutrality restrictions imposed by many MNOs which were difficult to quantify and price in. Most incumbent MNOs in protected markets block or demand additional charges to allow VoIP and/or tethering. For example T-Mobile Germany

’s

VoIP option (which is needed if one wants to use e.g. Skype or Viber on its smartphone) is not included in all tariffs where the

monthly fee is below €

. The additional fee for enabling Vo)P in such tariffs ranges from €

to €

.

Without a doubt most MNOs in EU’s

13 protected markets (markets where there are no independent challenger mobile

operators present such as Germany, Greece, Hungary, etc.) and as well some incumbents in progressive markets (markets that are not protected) resort to complicated, non-transparent and difficult to compare tariff structures to protect market hares and market price levels.

We fully support the Commission’s drive to improve

retail transparency and tighten the rules

of lengthy binding contracts. We encourage the Commission to be even bolder and ban outright the practice of binding consumers to lengthy contracts when they purchase a subsidized handset. Several MNOs in EU today are offering SIM only rolling contracts and the freedom to purchase a handset in 12, 24 or 36 monthly instalments.

15

http://europa.eu/rapid/press-release_IP-13-767_en.htm

16 http://www.telecoms.com/169152/ec-and-gsma-at-odds-over-single-market-reform/

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 5:

Member state domestic average prices versus EU's retail and wholesale roaming caps

Source: Rewheel EU27 mobile data cost competitiveness report May 2013, EU Commission draft, Rewheel analysis

How to eliminate international and roaming surcharges without resorting to a heavy handed regulatory intervention (wholesale access regulation) that could devastate the industry and harm competition In the leaked draft document DG CONNECT proposed to end roaming surcharges by substantially lowering the mandatory roaming wholesale rate caps

. DG CONNECT’s proposal was to cut the wholesale

roaming rates from the current 15cents/MB,

10cents/min and 2cents/SMS to 1.5cent/MB, 3cents/min and 1cent/SMS respectively starting at 1st of July 2014. In Exhibit 5 in addition to the price difference for the 2GB smartphone basket among the EU27 member states we have also presented the wholesale charge that an MNO would incur if one of its customers were to consume the entire 2G-basket

allowances on a visiting roaming network. The wholesale charge is based on the DG CONNECT’s proposed

(as per the leaked

draft legislation) wholesale rate caps of 1.5cent/MB, 3cents/min and 1cent/SMS. We make three key observations;

T

he proposed wholesale charge of €

.

would

yield a retail charge of around €

assuming a

% VAT and a

20% margin. This is more than 200% higher than the average retail price level in twelve EU member states

The Commission has so far failed to end roaming in Europe by regulating retail and wholesale caps. This is no urprise given the astronomical level of these caps shown in Exhibit 5.

If the Commission

’s

objective is to end roaming surcharges through wholesale access rate regulation it must set

caps that are not higher than 0.2cent/MB, 1cent/min and 0.4cent/SMS17 to accommodate as well consumers from

the EU’s most competitive member states

such as Finland, Austria etc

however, such a regulation would most

likely have lethal side effects for the mobile-only operators (the drivers of competition in the smartphone tariff pace), as explained later.

17

http://ec.europa.eu/competition/mergers/cases/decisions/m6497_20121212_20600_3210969_EN.pdf

€0

€20 €40

€60

€80

€100 €120

Member state domestic average prices versus EU's retail and wholesale roaming caps

Smartphone tariff basket 2GB&200mins&20SMSs

€1,140

€527

€320

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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In the most recent anecdotic twist of this drama, and while we were finalizing this report Reuters reported on the 28th of

August that Ms. Kroes has apparently dropped a plan to slash wholesale roaming rates.

Kroes' latest draft plan seen by

Reuters does not mention the issue at all.

18

This drama which started in 2012 and had many twists and turns is finally coming to end with a spectacular finale. The act had many players but without a doubt the protagonist was Ms. Kroes. Will she or will she not deliver a single European telecoms market by ending the roaming feast? The proposal to end roaming by regulating wholesale access rates to competitive levels has hit a wall. If the Commission proposes and the Parliament adopts mandatory mobile wholesale access at competitive rates for all EU28 member states 0.2cent/MB, 1cent/min and 0.4cent/SMS19 it will open

pandora’s box and risk ruining

the European mobile industry. The

Commission will not be able to limit the scope of the wholesale access to roaming only both on legal and technical grounds. Mobile wholesale access at competitive rates is a pill with toxic side effects:

Zero-capital MVNO speculators: It will open the mobile data door to MVNOs with speculative business models. Build a base at a small loss and then cash-in by selling the base back to the network operators. This causes uncontrolled price erosion.

Cable and OTT alternative operators: It will provide investment-free European wide mobile access to cable (UPC, etc.), OTT alternative providers (Google, Apple) and alternative WiFi ISPs. The Commission is mistaken if it is under the impression that the wholesale cost of 3 cent a minute and 1.5

cent per MB €

for

mins and GB

will protect mobile operators. Such alternative providers with home and public WiFi networks could easily direct most smartphone generated traffic through their own fixed or WiFi networks and only use the mobile networks for outdoor usage such minimizing their wholesale bill (e.g. steering 90% of the end consumers traffic onto their own WiFi networks and only 10% onto the wholesale cellular access). In essence they could capture a disproportionally high share of the current retail mobile customer base.

Effectively, the Commission would be creating an unquantifiable mobile industry revenue leakage. Revenues that would flow by force to competing industries (fixed, cable, WiFi ISPs, OTT) would starve mobile operators from the needed capital to invest in improving the coverage and cost efficiency (cost of capacity) of their networks. In other words such policy would dramatically weaken the case for pure mobile only investments, consequently weakening, if not killing, the biggest risk faced

today by the owners of convergent and fixed/cable only European telco groups.

If you cannot measure it, you cannot improve it

Lord Kelvin

Rewheel believes that rather than backtracking and eating her words Ms. Kroes and the Commission could still keep their promise to deliver a single European telecoms market and without having to resort to a heavy handed regulatory wholesale access intervention. The Commission could introduce an EU single market tariff to

erve EU’s single telecom market.

Competition in retail markets, tariff price transparency,

price convergence across EU’s 8 markets

and abolishing

roaming would be best served if the Commission introduced an EU single market tariff. The EU single market tariff hould be offered by all European MNOs, MVNOs, service providers and resellers. Each service provider shall be free to decide the price for the EU single market tariff and offer as well any other tariff that it wishes. The main attributes of an EU single market tariff should be:

Fully comparable: the allowances, terms and conditions shall be identical across EU28

Fully transparent: the simplified complete terms and conditions must be attached to the cover contract

18

http://www.reuters.com/article/2013/08/28/us-eu-telecoms-costs-idUSBRE97R12120130828

19

http://ec.europa.eu/competition/mergers/cases/decisions/m6497_20121212_20600_3210969_EN.pdf

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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Fully traceable: any price changes would be easily traceable both by consumers and antitrust authorities

Accommodative of normal usage: the tariff shall include allowances that are accommodative of the evolving normal usage habits of consumers i.e. in 2013 about 2GB of data volume (2Mbps), 200 of inclusive national, international (EU28) or roaming (E28) minutes. The price for SMS, video calls and out of bundle data or voice minutes shall be freely set by the retailers. Out of bundle data must be sold in buckets of 1GB and out of bundle minutes shall carry a rate per minute. In addition to the smartphone tariff the Commission should consider two more variants. A voice only EU single market tariff (where no data is bundled in) for feature phones and a data only mobile broadband tariff.

Must be borderless: The data and minute inclusive allowances could be used in the home member state or when roaming in EU28. The out of bundle rates for data and minutes and the rates for other services such as SMS shall be the same when consumed in any of the EU28 member states.

Must have no application restrictions: the customers shall be free to fully use the 2GB data allowance or any additional 1GB data volume purchased on any legal application they wish (e.g. VoIP, tethering, etc.) without incurring any additional charges (fully net neutral tariffs)

SIM-only rolling post paid contract: the tariff shall not include a subsidized handset and the contract shall be a rolling contract with one month notice

It shall be actively promoted: the EU single market tariff shall be actively promoted and become easily discoverable by consumers both online and in the physical sales locations

The EU single market tariff, if adopted, would overnight expose non-competitive pricing practices in the affected member tates by making a key offering of all European MNOs directly comparable for consumers, regulatory and antitrust authorities. The EU single market tariff while allowing full pricing freedom to MNOs (to reflect their cost base and profitability targets) would provide a very strong incentive to build in the real cost of roaming. MNOs that would stick to the

current cartel like prices

for roaming would stand out of the crowd and risk to lose domestic business to competitors.

In addition, by providing a strong incentive to ending roaming the Commission would be introducing a very powerful though targeted tool to enforce and monitor net-neutrality simultaneously across the EU28 member states. Despite the recent rhetoric of Ms. Kroes in the European P

arliament

So I will guarantee net neutrality

20

the leaked draft proposal, while gives

the right to users

to run applications and use services of their choice

, it also opens a back door to net-big pocket interests

by allowing service providers

to agree with each other on the treatment of the related data volumes or on the transmission of

traffic with a defined quality of service

.

Rewheel believes that the Commission must warrant that the European

consumers have a choice of an easily discoverable, reasonably priced, accommodative of normal usage net-neutral mobile data service, if that is their choice. Although if they opt to purchase instead something else service providers hall also have the right to sell them that. In Exhibit 6 below we present some progressive roaming offers from selected MNOs in Europe to demonstrate that some MNOs have on their own initiative introduced free roaming in selected EU countries where their group is present or EU wide roaming where consumers could fully use their domestic allowances for a daily fee.

20

http://europa.eu/rapid/press-release_SPEECH-13-622_en.htm

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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Exhibit 6:

Progressive roaming offers from selected European MNOs

Source: Rewheel EU27 mobile data cost competitiveness report May 2013, MNO web sites, Rewheel analysis

For helping the reader to gain a perspective on the price level we have also included in the chart the current EU retail and wholesale caps for a smartphone monthly consumption of 2GB, 200 off-net minutes and 20SMSs. For selecting the domestic tariffs and roaming add-ons, if any, we looked both for the cheapest domestic smartphone tariff that satisfied the basket and the cheapest way for consuming the full voice, SMS and data allowance while roaming. In doing o we assumed an opt-

out from the EU regulated €

monthly data roaming cap.

We have selected the following examples representing progressive roaming inclusive smartphone packages:

Voice, SMS and data roaming allowances are included in domestic tariffs: T-Mobile Germany Complete Comfort high-end tariffs are inclusive of roaming minutes and data. The Complete Comfort XL with unlimited domestic minutes and SMS and 2GB of data allowance includes 50 roaming minutes in Europe and 4 Travel & Surf WeekPass (50MB per pass). The SIM only version of t

he Complete Comfort XL costs €63.3.

German customers that

purchase T-

Mobile Premium Tarif for €

9.9 get unlimited minutes and SMS and

GB of data in Germany and

as well 250 minutes, 1000 SMSs and 700MB when roaming in Europe.

Domestic allowances can be fully used while roaming in Europe for a fixed daily fee of £3: Vodafone UK offers a roaming add-

on called the Vodafone EuroTraveller. The add-on

allows consumers to take their all their

UK minutes, texts and data (exclu

ding extras with them anywhere in Vodafone’s Europe zone for £ a day. )f

consumers exceed their monthly allowance while roaming they are charged at the standard UK price plan rate for making calls, sending texts and using mobile data as if they were in the UK.

Voice and SMS roaming allowances are included in domestic tariffs: Some of Hutchison 3G Austria new tariffs launched at 19th of August include as well European voice and SMS allowances. In addition customers can purchase a roaming data add-

on Europa GB for €

. Before launching the new tariffs (utchison G Austria used to offer a

ervice called

Like (ome whereby the domestic allowances could

be fully used while roaming in 5 European

countries where three was present at no extra cost. We are uncertain if this option is available by Hutchison 3G to new customers or it has been removed.

Domestic allowances can be fully used while roaming in selected countries at no extra cost: TeliaSonera

’s

Finnish customers, that are in any of the Sopiva family of postpaid smartphone tarrifs can freely use with no extra charge their domestic voice, SMS and data allowances when they roam abroad in five European countries where

EU retail cap 1

July 2013

EU wholesale

cap 1 July 2013

T-Mobile-DE

Vodafone-UK

3-AT

TeliaSonera-FI

3-UK

Fixed roaming fee

103.5

Data roaming fee

1,080.0

300.0

179.4

100.0

Voice & SMS roaming fee

59.5

20.4

45.1

Domestic tariff price

63.3

29.9

29.8

19.9

15.1

€0

€50

€100 €150 €200 €250 €300 €350

Progressive roaming offers from selected European MNOs

Smartphone tariff basket 2GB&200mis&20SMSs consumed while roaming in EU

€1,140

2 GB

2 GB

2 GB

2 GB

25 GB

20 GB

Vodafone Red Talk

2GB SIM only &

EuroTraveller

T-Mobile Complete Comfort XL SIM only &

Travel & Surf WeekPass

Sopiva Super

in five EU states where TeliaSonera is present

3 Feel Like

Home in five EU states where 3 is present

Hallo Europa SIM L & 2 x Europa 1GB option

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

TeliaSonera is present. TeliaSonera Finland

’s

free roaming offer is applicable to all postpaid smartphone tariffs

from entry level

minutes and GB for €9.9

to high-end

(1,200 minut

es and

GB for €9.9

. The service is

available in Sweden, Denmark, Estonia, Latvia, Lithuania and Norway. Strangely, the service is not available in Spain where TeliaSonera is present (Yoigo).

Domestic allowances can be fully used while roaming in selected countries at no extra cost: 3 UK customers can freely use with no extra charge their domestic voice, SMS and data allowances when they roam abroad in five European countries where 3 is present. The service is available in Italy, Sweden, Denmark, Austria and Ireland. Feel At Home

allows ’s UK customers to

use their UK allowances to call the UK, text the UK and use data on their

phones. If customers have Three-to-Three minutes, they are also able to use these to call someone else on 3 either in the UK or in the same Feel At Home country they are present.

According to our knowledge Vodafone UK is one of the very few operators that has so far introduced an EU wide borderless tariff where domestic allowances can be fully used for an additional daily fee of £3. From the terms and conditions that are

available in Vodafone’s website it is not clear if there is a maximum

period for which the service can be used abroad.

What we find disturbing is that the roaming offers of Vodafone UK, 3 UK and TeliaSonera Finland are not group wide. Other group MNOs are less inclined to end the punitive roaming charges i.e. they either

use EU’s retail caps or have roaming offers

which are substantially inferior. Is it a coincidence that the most competitive roaming offers are offered from MNOs that are based in the most competitive, lowest price EU markets? We do not think so.

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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Disclosures

The comparative analysis carried out by Rewheel Ltd. during the third quarter of 2013, solely on its own initiative, does not constitute an investment, legal or tax advice and is not intended in any way to give any direct or indirect recommendations regarding current or future stock transactions that any party might undertake after reading this report. Rewheel Ltd. and/or its affiliates, and their respective officers, directors and employees accept no liability whatsoever for any direct, indirect or consequential loss arising from their use of this report or its content. The authors of the report make no buy, sell or hold recommendations regarding the stock of the companies covered in this report. Rewheel Ltd. is not a certified financial advisory and is not currently regulated by any financial investment authority. The viewers of this report should consider this publication as only a single factor in making business, regulatory or competition enforcement decisions.

This report does not make, imply or suggest direct or indirect claims of unlawful anti-competitive actions undertaken from any of the mobile network operators or operator groups covered herein. The non-competitive practices that our analyses exposed are based solely on our views on what market behaviors promote rather than demote competition. The term non-competitive practices shall not be associated, interpreted or confused with unlawful anti-competitive actions under national and European competition law.

The data used in this comparative analysis are based solely on public information posted on mobile network operator websites. We believe the tariff information posted on mobile network operator web sites to be reliable but no representation is made by us that the row data used are complete, accurate, fully representative, fully fit for purpose, or were up to date at the time of collection. The data collection team made subjective judgments when translating, interpreting and screening for tariff interdependencies in the mobile network operator web sites. Such subjective interpretations and judgments of tariff conditions, Google translations and of our qualification rules were the sole discretion of the data collection team and of the report authors. Rewheel Ltd. accepts no liability for omissions, errors or simply for not being able to discover on the mobile network operator website a tariff with lower price that met the qualification criteria. We welcome feedback and suggestions from mobile network operators for existing or newly launched tariffs that meet our qualification criteria and which were not considered in our analysis. The findings, conclusions and correlations that the authors of this comparative analysis have reached are solely attributable to their subjective interpretations of Google translations, tariff conditions, qualification rule interpretations and mobile network operator classification & clustering rules.

MNO consolidation in Austria, Germany and EU’s single telecom market mess

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About Rewheel

Rewheel is an independent strategic advisory specializing in data-centric transformation of mobile operators and markets.

We are headquartered in Helsinki, Finland and our main operating footprint is Europe.

Since 2009 we have advised over 10 European mobile operators, including independent challengers as well as Tier-1 OpCos, regulators, competition authorities, a number of private equity and institutional investors and various mobiledata centric start-ups.

Since the onset of the mobile broadband centric 900, 1800 and 2100 MHz license renewal avalanche in 2011 in Europe we have been providing strategy, spectrum valuation and auction theory advice (together with our world class CCA/SMRA auction theorist partners) to five European spectrum authorisation processes (operator or regulator ide depending on country), including new entrants and acquisitions as well as license renewals in multi-band (typically 800, 900, 1800, 2100 and 2600 MHz) auctions.

Our advisors’ knowledge, experience and insights cover all important

aspects of successful data-centric mobile

operator business models. Our typical advisory engagements are:

Mobile-data centric operator business planning end-to-end

Mobile data pricing strategies

3G/LTE mobile infrastructure development strategy and investment planning

3G/LTE mobile infrastructure procurement strategy, network infrastructure cost structure competitiveness

benchmarking and optimisation (Rewheel is truly network vendor independent)

Spectrum acquisition strategy and NPV valuation

Industry expert advisory to policy makers, regulators and competition authorities

Contact information

For further information regarding this report or Rewheel please e-

mail rewheel@rewheel.fi or call Rewheel’s

managing partner, co-author of this flash report, Antonios Drossos at +358 44 203 2339.

APPENDIX

Part #9 Full report: Rewheel EU27 Mobile data cost competitiveness report (May 2013)

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

EU27 mobile data cost competitiveness report

May 2013

EU’s single teleco

arket is threatened by the lack of

obile netork infrastructure based

competition within

the national borders of half of EU’s

e

ber states and fro

the noticeable absence of pan-European

retail

operators offering borderless European tariffs.

Smartphone tariff prices: up to 33x difference in EU27

While in protected markets telco incumbents charge punitive premiums for mobile data allowances on smartphones, in progressive markets 5-10GB, over thousand voice minutes and SMSs became the standard element

of the affordable €

-20 (ARPU level) tariffs.

In progressive markets (e.g. Estonia, Finland and Austria) a GB of smartphone data volume (including thousands of voice minutes and SMSs) costs on average up to 22 times cheaper than in Greece which is the most expensive market in the EU.

Independent challengers (e.g. Tele2 and 3) price on average a GB of smartphone data volume (including similar sized voice minute and SMS bundles) up to 10 times cheaper than Vodafone, KPN, France Telecom, Telefonica or Deutsche Telekom.

Smartphone tariff data volume allowances: up to 500x difference in EU27

Average monthly cellular smartphone data usage has reached 1.5GB and where volume caps allow has exceeded 2GB.

In progressive markets independent challengers (e.g. Tele2 and 3) offer for the same price 100 to 500 times more data volume than what Vodafone, Deutsche Telekom, France Telecom or Telefonica offer in protected markets.

In progressive markets

, hen spending €

consumers get on average 10 times more (13GB vs 1.3GB) smartphone data volume than

in protected markets. On top they also get twice more minutes and SMSs.

Data only tariff volume allowances: up to 100x difference in EU27

In progressive markets independent challengers (e.g. Tele2 and 3) offer for the same price up to 100 times more data volume than what Deutsche Telekom, France Telecom, Telefonica or Vodafone offer in protected markets.

In progressive markets (e.g. Estonia, Finland and Denmark) a GB of mobile broadband data volume costs on average up to 14 times cheaper than in the Netherlands which is the most expensive market in the EU for mobile broadband.

Independent challengers (e.g. Tele2 and 3) price on average a GB of mobile broadband data volume up to 13 times cheaper than KPN, Telefonica, Vodafone, France Telecom or Deutsche Telekom.

Radio spectrum utilisation: over 10x differences between member states

In almost half of the EU27 member state markets the scarce national radio spectrum resources are used very inefficiently by multinational incumbent telco groups which are keen to protect their legacy fixed broadband assets and cement their European dominance with more consolation at the expense of competition.

Germany: the blueprint of the future consolidated EU single telecoms market? We hope not!

Should the future EU single telecoms market be tailored to the German template (

EU’s largest internal arket, ser ed by

Deutsche

Telekom, Vodafone, Telefonica and KPN E-Plus) or rather be simply allowed to evolve to something similar to the Finnish, Swedish, Danish models

here none of those four European Cha pions are present

and,

despite being sub-scale

internal markets,

martphone tariffs are up to ten times cheaper and radio spectrum utilisation is ten times higher?

1,094mins

1,352SMSs

1,448mins 1,745SMSs

925mins

1,204SMSs

1,268mins 2,007SMSs

722mins

1,409SMSs

2,427mins

2,256SMSs

717mins

1.032SMSs

1,206mins

1,341SMSs

1,170mins

2,523SMSs

2,288mins 1,741SMSs

1,703mins 1,933SMSs

€-

€5

€10

€15

€20

€25

Vodafone

KPN

France

Telecom

Telefonica

Deutsche

Telekom

Telekom

Austria

Telenor

Free, DNA,

Play, BITE

TeliaSonera

3

Tele2

Average price per GB and average mins&SMSs included in smartphone tariffs

Average includes all smartphone tariffs that met the smallest GB-basket (0.1GB, 100mins, 20SMSs)

Independent challengers Incumbents E4 group members (Deutsche Telekom, France Telecom, Telefonica, Vodafone)

TeliaSonera's and 3's 100GB martphone tariffs in Denmark are excluded from the averaging

Independent challangers and TeliaSonera ell in average a GB of smartphone data up to 10 times cheaper than E4 Group

Rewheel

o n e

t e p

a h e a d

EU27 mobile data cost competitiveness report

May 2013

2

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Policy recommendations

I trodu e o

petitio i EU’s

prote ted

markets (e.g. Germany, Greece, Hungary, Czech, Belgium)

Introduce pro isions in EU’s Regulatory fra e ork for electronic co

unications that

ill

andate national regulatory and

competition authorities to carry out periodic market analysis and determine the

minimum number of national mobile network

operators necessary to foster competition

(e.g. Ofcom analysis and related measures for ensuring 4 viable national wholesalers)

Safeguard o

petitio i EU’s

progressi e

arkets e.g. UK, Italy,

France, Poland)

Block the takeovers of independent challenger operators

(e.g. 3, Free Mobile, Play) by incumbent operators already present in the

national market (in-market consolidation).

Block the takeovers of independent challenger operators

(e.g. 3, Free Mobile, Play) by other multinational incumbent telco groups

who are not present in the country (cross-border consolidation that will increase concentration on European level and severely limit competition on a national level).

Mobile data retail cost transparency & convergence in EU27 member state markets

The Co

ission has been tracking in Digital Agenda’s Scoreboard the retail cost of oice inutes a erage re enue per inute).

It

hould, starting already in 2013, also introduce and

track the retail cost of mobile data

(average revenue per GB of smartphone data);

which is one of the most relevant cost competitiveness metrics of the digital economy.

Protect consumers against deliberately complicated pricing practices and improve retail transparency

by introducing a reference

martphone tariff

that all licensed MNOs in EU27 member states must price and make commercially available (having no VoIP or

tethering restrictions).

Inefficient use of scarce national spectrum resources

The Co

ission has been tracking in Digital Agenda’s Scoreboard the penetration

of mobile broadband active users. It should,

tarting already in 2013, also introduce and track

the mobile data consumption per capita

for member states

and

mobile data

consumption per customer

for MNOs. Penetration alone is not an adequate metric of digital progressiveness if consumption is

ystematically severely restricted by the supply side (MNOs).

Introduce pro isions in EU’s Regulatory fra e ork for electronic co

unications that ill

empower national regulatory authorities

to

attach efficient spectrum usage license conditions

(Spectrum hoarding occurs both when an MNO accumulates relatively high

amount of spectrum but as well when MNOs are heavily underutilizing their spectrum holdings, see Finnish mobile data consumption per capita which is more than ten times higher than in Germany).

EU single telecom regulator and pan-European spectrum assignments

Mobile networks (radio sites) are intrinsically local based. Spectrum is a scarce national resource. Mobile wholesale networks are assigned national frequencies along country borders and build local radio access distribution networks.

Competition in the mobile

markets is therefore intrinsically confined by the number of licensed wholesale national networks

.

Assigning spectrum across national borders (pan-European licenses), besides the obvious sovereignty concerns it will raise, it will provide the final blow to competition. These new licenses (e.g. 700MHz) can only end-up in the hands of large multinationals that have the financial scale for such massive acquisitions.

Independent challenger operators,

having lost the right to spectrum, will be

pushed down in the value chain, become marginalized site operators and

be forced to open their networks to the multinationals.

Democracies are best served by transparent objectives and ambiguous rules rather than by power concentration and structures that favour special interests. EU needs a revised single regulatory electronic communication framework that unambiguously guarantees competition, protects consumers and is strictly enforced by the 27 member state regulatory and competition authorities.

EU single telecom market needs EU borderless tariffs and pan-European retail operators

European Co

ission’s goal the difference bet een roa ing and national tariffs to approach zero by

5 see s truly

unattainable as far as smartphone tariffs are concerned. The

reference smartphone tariff

could become an

EU single tariff

by simply

requiring that the data, minute and SMS allowances could be freely (no extra charges) used while roaming anywhere in EU.

EU’s single teleco needs

pan-European retail operators that offer borderless tariffs.

Why there are none today? Clearly the

multinational incumbent telco groups have no incentive to end the roaming feast or offer Austrian level prices to Germans (T-Mobile Austria charges

€7

while T-Mobile Germany charges

€9

for the same smartphone tariff allowances).

But why there are no MVNOs that offer such service? It is technically possible and could be financially lucrative for an MVNO to offer a borderless EU tariff. One possible explanation is that MVNOs could be

contractually prohibited to use local wholesale agreements to

connect roamers or citizens from other member states

a Dutch that orks in Belgiu

. Such practice runs against EU’s single arket

rules and should be banned.

EU27 mobile data cost competitiveness report

May 2013

3

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Disclosures

The comparative analysis carried out by Rewheel Ltd. during the second quarter of 2013, solely on its own initiative, does not constitute an investment, legal or tax advice and is not intended in any way to give any direct or indirect recommendations regarding current or future stock transactions that any party might undertake after reading this report. Rewheel Ltd. and/or its affiliates, and their respective officers, directors and employees accept no liability whatsoever for any direct, indirect or consequential loss arising from their use of this report or its content. The authors of the report make no buy, sell or hold recommendations regarding the stock of the companies covered in this report. Rewheel Ltd. is not a certified financial advisory and is not currently regulated by any financial investment authority.

The viewers of this report should consider this publication as only a single factor

in making business, regulatory or competition enforcement decisions.

This report does not make, imply or suggest direct or indirect claims of unlawful anti-competitive actions undertaken from any of the mobile network operators or operator groups covered herein. The non-competitive practices that our analyses exposed are based solely on our views on what market behaviors promote rather than demote competition. The term non-competitive practices shall not be associated, interpreted or confused with unlawful anti-competitive actions under national and European competition law.

The data used in this comparative analysis are based solely on public information posted on mobile network operator websites. We believe the tariff information posted on mobile network operator web ites to be reliable but no representation is made by us that the row data used are complete, accurate, fully representative, fully fit for purpose, or were up to date at the time of collection. The data collection team made subjective judgments when translating, interpreting and screening for tariff interdependencies in the mobile network operator web sites. Such subjective interpretations and judgments of tariff conditions, Google translations and of our qualification rules were the sole discretion of the data collection team and of the report authors. Rewheel Ltd. accepts no liability for omissions, errors or simply for not being able to discover on the mobile network operator website a tariff with lower price that met the qualification criteria. We welcome feedback and suggestions from mobile network operators for existing or newly launched tariffs that meet our qualification criteria and which were not considered in our analysis. The findings, conclusions and correlations that the authors of this comparative analysis have reached are solely attributable to their subjective interpretations of Google translations, tariff conditions, qualification rule interpretations and mobile network operator classification & clustering rules.

EU27 mobile data cost competitiveness report

May 2013

4

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Report contents

1

Executive summary

mobile data cost competiveness and social-economic development in

EU member states ..................................................................................................................................... 5

2

Methodology ........................................................................................................................... 10

2.1

Mobile data cost competitiveness in EU27 member states ........................................................................................ 10

2.2

Mobile Network Operators ......................................................................................................................................... 10

2.3

Smartphone tariff GB-baskets ..................................................................................................................................... 11

2.4

S artphone tariff €-baskets

....................................................................................................................................... 12

2.5

Data only tariff GB-baskets ......................................................................................................................................... 13

2.6

Detailed qualification rules for smartphone tariffs ..................................................................................................... 13

2.7

Detailed qualification rules for data only tariffs .......................................................................................................... 15

2.8

Treatment of tariffs with unlimited data, minute and SMS volumes .......................................................................... 15

2.9

Data collected from MNO websites ............................................................................................................................ 16

3

MNO group and member state market classification rules .................................................... 17

3.1

MNO group classification rules ................................................................................................................................... 17

3.2

Member state market classification rules ................................................................................................................... 17

4

Sub €, ARPU-level

and unlimited data smartphone tariffs ................................................. 18

4.1

Sub € selected s artphone tariffs in EU7

............................................................................................................. 18

4.2

ARPU-level selected smartphone tariffs in EU27 ........................................................................................................ 19

4.3

Selected unlimited or very high data allowance smartphone tariffs in EU27.............................................................. 20

5

Member state level analysis.................................................................................................... 21

5.1

S artphone tariff €

-basket in EU27 member states ............................................................................................... 21

5.2

Smartphone tariff 2GB-basket in EU27 member states .............................................................................................. 22

5.3

Average smartphone tariff price among the 6 defined GB-baskets in EU27 member states ...................................... 22

5.4

Average smartphone tariff price and average GBs, minutes & SMSs included in EU27 member states ..................... 23

6

MNO group level analysis........................................................................................................ 26

6.1

Smartphone tariff GB-basket average price of independent challengers, incumbents and E4 group members ......... 26

6.2

Average smartphone tariff price and average GBs, minutes and SMSs included by MNO groups .............................. 27

6.3

Lowest from progressive and highest from protected 4GB-basket smartphone tariff prices of E4 group members .. 30

7

Member state level detailed basket analysis .......................................................................... 31

8

MNO level detailed basket analysis ........................................................................................ 37

9

Data only tariff analysis ........................................................................................................... 49

10

Germany, the blueprint of a consolidated EU single communication market? ...................... 53

11

List of exhibits ......................................................................................................................... 60

Annex 1

MNO tariff names .................................................................................................................. 62

About Rewheel ........................................................................................................................................ 75

EU27 mobile data cost competitiveness report

May 2013

5

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1

Executive summary

mobile data cost competiveness and

ocial-economic development in EU member states

For the traditional industries the cost of energy

Battered by the financial crisis, high indebtedness levels and the gradual loss of competitiveness

Europe’s econo

ies ha e entered

what many economists believe a prolonged period of stagnation.

According to the draft guidelines for the March 2013 summit conclusions

1

the EU heads of state

intended to focus

on key aspects of energy policy ai

ed at boosting groth, producti ity and

employment to help overcome the effects of the economic crisis. The EU heads were scheduled to meet and discuss how to lower energy prices and so improve the Uni

on’s industrial co

petiti eness

during an energy summit on the 22

nd

of May. In the draft document particular emphasis was given on

tackling

High energy prices and costs

that haper European copetiti eness .

While the Council was

focusing on key aspects of energy policy, the European Commission is busy safeguarding a level playing field so big businesses do not abuse their position of power. On the 14

th

of May

Europe’s

antitrust authority said it was investigating major multinational oil companies (Shell, BP and Statoil) over suspected anti-competitive agreements and price manipulation

2.

… for the digital

economy the cost of mobile data

Whi

le Europe’s econo

y is stagnating,

the digital arm of the economy is growing at seven times the

rate of the rest of the economy

3.

According to the Digital Agenda Commissioner, Mrs. Neelie Kroes

Europe is now profiting from a consistent, long-term policy put in place by national regulators: low

prices, more transparency and more competitiven

ess4.

However, as the Digital Score Board metrics

how there are stark differences between the state and growth of digital economies among the EU27 member states. The winners are the Nordics, UK and Austria where strong local national regulatory oversight and competition enforcement is driving price competition, penetration, cost competitiveness and growth. On the other side of the wall in

EU’s

any

protected national markets

multinational incumbent telco groups heavily lobby for more consolidation and are threatening with an investment embargo in a desperate attempt to resist change and protect their inherited oligopolistic high profit margins.

1

http://www.euractiv.com/energy/eu-leaders-sqare-circle-cheap-en-news-519606

2

http://uk.reuters.com/article/2013/05/14/uk-statoil-inspection-idUKBRE94D0N320130514

3

http://europa.eu/rapid/press-release_IP-12-1389_en.htm

4

http://www.dutchnews.nl/columns/2013/05/neelie_kroes_27_keys_to_open_o.php

EU27 mobile data cost competitiveness report

May 2013

6

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As energy cost is a key aspect of industrial competitiveness, communication (particularly mobile data) cost is a key aspect to digital competitiveness. Digital competitiveness in the form of affordable mobile internet access connections drives the adoption of digital applications, cloud computing, internet of mobile things, e-learning, e-heath and online trade that underpin economic growth.

Smartphones, thanks to their innovative user interfaces enabling instant and seamless internet access became the primary personal vehicles of the digital economy. Their increasingly affordable prices

no sub €

, also carry the potential to bridge the digital divide between the wealthier urbanized

ocieties

and the poorer,

ore rural societies of EU’s ne est

e

ber states.

But only, if mobile

network operators, entrusted with the exploitation of the member states

scarce and highly valuable

national radio spectrum resources, offer consumers and businesses the choice of affordable, competitively priced smartphone tariff plans.

Earlier Rewheel research: alarming price differences revealed

Our earlier research

5,

published in January 2013, revealed alarming, ten times, differences in the

absolute price level and affordability of one particular consumer smartphone tariff basket (2GB and 200 minutes per month) across the EU27 member states. Moreover, our analysis showed that in the affected member states high prices were already suppressing mobile internet adoption, as shown in Exhibit 1 below.

Exhibit 1 Mobile internet penetration tends to be significantly higher in those member states where ufficient data volume is included in affordable (ARPU-level) smartphone tariff plans

5

http://rewheel.fi/insights_14.php

SI

FR

LV

RO

LT

UK

PL

EE

IE

DK

AT

SE

FI

IT

BE

CY

BG

EL

MT

HU

NL

CZ

LU

DE

ES

SK

PT

R² = 0.3413

0%

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

100%

0%

50%

100%

150%

200%

250%

300%

350%

400%

450%

500%

penetration of active mobile internet users in January 2012

average market price of 2GB-200min smartphone tariff

as percentage of member state ARPU in 2010

There is an independent challenger MNO There is NO independent challenger MNO

3 to 5 times more expensive than what average consumers are used to pay for their mobile phone bills

2GB-200min martphone tariff basket affordable for the masses

EU27 mobile data cost competitiveness report

May 2013

7

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Source: Rewheel EU27 smartphone tariff competitiveness report

January 2013

Furthermore, we have shown (see Exhibit 2 below) that the single most influential factor behind high prices and low mobile internet penetration was the market dominance of large multinational incumbent telco groups.

Exhibit 2 The prices of 2GB-200min smartphone tariffs tend to be the lowest and mobile internet penetration the highest where none of the five European incumbent telcos are present

Source: Rewheel EU27 smartphone tariff competitiveness report

December 2012

Having strong financial dependency on historically high margin voice and SMS revenues and vested interest in protecting fixed broadband infrastructure assets, incumbent multinational groups are unwilling to drive the mass adoption of mobile internet access by offering affordable tariffs if that means that they will have to endure a profit margin hit. So they resort to defensive non-competitive trategies aimed at protecting their markets territories from independent challenger mobile only operators. Independent challenger mobile only operators, having no significant economies of scale, have pushed data cost competitiveness to new heights by most efficiently utilizing HSPA+, LTE, small cells and lean overheads. Their ability to offer profitably and reliably tens of gigabytes for single digit Euros per month is raising serious doubts about the necessity of private or state subsidized fixed broadband investments.

Competition concerns?

Our January 2013 report findings raised concerns among many national regulatory and competition authorities and among

the EU Co

ission’s Teleco

Antitrust Unit. Mr. Joa uín

Almunia, EU

’s

Vice

President of the European Commission responsible for Competition Policy, cited our research, warning

that

users pay up to ten times more to use their smartphones in those member states where there is

EU27

Ch+

Ch-

3MNO

4MNO

VF+

VF-

DT+

DT-

FT+

FT-

VF+,3MNO

DT+,3MNO

VF+DT+,3MNO

E5-

E5+

Ch+,E5-

Ch-,E5+

30% 35% 40% 45% 50% 55% 60%

€20

€25

€30

€35

€40

€45

€50

€55

Average mobile internet user

penetration

in the

pecific member state cluster

Average of

average market prices of the 2GB-200min smartphone tariff basket

in the specific

member state cluster

EU27

A verage fo r all EU27 member states

FT+

France Teleco m is present in the market

Ch+

There IS Challenger M NO

FT-

France Teleco m is NOT present in the market

Ch-

There is NO Challenger M NO

VF+,3MNO

Vo dafo ne is present and there are o nly 3 M NOs

3MNO

There are less than 4 M NOs

DT+,3MNO

Deutsche Teleko m is present and there are o nly 3 M NOs

4MNO

There are 4 M NOs

VF+DT+,3MNO

B o th Vo dafo ne and Deutsche Teleko m are present and o nly 3 M NOs

VF+

Vo dafo ne is present

E5-

M NOs belo nging to the "E5 Gro up" are NOT present in the market

VF-

Vo dafo ne is NOT present

E5+

M NOs belo nging to the "E5 Gro up" are present in the market

DT+

Deutsche Teleko m is present

Ch+,E5-

There is at least o ne challenger M NO and no "E5 Gro up" present

DT-

Deutsche Teleko m is NOT present

Ch-,E5+

"E5 Gro up" is present and there is NO challenger

EU27 mobile data cost competitiveness report

May 2013

8

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

no challenge

r to the big European operators6.

During the first half of 2013 we held many workshops

with national regulatory and competition authorities and we presented and elaborated our findings and recommendations to the DG Competition and DG Connect units of the European Commission in February 2013.

New, comprehensive Rewheel research: reconfirmed earlier findings, exposed further noncompetitive practices

The aim of our new comprehensive follow up research, carried out during the second quarter of 2013, was to widen our analysis and collect additional market information that will further strengthen and upport our list of recommended policy actions. We have expanded our analysis in three fronts;

We have now defined and analysed six smartphone usage baskets to cover all usage profiles from entry level to heavy user

We introduced and analysed five new

Euro baskets , i.e. ho

uch s

artphone data

volume allowance one can get for a specific price (and how many minutes and SMSs are also built within)

We have included and separately analysed data only tariffs i.e. MBB, tablet, iPad tarrifs

The outcome of this new comprehensive analysis has fully reconfirmed our earlier disturbing findings of very high prices that are prevalent in protected markets dominated by multinational telco groups and as well exposed further non-competitive market practices such as the inefficient use of allocated pectrum.

EU’s si gle tele o

arket is threate ed

y the la k of

o ile et

ork i frastru ture

ased

o

petitio

ithi the

atio al

orders of half of EU’s

e

er states a d fro

the

noticeable absence of pan-European retail operators offering borderless European tariffs.

By far the most disturbing finding of our analysis is that certain local mobile operators which belong to multinational telco groups are unwilling to drive mobile data competition in protected markets (i.e. have the highest prices and smallest data allowances) even though; they have the lowest market hare in the local mobile market, they have no fixed broadband business in the local market, they have been losing market share in mobile data, their spectrum utilization is low, their traffic is very low and stagnant for years while they have modernized their network and while they are enforcing the heaviest anti-neutrality rules in the market. There is no business logic behind such irrationally weak competitive behaviours (with the exception of the incompetence of local management and no group oversight). Perhaps one needs to look

beyond

the local market and into the EU-wide operational

6

http://europa.eu/rapid/press-release_SPEECH-13-168_en.htm

EU27 mobile data cost competitiveness report

May 2013

9

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footprint of multinational incumbent telco groups to find a business rational explanation for such noncompetitive practices which may not only be confined in protecting prices but may also extend to coordinating positions

7

ahead of radio spectrum auctions

(see Section 10, focused at Germany).

We addressed our concerns regarding this very disturbing finding to officials from DG Competition Telecom Antitrust Unit and DG Connect at the workshop we held during February 2013 and disclosed the content of our workshop presentation into the public domain.

8

We decided to widen our analysis and release, this time, all the findings and recommendations to the public domain. Our decision was triggered by the warm reception that our January 2013 report received and by responding to a request we received from EU

’s

Telecom Antitrust officials to release

our findings into the public domain as soon as possible.

7

http://www.telecompaper.com/news/german-watchdog-probes-mobile-firms-over-frequencies-info--941585

8http://rewheel.fi/downloads/Rewheel_smartphone_tariff_competitiveness_2012_report_supplement_PUBLIC.pdf

EU27 mobile data cost competitiveness report

May 2013

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2

Methodology

2.1

Mobile data cost competitiveness in EU27 member states

The primary aim of this comprehensive comparative follow up research analysis conducted by Rewheel during the second quarter of 2013 was to benchmark the mobile data cost competitiveness in EU27 member states. Having established the mobile data retail cost level in smartphones and data only tariffs for a variety of

GB and €

baskets we will set out to assess and expose the underlining non-

competitive practices and market drivers that are causing huge cost disparities on an MNO level, MNO group level and member state level.

2.2

Mobile Network Operators

The scope of our comprehensive comparative analysis covered MNOs holding a national mobile license in the 800, 900, 1800, 2100 MHz frequency bands in the EU27 member states according to GSMA list

9

that have launched commercial service and had tariffs on their web sites. MNOs with only

2600 MHz, CDMA or WiMAX license were excluded from the analysis. 91 MNOs in total were included in the analysis. We have excluded from the analysis Orange Austria which was acquired by H3G Austria and Tele2 Netherlands. Tele2 Netherlands has not launched a commercial service with its own frequencies at the time we collected the tariff data.

Mobile Virtual Network Operator (MVNO) tariffs or plans have been excluded from this release of our EU27 mobile data cost competitiveness report. According to our field experience from many European markets gained during the last three years, MVNOs are still confronted by substantial barriers of entry often erected by MNOs which are closely guarding mobile margins. In the voice centric era, a competitive pure bulk wholesale volume

€/

in

based deal was all an MVNO needed to compete

head to head with MNOs. However, in the mobile data era

here capacity is king, a copetitive

bulk wholesale volume based deal (

€/GB)

could still leave an MVNO with a major retail handicap.

Unless MVNOs get partial direct access to MNOs spectrum/network capacities (i.e. a capacity based wholesale rather than volume based) they will not be able to fulfill their role and stimulate competition in the data/smartphone centric mobile markets. We interpret the pre-conditions set out most recently by EU Competition Commission for the approval of Orange Austria

10

takeover by H3G

Austria a step towards the right direction: among the concessions agreed by H3G Austria was the

9

Source: GSMA http://maps.mobileworldlive.com/

10

http://europa.eu/rapid/press-release_IP-12-1361_en.htm

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commitment to provide on agreed terms wholesale access to its network for up to 30 percent of its capacity to up to 16 MVNOs in the coming 10 years.

2.3

Smartphone tariff GB-baskets

In our January 2013 smartphone tariff competitiveness report we targeted a basket with a minimum of 2GB data allowance and 200 off-net minutes to all national mobile and fixed networks. We selected the minimum monthly data volume allowance with the aim to get an allowance that can accommodate the working needs (email) and entertainment needs (browsing, Facebook, Youtube) of

the

ajority of

ainstrea

acti e nor

al s

artphone users, that

most typically are using i-OS,

Android or Windows 8 operating systems. We further provided a numbers of references whereby MNOs, national regulatory authorities and research firms reported in the US and in some progressive EU markets average smartphone monthly data usage ranging from 0.7 to 2GB.

We would like to add to those references a research published by Informa Telecoms & Media and Mobidia

11

in late 2012 that presented the global average cellular smartphone data monthly usage

figures. The overall sample analyzed consisted of more than 100,000 users globally and the data were collected during May 2012. The global average monthly cellular data usage was 1.5GB and 2.1GB respectively for smartphone users that were on >1GB and unlimited data allowance packages. In the UK the figures were 2.1GB and 1.9GB respectively for smartphone users that were on >1GB and unlimited data allowance packages.

In the fourth quarter of 2012 and during the first half of 2013 a number of European MNOs launched a wave of new smartphone tariffs with unlimited voice and SMS allowances. These new family of tariffs reflect a new era in the mobile industry whereby voice and SMS is commoditized and could be easily ubstituted by popular over the top applications such Skype and WhatsApp. The main price differentiator in these new unlimited voice and SMS family of tariffs is the data allowance built in. Most recently a number of MNOs have introduced more generous GB allowances in their high end tariffs (i.e. 5-10GB) to accommodate the steep increase in average monthly usage reported by Informa Telecoms & Media. We feel vindicated for our choice of 2GB in our January 2013 report. MNOs that were quick to criticize the allowance as excessive have two months later launched tariffs with 5GB or 10GB allowances.

In addition to the 2GB basket we have defined and will be using in our analysis five more GB baskets presented below.

11

Source: http://www.informatandm.com/wp-content/uploads/2012/08/Mobidia_final.pdf

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0.1GB-basket:

Includes as a minimum 0.1GB of mobile data, 100 off-net minutes to all

national mobile and fixed networks and 20 SMSs to all national mobile networks

0.5GB-basket:

Includes as a minimum 0.5GB of mobile data, 100 off-net minutes to all

national mobile and fixed networks and 20 SMSs to all national mobile networks

1GB-basket:

Includes as a minimum 1GB of mobile data, 100 off-net minutes to all national

mobile and fixed networks and 20 SMSs to all national mobile networks

2GB-basket:

Includes as a minimum 2GB of mobile data, 200 off-net minutes to all national

mobile and fixed networks and 20 SMSs to all national mobile networks

3GB-basket:

Includes as a minimum 2GB of mobile data, 500 off-net minutes to all national

mobile and fixed networks and 20 SMSs to all national mobile networks

4GB-basket:

Includes as a minimum 2GB of mobile data, 1,000 off-net minutes to all national

mobile and fixed networks and 20 SMSs to all national mobile networks

The 2GB-basket used in our analysis herein also included 20 SMSs. So the charts presenting the 2G- basket while quite similar are not identical to the charts presented in our January 2013 report. The differences are attributed both to the addition of the 20 SMSs and as well new tariffs with lower prices launched by MNOs during 2013.

2.4

S

artpho e tariff €-baskets

The primary aim of the GB-basket comparison is to expose price differences of comparable items for a variety of low, mid-range and high usage profiles. However, usage basket profiles fail to accurately capture the value (GBs, minutes and SMSs) that consumers receive when spending a certain amount of money. For example in Austria consumers can purchase 2GB, 1,000 minutes and 1,000 SMSs for as

little as €

. In

ore than ten

e

ber states a consu

er

ill need to spend

ore than €5 to

purchase the smallest GB-basket of 0.1GB, 100 minutes and 20 SMSs. Therefore we defined and

present belo

fi e € baskets

ith the ai

of capturing the alue for

money that consumers received

from MNOs, MNO groups and by the MNOs present in a member state.

-basket:

Lowest price smartphone tariff per MNO with the highest GB allowance which

includes a minimum of 100 minutes and 20 SMSs and

ha ing a price of e ual or less than €.

-basket:

Lowest price smartphone tariff per MNO with the highest GB allowance which

includes a minimum of 100 minutes and 20 SMSs and having a price of eq

ual or less than €.

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-basket:

Lowest price smartphone tariff per MNO with the highest GB allowance which

includes a minimum of 100 minutes and 20 SMSs and

ha ing a price of e ual or less than €.

-basket:

Lowest price smartphone tariff per MNO with the highest GB allowance which

includes a minimum of 100 minutes and 20 SMSs and

ha ing a price of e ual or less than €.

€100-basket:

Lowest price smartphone tariff per MNO with the highest GB allowance which

includes a minimum of 100 minutes and 20 SMSs and having a price of equal or less than

€100.

When

e applied the €-baskets

on an MNO Group level or member state level we selected the tariff

with the highest minutes if there were two tariffs with the same price and same GB allowances available by different MNOs.

2.5

Data only tariff GB-baskets

For data only mobile broadband (MBB), tablet and iPad tariffs we defined the following GB baskets.

5GB-basket:

Includes as a minimum 5GB of mobile data

10GB-basket:

Includes as a minimum 10GB of mobile data

20GB-basket:

Includes as a minimum 20GB of mobile data

We were surprised to see that a few MNOs are still offering data only tariffs with allowances that are maller than 1GB. On the positive side, as the data will show, many MNOs without fixed broadband interests have flooded the market with affordable substitutive offers of +50GB, starting from as low as

€ a

onth, and for €

-30 offering LTE speeds too.

2.6

Detailed qualification rules for smartphone tariffs

Below we present the detailed rules we applied in screening and selecting the qualified tariffs for each MNO.

We looked for the lowest price, consumer, post-paid, SIM only, promotional, integrated smartphone tariff that included as a minimum 0.1GB of mobile data, 100 off-net minutes to all national mobile and fixed networks and 20 SMSs to all national mobile networks.

loest price

means a tariff that fulfills all other conditions and has the lowest price

consumer

eans

not a business tariff or special tariff such as youth-only, senior-only, i-

phone-only, with phone subsidy-only, etc.

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post-paid :

implies prepaid offerings were excluded but rolling postpaid contracts were

considered in the analysis

SIM-only :

ome MNOs were offering a tariff in discounted price if the subscriber opted out

and did not purchase a new subsidized smartphone. In the event an MNO offered a GB allowance defined in one of our six GB-baskets only with a subsidized handset and not on a SIM-only basis we registered that tariff as the tariff with the lowest price. This was necessary because some MNOs, in a clearly protective tactic, only offer the high GB allowances on highend expensive tariffs that included a handset subsidy.

pro

otional

means promotional offers for limited time of period (Christmas offer, etc). We

calculated the blended monthly fee for the contract duration in cases the promotion was offering a discount for the few months after the customer has signed up.

integrated

means a tariff that includes both a minimum of GB of data volume at minimum

1Mbps speed and a minimum off-net minute and SMS allowance.

When we were trying to select the tariff with the lowest price that met a certain GB-basket we often had to add to an existing tariff an optional add-on of GBs, minutes or SMSs. This operation was quite often necessary because the GB, minute or SMS steps of the next available off-the-shelf tariff were much higher and the price was more expensive than taking a cheaper tariff and adding for example 1GB of additional monthly data allowance.

In doing so we only considered add-ons with a rolling monthly nature whereby the consumer had to activate the optional add-on just once rather than having to do that on a monthly basis. Add-ons

refills

that need reoccurring manual monthly reactivation by the consumers as soon as the GB

allowance has been depleted have been explicitly excluded. Besides being non-consumer friendly we could not understand the business logic of such one-time activations if they were not also offered on a rolling basis. It appears that certain MNOs that only offer smartphone data add-ons on a non-rolling basis attempt to de-incentivize the use of additional data even though such use would lead to additional tariff charges and company revenue. The only business rational explanation for such noncompetitive practice is that the MNO is actively forcing the consumers to binding 2-year contracts by purchasing a much more expensive tariff with handset subsidy and a sufficient GB allowance.

Finally where the terms and conditions were readily available on the MNO web site we logged in the database tariff usage restrictions such as VoIP and tethering. Certain E4 multinational incumbent telco groups are imposing such restrictions on a wide range of their tariffs. In many cases such restrictions are not fully explained on the website, but are hidden somewhere deep in the general terms and conditions documents. The deep inspection of such documents was beyond the scope of our investigation, therefore our database does not contain an exhaustive list of MNOs with such terms.

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2.7

Detailed qualification rules for data only tariffs

The detailed rules for the qualification of data only tariffs were quite straightforward. We included MNO

available tariffs classified into MBB, tablet and iPad categories. We registered the GB

allowance limits, speed limitations, LTE availability and usage restrictions such as VoIP and tethering.

2.8

Treatment of tariffs with unlimited data, minute and SMS volumes

A number of MNOs offer smartphone tariffs with unlimited data, minute or SMS volumes and as well data only tariffs with unlimited data volume. During the analysis we performed a number of averaging operations and therefore we had to assign finite volumes to these unlimited offerings.

In assigning the finite volumes for the unlimited parts of a tariff we observed the following rules.

Smartphone tariff unlimited data volume: we assigned

GB to tariffs offering truly

unlimited data volume. For tariffs that were marketed as unlimited but had a fair usage policy we used the volume cap defined in the fair usage. In Finland and Estonia where we assigned 10GB volume to tariffs with unlimited data volumes other MNOs offered much higher (15GB- 50GB) volume capped data for smartphones. In the UK where we also assigned 10GB to tariffs with unlimited data volumes other MNOs offered up to 8GB data volume in their martphone offers. In Romania where we also assigned 10GB to tariffs with unlimited data volumes other MNOs offered up to 4GB data volume in their smartphone offers but

consu

ers had the possibility to consu

e

GB by paying o erage charges e.g. €/

MB

when exceeded the 4GB.

Smartphone tariff unlimited minute volume: we assigned the volume cap mentioned in the fair usage policy if such information was available or the highest volume included in a martphone tariff by any other MNO in the same market. E.g. if the fair usage policy had a cap of 2,000 minutes then we assigned 2,000 minutes to the unlimited offering. If there was no fair usage policy but another MNO in the market offered a tariff with 1,500 minutes then we assigned 1,500 minutes to the tariff with the unlimited minute volume. If there was no MNO that offered a tariff that had more than 1,000 minutes then we assigned 1,000 minutes to tariffs with unlimited volume.

Smartphone tariff unlimited SMS volume: identical rules with unlimited minutes

Tablet and iPad tarrif unlimited data volume: we assigned a 10GB volume to tablet and iPad tariffs with unlimited volume.

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MBB tariff

ith unli

ited data olu

e:

e assigned

GB to tariffs offering truly unli

ited

data volume. For tariffs that were marketed as unlimited but had a fair usage policy we used the volume cap defined in the fair usage. In Austria, Finland, Estonia and Lithuania where we assigned 30GB volume to tariffs with unlimited data volumes other MNOs offered at least 30GB or higher volumes on their MBB tariffs. In Latvia where we also assigned 30GB to tariffs with unlimited data volumes other MNOs offered tariffs with up to 25GB data volume.

2.9

Data collected from MNO websites

The data were collected directly from the MNO web sites during the second quarter of 2013. The date of entry for each tariff was registered as well as the weblinks to the MNO website. The tariffs were collected between the 27

th

of March 2013 and the 21

t

of May 2013. Our data collection team could

read and understand English, Finnish, Swedish, French, Greek and Hungarian. For the remaining MNO web sites which were not available in any of these six languages the team used the automatic translation function of Google. The data collection team has taken screen shots from every single MNO tariff that was used in the comparative analysis. The name of each MNO tariff which was included in the analysis can be found in Annex 1. In total we screened thousands MNO tariffs and registered in our database 771.

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3

MNO group and member state market classification rules

3.1

MNO group classification rules

We have classified MNOs to three distinct (mutually exclusive) group categories:

E4 group members

Incumbents

Independent challengers

All MNOs belonging to the Deutsche Telekom Group, France Telecom Group, Vodafone Group, and Telefonica Group have been classified as E4 group members.

Any MNO, not belonging to the E4 group and fulfilling any of the below listed criteria has been

classified as Incu

bent :

It is the no.1 MNO in terms of subscription market share in any of the EU27 member states

If it is part of a group then there is at least one MNO in the group that holds a no.1 position in terms of subscription market share in any member state

If the owner of the MNO is an incumbent fixed operator or a

minority

shareholder in an

incumbent group

If during the year that preceded the tracking period (calendar year 2013) merger talks had been held with an incumbent MNO (e.g. WIND Hellas merger talks with Vodafone GR)

All the rest of the MNOs that have not been classified as either an E4 group member or as an incumbent have been classified as independent challenger operators.

3.2

Member state market classification rules

We have classified a member state market as

progressive

if there was at least one independent

challenger MNO present. Member states where there were no independent challenger MNOs but only E4 group and incumbent MNOs present have been labeled as

protected

markets.

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4

Su

, ARPU-level

and unlimited data smartphone tariffs

E4 group (Vodafone, Deutsche Telekom, France Telecom, Telefonica) members and other incumbents with vested interest in protecting and further strengthening their dominance in fixed broadband networks have cultivated the belief that mobile data is expensive and can only be offered to complement fixed offerings. They have labeled independent challenger operators

as

a ericks

and

their mobile data offerings

as

unsustainable . Our analysis of the mobile data cost competitiveness

across the EU27 member states discredits this notion. Incumbents that are mainly operating in progressive markets have joined independent challengers in the race of efficiently producing and retailing mobile data. In this section we provide a prelude of the stark contrast in smartphone tariff pricing and value for money (i.e. amount of data offered). We do that by using selected tariffs from independent challengers, incumbents and E4 group members, operating in progressive markets and protected markets.

4.1

Su €

elected smartphone tariffs in EU27

In Exhibit 3

belo

e present selected sub €

s

artphone

tariffs from progressive and protected

markets. The list of progressive member states where operators offer

ub €

s

artphone tariffs

includes both high ARPU member states such as Finland, Austria, UK, Italy, Slovenia and low ARPU member states such as Poland, Latvia, Lithuania and Romania.

Exhibit 3 Selected sub

martphone tariffs from progressive and protected

arkets ǀ MNO ie

Source: Rewheel analysis

0.2GB

0.1GB

0.1GB

0.2GB 0.1GB

5GB

1GB

Unlmt

0.5GB

1GB

0.2GB

Unlmt

0.5GB

0.1GB

O.5GB

5GB

Unlmt

1GB

0.2GB

1GB

1GB

Unlmt

2GB

€-

€1 €2 €3 €4 €5 €6 €7 €8 €9

€10 €11 €12

Selected smartphone tariffs (range

€4-€10)

from progressive and protected markets

Smartphone tariffs from progressive markets Smartphone tariffs from protected markets

In progressive markets MNOs offer smartphone tariffs for as low as

€5

100 m ins

U nl im it e d m ins

U n li m it e d m in

100 m ins

100 m ins

100 m ins

100 m ins

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Bulgaria is the only protected

arket

here a sub € s

artphone tariff

could be found. Bulgaria had

the fourth lowest ARPU in EU27 in 2010. While many of the smartphone tariffs include very small (<0.5GB) data allowances there are independent challengers (e.g. Tele2 and 3) and incumbents (e.g. TeliaSonera and Elisa) that offer more than 1GB or even unlimited volume

for less than €

.

In progressive markets independent challengers (e.g. Tele2 and 3) and incumbents (e.g. TeliaSonera and Elisa) offer smartphone tariffs with at least 1GB of data for less than

€.

4.2

ARPU-level selected smartphone tariffs in EU27

In Exhibit 4 below we present selected ARPU-

le el €

-

€ 7 s

artphone tariffs fro

progressi e and

protected markets.

Exhibit 4 Selected ARPU-level smartphone tariffs from progressive and protected markets

ǀ

MNO

view

Source: Rewheel analysis

Independent challengers (e.g. Tele2 and 3) and incumbents (e.g. TeliaSonera and Elisa) that are present mainly in progressive markets offer smartphone tariffs priced at ARPU level that include 10GB to 50GB or unlimited data. Deutsche Telekom, France Telecom, Telefonica and Vodafone for the same price offer in protected markets a dismal 0.2GB.

In progressive markets independent challengers (e.g. Tele2 and 3) offer for the same price 100 to 500 times more data volume than what Vodafone, Deutsche Telekom, France Telecom or Telefonica offer in protected markets.

Unlmtd

Unlmtd

20GB

11GB

50GB

35GB

10GB

0.1GB 0.2GB

0.1GB

0.2GB

0.15GB

0.2GB 0.1GB

0,2GB

€-

€5

€10

€15

€20

€25

€30

€35

Selected smartphone tariffs (range

€14-€27)

from progressive and protected markets

Smartphone tariffs from progressive markets Smartphone tariffs from protected markets

100 to 500 times more data volume for the same price

100 m ins

200 m ins

100 m ins

U nl im it e d m ins

1 0 0

m ins

1000 m ins

U nl im it e d m ins

100 m in

100 m ins

100 m ins

100 m ins

120 m ins

100 m ins

100 m ins

100 m ins

100 m ins

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4.3

Selected unlimited or very high data allowance smartphone tariffs in EU27

In Exhibit 5 below we present selected smartphone tariffs having an unlimited or very high (>8GB) data volume allowance. Several incumbents such as TeliaSonera, Telenor, TDC, Belgacom etc. offer martphone tariffs with up to 100GB. E4 group members as well do offer smartphone tariffs with more than 10GB although at a price that is several multiples of ARPU. Independent challengers offer martphone tariffs with unlimited or very high data allowance at ARPU level or at a small premium above ARPU level.

Exhibit 5 Selected unlimited or very high data volume smartphone tariffs

ǀ

MNO view

Source: Rewheel analysis

Unlmtd

Unlmtd

20GB

50GB

35GB

15GB

20GB

100GB

10GB

20GB

30GB

10GB15GB

16GB

8GB

100GB

11GB

25GB

20GB

10GB

11GB

€-

€20

€40

€60

€80

€100

€120

€140

Selected smartphone tariffs (10GB -100GB)

Independent challengers, incumbents and E4 group members

Independent challengers Incumbents E4 group members (Deutsche Telecom, France Telecom, TelefonicaO2, Vodafone)

Incumbents and E4 Group members also offer 10GB - 100GB smartphone tariffs

120 m ins

100 m ins

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5

Member state level analysis

In this section we present the results of the comparative member state

analysis starting

ith the €

-

basket and the 2GB-

basket. The €, €

, and €

-basket and 0.1GB, 0.5GB, 1GB, 3GB and 4G-basket

charts can be found in Section 7.

5.1

Smartphone tariff

-basket in EU27 member states

In Exhibit 6 below we present the

martphone tariff basket in EU27 member states.

Exhibit 6

smartphone tariff basket

ǀ

Member state view

Source: Rewheel analysis

In progressive markets consumers get on average 10 times more (13GB vs 1.3GB) smartphone data volume than in protected

arkets

he spe di g €. O top they also get

twice more minutes and

SMSs.

0 2 4 6 8

10 12 14 16 18 20 22

GB

Smartphone tariff

€30-basket

Lowest price smartphone tariff per member state with the highest GB allowance and a price of equal or less than

€30

5 0

G B

3 5

G B

Progressive markets average:

13GB for

€24

1,282mins & 1,243SMSs

Protected markets average:

1.3GB for

€26

783mins & 658SMSs

U nl im it e d da ta , a um e d 1 0

G B

w he n a v e ra g ing

U nl im it e d da ta , as um e d 1 0

G B

w he n av e ra gi ng

U nl im it e d da ta , a um e d 1 0

G B

w he n a v e ra g ing

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5.2

Smartphone tariff 2GB-basket in EU27 member states

In Exhibit 7 below we present the 2GB smartphone tariff basket in EU27 member states.

Exhibit 7 2GB smartphone tariff basket

ǀ

Member state view

Source: Rewheel analysis

There are 10 progressive markets where the 2GB-basket costs

less than €5 and

protected

arkets

here it costs

ore than €.

In protected markets the 2GB-basket costs on average

hi h is

% €

ore tha i

progressive markets.

5.3

Average smartphone tariff price among the 6 defined GB-baskets in EU27 member states

In Exhibit 8 below we present the average smartphone tariff prices among the 6 defined GB-baskets in EU27 member states.

€0 €5

€10 €15 €20 €25 €30 €35 €40 €45 €50

Smartphone tariff 2GB-basket

Lowest price smartphone tariff per member state with at least 2GB&200mins&20SMSs

In protected markets the 2GB-basket costs in average

€36

In progressive markets the 2GB-basket costs in average

€15

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Exhibit 8 Average smartphone tariff prices among the 6 defined GB-baskets

ǀ

Member state view

Source: Rewheel analysis

5.4

Average smartphone tariff price and average GBs, minutes & SMSs included in EU27 member states

In Exhibit 9 below we present the average smartphone tariff price and average GBs, minutes and SMSs included across the EU27 member states

12.

The main motivation for this chart was the fact that in

many progressive markets MNOs offered the highest defined 4GB-

basket for less than €7 and for a

bit more consumers could get much higher data allowances (50GB-100GB). In contrast, in many protected

arkets €

ould not

buy you even the smallest GB basket. For example in Finland and

Austria

ith € 7 and € 5

respectively consumers could buy the 4GB-basket and if they paid

€ and

€ they

get 50GB and 12GB respectively. By including the much higher GB allowance offers in

progressive markets in the averaging we are attempting to capture the overall value for money in terms of GB data allowances that consumers enjoy in progressive versus protected markets. At the ame time this view exposes the highly inefficient use of spectrum by MNOs in protected markets. Finally, in order not to bias

the Danish alue

e ha e e cluded fro

the a erage TeliaSonera’s and ’s

100GB smartphone tariffs that retailed

for €5 and € respecti ely.

Even by excluding the reasonably

priced tariffs, the Danish smartphone tariffs include on average the fourth highest GBs (5.5GB) among EU27. To put this in perspective, in some protected

arkets €40

would not even buy a smartphone

tariff with 2GB of data while in Denmark TeliaSonera and 3 are offering 100GB for this price level.

12

The chart below includes all smartphone tariffs recorded in the database that met the smallest GB-basket

(0.1GB&100mins&20SMSs) and therefore the values are slightly different from the average smartphone tariff prices among the 6 defined GB-baskets

€0

€10

€20

€30

€40

€50

€60

€70

Average smartphone tariff price among the 6 defined GB-baskets

(average of all MNO tariffs in a country for 0.1GB-basket, 0.5GB-basket, 1GB-basket, 2GB-basket, 3GB-basket and 4GB-basket)

In progressive markets the average price is

€22

In protected markets it is double

€44

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Exhibit 9 Average smartphone tariff price & average GBs, mins, SMSs included

ǀ

Member state view

Source: Rewheel analysis

With the exception of Luxemburg, in all protected

arkets consu

ers need to pay €5

on average to

get roughly 2GB of smartphone data volume and some 1,000 minutes and 1,000 SMSs. In contrast, in progressive markets consumers could buy on average 5GB and more than 1,000 minutes and 1000 SMSs

for €5.

In Exhibit 10 below we present the average price per GB included in smartphone tariffs

in EU27.

Exhibit 10 Average price per GB included in smartphone tariffs

ǀ

Member state view

Source: Rewheel analysis

2.4GB

2.3GB

2.3GB

2.2GB

2.5GB

1.8GB

4.6GB

2.2GB

2.5GB

2.0GB

6.6GB

2.1GB

2.3GB

2.1GB

3.8GB

3.8GB

5.5GB

2.3GB

4.0GB

3.4GB

3.3GB

3.1GB

3.3GB12GB

12GB

3.8GB

2.5GB

€0

€10

€20

€30

€40

€50

€60

€70

Average smartphone tariff price & average GBs, mins, SMSs included

Average includes all database smartphone tariffs that met the smallest GB-basket (0.1GB&100mins20SMSs)

1,6 77 m in

1,9 42 SS M Ss

61 4m in

25 1S M Ss

1,8 33 m in

1,1 94 SM Ss

1,6 34 m in 2,2 25 SM Ss

41 8m in

15 52 SM Ss

43 8m in

20 3S M Ss

49 8m in 28 7S M Ss

80 6m in

1,0 98 SM Ss

79 5m in 86 3S M Ss

49 3m in 79 5S M Ss

2,2 15 m in 2,2 38 SM Ss

45 9m in

65 SM Ss

1,2 06 m in

3,0 00 SM Ss

41 4m in

59 8S M Ss

95 9m in 58 8S M Ss

2,6 58 m in

2,8 85 SM Ss

81 12 m in

1,0 00 SM Ss

1,4 40 m in

1,4 46 SM Ss

50 5m in

32 8 SM Ss

69 1m in

93 5S M Ss

1,2 50 m in

5,0 00 SM Ss

94 30 m in

1,2 79 SM Ss

2,7 69 m in

2,3 85 SM Ss

1,0 12 m in

73 8S M Ss

2,2 77 m in

2,2 09

6 0 0 m

6 0 SM Ss

521m 3 ,6 98 SM Ss

In progressive markets

€25

buys

5GB & 1,210mins & 1,631SMSs

In protected markets

€45

buys

2.5GB & 1,006mins & 1,125SMSs

TeliaSonera's and 3's 100GB martphone tariffs in Denmark are excluded from the averaging

€0

€5

€10

€15

€20

€25

€30

Average price per GB included in smartphone tariffs

Average includes all database smartphone tariffs that met the smallest GB-basket (0.1GB&100mins&20SMSs)

In protected markets a GB of martphone data costs in average

€20

In progressive markets a GB of martphone data cost in average

€6

TeliaSonera's and 3's 100GB martphone tariffs in Denmark are excluded from the averaging

EU27 mobile data cost competitiveness report

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In progressive markets (e.g. Estonia, Finland and Austria) a GB of smartphone data volume (including thousands of voice minutes and SMSs) costs on average up to 22 times cheaper than in Greece which is the most expensive market in the EU.

EU27 mobile data cost competitiveness report

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6

MNO group level analysis

In this section we present the results of the comparative MNO group analysis. Besides providing comparative charts between the individual independent challengers, incumbents and E4 group members we have also analyzed the price level of some other MNO groups. We selected all the E4 group members (Deutsche Telekom, France Telecom, Telefonica and Vodafone), incumbents that are present in at least three EU member states (TeliaSonera, Telenor, KPN and Telekom Austria) and independent challenger groups that are present in at least three EU member states (Tele2 and 3). We also created a custom independent challenger group by averaging among Free Mobile France, DNA Finland, Play Poland and Bite Latvia & Lithuania.

6.1

Smartphone tariff GB-basket average price of independent challengers, incumbents and E4 group members

In Exhibit 11 below we present the average price of smartphone tariffs of the six GB-baskets for independent challengers, incumbents and E4 group members.

Exhibit 11 Smartphone tariff GB-basket average price

ǀ

MNO group view

Source: Rewheel analysis

With the exception of the smallest GB-basket (0.1GB-basket) the E4 group members charge on average between 2 and 3 times more than independent challengers.

€0

€10

€20

€30 €40

€50

€60

€70

0.1GB-basket

0.5GB-basket

1GB-basket

2GB-basket

3GB-basket

4GB-basket

Smartphone tariff GB-basket average price

Independent challengers vs incumbents vs E4 group members

Independent challengers Incumbents E4 group members (Deutsche Telekom, France Telecom, Telefonica, Vodafone)

EU27 mobile data cost competitiveness report

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6.2

Average smartphone tariff price and average GBs, minutes and SMSs included by MNO groups

In Exhibit 12 below we present the average smartphone tariff price and average GBs included by various groups. The chart includes all database smartphone tariffs per group that met the smallest GB- basket (0.1GB&100mins&20SMSs). As for the member state averages, in order not to bias

TeliaSonera’s and ’s alues

e ha e e cluded fro

the a erage TeliaSonera’s and ’s

GB Danish

martphone tariffs.

Exhibit 12 Average smartphone tariff price and GBs included

ǀ

MNO group view

Source: Rewheel analysis

Independent challenger groups such as 3 and Tele 2 offer on average up to 4 times more data volume than Vodafone, at one third of the price. So 12 times more value.

2GB

2GB

2GB

2GB

4GB

2GB

2GB

6GB

6GB

8GB

4GB

€-

€5

€10 €15 €20 €25 €30 €35 €40 €45 €50

Vodafone

KPN

France

Telecom

TelefonicaO2

Telenor

Deutsche

Telekom

Telekom

Austria

TeliaSonera

3

Tele2

Free, DNA,

Play, BITE

Average smartphone tariff price and GBs included

Average includes all database smartphone tariffs that met the smallest GB-basket (0.1GB, 100mins, 20SMSs)

Independent challengers

Incumbents

E4 group members (Deutsche Telekom, France Telecom, Telefonica, Vodafone)

TeliaSonera's and 3's 100GB martphone tariffs in Denmark are excluded from the averaging

EU27 mobile data cost competitiveness report

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28

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In Exhibit 13 below we present the average price per GB and average GBs, minutes, SMSs included by various MNO groups in their smartphone tariffs.

Exhibit 13 Average price per GB and average mins & SMSs included in smartphone tariffs

ǀ

MNO

group view

Source: Rewheel analysis

What is evident and surprisingly similar with the member state view of this chart is that independent challengers price a GB on average

belo €5, so

eti

es as lo

as €.

Tele

inclusive of

ubstantial voice and SMS bundles

hile the E Group

e

bers bet

een € 5 and as high as €

(Vodafone). The average price of GB of smartphone data volume in protected markets ranged from

€5 to €7.

Independent challengers (e.g. Tele2 and 3) price on average a GB of smartphone data volume (including similar sized voice minute and SMS bundles) up to 10 times cheaper than Vodafone, KPN, France Telecom, Telefonica or Deutsche Telekom.

1,094mins 1,352SMSs

1,448mins

1,745SMSs

925mins

1,204SMSs

1,268mins

2,007SMSs

722mins

1,409SMSs

2,427mins 2,256SMSs

717mins

1.032SMSs

1,206mins

1,341SMSs

1,170mins

2,523SMSs

2,288mins

1,741SMSs

1,703mins

1,933SMSs

€-

€5

€10

€15

€20

€25

Vodafone

KPN

France

Telecom

Telefonica

Deutsche

Telekom

Telekom

Austria

Telenor

Free, DNA,

Play, BITE

TeliaSonera

3

Tele2

Average price per GB and average mins&SMSs included in smartphone tariffs

Average includes all smartphone tariffs that met the smallest GB-basket (0.1GB, 100mins, 20SMSs)

Independent challengers Incumbents E4 group members (Deutsche Telekom, France Telecom, Telefonica, Vodafone)

TeliaSonera's and 3's 100GB martphone offers in Denmark are excluded from the averaging

Independent challangers and TeliaSonera ell in average a GB of smartphone data up to 10 times cheaper than E4 Group

EU27 mobile data cost competitiveness report

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The obvious question that needs to be asked is how is it technologically possible and economically viable for Tele2, 3 and TeliaSonera to offer on average 4 times more GBs at 3 times lower price?

Do independent challengers have privileged access to more efficient technologies (i.e. LTE) than the E4 group members?

Do they hold relatively more spectrum capacity than the E4 group members?

Do independent challengers have access to more radio sites and their spectrum reuse factor is higher than the E4 group members?

Or are independent challengers (i.e. Tele2, DNA) unprofitable?

None of the above is true. The answer is actually very simple. Independent challengers and incumbents such as TeliaSonera that are present mainly in progressive markets are utilizing the pectrum resources assigned to them. In contrast, incumbent telco groups, having substantial interests in European fixed broadband assets, rather that utilising their spectrum resources instead they appear to be more concerned about keeping the unit price of mobile data on very high and often

consu

er unaffordable le el by restricting supply, the sa

e

ay the laful cartel of OPEC controls

the price of oil by turning the tap off. In progressive markets (where at least one independent challenger is present that has triggered the spectrum utilisation competition) such as Finland, Sweden Austria and UK the mobile data consumption per capita, as shown in Exhibit 14 below is up to ten times higher than in protected markets (where none of the MNOs are strategically incentivised in

triggering a capacity play on the

arket.

Exhibit 14 Annual mobile data consumption per capita in selected member states

Source: Regulator reports, Rewheel analysis

0

5

10

15

20

25

G B / a nn um / ca pi ta

2009

2010

2011

2012(e)

EU27 mobile data cost competitiveness report

May 2013

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Note that the spirit of the EU electronic communications directives and Radio Spectrum Policy Framework clearly envisages and promotes the efficient allocation and use of the EU standardized pectrum bands.

In almost half of the EU27 member state markets spectrum is used very inefficiently by many incumbent telco groups who are keen to protect their legacy fixed assets and cement their European dominance with more consolation at the expense of competition.

6.3

Lowest from progressive and highest from protected 4GB-basket martphone tariff prices of E4 group members

In Exhibit 15 below we present the lowest from progressive markets and highest from protected markets 4GB-basket smartphone tariff prices of E4 group members.

Exhibit 15 Lowest from progressive & highest from protected 4GB-

asket pri e ǀ MNO Group ie

Source: Rewheel analysis

As it can be clearly seen from the chart E4 group members

are

capable of pricing competitively when

facing real competition from independent challengers. But when operating in protected markets and face only

friendly copetition by other E group

members or incumbents (e.g. Germany),

apparently they are much less keen to offer competitively priced smartphone tariffs.

5GB, 1,000mins

4GB, unlmt mins

4GB, unlmt mins

4GB, unlmt mins

4GB, unlmt mins

10GB, unlmt mins

4GB, unlmt mins

10GB, unlmtd mins

€-

€20

€40

€60

€80

€100

€120

€140

€160

AT-Deutsche

Telekom

DE-Deutsche

Telekom

PL-France

Telecom

PT-France

Telecom

UK-

TelefonicaO2

ES-

TelefonicaO2

UK-VodafoneDE-Vodafone

Lowest from progressive & highest from protected

4GB-basket price (minimum 4GB, 1,000mins, 20SMSs)

Progressive markets "Protected" markets

In progressive markets where E4 group members are facing real competition from independent challengers they are capable of pricing at competitive levels

EU27 mobile data cost competitiveness report

May 2013

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7

Member state level detailed basket analysis

In this section we present all

€-baskets

and GB-baskets for the EU27 member states.

In the

-

basket, €

-

basket and €

-basket some member states have no values and are grouped

on the right hand side of the charts. Member states were grouped without a GB value because there

as no tariff a ailable by any of the MNO present in the

arket that

as lo

er than the

onetary €

value of the basket that also met the minimum 0-1GB-basket (0.1GB & 100mins & 20SMSs). In other words the entry level smartphone tariffs in the member state were more expensive than the defined

onetary € alue of the basket.

Exhibit 16 Smartphone

tariff €

-basket

ǀ

Member state view

Source: Rewheel analysis

The only protected member state market where a smartphone tariff is available for a price which is

less than € is Bulgaria.

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 5.5 6.0

GB

Smartphone tariff

€10-basket

Lowest price smartphone tariff per member state with the highest GB allowance and a price of equal or less than

€10

Progressive markets average:

3.8GB for

€8

750mins & 536SMSs

Protected markets average:

0.15GB for

€9

150mins & 20SMSs

U nl im it e d da ta , a um e d 1 0

G B

w he n a v e ra g ing

U nl im it e d da ta , as um e d 1 0

G B

w he n av e ra gi ng

EU27 mobile data cost competitiveness report

May 2013

32

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Exhibit 17 Smartphone

tariff €

-basket

ǀ

Member state view

Source: Rewheel analysis

Exhibit 18 Smartphone

tariff €

-basket

ǀ

Member state view

Source: Rewheel analysis

In progressive markets consumers get on average 10 times more (13GB vs 1.3GB) smartphone data volume than in protected

arkets

he spe di g €. O top they also get t

i e

as many minutes

and SMSs.

0 2 4 6 8

10 12 14 16 18 20 22

GB

Smartphone tariff

€20-basket

Lowest price smartphone tariff per member state with the highest GB allowance and a price of equal or less than

€20

U nl im it e d da ta , as um e d 1 0

G B

w he n av e ra gi ng

3 5

G B

Progressive markets average:

8.1GB for

€16

692mins & 809SMSs

Protected markets average:

0.6GB for

€17

119mins & 585SMSs

U nl im it e d da ta , as um e d 1 0

G B

w he n av e ra gi ng

U n lim it e d

d a ta ,a u m e d

1 0

G B

w h e n

a v e ra g in g

0 2 4 6 8

10 12 14 16 18 20 22

GB

Smartphone tariff

€30-basket

Lowest price smartphone tariff per member state with the highest GB allowance and a price of equal or less than

€30

5 0

G B

3 5

G B

Progressive markets average:

13GB for

€24

1,282mins & 1,243SMSs

Protected markets average:

1.3GB for

€26

783mins & 658SMSs

U nl im it e d da ta , a um e d 1 0

G B

w he n a v e ra g ing

U nl im it e d da ta , as um e d 1 0

G B

w he n av e ra gi ng

U nl im it e d da ta , a um e d 1 0

G B

w he n a v e ra g ing

EU27 mobile data cost competitiveness report

May 2013

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Exhibit 19 Smartphone

tariff €

-basket

ǀ

Member state View

Source: Rewheel analysis

Exhibit 20 Smartphone

tariff €

-basket

ǀ

Member state view

Source: Rewheel analysis

Consumers need to pay o

n a erage €7 in protected

arkets

to purchase very large accommodative

data allowances (i.e. 7.6GB). In progressive markets they get similar very large accommodative data allowances (i.e. 8.1GB) by paying on average as little as

€.

Next we present the GB-baskets.

0 2 4 6 8

10 12 14 16 18 20 22

GB

Smartphone tariff

€40-basket

Lowest price smartphone tariff per member state with the highest GB allowance and a price of equal or less than

€40

5 0

G B

Progressive markets average:

14GB for

€27

1,658mins & 1,271SMSs

3 5

G B

Protected markets average:

2.3GB for

€35

584mins & 967SMSs

U nl im it e d da ta , a um e d 1 0

G B

w he n a v e ra g ing

U nl im it e d da ta , as um e d 1 0

G B

w he n av e ra gi ng

U nl im it e d da ta , a um e d 1 0

G B

w he n a v e ra g ing

0 2 4 6 8

10 12 14 16 18 20 22

GB

Smartphone tariff

€100-basket

Lowest price smartphone tariff per member state with the highest GB allowance and a price of equal or less than

€100

1 0 0

G B ,

e xc lude d fr om

the

a v e ra g ing

Progressive markets average:

16GB for

€31

1,555mins & 1,138SMSs

5 0

G B

3 5

G B

Protected markets average:

7.6GB for

€70

1,969mins & 1,659SMSs

U n li m it e d

d a ta , a u m e d

1 0

G B

w h e n

a v e ra g in g

U nl im it e d da ta , as um e d 1 0

G B

w he n av e ra gi ng

U n li m it e d

d a ta , a u m e d

1 0

G B

w h e n

a v e ra g in g

3 0

G B

EU27 mobile data cost competitiveness report

May 2013

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Exhibit 21 Smartphone tariff 0.1GB-basket

ǀ

Member state view

Source: Rewheel analysis

There is more than 6 times price difference for the 0.1GB-basket between the EU27 member states.

Exhibit 22 Smartphone tariff 0.5GB-basket

ǀ

member state view

Source: Rewheel analysis

There is more than 4 times price difference for the 0.5GB-basket between the EU27 member states.

€0

€5

€10

€15

€20

€25

€30

€35

Smartphone tariff 0.1GB-basket

Lowest price smartphone tariff per member state with at least 0.1GB&100mins&20SMSs

In protected markets the 0.1GB-basket costs in average

€17

In progressive markets the 0.1GB-basket costs in average

€9

€0

€5

€10

€15

€20

€25

€30

€35

Smartphone tariff 0.5GB-basket

Lowest price smartphone tariff per member state with at least 0.5GB&100mins&20SMSs

In protected"markets the 0.5GB-basket costs in average

€21

In progressive markets the 0.5GB-basket costs in average

€11

EU27 mobile data cost competitiveness report

May 2013

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Exhibit 23 Smartphone tariff 1GB-basket

ǀ

Member state view

Source: Rewheel analysis

There is more than 5 times price difference for the 1GB-basket between the EU27 member states.

Exhibit 24 Smartphone tariff 2GB-basket

ǀ

Member state view

Source: Rewheel analysis

There is more than 6 times price difference for the 2GB-basket between the EU27 member states.

€0 €5

€10 €15 €20 €25 €30 €35 €40 €45

Smartphone tariff 1GB-basket

Lowest price smartphone tariff per member state with at least 1GB&100mins&20SMSs

In protected"markets the 1GB-basket costs in average

€24

In progressive markets the 1GB-basket costs in average

€12

€0 €5

€10 €15 €20 €25 €30 €35 €40 €45 €50

Smartphone tariff 2GB-basket

Lowest price smartphone tariff per member state with at least 2GB&200mins&20SMSs

In protected markets the 2GB-basket costs in average

€36

In progressive markets the 2GB-basket costs in average

€15

EU27 mobile data cost competitiveness report

May 2013

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Exhibit 25 Smartphone tariff 3GB-basket

ǀ

Member state view

Source: Rewheel analysis

There is more than 9 times price difference for the 3GB-basket between the EU27 member states.

Exhibit 26 Smartphone tariff 4GB-basket

ǀ

Member state view

Source: Rewheel analysis

There is over 10 times price difference for the 4GB-basket between the EU27 member states.

€0

€10 €20 €30 €40 €50 €60 €70 €80

Smartphone tariff 3GB-basket

Lowest price smartphone tariff per member state with at least 3GB&500mins&20SMSs

In protected markets the 3GB-basket costs in average

€51

In progressive markets the 3GB-basket costs in average

€22

€0

€10 €20 €30 €40 €50 €60 €70 €80 €90

Smartphone tariff 4GB-basket

Lowest price smartphone tariff per member state with at least 4GB&1,000mins&20SMSs

In protected markets the 4GB-basket costs in average

€61

In progressive markets the 4GB-basket costs in average

€27

EU27 mobile data cost competitiveness report

May 2013

37

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8

MNO level detailed basket analysis

In this section we present

the €-baskets

and the GB-baskets for all 91 MNOs present in the EU27

member states.

For the €-baskets

we coloured the MNOs based on their market classification (progressive versus

protected) and for the GB-baskets we coloured the MNOs based on their group classification (Independent challengers, incumbents and E4 group members).

We start

ith the €-baskets.

EU27 mobile data cost competitiveness report

May 2013

38

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Exhibit 27

S

artpho e tariff €

-basket

ǀ

MNO view

Source: Rewheel analysis

0

1

2

3

4

5

6

7

8

9

10

AT-Telekom Austria

FI-DNA

EL-Deutsche Telecom

EL-Vodafone

EL-Wind Hellas EE-TeliaSonera

CZ-Deutsche Telecom

CZ-TelefonicaO2

CZ-Vodafone

HU-Deutsche Telecom

HU-Telenor

HU-Vodafone

IT-Telecom Italia

IT-Vodafone

IT-Wind

UK-Deutsche Telecom

UK-TelefonicaO2

UK-Vodafone

NL-KPN

NL-Vodafone

NL-Deutsche Telecom

SK-France Telecom

SK-Deutsche Telecom

SK-TelefonicaO2

FR-France Telecom

FR-SFR

FR-Bouygues Telecom

FR-Free Mobile

IE-Vodafone

IE-TelefonicaO2

IE-Eircom

IE-3

SE-TeliaSonera

SE-Tele2

SE-Telenor

SE-3

DK-TDC

DK-Telenor

DK-TeliaSonera

DK-3

DE-Deutsche Telecom

DE-Vodafone

DE-TelefonicaO2

DE-KPN

ES-TelefonicaO2

ES-Vodafone

ES-France Telecom

ES-TeliaSonera

PL-France Telecom

PL-Play

BE-Belgacom

BE-France Telecom

BE-KPN

MT-Vodafone

MT-GO

MT-Melita

CY-Cyprus Telecom

CY-MTN

RO-France Telecom

RO-Deutsche Telecom

LU-PT Luxemburg

LU-France Telecom

LU-Belgacom

PT-PT Telecom

PT-Vodafone

PT-France Telecom

LV-TeliaSonera

BG-Telekom Austria

BG-Bulgaria Telecom

SI-Telecom Slovenia

SI-Telekom Austria

SI-Tusmobil

PL-Deutsche Telecom

LV-Bite

BG-Deutsche Telecom

PL-Polkomtel

RO-Vodafone

UK-3

LV-Tele2

AT-Deutsche Telecom

FI-TeliaSonera

LT-TeliaSonera

LT-Tele2

LT-Bite

SI-T2

AT-3

IT-3

EE-Tele2

FI-Elisa

EE-Elisa

RO-RCS-RDS

GB

Smartphone tariff

€10-basket

Lowest price smartphone tariff per MNO with the highest GB allowance and a price of equal or less than

€10

Smartphone tariffs from progressive markets Smartphone tariffs from protected markets

EU27 mobile data cost competitiveness report

May 2013

39

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 28 Smartphone

tariff €

-basket

ǀ

MNO view

Source: Rewheel analysis

0

1

2

3

4

5

6

7

8

9

10

EL-Deutsche Telecom

EL-Vodafone

EL-Wind Hellas

CZ-Deutsche Telecom

CZ-TelefonicaO2

CZ-Vodafone

HU-Telenor

IT-Telecom Italia

IT-Vodafone

NL-KPN

SK-France Telecom

IE-Vodafone

IE-TelefonicaO2

IE-Eircom

IE-3

SE-TeliaSonera

DK-TDC

DK-3

DE-Deutsche Telecom

DE-Vodafone

DE-TelefonicaO2

ES-France Telecom

ES-TeliaSonera

MT-Vodafone

MT-GO

MT-Melita

CY-Cyprus Telecom

LU-Belgacom

AT-Telekom Austria

SK-Deutsche Telecom

LU-PT Luxemburg

LU-France Telecom

SI-Telecom Slovenia

RO-France Telecom

NL-Vodafone

DE-KPN

BE-KPN

PT-Vodafone

RO-Vodafone

HU-Deutsche Telecom

HU-Vodafone

UK-TelefonicaO2

UK-Vodafone

NL-Deutsche Telecom

SK-TelefonicaO2

FR-France Telecom

FR-Bouygues Telecom

SE-3

ES-TelefonicaO2

BE-Belgacom

CY-MTN

PT-PT Telecom

PL-Polkomtel

UK-Deutsche Telecom

ES-Vodafone

BG-Telekom Austria

SE-Tele2

SE-Telenor

DK-TeliaSonera

PL-France Telecom

BE-France Telecom PT-France Telecom

BG-Deutsche Telecom

SI-Telekom Austria

BG-Bulgaria Telecom

PL-Deutsche Telecom

PL-Play

LV-TeliaSonera

LV-Tele2

SI-Tusmobil

SI-T2

LV-Bite

RO-Deutsche Telecom

IT-Wind

FR-SFR

FR-Free Mobile

DK-Telenor

LT-Bite

LT-TeliaSonera

IT-3

LT-Tele2

AT-3

AT-Deutsche Telecom

FI-Elisa FI-DNA

EE-Elisa

UK-3

RO-RCS-RDS

EE-TeliaSonera

FI-TeliaSonera

EE-Tele2

GB

Smartphone tariff

€20-basket

Lowest price smartphone tariff per MNO with the highest GB allowance and a price of equal or less than

€20

Smartphone tariffs from progressive markets Smartphone tariffs from protected markets

EU27 mobile data cost competitiveness report

May 2013

40

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 29 Smartphone

tariff €

-basket

ǀ

MNO view

Source: Rewheel analysis

0

1

2

3

4

5

6

7

8

9

10

MT-Vodafone

MT-GO

MT-Melita

LU-Belgacom DE-Vodafone

EL-Vodafone

NL-Vodafone

DE-Deutsche Telecom

CY-Cyprus Telecom

NL-KPN

IE-TelefonicaO2

EL-Deutsche Telecom

EL-Wind Hellas

IT-Vodafone

FR-Bouygues Telecom

SE-TeliaSonera

DE-TelefonicaO2

DE-KPN

ES-TelefonicaO2

BE-KPN

RO-Vodafone

LU-PT Luxemburg

CZ-Vodafone

PT-PT Telecom

AT-Telekom Austria

CZ-Deutsche Telecom

CZ-TelefonicaO2

HU-Telenor

HU-Vodafone

IT-Telecom Italia

UK-TelefonicaO2

NL-Deutsche Telecom

SK-TelefonicaO2

IE-Vodafone

ES-Vodafone

ES-France Telecom

ES-TeliaSonera

BE-Belgacom

CY-MTN

RO-France Telecom

LU-France Telecom

PT-Vodafone

PT-France Telecom

SI-Telecom Slovenia

HU-Deutsche Telecom

UK-Deutsche Telecom

BG-Bulgaria Telecom

SK-France Telecom

SK-Deutsche Telecom

FR-France Telecom

IE-Eircom

PL-France Telecom

BE-France Telecom

BG-Telekom Austria

SI-Tusmobil

UK-Vodafone

SE-3

BG-Deutsche Telecom RO-Deutsche Telecom

IT-Wind

FR-SFR

FR-Free Mobile

DK-Telenor

SI-T2

SE-Tele2

PL-Play

LT-TeliaSonera

LT-Bite

SI-Telekom Austria

IT-3

SE-Telenor

DK-TDC

DK-TeliaSonera

PL-Deutsche Telecom

LT-Tele2

AT-Deutsche Telecom

PL-Polkomtel

FI-Elisa FI-DNA

EE-Elisa

UK-3

IE-3

DK-3

RO-RCS-RDS

LV-TeliaSonera

LV-Tele2

LV-Bite

AT-3

EE-TeliaSonera

EE-Tele2

FI-TeliaSonera

GB

Smartphone tariff

€30-basket

Lowest price smartphone tariff per MNO with the highest GB allowance and a price of equal or less than

€30

Smartphone tariffs from progressive markets Smartphone tariffs from protected markets

EU27 mobile data cost competitiveness report

May 2013

41

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 30 Smartphone

tariff €

-basket

ǀ

MNO view

Source: Rewheel analysis

0

1

2

3

4

5

6

7

8

9

10

MT-Vodafone

DE-Vodafone

EL-Vodafone

DE-Deutsche Telecom

SE-TeliaSonera

LU-PT Luxemburg

EL-Wind Hellas

CZ-Deutsche Telecom

HU-Telenor

HU-Vodafone

NL-KPN

NL-Vodafone

SK-TelefonicaO2

IE-TelefonicaO2

MT-GO

CY-Cyprus Telecom

LU-Belgacom

PT-PT Telecom

PT-Vodafone CZ-Vodafone

EL-Deutsche Telecom

HU-Deutsche Telecom

IE-Vodafone

ES-TelefonicaO2

ES-Vodafone

ES-France Telecom

BG-Bulgaria Telecom

IT-Telecom Italia

SK-France Telecom

SK-Deutsche Telecom

IE-Eircom

DE-TelefonicaO2

DE-KPN

ES-TeliaSonera

BE-Belgacom

BE-KPN

RO-France Telecom

RO-Vodafone

LU-France Telecom PT-France Telecom

UK-Vodafone

IT-Vodafone

CY-MTN

AT-Telekom Austria

CZ-TelefonicaO2

IT-Wind

UK-Deutsche Telecom NL-Deutsche Telecom

FR-France Telecom

FR-SFR

FR-Bouygues Telecom

FR-Free Mobile

DK-Telenor

BE-France Telecom

MT-Melita

BG-Telekom Austria

BG-Deutsche Telecom

UK-TelefonicaO2

SE-Tele2

PL-France Telecom

PL-Play

LT-TeliaSonera

LT-Bite

SI-Telekom Austria

RO-Deutsche Telecom

SE-Telenor

DK-TDC

DK-TeliaSonera

PL-Deutsche Telecom

LT-Tele2

SI-Tusmobil

SI-T2

SE-3

SI-Telecom Slovenia

AT-Deutsche Telecom

PL-Polkomtel

FI-Elisa FI-DNA

EE-Elisa

UK-3

IE-3

DK-3

RO-RCS-RDS

LV-TeliaSonera

LV-Tele2

LV-Bite

AT-3

EE-TeliaSonera

IT-3

EE-Tele2

FI-TeliaSonera

GB

Smartphone tariff

€40-basket

Lowest price smartphone tariff per MNO with the highest GB allowance and a price of equal or less than

€40

Smartphone tariffs from progressive markets Smartphone tariffs from protected markets

EU27 mobile data cost competitiveness report

May 2013

42

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 31 Smartphone

tariff €100-basket

ǀ

MNO view

Source: Rewheel analysis

0

1

2

3

4

5

6

7

8

9

10

EL-Wind Hellas

ES-TelefonicaO2

HU-Telenor

IT-Telecom Italia

IT-Wind

FR-Free Mobile

ES-France Telecom

ES-TeliaSonera

MT-Vodafone

BG-Bulgaria Telecom

CZ-Deutsche Telecom

HU-Deutsche Telecom

HU-Vodafone

UK-TelefonicaO2

UK-Vodafone

NL-Vodafone

NL-Deutsche Telecom

SK-Deutsche Telecom

SK-TelefonicaO2

FR-SFR

SE-TeliaSonera

DE-Deutsche Telecom

PL-France Telecom

PL-Play MT-GO

RO-France Telecom

RO-Vodafone

LT-TeliaSonera

LT-Bite

BG-Telekom Austria

SI-Telekom Austria

MT-Melita

PT-France Telecom

BG-Deutsche Telecom

CZ-Vodafone

RO-Deutsche Telecom

AT-Telekom Austria

EL-Vodafone

IT-Vodafone

NL-KPN

SK-France Telecom FR-France Telecom

FR-Bouygues Telecom

IE-TelefonicaO2

DE-TelefonicaO2

DE-KPN

ES-Vodafone

PL-Deutsche Telecom

BE-Belgacom

BE-France Telecom

CY-Cyprus Telecom

CY-MTN

PT-PT Telecom

PT-Vodafone

LT-Tele2

SI-Tusmobil

SI-T2

SE-3

EL-Deutsche Telecom

IE-Vodafone

BE-KPN

AT-Deutsche Telecom

PL-Polkomtel

UK-Deutsche Telecom

FI-Elisa FI-DNA

EE-Elisa

CZ-TelefonicaO2

UK-3

IE-3

SE-Tele2

DK-Telenor

DE-Vodafone

RO-RCS-RDS

LV-TeliaSonera

LV-Tele2

LV-Bite

LU-France Telecom

AT-3

EE-TeliaSonera

IE-Eircom

SE-Telenor

SI-Telecom Slovenia

IT-3

DK-TDC

LU-PT Luxemburg

LU-Belgacom

EE-Tele2

FI-TeliaSonera

DK-TeliaSonera

DK-3

GB

Smartphone tariff

€100-basket

Lowest price smartphone tariff per MNO with the highest GB allowance and a price of equal or less than

€100

Smartphone tariffs from progressive markets Smartphone tariffs from protected markets

EU27 mobile data cost competitiveness report

May 2013

43

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Next we present the GB-baskets.

Exhibit 32 Smartphone tariff 0.1GB-basket

ǀ

MNO view

Source: Rewheel analysis

€0

€5

€10

€15

€20

€25

€30

€35

€40

€45

€50

PL-Polkomtel

LT-Tele2

LV-Bite

LT-TeliaSonera

LT-Bite

EE-Tele2

AT-3

EE-Elisa

LV-Tele2

SI-T2

RO-Vodafone

RO-RCS-RDS

PL-Deutsche Telecom

UK-3

BG-Deutsche Telecom

FI-Elisa

FI-TeliaSonera

AT-Deutsche Telecom

IT-3

PL-Play

RO-Deutsche Telecom

EE-TeliaSonera

HU-Vodafone

BG-Bulgaria Telecom

BG-Telekom Austria RO-France Telecom

UK-Deutsche Telecom

PL-France Telecom BE-France Telecom

UK-Vodafone

SE-Tele2

FI-DNA

UK-TelefonicaO2

HU-Deutsche Telecom

DK-Telenor

FR-SFR

SE-3

LV-TeliaSonera

CY-MTN

SI-Tusmobil

IT-Wind

SK-TelefonicaO2

DE-KPN

BE-Belgacom

PT-PT Telecom

PT-France Telecom

NL-Deutsche Telecom

LU-France Telecom

PT-Vodafone ES-Vodafone

DK-TeliaSonera

SE-Telenor

SI-Telecom Slovenia

AT-Telekom Austria

SK-Deutsche Telecom

NL-Vodafone

BE-KPN

LU-PT Luxemburg

ES-TelefonicaO2

FR-France Telecom

FR-Bouygues Telecom

FR-Free Mobile

SI-Telekom Austria

DE-Deutsche Telecom

DE-Vodafone

DE-TelefonicaO2

ES-France Telecom

IE-Eircom

IE-3

DK-TDC

SK-France Telecom

DK-3

CY-Cyprus Telecom

SE-TeliaSonera

CZ-Deutsche Telecom

HU-Telenor

CZ-Vodafone

IE-Vodafone

CZ-TelefonicaO2

EL-Vodafone

ES-TeliaSonera

EL-Deutsche Telecom

NL-KPN

IT-Telecom Italia

IT-Vodafone

EL-Wind Hellas

IE-TelefonicaO2

MT-Melita

MT-GO

LU-Belgacom

MT-Vodafone

Smartphone tariff 0.1GB-basket

minimum 0.1GB,&100mins&20SMSs

Independent challenger s

Incumbents

E4 Group members (Deutsche Teleckm, France Telecom, Telefonica, Vodafone)

EU27 mobile data cost competitiveness report

May 2013

44

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 33 Smartphone tariff 0.5GB-basket

ǀ

MNO view

Source: Rewheel analysis

€0

€10

€20

€30

€40

€50

€60

€70

EE-Tele2

AT-3

EE-Elisa

LV-Tele2

SI-T2

RO-RCS-RDS

LT-Bite

UK-3

LT-Tele2

LT-TeliaSonera

FI-Elisa

FI-TeliaSonera

AT-Deutsche Telecom

IT-3

PL-Play LV-Bite

EE-TeliaSonera

PL-France Telecom

BE-France Telecom

FI-DNA

BG-Bulgaria Telecom

PL-Polkomtel

BG-Deutsche Telecom

SE-3

BG-Telekom Austria

SI-Tusmobil

FR-SFR

IT-Wind

BE-Belgacom

UK-Deutsche Telecom

HU-Vodafone

PT-PT Telecom

SE-Tele2

PT-France Telecom

ES-Vodafone

LV-TeliaSonera

DK-TeliaSonera

RO-Deutsche Telecom

SE-Telenor

DK-Telenor

UK-Vodafone

HU-Deutsche Telecom

UK-TelefonicaO2

CY-MTN

PL-Deutsche Telecom

ES-TelefonicaO2

FR-France Telecom

FR-Bouygues Telecom

FR-Free Mobile

SI-Telekom Austria

NL-Deutsche Telecom

SK-TelefonicaO2

ES-France Telecom

IE-Eircom

IE-3

DK-TDC

SK-France Telecom

DK-3

LU-France Telecom

HU-Telenor

RO-France Telecom

SI-Telecom Slovenia

SE-TeliaSonera

SK-Deutsche Telecom

LU-PT Luxemburg

AT-Telekom Austria

IE-Vodafone

RO-Vodafone

CZ-TelefonicaO2

ES-TeliaSonera

CZ-Vodafone PT-Vodafone

CZ-Deutsche Telecom

IT-Telecom Italia

IT-Vodafone

BE-KPN

DE-TelefonicaO2

EL-Wind Hellas

DE-KPN

MT-Melita

EL-Deutsche Telecom

NL-KPN

MT-GO

NL-Vodafone

IE-TelefonicaO2

CY-Cyprus Telecom

DE-Deutsche Telecom

LU-Belgacom

EL-Vodafone

MT-Vodafone

DE-Vodafone

Smartphone tariff 0.5GB-basket

minumum 0.5GB&100mins&20SMSs

Independent challenger s

Incumbents

E4 Group members (Deutsche Teleckm, France Telecom, Telefonica, Vodafone)

EU27 mobile data cost competitiveness report

May 2013

45

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 34 Smartphone tariff 1GB-basket

ǀ

MNO view

Source: Rewheel analysis

€0

€10

€20

€30

€40

€50

€60

€70

EE-Tele2

AT-3

EE-Elisa

SI-T2

RO-RCS-RDS

LT-Tele2

LT-TeliaSonera

LT-Bite FI-Elisa

FI-TeliaSonera

AT-Deutsche Telecom

IT-3

PL-Play

LV-Tele2

EE-TeliaSonera

LV-Bite

FI-DNA

BG-Deutsche Telecom

IT-Wind

BE-France Telecom

SI-Tusmobil

UK-3

BG-Bulgaria Telecom

SE-Tele2

PL-France Telecom PT-France Telecom

LV-TeliaSonera

DK-TeliaSonera

SE-Telenor

DK-Telenor

RO-Deutsche Telecom

PL-Deutsche Telecom

FR-Free Mobile

SI-Telekom Austria

FR-SFR

IE-Eircom

IE-3

DK-TDC

NL-Deutsche Telecom UK-Deutsche Telecom

DK-3

SK-France Telecom LU-France Telecom

BE-Belgacom

CY-MTN

RO-France Telecom

SI-Telecom Slovenia

UK-Vodafone

SE-3

UK-TelefonicaO2

AT-Telekom Austria

HU-Telenor

CZ-TelefonicaO2

ES-France Telecom

HU-Vodafone

SK-TelefonicaO2

ES-TeliaSonera

HU-Deutsche Telecom

BG-Telekom Austria

PL-Polkomtel

PT-Vodafone ES-Vodafone

CZ-Deutsche Telecom

IT-Telecom Italia

FR-France Telecom

SK-Deutsche Telecom

IE-Vodafone

MT-Melita

ES-TelefonicaO2

PT-PT Telecom

NL-KPN

RO-Vodafone

IT-Vodafone

CZ-Vodafone

FR-Bouygues Telecom

EL-Wind Hellas

IE-TelefonicaO2

CY-Cyprus Telecom

MT-GO

EL-Deutsche Telecom

NL-Vodafone

BE-KPN

DE-TelefonicaO2

DE-KPN

LU-Belgacom

SE-TeliaSonera

EL-Vodafone

LU-PT Luxemburg

DE-Deutsche Telecom

MT-Vodafone

DE-Vodafone

Smartphone tariff 1GB-basket

minimum 1GB&100mins&20SMSs

Independent challenger s

Incumbents

E4 Group members (Deutsche Teleckm, France Telecom, Telefonica, Vodafone)

EU27 mobile data cost competitiveness report

May 2013

46

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 35 Smartphone tariff 2GB-basket

ǀ

MNO view

Source: Rewheel analysis

€0

€10

€20

€30

€40

€50

€60

€70

€80

€90

EE-Tele2

EE-Elisa

AT-3

IT-3

RO-RCS-RDS

LV-Tele2

LV-Bite

FI-Elisa

SI-T2

AT-Deutsche Telecom

LT-Tele2

PL-Play

EE-TeliaSonera

LT-Bite

IT-Wind

UK-3

LT-TeliaSonera

FI-TeliaSonera

LV-TeliaSonera

FI-DNA

PL-Deutsche Telecom

FR-Free Mobile

FR-SFR

SI-Tusmobil

IE-3

RO-Deutsche Telecom BG-Deutsche Telecom

SE-Telenor

DK-3

UK-Vodafone

SE-3

DK-Telenor

IE-Eircom

PL-France Telecom

DK-TeliaSonera

BG-Telekom Austria

PL-Polkomtel

BE-France Telecom

SI-Telekom Austria

SE-Tele2

FR-France Telecom

SK-Deutsche Telecom

UK-TelefonicaO2

AT-Telekom Austria

SK-France Telecom

SI-Telecom Slovenia

NL-Deutsche Telecom

PT-France Telecom

BE-Belgacom

RO-France Telecom

IT-Telecom Italia

DK-TDC

FR-Bouygues Telecom

RO-Vodafone

UK-Deutsche Telecom

CZ-TelefonicaO2

LU-France Telecom

ES-TeliaSonera

IT-Vodafone

BE-KPN

CY-MTN

DE-TelefonicaO2

DE-KPN

IE-TelefonicaO2

HU-Telenor

SE-TeliaSonera

BG-Bulgaria Telecom

NL-KPN

CZ-Deutsche Telecom

CY-Cyprus Telecom

HU-Deutsche Telecom

EL-Deutsche Telecom

MT-Melita

LU-Belgacom

ES-France Telecom

EL-Vodafone

HU-Vodafone

LU-PT Luxemburg

IE-Vodafone

EL-Wind Hellas

NL-Vodafone

CZ-Vodafone

SK-TelefonicaO2 ES-TelefonicaO2

ES-Vodafone

MT-GO

PT-PT Telecom

MT-Vodafone

PT-Vodafone

DE-Vodafone

DE-Deutsche Telecom

Smartariff phone 2GB-basket

minimum 2GB&200mins&20SMSs

Independent challenger s

Incumbents

E4 Group members (Deutsche Teleckm, France Telecom, Telefonica, Vodafone)

EU27 mobile data cost competitiveness report

May 2013

47

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 36 Smartphone tariff 3GB-basket

ǀ

MNO view

Source: Rewheel analysis

€0

€20

€40

€60

€80

€100

€120

€140

€160

€180

EE-Tele2

EE-Elisa

FI-Elisa

AT-3

LT-Tele2

AT-Deutsche Telecom

LT-TeliaSonera

UK-3

LT-Bite FI-DNA

FI-TeliaSonera

FR-Free Mobile

FR-SFR

RO-RCS-RDS

LV-Tele2

LV-Bite

IT-Wind

DK-3

LV-TeliaSonera

IT-3

EE-TeliaSonera

DK-TeliaSonera

PL-Play

SI-Telekom Austria

PL-Deutsche Telecom

SE-Telenor

RO-Deutsche Telecom

PL-France Telecom

BG-Deutsche Telecom

DK-Telenor

SE-3

BG-Telekom Austria

AT-Telekom Austria

PL-Polkomtel

SI-T2

FR-France Telecom

SI-Telecom Slovenia

UK-TelefonicaO2

UK-Deutsche Telecom

CZ-TelefonicaO2

FR-Bouygues Telecom

SI-Tusmobil

DK-TDC

UK-Vodafone

SE-TeliaSonera

NL-Deutsche Telecom

IE-Eircom

IT-Telecom Italia

DE-KPN

LU-Belgacom

SE-Tele2

IE-TelefonicaO2

SK-France Telecom

CZ-Deutsche Telecom

DE-TelefonicaO2

BE-KPN

SK-Deutsche Telecom

NL-Vodafone

RO-Vodafone

LU-PT Luxemburg

LU-France Telecom

IE-3

SK-TelefonicaO2

RO-France Telecom

ES-Vodafone CZ-Vodafone

ES-TeliaSonera

EL-Vodafone

IT-Vodafone

PT-France Telecom

HU-Deutsche Telecom

BE-France Telecom

BE-Belgacom

CY-MTN

ES-France Telecom

EL-Deutsche Telecom

PT-PT Telecom

PT-Vodafone

HU-Vodafone

NL-KPN

HU-Telenor

IE-Vodafone

MT-Melita

BG-Bulgaria Telecom

DE-Vodafone

CY-Cyprus Telecom

DE-Deutsche Telecom

MT-GO

MT-Vodafone

ES-TelefonicaO2

EL-Wind Hellas

Smartphone tariff 3GB-basket

minimum 3GB,&500mins&20SMSs

Independent challenger s

Incumbents

E4 Group members (Deutsche Teleckm, France Telecom, Telefonica, Vodafone)

EU27 mobile data cost competitiveness report

May 2013

48

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 37 Smartphone tariff 4GB-basket

ǀ

MNO view

Source: Rewheel analysis

There is 10, 9, 9, 11,18 and 33 times price difference for the 0.1GB-basket, 0.5GB-basket, 1GB-basket, 2GB-basket, 3GB-basket and 4GB-basket, respectively, between the 91 MNOs.

€0

€50

€100

€150

€200

€250

€300

IT-Telecom Italia

IT-Wind

FR-Free Mobile

ES-TeliaSonera

EE-Tele2

EE-Elisa

AT-3

LT-Tele2

FI-Elisa

AT-Deutsche Telecom

LV-Tele2

LV-Bite

FI-TeliaSonera

LT-TeliaSonera

UK-3 DK-3

LV-TeliaSonera

LT-Bite

DK-TeliaSonera

PL-Play

FI-DNA

SI-Telekom Austria PL-France Telecom

RO-RCS-RDS

EE-TeliaSonera

SE-3

RO-Deutsche Telecom

IT-3

UK-TelefonicaO2

PL-Deutsche Telecom

SI-Telecom Slovenia

SI-Tusmobil DK-Telenor

UK-Vodafone

BG-Telekom Austria

UK-Deutsche Telecom

DE-KPN

LU-Belgacom

SE-Tele2

FR-SFR

CZ-Deutsche Telecom

CZ-TelefonicaO2

FR-Bouygues Telecom

AT-Telekom Austria

PL-Polkomtel

SE-Telenor

DE-TelefonicaO2

BE-KPN

FR-France Telecom

SK-Deutsche Telecom

NL-Vodafone

RO-Vodafone

LU-PT Luxemburg

LU-France Telecom

IE-Eircom

SK-TelefonicaO2

NL-Deutsche Telecom

SI-T2

IT-Vodafone

SE-TeliaSonera

BE-France Telecom

IE-TelefonicaO2

BE-Belgacom

BG-Deutsche Telecom

DK-TDC

PT-France Telecom

PT-PT Telecom

PT-Vodafone

IE-3

HU-Vodafone

NL-KPN

SK-France Telecom

CZ-Vodafone

IE-Vodafone

ES-Vodafone

HU-Deutsche Telecom

MT-Melita

CY-MTN

EL-Vodafone

RO-France Telecom

EL-Deutsche Telecom

DE-Vodafone

DE-Deutsche Telecom

MT-GO

CY-Cyprus Telecom

MT-Vodafone

HU-Telenor

BG-Bulgaria Telecom

ES-TelefonicaO2

EL-Wind Hellas

ES-France Telecom

Smartphone tariff 4GB-basket

minimum 4GB&1,000mins&20SMSs

Independent challenger s

Incumbents

E4 Group members (Deutsche Teleckm, France Telecom, Telefonica, Vodafone)

EU27 mobile data cost competitiveness report

May 2013

49

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

9

Data only tariff analysis

In this section we present the results of comparative analysis of the data only tariffs. As with the martphone tariff analysis we will first present selected ARPU-

le el €

-

€5 data only tariffs fro

progressive markets and protected markets.

The selected ARPU-level data only tariffs are presented in Exhibit 38 below.

Exhibit 38 Selected data only tariffs from progressive and protected markets

ǀ

MNO view

Source: Rewheel analysis

In progressive markets MNOs offer for the same price up to 100 times more data volume than what Deutsche Telekom, France Telecom, Telefonica, Vodafone or KPN offer in protected markets.

20GB

10GB

Unlmt

Unlmt

20GBUnlmt

10GB

15GB

25GB

30GB

15GB

50GB

1GB

1GB 1GB

0.5GB

0.5GB

1GB

1GB

€-

€5

€10

€15

€20

€25

€30

€35

Selected data only tariffs from progressive and protected markets

(MBB, tablet and iPad tariffs from

€10-€25)

Smartphone tariffs from protected markets

100 times more data volume for the same price

200 m ins

100 m ins

100 m ins

Smartphone tariffs from progressive markets

EU27 mobile data cost competitiveness report

May 2013

50

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

The 5GB-basket, 10GB-basket and 20GB-basket for data only tariffs are presented below.

Exhibit 39 Data only 5GB-basket

ǀ

Member state view

Source: Rewheel analysis

Exhibit 40 Data only 10GB-basket

ǀ

Member state view

Source: Rewheel analysis

5GB

5GB

5GB

5GB

15GB 30GB

5GB

20GB

5GB5GB

10GB

10GB 5GB

10GB

10GB

5GB

5GB5GB

5GB

5GB10GB

20GB

10GB

5GB

6GB30GB

5GB

€0

€5

€10 €15 €20 €25

€30

€35 €40 €45 €50

Data only 5GB-basket

Lowest available price per member state & GB allowance of data only (MBB, tablet, iPad) tariffs with minimum allowance of 5GB

Progressive markets

Protected markets

10GB

25GB

15GB

10GB

10GB

10GB

12GB 30GB 15GB

20GB

10GB

15GB

10GB 10GB

10GB

10GB

10GB

10GB

10GB

Unlm

10GB 10GB

10GB

10GB

30GB

10GB

€0

€10

€20

€30

€40

€50

€60

Data only 10GB-basket

Lowest available price per member state & GB allowance of data only (MBB, tablet, iPad) tariffs with minimum allowance of 10GB

Progressive markets

Protected markets

EU27 mobile data cost competitiveness report

May 2013

51

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Exhibit 41 Data only 20GB-basket

ǀ

Member state view

Source: Rewheel analysis

The average price per GB included in data only tariffs in EU27 member states is presented in Exhibit 42 below.

Exhibit 42 Average price per GB included in data only tariffs

ǀ

Member state view

Source: Rewheel analysis

As it can be seen above in 11 progressive member state markets the average price per GB included in data only tariffs is close to or below

€.

On the other side, in protected markets where E4 group

members and other incumbents have vested fixed broadband interest (e.g. Netherlands, Belgium, Spain and Germany) the average price per GB is up to 14 times higher.

25GB

40GB

20GB

30GB

30GB

30GB 30GB 30GB

30GB

25GB

20GB 20GB

30GB

30GB

20GB

50GB

50GB

Unlm

€0

€10

€20

€30

€40

€50

€60

Data only 20GB-basket

Lowest available price per member state & GB allowance of data only (MBB, tablet, iPad) tariffs with minimum allowance of 20GB

Protected markets

Progressive markets

15GB

5GB

10GB

10GB

10GB

15GB

40GB

30GB

15GB

12GB

30GB

15GB

25GB

20GB

30GB

50GB

20GB

100GB

40GB

38GB

Unlm

150GB

Unlm

Unlm

50GB

Unlm

1,000GB

€0.0

€1.0

€2.0

€3.0

€4.0 €5.0 €6.0 €7.0 €8.0 €9.0

€10.0

Average price per GB included in data only tariffs

Average price per GB & maximum GB allowance offered per Member State in data only (MBB, tablet, iPad) tariffs

In progressive market

€18

buys 17 GB

In protected markets

€24

buys 7 GB

TeliaSonera's and 3's 500GB and 1,000GB MBB tariffs in Denmark are excluded from the averaging

EU27 mobile data cost competitiveness report

May 2013

52

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

In progressive markets (e.g. Estonia, Finland and Denmark) a GB of mobile broadband data volume costs on average up to 14 times cheaper than in the Netherlands which is the most expensive market in the EU for mobile broadband.

Exhibit 43 Average GB price included in data-only tariffs

ǀ

MNO Group view

Source: Rewheel analysis

Independent challengers (e.g. Tele2 and 3) price a GB of mobile broadband data volume on average up to 13 times cheaper than KPN, Telefonica, Vodafone, France Telecom or Deutsche Telekom.

€0 €1 €2 €3 €4 €5 €6 €7 €8 €9

KPN

Telefonica

Vodafone

France

Telecom

Deutsche

Telekom

Telekom

Austria

Telenor

TeliaSonera

Tele2

BITE, DNA,

Play

3

Average price per GB included in data-only tariffs

Independent challengers

Incumbents

E4 group members (Deutsche Telekom, France Telecom, Telefonica, Vodafone)

Independent challengers and incumbents that are mainly present in progressive markets (TeliaSonera) price a GB of data close or below

€1

TeliaSonera's and 3's 500GB and 1,000GB MBB tariffs in Denmark are excluded from the averaging

EU27 mobile data cost competitiveness report

May 2013

53

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10

Germany, the blueprint of a consolidated EU single communication market?

Germany, the member state with the largest internal market, has one of the highest consumer martphone tariff prices, several times higher than in the UK and other progressive member states like Finland, Denmark or Sweden, as presented in Exhibit 44 below.

Exhibit 44 German vs UK and Nordic smartphone tariff pricing

Source: Rewheel analysis

As seen in Exhibit 45, in terms of smartphone tariff GB allowances, the difference is even more

triking: €

buys as fe as

0.2GB of smartphone data allowance in Germany, while in the UK and in

many other

small

member states MNOs offer several tens of GBs and even unlimited volume for

this price level. So in GB allowance terms Germany has one of the most restrictive smartphone tariff offers in Europe i.e. up to 100 times more restrictive than in many progressive member states.

€0

€10

€20

€30

€40

€50

€60

€70

€80

Germany

Sweden

Denmark

UK

Finland

German vs UK and Nordic smartphone tariff pricing

Bars represent the average price among all MNO tariffs that met the GB-basket in a member state

1GB, 100min, 20SMS

2GB, 200min, 20 SMS

4GB, 1000min, 20 SMS

EU27 mobile data cost competitiveness report

May 2013

54

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Exhibit 45 German vs UK and Nordic smartphone tariff data volume allowances

Source: Rewheel analysis

What

akes Ger

any’s case e en

ore disturbing is that its to largest

obile operators, Deutsche

Telekom and Vodafone are charging double as much for the same smartphone tariff plans than what they charge in the UK (where an independent challenger is present), as shown in Exhibit 46 below.

Exhibit 46 Smartphone basket prices of Deutsche Telekom, Vodafone and Telefonica in Germany vs UK

Source: Rewheel analysis

The difference becomes even more striking if the German and the UK smartphone tariffs are compared from the gigabyte allowances point of view, as presented in Exhibit 47. While the price differences were double, in GB allowances we can observe up to 22 times differences.

0.2GB

1GB

3GB

unlm

unlm

1GB

5GB

10GB

unlm

unlm

2GB

5.5GB

10GB

unlm

unlm

0 2 4 6 8

10 12 14 16 18 20

Germany

Sweden

Denmark

UK

Finland

GB

German vs UK and Nordic smartphone tariff data volume allowances

€20

basket

€30

basket

€40

basket

€0

€10 €20 €30 €40 €50 €60 €70 €80 €90

€100

Germany

UK

Deutsche Telekom Prices

Germany vs UK

1GB, 100min, 20SMS 2GB, 200min, 20 SMS 4GB, 1000min, 20 SMS

€0

€10 €20 €30 €40 €50 €60 €70 €80 €90

€100

Germany

UK

Vodafone Prices

Germany vs UK

€0

€10 €20 €30 €40 €50 €60 €70 €80 €90

€100

Germany

UK

Telefonica Prices

Germany vs UK

EU27 mobile data cost competitiveness report

May 2013

55

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Exhibit 47 Smartphone tariff GB allowanced of Deutsche Telekom, Vodafone and Telefonica in Germany vs UK

Source: Rewheel analysis

High prices and restrictive GB allowances suppress mobile internet adoption in Germany!

Apparently, the high smartphone tariff prices and very restrictive data volumes have adversely impacted

the co

petiti eness of Ger

any’s digital econo

y. As

Exhibit 48 below shows, the

penetration of active mobile internet users in Germany is below EU Average, well below UK and some half of the level measured in Denmark, Finland and Sweden.

Exhibit 48 Penetration of active mobile broadband users (including smartphones and data only devices) in Germany versus UK and Nordic member states

Source: EU Commission

0

0.75

0.2

1.5

0.2

3

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0

Germany

UK

GB

Deutsche Telekom GBs

Germany vs UK

€20

basket

€30

basket

€40

basket

0

0.5

0.1

2.25

0.1

2.25

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0

Germany

UK

GB

Vodafone GBs

Germany vs UK

0

0.5

0.5

1

2

4

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0

Germany

UK

GB

Telefoncia GBs

Germany vs UK

0%

20%

40%

60%

80%

100%

120%

Germany

EU AVERAGE

UK

Denmark

Finland

Sweden

Penetration of active mobile broadband users, Germany vs UK and Nordic Member States

January 2012

June 2012

EU27 mobile data cost competitiveness report

May 2013

56

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The high smartphone tariff prices and restrictive data volume allowances have not only led to below average penetration, but also to strikingly low mobile data volume consumption. In Exhibit 49 below we compared

the utilisation of Ger

any’s

radio spectrum resources, expressed as average mobile

data volume consumption per capita, with UK and the three most progressive Nordic member states. Compared to Finland and Sweden, we can observe a striking ten times difference (Note: in Finland the 800 MHz digital divide frequencies have not yet been assigned). In the UK the per capita consumption is double compared to Germany, despite the fact that none of the UK operators have taken into use the 800 and 2600 MHz frequency bands yet. In Germany, all EU-harmonised frequency bands (800, 900, 1800, 2100, 2600 MHz

ha e been fully allocated to the four MNOs since the

BIG BANG

pectrum auctions.

Exhibit 49 Utilisation of radio spectrum resources, expressed as annual mobile data consumption per capita, Germany vs UK and Nordic member states

Source: Regulator websites, Rewheel analysis and estimations

So what is going on in Germany?

Germany has four financially strong mobile network operators: Deutsche Telekom, Vodafone, Telefonica and E-Plus, the latter one belonging to the Dutch KPN Group. One would expect these

European Cha

pions , especially the ones

ith currently loer

arket shares, that is Telefonica and

E-Plus, to look at the smartphone centric market transformation as an opportunity to secure or improve their market share, especially in light of the fact that according to Exhibit 49 they should have plenty of unused radio spectrum capacities to make their smartphone offers more consumer

1.2GB

1.8GB

5.2GB

10.7GB

11.3GB

1.7GB

3.8GB (e)

7.4GB (e)

16.7GB (e)

22.2GB (e)

0

5

10

15

20

25

Germany

UK

Denmark

Sweden

Finland

GB

German vs UK and Nordic annual cellular mobile data consumption per capita

2011

2012

LTE 800

MHz

2600

MHz

LTE 800

MHz

2600

MHz

LTE 800

MHz

2600

MHz

LTE 800

MHz

2600

MHz

LTE 800

MHz

2600

MHz

EU27 mobile data cost competitiveness report

May 2013

57

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

appealing (see our analysis

13

published after the 2010 German BIG BANG auction arguing that building

on the favourable spectrum capacity positions outcome and after the modernisation of its full network infrastructure E-Plus had the chance to gain substantial market share by implementing an

urban capacity challenger strategy.

What could hold the two smaller operators back from increasing spectrum utilisation?

All four MNOs have very strong dependency on historic voice and SMS revenue streams (subject to cannibalization risk) and either locally or through their international parent companies strong interests in EU-wide fixed broadband investments. Furthermore, all four are core members of ETNO, the

incu

bent teleco

operators’ lobby organization,

hich has been hea y lobbying for public

funding

of EU wide investments into widening the reach of high-speed broadband infrastructure

14

and for

allowing consolidation in four player markets like Germany, Italy and Spain.

Considering the substantial fixed broadband interests that these operators have, a corporate strategy whereby they use all levers in their disposals to lower the drive of the mobile internet markets in order to protect the valuations of their fixed broadband assets in Germany, Netherlands and Spain makes sense. Apart from their fixed broadband assets, another key strategic strength at the disposal

of these

ultinational incu

bent telco groups is their single key influencing po

er on the EU le el

policy

aking. By successfully lobbying for a policy fra

e

ork that fa ors fi ed

obile con ergent

players as opposed to

obile pure play operators, they ha e good chances in

inning EU and

member state funds for expanding their fixed broadband infrastructures, in turn further cementing their dominant positions in the fixed broadband markets. And in their mobile markets too, if they ucceed to convince policy makers and regulators to allow consolidation (i.e. elimination of independent challenger mobile operators in progressive markets) and prevent the entrance of new independent challengers (i.e. not reserving radio spectrum for potential new entrants on the radio pectrum auctions) into their territories.

13

http://www.rewheel.fi/insights_11.php

14

http://www.bloomberg.com/video/how-do-e-u-budget-cuts-impact-telecom-broadband-mSuYfmzKQResXGgtMjfgoA.html

EU27 mobile data cost competitiveness report

May 2013

58

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The blueprint of the consolidated EU single telecoms market? We hope not!

Undoubtedly, multinational incumbent telco groups and their investors have good reasons to lobby

EU’ decision

akers to enact friendly policies that

ill protect their inherited oligopolistic high profit

margins. But will the German model serve the best interest of consumers and business in other EU member

tates? In Re heel’s opinion clearly: NOT. As su

arised in

Exhibit 50 below, enforcing an

o erly con ergent player friendly Ger

an

odel

ould se erely li

it copetition

in the mobile

markets, leading to high prices for consumers and the internet of mobile things and sever under-

utilisation of the

e

ber states’ scarce national radio spectru

resources.

Exhibit 50 Comparison of the German model vs UK and the small Nordic member states

Source: Rewheel analysis

Collusion concerns?

Ger

any’s old 9 MHz and

MHz radio spectru

consessions are e piring in

15

and

according to recent press articles the four incumbent oparators forecast no excess demand for pectrum capacities in these bands. Rewheel was really surprised on this position for two reasons.

Firstly, simply because based on the skyrocketing mobile data consumption evidenced in many other member states it seems highly unlikely that in Germany no excess spectrum demand will arise in the next 15 to 20 years. Unless of course, as suspected by the German Federeal Cartel office and reported by Der Spiegel

16,

if operators reached some sort of an understanding to avoid the expensive auction.

In the absence of such alleged understanding, operators in other EU markets bidded competitively (UK, Ireland, Switzerland) and in some cases aggresively (Netherlands) to secure as much spectrum as economically possible so they can respond to a capacity war launched by the smallest operator in the market (e..g 3 UK unlimited smartphone data tariffs).

15

http://www.telecompaper.com/news/e-plus-opposes-any-frequency-2016-auction--941580

16

http://www.telecompaper.com/news/german-watchdog-probes-mobile-firms-over-frequencies-info--941585

Germany

UK

Nordic Member States

Scale

Large (82m pop)

Large (63m pop)

Small-medium (5-10m pop)

Number of MNOs

4

4

3 or 4

Presence of large incumbent "European Champions"

DT,VF,TE,KPN

VF, DT-FT

none

Presence of independent challangers

none

Three

Three, Tele2, DNA

Smartphone tariffs

Uncompetitive

Competitive

Very competitive

Smartphone data volume allowances

Very restrictive

Very large

Very large

Mobile internet penetration

Below EU average

Well above EU average

Nearly 100%

Radiospectrum allocated to MNOs

Fully

Partly

Partly

Mobile data consumption per capita

Very low

High

Very high

Utilisation of scarce national radio spectrum assets

Extremely low

High

Very high

EU27 mobile data cost competitiveness report

May 2013

59

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Secondly, because back in 2011, E-Plus heavily lobbied to secure incremental sub 1 GHz spectrum holdings

17

and suddenly now after a strategic U-Turn, is arguing that the status quo concerning mobile

telecoms frequency licences should be maintained at least until 2020.

Ger

a y’s strategi

national interest: increase the utilisation of scarce national spectrum resources

rather than let the current mobile players hoard spectrum in order to protect their EU wide fixed asset interests!

One thing is clear: for reasons we do not understand none of the four mobile operators that are currenly present in Germany see business justification for the next 15 years or so to substantially increase the share of their own spectrum holdings. That implies that they see no business value in investing into more capacity that would enable them to produce more cost efficiently gigabytes, voice minutes and SMSs. In other words none of the four incumbent

’s

trategic interests is to maximize the

economocally viable

utilisation of Ger

any’s national radio fre uency assets.

Therefore, the only

reasonable option left for the German state to encourage and support healthy competition in the production and supply of mobile data (that drives the growth of the digital economy) is to test the appetite of the markets for a new operator entry. Such entry will make sense if the operator/investor

’s

business models and ambitions

are

aligned

ith the Ger

an state’s strategic

interests in driving the growth of the digital economy by increasing the production efficinecy and lowering the supply cost of mobile data.

17

http://www.telecompaper.com/news/e-plus-criticises-900-mhz-redistribution-study--796201

EU27 mobile data cost competitiveness report

May 2013

60

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11

List of exhibits

Exhibit 1 Mobile internet penetration tends to be significantly higher in those member states where sufficient data volume is included in affordable (ARPU-level) smartphone tariff plans ............................................................. 6

Exhibit 2 The prices of 2GB-200min smartphone tariffs tend to be the lowest and mobile internet prices the highest where none of the five big European incumbent telcos are present ............................................................. 7

E hibit Selected sub € s

artphone tariffs fro

progressi e and protected arkets ǀ MNO ie

.................... 18

Exhibit 4 Selected ARPU-

le el s

artphone tariffs fro

progressi e and protected

arkets ǀ MNO ie

............... 19

Exhibit 5 Selected unlimited or very high data volume smart

phone tariffs ǀ MNO ie

.......................................... 20

E hibit € s

artphone tariff basket ǀ Me

ber state ie

................................................................................... 21

E hibit 7 GB s

artphone tariff basket ǀ Me

ber state ie

.................................................................................. 22

Exhibit 8 Average smartphone tariff prices among the 6 defined GB-

baskets ǀ Me

ber state ie

....................... 23

E

hibit 9 A erage s

artphone tariff price & aerage GBs, ins, SMSs included ǀ Me

ber state ie

................... 24

Exhibit 10 Average price per GB included in smartphone tariffs

ǀ

Member state view ............................................ 24

Exhibit 11 Smartphone tariff GB-

basket aerage price ǀ MNO group ie

............................................................... 26

E hibit

A erage s

artphone tariff price and GBs included ǀ MNO group ie

................................................... 27

E hibit

A erage price per GB and a erage

ins & SMSs included in s

artphone tariffs ǀ MNO group ie

...... 28

Exhibit 14 Annual mobile data consumption per capita in selected member states ................................................ 29

Exhibit 15 Lowest from progressive & highest from protected 4GB-basket

price ǀ MNO Group ie

..................... 30

E hibit

S artphone tariff €

-

basket ǀ Me

ber state ie

................................................................................ 31

E hibit 7 S artphone tariff €

-

basket ǀ Me

ber state ie

................................................................................ 32

E hibit

S artphone tariff €

-

basket ǀ Me

ber state ie

................................................................................ 32

E hibit 9 S artphone tariff €

-

basket ǀ Me

ber state Vie

............................................................................... 33

Exhibit 20 Smartphone tar

iff €

-

basket ǀ Me

ber state ie

.............................................................................. 33

Exhibit 21 Smartphone tariff 0.1GB-

basket ǀ Me

ber state ie

............................................................................ 34

Exhibit 22 Smartphone tariff 0.5GB-

basket ǀ

e ber state ie

............................................................................. 34

Exhibit 23 Smartphone tariff 1GB-

basket ǀ Me

ber state ie

............................................................................... 35

Exhibit 24 Smartphone tariff 2GB-

basket ǀ Me

ber state ie

............................................................................... 35

Exhibit 25 Smartphone tariff 3GB-

basket ǀ Me

ber state ie

............................................................................... 36

Exhibit 26 Smartphone tariff 4GB-

basket ǀ Me

ber state ie

............................................................................... 36

E hibit 7 S artphone tariff €

-

basket ǀ MNO ie

.............................................................................................. 38

Exhibit 28 Smartphone tariff

-

basket ǀ MNO ie

.............................................................................................. 39

E hibit 9 S artphone tariff €

-

basket ǀ MNO ie

.............................................................................................. 40

E hibit

S artphone tariff €

-

basket ǀ MNO ie

.............................................................................................. 41

E hibit

S artphone tariff €

-

basket ǀ MNO ie

............................................................................................ 42

Exhibit 32 Smartphone tariff 0.1GB-

basket ǀ

MNO view ........................................................................................... 43

Exhibit 33 Smartphone tariff 0.5GB-

basket ǀ MNO ie

........................................................................................... 44

Exhibit 34 Smartphone tariff 1GB-

basket ǀ MNO ie

.............................................................................................. 45

Exhibit 35 Smartphone tariff 2GB-

basket ǀ MNO ie

.............................................................................................. 46

Exhibit 36 Smartphone tariff 3GB-

basket ǀ MNO ie

.............................................................................................. 47

Exhibit 37 Smartphone tariff 4GB-

basket ǀ MNO ie

.............................................................................................. 48

Exhibit 38 Selected data only tariffs from

progressi e and protected

arkets ǀ MNO ie

.................................... 49

EU27 mobile data cost competitiveness report

May 2013

61

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Exhibit 39 Data only 5GB-

basket ǀ Me

ber state ie

............................................................................................. 50

Exhibit 40 Data only 10GB-

basket ǀ Me

ber state ie

........................................................................................... 50

Exhibit 41 Data only 20GB-

basket ǀ Me

ber

state view ........................................................................................... 51

E hibit

A erage price per GB included in data only tariffs ǀ Me

ber state ie

................................................. 51

Exhibit 43 Average GB price included in data-

only tariffs ǀ MNO Group ie

.......................................................... 52

Exhibit 44 German vs UK and Nordic smartphone tariff pricing ............................................................................... 53

Exhibit 45 German vs UK and Nordic smartphone tariff data volume allowances ................................................... 54

Exhibit 46 Smartphone basket prices of Deutsche Telekom, Vodafone and Telefonica in Germany vs UK .............. 54

Exhibit 47 Smartphone tariff GB allowanced of Deutsche Telekom, Vodafone and Telefonica in Germany vs UK .. 55

Exhibit 48 Penetration of active mobile broadband users (including smartphones and data only devices) in Germany versus UK and Nordic member states ....................................................................................................... 55

Exhibit 49 Utilisation of radio spectrum resources, expressed as annual mobile data consumption per capita, Germany vs UK and Nordic member states .............................................................................................................. 56

Exhibit 50 Comparison of the German model vs UK and the small Nordic member states ...................................... 58

EU27 mobile data cost competitiveness report

May 2013

62

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Annex 1

MNO tariff names

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

1

AT

PROG

INCU

Telekom Austria

A1 Basic SIM Pur

2

AT

PROG

INCU

Telekom Austria

A1 Go! S

3

AT

PROG

INCU

Telekom Austria

A1 Go! M

4

AT

PROG

INCU

Telekom Austria

A1 Go! L

5

AT

PROG

INCU

Telekom Austria

A1 Mobil Breitband 1

6

AT

PROG

INCU

Telekom Austria

A1 Mobil Breitband 2

7

AT

PROG

INCU

Telekom Austria

A1 Mobil Breitband 3

8

AT

PROG

INCU

Telekom Austria

A1 Mobil Breitband 4G/LTE

9

AT

PROG

E4

Deutsche Telecom

ALL Inclusive 1000

10

AT

PROG

E4

Deutsche Telecom

ALL Inclusive 1000 + Unlimited Internet

11

AT

PROG

E4

Deutsche Telecom

ALL Inclusive 1000 + Unlimited Internet Plus

12

AT

PROG

E4

Deutsche Telecom

ALL Inclusive 1000 + Unlimited Internet Max

13

AT

PROG

E4

Deutsche Telecom

ALL INCLUSIVE INTERNET 3G

14

AT

PROG

E4

Deutsche Telecom

ALL INCLUSIVE INTERNET

15

AT

PROG

E4

Deutsche Telecom

ALL INCLUSIVE INTERNET PLUS

16

AT

PROG

E4

Deutsche Telecom

ALL INCLUSIVE INTERNET LTE

17

AT

PROG

CHAL

3

3Single

18

AT

PROG

CHAL

3

Superphone L

19

AT

PROG

CHAL

3

Superphone XL

20

AT

PROG

CHAL

3

Superphone XXL

21

AT

PROG

CHAL

3

Superphone XXL + Doppelte Highspeed GB

22

AT

PROG

CHAL

3

i-Pad Tarife

23

AT

PROG

CHAL

3

i-Pad Tarife

24

AT

PROG

CHAL

3

3Super SIM Data 1GB

25

AT

PROG

CHAL

3

3Super SIM Data 10GB

26

AT

PROG

CHAL

3

3Super SIM Data Super Flat

27

AT

PROG

CHAL

3

3Super SIM Data Super Speed Flat

28

FI

PROG

INCU

Elisa

Reilu 2M

29

FI

PROG

INCU

Elisa

Reilu 2M

30

FI

PROG

INCU

Elisa

Reilu 2M

31

FI

PROG

INCU

Elisa

Reilu 2M

32

FI

PROG

INCU

Elisa

Reilu 3G jopa 21M

33

FI

PROG

INCU

Elisa

MegaReilu 3G

34

FI

PROG

INCU

Elisa

DNA Veppi

35

FI

PROG

INCU

Elisa

Mobiililaajakaista 4G

36

FI

PROG

INCU

Elisa

Mobiililaajakaista 4G Super

37

FI

PROG

INCU

TeliaSonera

Startti Plus

38

FI

PROG

INCU

TeliaSonera

Näppärä

39

FI

PROG

INCU

TeliaSonera

Näppärä Plus Netti

40

FI

PROG

INCU

TeliaSonera

Surffilauta 3G

41

FI

PROG

INCU

TeliaSonera

Fiksu

42

FI

PROG

INCU

TeliaSonera

Super

43

FI

PROG

INCU

TeliaSonera

Surffilauta 4G

44

FI

PROG

INCU

TeliaSonera

Liikkuva laajakaista Perus

45

FI

PROG

INCU

TeliaSonera

Liikkuva laajakaista Plus

46

FI

PROG

INCU

TeliaSonera

Liikkuva laajakaista Teho

47

FI

PROG

CHAL

DNA

Älypaketti

48

FI

PROG

CHAL

DNA

Älypaketti

49

FI

PROG

CHAL

DNA

Älypaketti

50

FI

PROG

CHAL

DNA

Super Älypaketti

51

FI

PROG

CHAL

DNA

DNA Veppi

52

FI

PROG

CHAL

DNA

DNA Veppi

EU27 mobile data cost competitiveness report

May 2013

63

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

53

EL

PROT

E4

Deutsche Telecom

COSMOTE฀Α Ε ΙΟ Ι Α 5

54

EL

PROT

E4

Deutsche Telecom

COSMOTE ECONOMY 20 + COSMOTEInternet Monthly Pass 750

55

EL

PROT

E4

Deutsche Telecom

COSMOTE ECONOMY 20 + COSMOTEInternet Monthly Pass 1,5GB

56

EL

PROT

E4

Deutsche Telecom

COSMOTE ECONOMY 30 + COSMOTEInternet Monthly Pass 3GB

57

EL

PROT

E4

Deutsche Telecom

COSMOTE ฀Α Ε ΙΟ Ι Α 7 + COSMOTE฀Internet Monthly Pass .5GB

58

EL

PROT

E4

Deutsche Telecom

COSMOTE ฀Α Ε ΙΟ Ι Α

+ COSMOTE฀Internet Monthly Pass GB

59

EL

PROT

E4

Deutsche Telecom

COSMOTEi-Data 2GB

60

EL

PROT

E4

Deutsche Telecom

COSMOTEInternet On The Go 1GB

61

EL

PROT

E4

Deutsche Telecom

COSMOTEInternet On The Go 2GB

62

EL

PROT

E4

Deutsche Telecom

COSMOTEInternet On The Go 3GB

63

EL

PROT

E4

Deutsche Telecom

COSMOTEInternet On The Go 5GB

64

EL

PROT

E4

Deutsche Telecom

COSMOTEInternet On The Go 10GB

65

EL

PROT

E4

Deutsche Telecom

COSMOTEInternet On The Go 20GB

66

EL

PROT

E4

Vodafone

Unlimited 35

67

EL

PROT

E4

Vodafone

Red 1

68

EL

PROT

E4

Vodafone

ρος ό ο ς

+ Internet σ ο ινη ό σο Unli ited and SMSs

69

EL

PROT

E4

Vodafone

ρος ό ο ς

+ Internet σ ο ινη ό σο Unli ited and

ins

70

EL

PROT

E4

Vodafone

Red 3

71

EL

PROT

E4

Vodafone

Vodafone Mobile Broadband

72

EL

PROT

E4

Vodafone

Vodafone Mobile Broadband

73

EL

PROT

E4

Vodafone

Vodafone Mobile Broadband

74

EL

PROT

E4

Vodafone

Vodafone Mobile Broadband

75

EL

PROT

INCU

Wind Hellas

Wind to ALL 40

76

EL

PROT

INCU

Wind Hellas

Wind to ALL 50

77

EL

PROT

INCU

Wind Hellas

Wind to ALL 40 + Mobile Internet 1500MB

78

EL

PROT

INCU

Wind Hellas

Wind to ALL + Mobile Internet 5 MB With

MB at € .

/MB

79

EL

PROT

INCU

Wind Hellas

Wind to ALL 5 + Mobile Internet 5 MB With 5 MB at € .

/MB

80

EL

PROT

INCU

Wind Hellas

WIND Mobile Broadband Control

81

EL

PROT

INCU

Wind Hellas

WIND Mobile Broadband Control

82

EL

PROT

INCU

Wind Hellas

WIND Mobile Broadband Control

83

EE

PROG

INCU

TeliaSonera

MinuEMT

84

EE

PROG

INCU

TeliaSonera

MinuEMT

85

EE

PROG

INCU

TeliaSonera

MinuEMT

86

EE

PROG

INCU

TeliaSonera

MinuEMT

87

EE

PROG

INCU

TeliaSonera

MinuEMT

88

EE

PROG

INCU

TeliaSonera

Internet arvutis XS

89

EE

PROG

INCU

TeliaSonera

Internet arvutis S

90

EE

PROG

INCU

TeliaSonera

Internet arvutis M+4G

91

EE

PROG

INCU

TeliaSonera

Internet arvutis L+4G

92

EE

PROG

INCU

TeliaSonera

Internet arvutis XL+4G

93

EE

PROG

CHAL

Tele2

Nutipakett 4.99 and 200mins

94

EE

PROG

CHAL

Tele2

Nutipakett 7.99

95

EE

PROG

CHAL

Tele2

Nutipakett 7.99 + Internet Mobiilis Large

96

EE

PROG

CHAL

Tele2

Nutipakett 7.99 + Internet Mobiilis Extra Large

97

EE

PROG

CHAL

Tele2

Internet Avrutis Small

98

EE

PROG

CHAL

Tele2

Internet Avrutis Medium

99

EE

PROG

CHAL

Tele2

Internet AvrutisLarge

100

EE

PROG

CHAL

Tele2

Internet Avrutis Extra Large

101

EE

PROG

CHAL

Tele2

Tele2 4G Small

102

EE

PROG

CHAL

Tele2

Tele2 4G Medium

103

EE

PROG

CHAL

Tele2

Tele2 4G Large

104

EE

PROG

INCU

Elisa

Nutikalt piiramatud kõnepaketid

105

EE

PROG

INCU

Elisa

Nutikalt piiramatud kõnepaketid

106

EE

PROG

INCU

Elisa

Nutikalt piiramatud kõnepaketid

107

EE

PROG

INCU

Elisa

Nutikalt piiramatud kõnepaketid

108

EE

PROG

INCU

Elisa

MiNT arvutis

109

EE

PROG

INCU

Elisa

MiNT arvutis

110

EE

PROG

INCU

Elisa

MiNT arvutis

111

EE

PROG

INCU

Elisa

MiNT arvutis

EU27 mobile data cost competitiveness report

May 2013

64

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

112

CZ

PROT

E4

Deutsche Telecom

S nami 590

113

CZ

PROT

E4

Deutsche Telecom

S nami sit nesit

114

CZ

PROT

E4

Deutsche Telecom

S nami sit nesit and Mobilní internet 1 GB

115

CZ

PROT

E4

Deutsche Telecom

S nami sit nesit and Mobilní internet 3 GB

116

CZ

PROT

E4

Deutsche Telecom

Pro tablet

117

CZ

PROT

E4

Deutsche Telecom

Pro tablet

118

CZ

PROT

E4

Deutsche Telecom

Pro notebook

119

CZ

PROT

E4

Deutsche Telecom

Pro notebook

120

CZ

PROT

E4

TelefonicaO2

Free O2 Plus 1GB

121

CZ

PROT

E4

TelefonicaO2

Free CZ 3GB

122

CZ

PROT

E4

TelefonicaO2

Free CZ 10GB

123

CZ

PROT

E4

TelefonicaO2

Mobilní internet M

124

CZ

PROT

E4

TelefonicaO2

Mobilní internet L

125

CZ

PROT

E4

TelefonicaO2

Mobilní internet XL

126

CZ

PROT

E4

Vodafone

Fer tarif 599

127

CZ

PROT

E4

Vodafone

Neo ezené olání ฀do šech sítí

128

CZ

PROT

E4

Vodafone

Neo ezené olání ฀do šech sítí and

MB dat zaplatíte

, 7 Kč četně DPH

129

CZ

PROT

E4

Vodafone

Neo ezené olání ฀do šech sítí and

MB dat zaplatíte

, 7 Kč četně DPH

130

CZ

PROT

E4

Vodafone

Neo ezené olání ฀do šech sítí and

MB dat zaplatíte

, 7 Kč četně DPH

131

CZ

PROT

E4

Vodafone

Neo ezené olání ฀do šech sítí and

MB dat zaplatíte

, 7 Kč četně DPH

132

CZ

PROT

E4

Vodafone

Internet v tabletu Premium

133

CZ

PROT

E4

Vodafone

Internet do notebooku Připojení pro notebook super

134

CZ

PROT

E4

Vodafone

Internet do notebooku Připojení pro notebook pre iu

135

HU

PROT

E4

Deutsche Telecom

Mozaik XS with 100 mins and 10 SMSs package and 10 SMSs extra

136

HU

PROT

E4

Deutsche Telecom

Mozaik S with 30 SMSs package

137

HU

PROT

E4

Deutsche Telecom

Mozaik S with 30 SMSs package + GO! Net XL

138

HU

PROT

E4

Deutsche Telecom

Mozaik L with 100 SMSs package + Net&Roll 1GB LTE

139

HU

PROT

E4

Deutsche Telecom

Mozaik XL with 200 SMSs package + Net&Roll 1GB LTE

140

HU

PROT

E4

Deutsche Telecom

Mozaik XXL with 1000mins 500 SMSs package + Net&Roll 1GB LTE

141

HU

PROT

E4

Deutsche Telecom

Net & Roll XS

142

HU

PROT

E4

Deutsche Telecom

ikon Net 2 GB

143

HU

PROT

E4

Deutsche Telecom

Net & Roll S

144

HU

PROT

E4

Deutsche Telecom

Net & Roll M

145

HU

PROT

E4

Deutsche Telecom

Net & Roll L

146

HU

PROT

INCU

Telenor

SmarttarifaExtra 1 with 100 offnet minutes and 20 SMS

147

HU

PROT

INCU

Telenor

SmarttarifaExtra 2 with 100 offnet minutes and 20 SMS

148

HU

PROT

INCU

Telenor

SmarttarifaExtra 3 with 200mins and 20 SMS

149

HU

PROT

INCU

Telenor

SmarttarifaExtra 4 with 500mins and 20 SMS

150

HU

PROT

INCU

Telenor

SmarttarifaExtra 5 and 1000mins and 20 SMS

151

HU

PROT

INCU

Telenor

Start

152

HU

PROT

INCU

Telenor

Active

153

HU

PROT

INCU

Telenor

Medium

154

HU

PROT

INCU

Telenor

Heavy

155

HU

PROT

INCU

Telenor

Pro

156

HU

PROT

E4

Vodafone

Vodafone Matrix 1 with 100mins

157

HU

PROT

E4

Vodafone

Vodafone Matrix 2

158

HU

PROT

E4

Vodafone

Vodafone Matrix 4

159

HU

PROT

E4

Vodafone

Vodafone Matrix 5

160

HU

PROT

E4

Vodafone

Vodafone Red Standard SIM only

161

HU

PROT

E4

Vodafone

Vodafone Red Super

162

HU

PROT

E4

Vodafone

Internet for your iPad

163

HU

PROT

E4

Vodafone

MobilNet 7

164

HU

PROT

E4

Vodafone

MobilNet 14

165

HU

PROT

E4

Vodafone

MobilNet 21

EU27 mobile data cost competitiveness report

May 2013

65

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

166

IT

PROG

INCU

Telecom Italia

Tutto Compreso 300

167

IT

PROG

INCU

Telecom Italia

Tutto Compreso 300 and Opzione Internet Plus

168

IT

PROG

INCU

Telecom Italia

Tutto Compreso 700 and Tutto Smartphone and Opzione Internet Plus

169

IT

PROG

INCU

Telecom Italia

Tutto Compreso 1500 and Tutto Smartphone nd Opzione Internet Plus

170

IT

PROG

INCU

Telecom Italia

Internet Start

171

IT

PROG

INCU

Telecom Italia

Internet Large

172

IT

PROG

INCU

Telecom Italia

Internet 42.2

173

IT

PROG

INCU

Telecom Italia

Internet 4G

174

IT

PROG

E4

Vodafone

Smart 500

175

IT

PROG

E4

Vodafone

Smart 500 plus 500MB

176

IT

PROG

E4

Vodafone

Smart 500 plus 2GB

177

IT

PROG

E4

Vodafone

Relax Complete SIM only

178

IT

PROG

E4

Vodafone

Internet GO 1 Anno 1GB

179

IT

PROG

E4

Vodafone

Internet GO 1 Anno 5GB

180

IT

PROG

CHAL

Wind

All Inclusive Smart

181

IT

PROG

CHAL

Wind

All Inclusive Silver

182

IT

PROG

CHAL

Wind

All Inclusive Smart and 1GB

183

IT

PROG

CHAL

Wind

All Inclusive Silver and 1GB

184

IT

PROG

CHAL

Wind

INTERNET NO STOP

185

IT

PROG

CHAL

Wind

MEGA UNLIMITED

186

IT

PROG

CHAL

3

Top SIM 400

187

IT

PROG

CHAL

3

Top SIM 400 and Super Internet per Smartphone

188

IT

PROG

CHAL

3

Top SIM 800 and Super Internet per Smartphone

189

IT

PROG

CHAL

3

Top SIM 1600 and Super Internet per Smartphone

190

IT

PROG

CHAL

3

Top SIM 3000

191

IT

PROG

CHAL

3

Web Light

192

IT

PROG

CHAL

3

Web Senza Limiti

193

UK

PROG

E4

Deutsche Telecom

Pay monthly SIM only plans

194

UK

PROG

E4

Deutsche Telecom

Pay monthly SIM only plans

195

UK

PROG

E4

Deutsche Telecom

Pay monthly SIM only plans

196

UK

PROG

E4

Deutsche Telecom

26 month 4GEE

197

UK

PROG

E4

Deutsche Telecom

27 month 4GEE

198

UK

PROG

E4

Deutsche Telecom

28 month 4GEE

199

UK

PROG

E4

Deutsche Telecom

Mobile broadband SIM only

200

UK

PROG

E4

Deutsche Telecom

Mobile broadband SIM only

201

UK

PROG

E4

Deutsche Telecom

Mobile broadband SIM only

202

UK

PROG

E4

TelefonicaO2

Simplicity

203

UK

PROG

E4

TelefonicaO2

Simplicity

204

UK

PROG

E4

TelefonicaO2

Simplicity

205

UK

PROG

E4

TelefonicaO2

Simplicity

206

UK

PROG

E4

TelefonicaO2

Simplicity and bolt on double your data

207

UK

PROG

E4

TelefonicaO2

Simplicity for iPad

208

UK

PROG

E4

TelefonicaO2

Simplicity for iPad

209

UK

PROG

E4

Vodafone

Vodafone Red SIM only 12 months

210

UK

PROG

E4

Vodafone

Vodafone Red SIM only 12 months

211

UK

PROG

E4

Vodafone

Vodafone Red SIM only 12 months + Vodafone Boost

212

UK

PROG

E4

Vodafone

Vodafone Red SIM only 12 months

213

UK

PROG

E4

Vodafone

Vodafone Red SIM only 12 months + Vodafone Boost

214

UK

PROG

E4

Vodafone

I-Pad on SIM only

215

UK

PROG

E4

Vodafone

I-Pad on SIM only

216

UK

PROG

E4

Vodafone

SIM only internet plan

217

UK

PROG

E4

Vodafone

SIM only internet plan

218

UK

PROG

CHAL

3

Essential Internet SIM 200 1 2months

219

UK

PROG

CHAL

3

Ultimate Internet SIM 200 1 2 months

220

UK

PROG

CHAL

3

Ultimate Internet SIM 600 12 months

221

UK

PROG

CHAL

3

The One Plan 12 Month SIM Only

222

UK

PROG

CHAL

3

Broadband 1GB

223

UK

PROG

CHAL

3

Broadband 15GB 24 month

EU27 mobile data cost competitiveness report

May 2013

66

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

224

NL

PROT

INCU

KPN

Stel je abonnement samen

225

NL

PROT

INCU

KPN

Stel je abonnement samen

226

NL

PROT

INCU

KPN

Stel je abonnement samen

227

NL

PROT

INCU

KPN

Stel je abonnement samen

228

NL

PROT

INCU

KPN

Stel je abonnement samen

229

NL

PROT

INCU

KPN

Stel je abonnement samen

230

NL

PROT

INCU

KPN

Stel je mobiele internet abonnement samen

231

NL

PROT

INCU

KPN

Stel je mobiele internet abonnement samen

232

NL

PROT

INCU

KPN

Stel je mobiele internet abonnement samen

233

NL

PROT

E4

Vodafone

SIM only

234

NL

PROT

E4

Vodafone

Red Essential SIM only

235

NL

PROT

E4

Vodafone

Red SIM only

236

NL

PROT

E4

Vodafone

Red Super only

237

NL

PROT

E4

Vodafone

Tablet Sim Only Start

238

NL

PROT

E4

Vodafone

Tablet Sim Only Basis

239

NL

PROT

E4

Vodafone

Mobiel Breedband Start

240

NL

PROT

E4

Vodafone

Mobiel Breedband Basis

241

NL

PROT

E4

Vodafone

Mobiel Breedband Extra

242

NL

PROT

E4

Deutsche Telecom

Smart Plus 150

243

NL

PROT

E4

Deutsche Telecom

Smart Plus 250

244

NL

PROT

E4

Deutsche Telecom

i-Smart 150 SIM only

245

NL

PROT

E4

Deutsche Telecom

i-Smart 300 SIM only and Onbeperkt Internet Voordeelbundel

246

NL

PROT

E4

Deutsche Telecom

i-Smart 500 SIM only Onbeperkt Internet

247

NL

PROT

E4

Deutsche Telecom

i-Smart 750 SIM only Onbeperkt Bel & Sms and Onbeperkt Internet

248

NL

PROT

E4

Deutsche Telecom

Internet Standaard

249

NL

PROT

E4

Deutsche Telecom

Internet Extra

250

NL

PROT

E4

Deutsche Telecom

Internet Maximaal

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

251

SK

PROT

E4

France Telecom

WOW 100mins plus 70SMS package and internetu v mobile start

252

SK

PROT

E4

France Telecom

WOW 100mins plus 70SMS package and internetu v mobile Klasik

253

SK

PROT

E4

France Telecom

WOW 200mins plus 70SMS package and internetu v mobile Klasik

254

SK

PROT

E4

France Telecom

WOW 200mins plus 70SMS package and internetu v mobile Premium

255

SK

PROT

E4

France Telecom

WOW 200mins plus 70SMS package and internetu v mobile Premium

256

SK

PROT

E4

France Telecom

Mobilný internet Start

257

SK

PROT

E4

France Telecom

Mobilný internet Klasik

258

SK

PROT

E4

France Telecom

Mobilný internet Premium

259

SK

PROT

E4

France Telecom

Mobilný internet Extra

260

SK

PROT

E4

France Telecom

Mobilný internet Ultra

261

SK

PROT

E4

Deutsche Telecom

Happy S

262

SK

PROT

E4

Deutsche Telecom

Happy M

263

SK

PROT

E4

Deutsche Telecom

Happy L

264

SK

PROT

E4

Deutsche Telecom

Happy XL

265

SK

PROT

E4

Deutsche Telecom

Happy XL + Neobmedzenýinternet v mobile

266

SK

PROT

E4

Deutsche Telecom

Mobilný internet500

267

SK

PROT

E4

Deutsche Telecom

Mobilný internet200

268

SK

PROT

E4

Deutsche Telecom

Mobilný internet5000

269

SK

PROT

E4

Deutsche Telecom

Mobilný internet10000

270

SK

PROT

E4

Deutsche Telecom

Mobilný internet200000

271

SK

PROT

E4

TelefonicaO2

O Paušál

272

SK

PROT

E4

TelefonicaO2

O Paušál

273

SK

PROT

E4

TelefonicaO2

O Paušál + Internet฀do obilu

274

SK

PROT

E4

TelefonicaO2

O Paušál + ti es restoration SMS

275

SK

PROT

E4

TelefonicaO2

Internet do notebooku

276

FR

PROG

E4

France Telecom

Origami Star

277

FR

PROG

E4

France Telecom

Origami Star

278

FR

PROG

E4

France Telecom

Origami Star

279

FR

PROG

E4

France Telecom

Origami Jet

280

FR

PROG

E4

France Telecom

forfaits Let's gopour clé internet

281

FR

PROG

E4

France Telecom

forfaits Let's gopour clé internet

282

FR

PROG

E4

France Telecom

forfaits Let's gopour clé internet

283

FR

PROG

CHAL

SFR

SÉRIE RED 24h/24

284

FR

PROG

CHAL

SFR

Carré 2h

285

FR

PROG

CHAL

SFR

SÉRIE RED 3Go

286

FR

PROG

CHAL

SFR

Carré 4Go

287

FR

PROG

CHAL

SFR

3GO

288

FR

PROG

CHAL

SFR

6GO

289

FR

PROG

CHAL

Bouygues Telecom

Relax 2h

290

FR

PROG

CHAL

Bouygues Telecom

Relax Unlimited

291

FR

PROG

CHAL

Bouygues Telecom

Smartphone 2GB

292

FR

PROG

CHAL

Bouygues Telecom

Smartphone 3GB

293

FR

PROG

CHAL

Bouygues Telecom

Smartphone Unlimited 24

294

FR

PROG

CHAL

Bouygues Telecom

FORFAIT INTERNET 500 MO

295

FR

PROG

CHAL

Bouygues Telecom

FORFAIT INTERNET 5 GO

296

FR

PROG

CHAL

Free Mobile

Forfait Free

EU27 mobile data cost competitiveness report

May 2013

67

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

297

IE

PROG

E4

Vodafone

MyWay Plus - SIM Only

298

IE

PROG

E4

Vodafone

MyWay Plus - SIM Only

299

IE

PROG

E4

Vodafone

MyWay Plus - SIM Only

300

IE

PROG

E4

Vodafone

MyWay Plus - SIM Only

301

IE

PROG

E4

Vodafone

Red Super

302

IE

PROG

E4

Vodafone

Occasional mobile broadband

303

IE

PROG

E4

Vodafone

Vodafone Mobile Broadband 1GB

304

IE

PROG

E4

Vodafone

Vodafone Performance Pro

305

IE

PROG

E4

TelefonicaO2

O2 Choices SIM 500 12Mth

306

IE

PROG

E4

TelefonicaO2

O2 Choices SIM 1200 12Mth

307

IE

PROG

E4

TelefonicaO2

O2 Choices SIM 1200 12Mth

308

IE

PROG

E4

TelefonicaO2

O2 Choices SIM 1200 12Mth

309

IE

PROG

E4

TelefonicaO2

O2 Choices SIM 2000 12Mth

310

IE

PROG

E4

TelefonicaO2

Mobile Broadband

311

IE

PROG

INCU

Eircom

Talk and text

312

IE

PROG

INCU

Eircom

Build your own plan

313

IE

PROG

INCU

Eircom

Build your own plan

314

IE

PROG

INCU

Eircom

Build your own plan

315

IE

PROG

INCU

Eircom

Build your own plan

316

IE

PROG

INCU

Eircom

20GB SIM only

317

IE

PROG

CHAL

3

Classic Flex Max

318

IE

PROG

CHAL

3

Super Flex Max

319

IE

PROG

CHAL

3

Mega Flex Max

320

IE

PROG

CHAL

3

3Broadband Light

321

IE

PROG

CHAL

3

3Broadband Active

322

IE

PROG

CHAL

3

3Broadband Pro

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

323

SE

PROG

INCU

TeliaSonera

Telia Mobil Rörlig

324

SE

PROG

INCU

TeliaSonera

Telia Mobil Total Liten

325

SE

PROG

INCU

TeliaSonera

Telia Mobil Total Melan

326

SE

PROG

INCU

TeliaSonera

Telia Mobil Dela

327

SE

PROG

INCU

TeliaSonera

Telia Mobilt bredband 2 GB

328

SE

PROG

INCU

TeliaSonera

Telia Mobilt bredband 4 GB

329

SE

PROG

INCU

TeliaSonera

Telia Mobilt bredband 6 GB

330

SE

PROG

INCU

TeliaSonera

Telia Mobilt bredband 8 GB

331

SE

PROG

INCU

TeliaSonera

Telia Mobilt bredband 10 GB

332

SE

PROG

CHAL

Tele2

Snakis Small

333

SE

PROG

CHAL

Tele2

Snakis Small

334

SE

PROG

CHAL

Tele2

Volym Låg + Mobilsurf Small

335

SE

PROG

CHAL

Tele2

Volym Mellan + Mobilsurf Small

336

SE

PROG

CHAL

Tele2

Volym Hög

337

SE

PROG

CHAL

Tele2

Mobilt Bredband Small

338

SE

PROG

CHAL

Tele2

Mobilt Bredband Medium

339

SE

PROG

CHAL

Tele2

Mobilt Bredband Large

340

SE

PROG

CHAL

Tele2

Mobilt Bredband XL

341

SE

PROG

CHAL

Tele2

Small

342

SE

PROG

CHAL

Tele2

Medium

343

SE

PROG

INCU

Telenor

Pott med Surf149

344

SE

PROG

INCU

Telenor

Pott med Surf299

345

SE

PROG

INCU

Telenor

Pott med Surf399

346

SE

PROG

INCU

Telenor

FastPris Pott

347

SE

PROG

INCU

Telenor

4G Mini

348

SE

PROG

INCU

Telenor

4G Maxi

349

SE

PROG

INCU

Telenor

4G Premium

350

SE

PROG

INCU

Telenor

4G Premium+

351

SE

PROG

INCU

Telenor

Ipad Medium

352

SE

PROG

INCU

Telenor

Ipad Large

353

SE

PROG

INCU

Telenor

Ipad Extra Large

354

SE

PROG

CHAL

3

3MiniPlus + 3Vänner Plus

355

SE

PROG

CHAL

3

3MiniPlus + 3Vänner Plus + 3Mobilsurf Plus

356

SE

PROG

CHAL

3

3MiniPlus + 3Vänner Plus + 3Mobilsurf Max

357

SE

PROG

CHAL

3

3Bredband Surf

358

SE

PROG

CHAL

3

3Maxfart 3GB

359

SE

PROG

CHAL

3

3Bredband Medium

360

SE

PROG

CHAL

3

3Maxfart 30GB

361

SE

PROG

CHAL

3

3Maxfart Fri surf

EU27 mobile data cost competitiveness report

May 2013

68

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

362

DK

PROG

INCU

TDC

Pak selv

363

DK

PROG

INCU

TDC

Pak selv

364

DK

PROG

INCU

TDC

Pak selv

365

DK

PROG

INCU

TDC

Pak selv

366

DK

PROG

INCU

TDC

Pak selv

367

DK

PROG

INCU

TDC

Mobilpakker

368

DK

PROG

INCU

TDC

TDC Mobilt Bredbånd Mellem

369

DK

PROG

INCU

TDC

TDC Mobilt Bredbånd Stor

370

DK

PROG

INCU

TDC

TDC Mobilt Bredbånd Ekstra Stor

371

DK

PROG

INCU

Telenor

Lillenor

372

DK

PROG

INCU

Telenor

Vælg et mobilabonnement

373

DK

PROG

INCU

Telenor

Vælg et mobilabonnement

374

DK

PROG

INCU

Telenor

Vælg et mobilabonnement

375

DK

PROG

INCU

Telenor

Vælg et mobilabonnement

376

DK

PROG

INCU

Telenor

Vælg et mobilabonnement

377

DK

PROG

INCU

Telenor

Mobilt Bredbånd M

378

DK

PROG

INCU

Telenor

Mobilt Bredbånd L

379

DK

PROG

INCU

Telenor

Mobilt Bredbånd XL

380

DK

PROG

INCU

TeliaSonera

4SURE Light 3 timer

381

DK

PROG

INCU

TeliaSonera

4SURE Light Fri tale

382

DK

PROG

INCU

TeliaSonera

4SURE Premium

383

DK

PROG

INCU

TeliaSonera

4Everyhting light

384

DK

PROG

INCU

TeliaSonera

4Everyhting premium

385

DK

PROG

INCU

TeliaSonera

4LIFE Light

386

DK

PROG

INCU

TeliaSonera

4LIFE Full

387

DK

PROG

INCU

TeliaSonera

4LIFE Premium

388

DK

PROG

INCU

TeliaSonera

4LIFE Premium plus

389

DK

PROG

CHAL

3

3 FRI tale 1GB

390

DK

PROG

CHAL

3

4 FRI tale 5GB

391

DK

PROG

CHAL

3

5 FRI tale 10GB

392

DK

PROG

CHAL

3

6 FRI tale Fri Data

393

DK

PROG

CHAL

3

3Mobilt Bredbånd 1GB

394

DK

PROG

CHAL

3

3Mobilt Bredbånd 10GB

395

DK

PROG

CHAL

3

3Mobilt Bredbånd 40GB

396

DK

PROG

CHAL

3

3Mobilt Bredbånd 200GB

397

DK

PROG

CHAL

3

3Mobilt Bredbånd FRI DATA

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

398

DE

PROT

E4

Deutsche Telecom

Special Call & Surf Mobil

399

DE

PROT

E4

Deutsche Telecom

Special Complete Mobil XL

400

DE

PROT

E4

Deutsche Telecom

Complete Mobil L

401

DE

PROT

E4

Deutsche Telecom

Complete Mobil L + LTE option

402

DE

PROT

E4

Deutsche Telecom

Complete Mobil L + LTE option with 200mins

403

DE

PROT

E4

Deutsche Telecom

Complete Mobil XL

404

DE

PROT

E4

Deutsche Telecom

Complete Mobil XL + LTE option

405

DE

PROT

E4

Deutsche Telecom

Für Einsteiger

406

DE

PROT

E4

Deutsche Telecom

Für Viel-Surfer

407

DE

PROT

E4

Deutsche Telecom

Für Intensiv-Surfer

408

DE

PROT

E4

Vodafone

Red Basic 100

409

DE

PROT

E4

Vodafone

Super Flat Internet Basic with 100Mmins and high-speed volume to 200 MB

410

DE

PROT

E4

Vodafone

Super Flat Internet Basic with 100Mmins and high-speed volume to 1 GB

411

DE

PROT

E4

Vodafone

Red L

412

DE

PROT

E4

Vodafone

Red Premium

413

DE

PROT

E4

Vodafone

MobileInternet Flat 3,6 light

414

DE

PROT

E4

Vodafone

MobileInternet Flat 21,6

415

DE

PROT

E4

Vodafone

MobileInternet Flat 42,2

416

DE

PROT

E4

Vodafone

MobileInternet Flat 50,0

417

DE

PROT

E4

TelefonicaO2

Basic 300MB

418

DE

PROT

E4

TelefonicaO2

M

419

DE

PROT

E4

TelefonicaO2

L

420

DE

PROT

E4

TelefonicaO2

XL

421

DE

PROT

E4

TelefonicaO2

O2 Go + Surf Flat M

422

DE

PROT

E4

TelefonicaO2

O2 Go + Surf Flat L

423

DE

PROT

E4

TelefonicaO2

O2 Go + Surf Flat XL

424

DE

PROT

E4

TelefonicaO2

O2 Go + Surf Flat XXL

425

DE

PROT

INCU

KPN

Base Smart

426

DE

PROT

INCU

KPN

Base all-in

427

DE

PROT

INCU

KPN

Base all-in plus 2GB

428

DE

PROT

INCU

KPN

Base all-in plus 5GB

429

DE

PROT

INCU

KPN

Internet Flat XL Plus

430

DE

PROT

INCU

KPN

IFI XXL Plus

EU27 mobile data cost competitiveness report

May 2013

69

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

431

ES

PROT

E4

TelefonicaO2

Contrato Movistar Cero

432

ES

PROT

E4

TelefonicaO2

Contrato Movistar Cero + 1 GB extra de navegación

433

ES

PROT

E4

TelefonicaO2

Movistar Total Contract

434

ES

PROT

E4

TelefonicaO2

Movistar Total Contract 1 GB extra de navegación

435

ES

PROT

E4

TelefonicaO2

Habla y Navega 75 + Tarifa Plana Internet 40

436

ES

PROT

E4

TelefonicaO2

Tarifa Plana Internet 20

437

ES

PROT

E4

TelefonicaO2

Tarifa Plana Internet 25

438

ES

PROT

E4

TelefonicaO2

Tarifa Plana Internet 40

439

ES

PROT

E4

Vodafone

Base2

440

ES

PROT

E4

Vodafone

Base3

441

ES

PROT

E4

Vodafone

Red

442

ES

PROT

E4

Vodafone

Red3

443

ES

PROT

E4

Vodafone

Red5

444

ES

PROT

E4

Vodafone

Tarifa Internet Tablet 1GB

445

ES

PROT

E4

Vodafone

Tarifa Internet Móvil 2GB

446

ES

PROT

E4

Vodafone

Tarifa Internet Móvil 5GB

447

ES

PROT

E4

France Telecom

Dolphin 12 SIM

448

ES

PROT

E4

France Telecom

Ballena 22

449

ES

PROT

E4

France Telecom

Ballena 32

450

ES

PROT

E4

France Telecom

Dolphin 35 SIM

451

ES

PROT

E4

France Telecom

Dolphin 35 SIM + Bonos Internet Extra

452

ES

PROT

E4

France Telecom

Ballena 55

453

ES

PROT

E4

France Telecom

Ballena 55 with 1000mins and 4xTarifa Internet Plus

454

ES

PROT

E4

France Telecom

Internet Móvil 2GB

455

ES

PROT

E4

France Telecom

Internet Móvil 10GB

456

ES

PROT

E4

France Telecom

Internet Móvil 2GB

457

ES

PROT

E4

France Telecom

Internet Móvil 10GB

458

ES

PROT

INCU

TeliaSonera

LA MEGA PLANA 20

459

ES

PROT

INCU

TeliaSonera

LA MEGA PLANA 20 + BONO 9 INTERNET

460

ES

PROT

INCU

TeliaSonera

LA INFINITE 30 + BONO 9 INTERNET

461

ES

PROT

INCU

TeliaSonera

LA INFINITE 39 + BONO 9 INTERNET

462

ES

PROT

INCU

TeliaSonera

BONO 9 INTERNET

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

463

PL

PROG

E4

France Telecom

Smart Plan Multi Tylko Sim

464

PL

PROG

E4

France Telecom

Smart Plan Multi Tylko Sim

465

PL

PROG

E4

France Telecom

Smart Plan Multi Tylko Sim

466

PL

PROG

E4

France Telecom

Rozmowy bez limitu

467

PL

PROG

E4

France Telecom

Rozmowy bez limitu + 2GB for 19zl

468

PL

PROG

E4

France Telecom

Orange Free bez modemu

469

PL

PROG

E4

France Telecom

Orange Free bez modemu

470

PL

PROG

E4

France Telecom

Orange Free bez modemu

471

PL

PROG

E4

France Telecom

Orange Free bez modemu

472

PL

PROG

E4

France Telecom

Orange Free bez modemu

473

PL

PROG

CHAL

Polkomtel

Oferta "Oszczędzasz - Tylko SIM

474

PL

PROG

CHAL

Polkomtel

Oferta "Oszczędzasz - Tylko SIM + Pakiet interneto y 5 zł Non Stop

475

PL

PROG

CHAL

Polkomtel

Oferta "Oszczędzasz - Tylko SIM + Pakiet interneto y 5 zł Non Stop

476

PL

PROG

CHAL

Polkomtel

Oferta "Oszczędzasz - Tylko SIM + Pakiet interneto y 5 zł Non Stop

477

PL

PROG

CHAL

Polkomtel

Oferta "Oszczędzasz - Tylko SIM + Pakiet interneto y 5 zł Non Stop

478

PL

PROG

CHAL

Polkomtel

Oferta "Oszczędzasz - Tylko SIM + Pakiet interneto y 5 zł Non Stop ith

ins

479

PL

PROG

CHAL

Polkomtel

Internet Mobilny - oferta bez modemu

480

PL

PROG

CHAL

Polkomtel

Internet Mobilny - oferta bez modemu

481

PL

PROG

CHAL

Polkomtel

Internet Mobilny - oferta bez modemu

482

PL

PROG

CHAL

Polkomtel

Internet Mobilny - oferta bez modemu

483

PL

PROG

CHAL

Polkomtel

Internet Mobilny - oferta bez modemu

484

PL

PROG

CHAL

Polkomtel

Internet Mobilny - oferta bez modemu

485

PL

PROG

CHAL

Polkomtel

Internet Mobilny - oferta bez modemu

486

PL

PROG

E4

Deutsche Telecom

Oferta bez telefonu + 100 MB

487

PL

PROG

E4

Deutsche Telecom

Oferta bez telefonu + 2GB

488

PL

PROG

E4

Deutsche Telecom

Oferta bez telefonu + 5GB

489

PL

PROG

E4

Deutsche Telecom

Oferta bez telefonu + 5GB

490

PL

PROG

E4

Deutsche Telecom

Oferta bez telefonu + 5GB

491

PL

PROG

E4

Deutsche Telecom

Blueconnect tylko SIM

492

PL

PROG

E4

Deutsche Telecom

Blueconnect tylko SIM

493

PL

PROG

CHAL

Play

FORMUŁA S za 9 zł

494

PL

PROG

CHAL

Play

FORMUŁA M za 9 zł

495

PL

PROG

CHAL

Play

FORMULA L for 59 zł

496

PL

PROG

CHAL

Play

FORMULA L for 99 zł

497

PL

PROG

CHAL

Play

FORMULA L for 99 zł + Pakiet ,5 GB - 5 zł iesięcznie

498

PL

PROG

CHAL

Play

No y Play Online GB bez ode u za 9,9 zł

499

PL

PROG

CHAL

Play

No y Play Online GB bez ode u za 9,9 zł

500

PL

PROG

CHAL

Play

No y Play Online GB bez ode u za 9,9 zł

501

PL

PROG

CHAL

Play

No y Play Online GB bez ode u za 9,9 zł

EU27 mobile data cost competitiveness report

May 2013

70

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

502

BE

PROT

INCU

Belgacom

Smart+ 15

503

BE

PROT

INCU

Belgacom

Smart+ 25

504

BE

PROT

INCU

Belgacom

Smart+ 35

505

BE

PROT

INCU

Belgacom

Smart+ 65

506

BE

PROT

INCU

Belgacom

Mobile InternetComfort

507

BE

PROT

INCU

Belgacom

Mobile InternetFavorite

508

BE

PROT

INCU

Belgacom

Mobile InternetFavorite for iPad

509

BE

PROT

E4

France Telecom

Dauphin 12

510

BE

PROT

E4

France Telecom

Dauphin 15

511

BE

PROT

E4

France Telecom

Panthère 28

512

BE

PROT

E4

France Telecom

Panthère 36

513

BE

PROT

E4

France Telecom

Panthère 60

514

BE

PROT

E4

France Telecom

Usagerégulier

515

BE

PROT

E4

France Telecom

Usageintensif

516

BE

PROT

INCU

KPN

B-19

517

BE

PROT

INCU

KPN

B-29

518

BE

PROT

INCU

KPN

B-39

519

BE

PROT

INCU

KPN

B-49

520

BE

PROT

INCU

KPN

B-59

521

BE

PROT

INCU

KPN

internet anywhere 10

522

BE

PROT

INCU

KPN

internet anywhere 15

523

BE

PROT

INCU

KPN

internet anywhere 30

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

524

MT

PROT

E4

Vodafone

Smartphone 35 and 50mins and 20 SMSs

525

MT

PROT

E4

Vodafone

Smartphone 55

526

MT

PROT

E4

Vodafone

Red

527

MT

PROT

E4

Vodafone

Red Premium

528

MT

PROT

E4

Vodafone

Red Premium + 1GB

529

MT

PROT

E4

Vodafone

Liberty LiteData bundle: 2GB

530

MT

PROT

E4

Vodafone

Liberty PlusData bundle: 5GB

531

MT

PROT

E4

Vodafone

Liberty MaxData bundle: 12GB

532

MT

PROT

INCU

GO

Pay monthly 15 with 500MB and 50mins extra

533

MT

PROT

INCU

GO

Pay monthly 15 with 1GB and 50mins extra

534

MT

PROT

INCU

GO

Limiteless 60

535

MT

PROT

INCU

GO

Limiteless 99

536

MT

PROT

INCU

GO

5GB

537

MT

PROT

INCU

GO

12GB

538

MT

PROT

INCU

Melita

Medium Pay Monthly with 3GB and 40mins extra

539

MT

PROT

INCU

Melita

Extra Large Pay Monthly with 3GB

540

MT

PROT

INCU

Melita

Unlimited XXL

541

MT

PROT

INCU

Melita

Unlimited XXL and 3 times 350MB

542

MT

PROT

INCU

Melita

Melita Connector Price Plan

543

CY

PROT

INCU

Cyprus Telecom

Make your own

544

CY

PROT

INCU

Cyprus Telecom

Make your own

545

CY

PROT

INCU

Cyprus Telecom

Make your own

546

CY

PROT

INCU

Cyprus Telecom

Make your own

547

CY

PROT

INCU

Cyprus Telecom

Make your own

548

CY

PROT

INCU

Cyprus Telecom

Make your own

549

CY

PROT

INCU

Cyprus Telecom

VODAFONE MOBILE BROADBAND PAY MONTHLY

550

CY

PROT

INCU

Cyprus Telecom

VODAFONE MOBILE BROADBAND PAY MONTHLY

551

CY

PROT

INCU

Cyprus Telecom

VODAFONE MOBILE BROADBAND PAY MONTHLY

552

CY

PROT

INCU

Cyprus Telecom

VODAFONE MOBILE BROADBAND PAY MONTHLY

553

CY

PROT

INCU

Cyprus Telecom

VODAFONE MOBILE BROADBAND PAY MONTHLY

554

CY

PROT

INCU

MTN

MTN 140 + MTN Mobile Internet 250MB

555

CY

PROT

INCU

MTN

MTN 140 + MTN Mobile Internet 500MB

556

CY

PROT

INCU

MTN

MTN 140 + MTN Mobile Internet 1GB

557

CY

PROT

INCU

MTN

MTN 350 + MTN Mobile Internet 2.5GB

558

CY

PROT

INCU

MTN

MTN 600 + MTN Mobile Internet 5GB

559

CY

PROT

INCU

MTN

MTN 900 + MTN Mobile Internet 5GB and 100mins

560

CY

PROT

INCU

MTN

MTN Mobile Broadband 1GB

561

CY

PROT

INCU

MTN

MTN Mobile Broadband 2.5GB

562

CY

PROT

INCU

MTN

MTN Mobile Broadband 5GB

563

CY

PROT

INCU

MTN

MTN Mobile Internet 25GB

564

CY

PROT

INCU

MTN

MTN Mobile Broadband Unlimited*

EU27 mobile data cost competitiveness report

May 2013

71

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

565

RO

PROG

E4

France Telecom

Cangur 9

566

RO

PROG

E4

France Telecom

Cangur 18 and 50MB option and 75 mins option to national networks

567

RO

PROG

E4

France Telecom

Panteră

568

RO

PROG

E4

France Telecom

Panteră and ti es 5 MB = GB e tra

569

RO

PROG

E4

France Telecom

Panteră 9 and GB option

570

RO

PROG

E4

France Telecom

Panteră 9 and GB option and 75 ins option to national net orks

571

RO

PROG

E4

France Telecom

Panteră 9 and GB option and 75 ins option to national net orks and 5 ins

572

RO

PROG

E4

France Telecom

abonamentul Colibri 8

573

RO

PROG

E4

France Telecom

abonamentul Colibri 10

574

RO

PROG

E4

France Telecom

abonamentul Colibri 13

575

RO

PROG

E4

France Telecom

abonamentul Colibri 15

576

RO

PROG

E4

France Telecom

abonamentul Colibri 25

577

RO

PROG

E4

Vodafone

Mega 8 Plus

578

RO

PROG

E4

Vodafone

Red 25

579

RO

PROG

E4

Vodafone

Mega 25 and 1GB internet option

580

RO

PROG

E4

Vodafone

Red 35

581

RO

PROG

E4

Vodafone

Red 50

582

RO

PROG

E4

Vodafone

Standard

583

RO

PROG

E4

Vodafone

Plus

584

RO

PROG

E4

Vodafone

Extra

585

RO

PROG

E4

Vodafone

Turbo 75

586

RO

PROG

E4

Vodafone

Turbo 100

587

RO

PROG

E4

Deutsche Telecom

Cosmote S data+

588

RO

PROG

E4

Deutsche Telecom

COSMOTE All Free 600 and Connect Mobile S+

589

RO

PROG

E4

Deutsche Telecom

Cosmote S data+ and Connect Mobile L+

590

RO

PROG

E4

Deutsche Telecom

COSMOTE All Free 600 and Connect Mobile L+

591

RO

PROG

E4

Deutsche Telecom

COSMOTE All Free 1000 and Connect Mobile L+

592

RO

PROG

E4

Deutsche Telecom

COSMOTE All Free 1000 and Connect Mobile XL+

593

RO

PROG

E4

Deutsche Telecom

Connect XS

594

RO

PROG

E4

Deutsche Telecom

Connect S

595

RO

PROG

E4

Deutsche Telecom

Connect M

596

RO

PROG

E4

Deutsche Telecom

Connect L

597

RO

PROG

E4

Deutsche Telecom

Connect XL

598

RO

PROG

E4

Deutsche Telecom

Connect XXL

599

RO

PROG

CHAL

RCS-RDS

DIGI MOBIL PLUS and Digi Net Mobil Smartphone Special

600

RO

PROG

CHAL

RCS-RDS

DIGI MOBIL PLUS and Digi Net Mobil Smartphone Special

601

RO

PROG

CHAL

RCS-RDS

DIGI MOBIL PLUS and Digi Net Mobil Smartphone Special

602

RO

PROG

CHAL

RCS-RDS

DIGI MOBIL PLUS and Digi Net Mobil Smartphone Special

603

RO

PROG

CHAL

RCS-RDS

DIGI MOBIL PLUS and Digi Net Mobil Smartphone Special

604

RO

PROG

CHAL

RCS-RDS

DIGI MOBIL PLUS and Digi Net Mobil Smartphone Special

605

RO

PROG

CHAL

RCS-RDS

Standard

606

RO

PROG

CHAL

RCS-RDS

Standard Plus

EU27 mobile data cost competitiveness report

May 2013

72

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

607

LU

PROT

INCU

PT Luxemburg

Basic and Budget

608

LU

PROT

INCU

PT Luxemburg

Basic and Power

609

LU

PROT

INCU

PT Luxemburg

Basic and Ultra

610

LU

PROT

INCU

PT Luxemburg

Relax and Ultra

611

LU

PROT

INCU

PT Luxemburg

Relax and Ultra +

612

LU

PROT

INCU

PT Luxemburg

iPadS

613

LU

PROT

INCU

PT Luxemburg

iPadL

614

LU

PROT

INCU

PT Luxemburg

Ultra

615

LU

PROT

INCU

PT Luxemburg

Ultra+

616

LU

PROT

E4

France Telecom

Basic and Internet Everywhere Medium

617

LU

PROT

E4

France Telecom

Basic and Internet Everywhere Large

618

LU

PROT

E4

France Telecom

Hello Europe Surf and 80mins extra

619

LU

PROT

E4

France Telecom

Hello Europe Surf Flat

620

LU

PROT

E4

France Telecom

Hello Europe Flat and Internet Everywhere Unlimited

621

LU

PROT

E4

France Telecom

iPad data unlimited

622

LU

PROT

E4

France Telecom

Large

623

LU

PROT

E4

France Telecom

Unlimited

624

LU

PROT

E4

France Telecom

4G

625

LU

PROT

INCU

Belgacom

Tango Easy Total and Tango Internet Mobile S

626

LU

PROT

INCU

Belgacom

Tango Easy Total and Tango Internet Mobile L

627

LU

PROT

INCU

Belgacom

Tango Smart 45

628

LU

PROT

INCU

Belgacom

iPad XL

629

LU

PROT

INCU

Belgacom

Tango Internet Mobile L

630

LU

PROT

INCU

Belgacom

Tango Internet Mobile XL

631

LU

PROT

INCU

Belgacom

Tango Internet Mobile 4G XL

632

PT

PROT

INCU

PT Telecom

All netUNLIMITED 15

633

PT

PROT

INCU

PT Telecom

All netUNLIMITED 30

634

PT

PROT

INCU

PT Telecom

All netUNLIMITED 60

635

PT

PROT

INCU

PT Telecom

Unlimited XL

636

PT

PROT

INCU

PT Telecom

Soft Tablet

637

PT

PROT

INCU

PT Telecom

Regular Tablet

638

PT

PROT

INCU

PT Telecom

Soft

639

PT

PROT

INCU

PT Telecom

Regular

640

PT

PROT

INCU

PT Telecom

Plus

641

PT

PROT

INCU

PT Telecom

Hiper4G

642

PT

PROT

INCU

PT Telecom

Mega4G

643

PT

PROT

E4

Vodafone

Base

644

PT

PROT

E4

Vodafone

Base and

MB for € .99

645

PT

PROT

E4

Vodafone

RedTop

646

PT

PROT

E4

Vodafone

Tablet Light

647

PT

PROT

E4

Vodafone

Tablet Plus

648

PT

PROT

E4

Vodafone

Tablet Max

649

PT

PROT

E4

Vodafone

3G Light

650

PT

PROT

E4

Vodafone

3G Plus

651

PT

PROT

E4

Vodafone

3G Max

652

PT

PROT

E4

Vodafone

3G Top

653

PT

PROT

E4

Vodafone

4G 50

654

PT

PROT

E4

Vodafone

4G 100

655

PT

PROT

E4

Vodafone

4G 150

656

PT

PROT

E4

France Telecom

Smart

657

PT

PROT

E4

France Telecom

Smart

658

PT

PROT

E4

France Telecom

Smart and 1GB option

659

PT

PROT

E4

France Telecom

Smart and 1GB option 4x300MB

660

PT

PROT

E4

France Telecom

Smart and 1GB option 7x300MB

661

PT

PROT

E4

France Telecom

Basic

662

PT

PROT

E4

France Telecom

Light

663

PT

PROT

E4

France Telecom

Xpress

664

PT

PROT

E4

France Telecom

Xpress Unlimited

665

PT

PROT

E4

France Telecom

4G 50

666

PT

PROT

E4

France Telecom

4G 100

EU27 mobile data cost competitiveness report

May 2013

73

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

668

LV

PROG

INCU

TeliaSonera

Briviba

669

LV

PROG

INCU

TeliaSonera

Briviba

670

LV

PROG

INCU

TeliaSonera

Briviba

671

LV

PROG

INCU

TeliaSonera

INTERNETS DATORĀ 5

672

LV

PROG

INCU

TeliaSonera

INTERNETS DATORĀ 7

673

LV

PROG

INCU

TeliaSonera

INTERNETS DATORĀ

674

LV

PROG

INCU

TeliaSonera

INTERNETS DATORĀ 9

675

LV

PROG

CHAL

Tele2

Nr.5 atceļa ฀li itus!

676

LV

PROG

CHAL

Tele2

Zelts

677

LV

PROG

CHAL

Tele2

Nr.5 atceļa ฀li itus! and GB

678

LV

PROG

CHAL

Tele2

Ekonomiskais

679

LV

PROG

CHAL

Tele2

Klasiskais

680

LV

PROG

CHAL

Tele2

Turbo

681

LV

PROG

CHAL

Bite

Bite 3.47

682

LV

PROG

CHAL

Bite

Bite . 7 and Internets telefonā 5

683

LV

PROG

CHAL

Bite

Bite . 7 and Internets telefonā

684

LV

PROG

CHAL

Bite

Bite 5.55 and Internets telefonā

685

LV

PROG

CHAL

Bite

Bite 5.55 and Internets telefonā

686

LV

PROG

CHAL

Bite

START

687

LV

PROG

CHAL

Bite

MINI

688

LV

PROG

CHAL

Bite

STANDARD

689

LV

PROG

CHAL

Bite

PRO

690

LT

PROG

INCU

TeliaSonera

Susikurkite planą patys

691

LT

PROG

INCU

TeliaSonera

Susikurkite planą patys

692

LT

PROG

INCU

TeliaSonera

Susikurkite planą patys

693

LT

PROG

INCU

TeliaSonera

Susikurkite planą patys

694

LT

PROG

INCU

TeliaSonera

Susikurkite planą patys

695

LT

PROG

INCU

TeliaSonera

Mobiliojo interneto planai kompiuteryje

696

LT

PROG

INCU

TeliaSonera

Mobiliojo interneto planai kompiuteryje

697

LT

PROG

INCU

TeliaSonera

Mobiliojo interneto planai kompiuteryje

698

LT

PROG

INCU

TeliaSonera

Mobiliojo interneto planai kompiuteryje

699

LT

PROG

CHAL

Tele2

Planas 100

700

LT

PROG

CHAL

Tele2

Planas 300

701

LT

PROG

CHAL

Tele2

Planas 300

702

LT

PROG

CHAL

Tele2

Planas 500

703

LT

PROG

CHAL

Tele2

Planas 1000

704

LT

PROG

CHAL

Tele2

Mobile Internet S (without modem)

705

LT

PROG

CHAL

Tele2

Mobile Internet M (without modem)

706

LT

PROG

CHAL

Tele2

Mobile Internet L (without modem)

707

LT

PROG

CHAL

Bite

Kartais and Internetas 200

708

LT

PROG

CHAL

Bite

Kartais and Internetas 500

709

LT

PROG

CHAL

Bite

Kartais and Internetas 500 and 500MB for 0.01LT/MB

710

LT

PROG

CHAL

Bite

Vidutiniškai and Internetas 5 and 5 MB for . LT/MB

711

LT

PROG

CHAL

Bite

Dažnai and Internetas 5 and 5 MB for . LT/MB

712

LT

PROG

CHAL

Bite

Visada and Internetas 500 and 3500MB for 0.01LT/MB

713

LT

PROG

CHAL

Bite

GO

714

LT

PROG

CHAL

Bite

STANDARD

715

LT

PROG

CHAL

Bite

NO LIMIT

EU27 mobile data cost competitiveness report

May 2013

74

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Numbering Member State identifier

Market identifier

Group identifier

MNO name

Tariff name

716

BG

PROT

INCU

Telekom Austria

тел о и S and тел ъ ф S

717

BG

PROT

INCU

Telekom Austria

тел

т

718

BG

PROT

INCU

Telekom Austria

тел

т and тел ъ ф M

719

BG

PROT

INCU

Telekom Austria

тел

т

720

BG

PROT

INCU

Telekom Austria

тел

т and тел ъ ф L

721

BG

PROT

INCU

Telekom Austria

тел о иле и те ет M

722

BG

PROT

INCU

Telekom Austria

тел о иле и те ет M

723

BG

PROT

INCU

Telekom Austria

тел о иле и те ет M

724

BG

PROT

E4

Deutsche Telecom

Globul Web & Talk

725

BG

PROT

E4

Deutsche Telecom

GLOBUL UNIVERSE and еог

иче о иле и те ет,

В

726

BG

PROT

E4

Deutsche Telecom

GLOBUL UNIVERSE and еог

иче о иле и те ет, 5 В

727

BG

PROT

E4

Deutsche Telecom

Globul Web & Talk and еог

иче о иле и те ет, 5 В

728

BG

PROT

E4

Deutsche Telecom

Globul Web & Talk and еог

иче о иле и те ет, 5 В

729

BG

PROT

E4

Deutsche Telecom

GLOBUL GOWEB UNLIMITED

730

BG

PROT

E4

Deutsche Telecom

GLOBUL GOWEB UNLIMITED

731

BG

PROT

E4

Deutsche Telecom

GLOBUL GOWEB UNLIMITED

732

BG

PROT

E4

Deutsche Telecom

GLOBUL GOWEB UNLIMITED

733

BG

PROT

INCU

Bulgaria Telecom

MegaCallS and +DATA Unlimited M

734

BG

PROT

INCU

Bulgaria Telecom

MegaCallS and +DATA Unlimited L

735

BG

PROT

INCU

Bulgaria Telecom

MegaCallS and +DATA Unlimited XL

736

BG

PROT

INCU

Bulgaria Telecom

Net&Call Top and 170mins extra and +DATA Unlimited L

737

BG

PROT

INCU

Bulgaria Telecom

Net&Call Max and 440mins extra and +DATA Unlimited L

738

BG

PROT

INCU

Bulgaria Telecom

Net&Call Max and 910mins extra

739

BG

PROT

INCU

Bulgaria Telecom

Traffic Unlimited S

740

BG

PROT

INCU

Bulgaria Telecom

Traffic Unlimited M

741

BG

PROT

INCU

Bulgaria Telecom

Traffic Unlimited L

742

BG

PROT

INCU

Bulgaria Telecom

Traffic Unlimited XL

743

SI

PROG

INCU

Telecom Slovenia

Povezani 400

744

SI

PROG

INCU

Telecom Slovenia

Povezani 2000

745

SI

PROG

INCU

Telecom Slovenia

Povezani 2000 and Mobilni Internet 1 GB

746

SI

PROG

INCU

Telecom Slovenia

Povezani 2000 and Mobilni Internet 2 GB

747

SI

PROG

INCU

Telecom Slovenia

Povezani 2000 and Mobilni Internet 5 GB

748

SI

PROG

INCU

Telecom Slovenia

Povezani 2000 and Mobilni Internet 15GB

749

SI

PROG

INCU

Telecom Slovenia

Internet mini

750

SI

PROG

INCU

Telecom Slovenia

Internet start

751

SI

PROG

INCU

Telecom Slovenia

Internet neomejeno

752

SI

PROG

INCU

Telecom Slovenia

Internet LTE/4G

753

SI

PROG

INCU

Telekom Austria

Packet 9

754

SI

PROG

INCU

Telekom Austria

Packet 9 and Maxi Plus

755

SI

PROG

INCU

Telekom Austria

Mobilni internet S

756

SI

PROG

INCU

Telekom Austria

Mobilni internet M

757

SI

PROG

INCU

Telekom Austria

Mobilni internet L

758

SI

PROG

CHAL

Tusmobil

paket Najbližji

759

SI

PROG

CHAL

Tusmobil

Dodatni naročniški paket tuš obil + and Dodatni naročniški paket tuš obil GB*

760

SI

PROG

CHAL

Tusmobil

Free 20

761

SI

PROG

CHAL

Tusmobil

Free 40

762

SI

PROG

CHAL

Tusmobil

Mesečna naročnina do GB

763

SI

PROG

CHAL

Tusmobil

Mesečna naročnina od GB dalje neo ejeno*

764

SI

PROG

CHAL

T2

S

765

SI

PROG

CHAL

T2

M

766

SI

PROG

CHAL

T2

L

767

SI

PROG

CHAL

T2

XL

768

SI

PROG

CHAL

T2

XXL

769

SI

PROG

CHAL

T2

Podatkvoni L

770

SI

PROG

CHAL

T2

Podatkvoni M

771

SI

PROG

CHAL

T2

Podatkvoni S

EU27 mobile data cost competitiveness report

May 2013

75

© REWHEEL 2013 all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

About Rewheel

Rewheel is an independent strategic advisory specializing in data-centric transformation of mobile operators and markets.

We are headquartered in Helsinki, Finland and our main operating footprint is Europe.

Since 2009 we have advised over 10 European mobile operators, including independent challengers as well as Tier-1 OpCos, regulators, competition authorities, a number of private equity and institutional investors and various mobile-data centric start-ups.

Since the onset of the mobile broadband centric 900, 1800 and 2100 MHz license renewal avalanche in 2011 in Europe we have been providing strategy, spectrum valuation and auction theory advice (together with our world class CCA/SMRA auction theorist partners) to five European spectrum authorisation processes (operator or regulator side depending on country), including new entrants and acquisitions as well as license renewals in multi-band (typically 800, 900, 1800, 2100 and 2600 MHz) auctions.

Our ad isors’

knowledge, experience and insights cover all important aspects of successful data-

centric mobile operator business models. Our typical advisory engagements are:

Mobile-data centric operator business planning end-to-end

Mobile data pricing strategies

3G/LTE mobile infrastructure development strategy and investment planning

3G/LTE mobile infrastructure procurement strategy, network infrastructure cost structure competitiveness benchmarking and optimisation (Rewheel is truly network vendor independent)

Spectrum acquisition strategy and NPV valuation

Industry expert advisory to policy makers, regulators and competition authorities

Contact information

For further information regarding this report or Rewheel please e-mail rewheel@rewheel.fi or call

Re heel’s

managing partner, co-author of this report, Antonios Drossos at +358 44 203 2339.

APPENDIX

Part #10 Executive preview: Rewheel martphone tariff competitiveness report (December 2012)

Telcogroups' protective pricing widens

the digital divide between poor and

wealthy EU member states

Rewheel EU27 smartphone tariff competitiveness report

December 2012

Telcogroups' protective pricing widens the digital divide between poor and wealthy EU member states Report highlights

Pri es i

e

er states ith prote ted

arkets are up to te ti

es higher tha i

e

er states ith progressi e

markets.

European consumers need to pay

et ee € a d

a month to

use

their smartphones (2GB data

allowance and 200 off-net minutes). Which EU markets are protected and why?

In the most

progressi e

arkets

ith

very high penetration smartphone tariff prices have converged to the

general mobile ARPU levels. On the contrary

i prote ted

arkets

smartphone tariffs are priced by telcogroups

beyond the reach of the average consumer (3 to 5 times ARPU). In which member states are smartphone tariff prices in parity with ARPU and which MNOs charge up to 5 times the market ARPU?

Competition could only be ignited b

y the prese

e of i depe de t

challenger mobile operators.

The lowest

available price in member states where all MNOs belong to incumbent telcogroups or

the

E5 Group (Vodafone,

Deutsche Telekom, France Telecom, Telefonica and Telecom Italia) is 140% higher than in member states where there is at least one independent challenger MNO.

E5 Group MNOs do not drive price competition in markets where they are the challenger no.3 or 4 operators. E5 Group MNOs price at the same uncompetitive level

( ore tha €40)

both when they are the market incumbent (no.1

or 2) or the market challenger (no.3 or 4). Independent challenger MNOs price on average

elo €20.

Further operator consolidation in Europe would most likely yield higher prices for consumers. The lowest available price in member states where only 3 MNOs are present is 46% higher than in member states having 4 MNOs.

Telcogroups' protective pricing harms EU mobile internet adoption. The penetration of active mobile broadband users in member states where an independent challenger MNO is present is on average 34% higher than in member states where only incumbents and/or E5 Group members are present.

Telcogroups' protective pricing widens the digital divide between poor and wealthy EU member states. In progressive markets of wealthier member states (e.g. Finland, Denmark, UK) consumers need to spend as little as 1% of their monthly net wage income to use their smartphones while in

the prote ted

arkets of

poorer member states

(e.g. Czech, Hungary, Bulgaria) consumers need to spend a staggering 10%-17% of their monthly net wage income.

In order to get much better visibility into the real competitive dynamics of the increasingly smartphone-centric mobile markets national regulators and the European Commission must start tracking mobile data consumption per capita next to mobile broadband penetration. This requires the reporting and tracking of mobile data traffic volumes

of all MNOs prese t i a

arket. “u h prati e has ee

idel adopted i the EU’s

ost

mobile data

progressi e

Nordic member states.

€0

€10 €20 €30 €40 €50 €60

Lowest price in the member states for minimum 2GByte data allowance and 200 off-net minutes per month smartphone tariff

There is NO independent challenger Mobile Network Operator in the market, only incumbents and E5 Group members

There IS challenger Mobile Network Operator in the market

C Z E C H

RE P U BL IC

G RE E C E

G E R M A N Y

H U N G A R Y

O ly MNOs ith i u

e t a d E5 Group asso iatios

PROTECTED MARKET“

Presence of independent challenger MNO(s)

PROGRESSIVE MARKETS

on average 34% higher mobile data penetration

Rewheel

o n e

t e p

a h e a d

© Rewheel Ltd. January 2013, all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Rewheel EU27 smartphone tariff competitiveness report

December 2012 - HIGHLIGHTS

2

© Rewheel Ltd. January 2013, all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Disclosures

The comparative analysis carried out by Rewheel Ltd. during December 2012, solely on its own initiative, does not constitute an investment, legal or tax advice and is not intended in any way to give any direct or indirect recommendations regarding current or future stock transactions that any party might undertake after reading this report. This report does not make, imply or suggest direct or indirect claims of anti-competitive practices undertaken from any of the mobile network operators or operator groups covered herein. Rewheel Ltd. and/or its affiliates, and their respective officers, directors and employees accept no liability whatsoever for any direct, indirect or consequential loss arising from their use of this report or its content. The authors of the report make no buy, sell or hold recommendations regarding the stock of the companies covered in this report. Rewheel Ltd. is not a certified financial advisory and is not currently regulated by any financial investment authority. The viewers of this report should consider this publication as only a single factor in making business or regulatory decisions.

The data used in this comparative analysis are based solely on public information posted on mobile network operator websites. We believe the tariff information posted on mobile network operator web ites to be reliable but no representation is made by us that the row data used are complete, accurate, fully representative, fit for purpose, or were up to date at the time of collection. The data collection team made subjective judgments when translating, interpreting and screening for tariff interdependencies in the mobile network operator web sites. Such subjective interpretations and judgments of tariff conditions, Google translations and of our qualification rules were the sole discretion of the data collection team and of the report authors. Rewheel Ltd. accepts no liability for omissions, errors or simply for not being able to discover on the mobile network operator website a tariff with lower price that met the qualification criteria. We welcome feedback and suggestions from mobile network operators for existing or newly launched tariffs that meet our qualification criteria and which were not considered in our analysis. The findings, conclusions and correlations that the authors of this comparative analysis have reached are solely attributable to their subjective interpretations of Google translations, tariff conditions, qualification rule interpretations and mobile network operator classification & clustering rules.

Rewheel EU27 smartphone tariff competitiveness report

December 2012 - HIGHLIGHTS

3

© Rewheel Ltd. January 2013, all rights reserved | www.rewheel.fi | rewheel@rewheel.fi | +358 44 203 2339

Report contents

1

INTRODUCTION

SMARTPHONE TARIFF COMPETIVENESS AND SOCIAL-ECONOMIC DEVELOPMENT IN EU MEMBER

STATES ................................................................................................................................................................................... 5 2 METHODOLOGY ............................................................................................................................................................ 7

2.1

SUBJECT

OF THE COMPARATIVE ANALYSIS

:

SMARTPHONE TARIFFS

................................................................................................ 7

2.2

TARGETED

SMARTPHONE INTEGRATED

(DATA

&

VOICE

)

TARIFF

:

2GB

AND

200

MINUTES OFF

-NET

MINUTES PER MONTH

....................... 8

2.3

DATA

COLLECTION

:

MNO

WEBSITES

................................................................................................................................... 12

2.4

DETAILED

QUALIFICATION RULES FOR THE TARGET TARIFF

........................................................................................................ 12

3

RELEVANT MACROECONOMIC & MOBILE INDUSTRY METRICS ..................................................................................... 14

3.1

COMPARATIVE

PRICE

LEVEL

IN

EU27

MEMBER STATES

........................................................................................................... 14

3.2

REAL

MONTHLY ADJUSTED GROSS DISPOSABLE INCOME OF HOUSEHOLDS PER CAPITA IN

PPS .......................................................... 14

3.3

MONTHLY

NET WAGE INCOME IN

EU27

MEMBER STATES

........................................................................................................ 15

3.4

ARPU

IN

EU27

MEMBER STATES

....................................................................................................................................... 16

4

MEMBER STATE LEVEL PRICE COMPARISON................................................................................................................. 17

4.1

RELATIONSHIP

BETWEEN AVERAGE MARKET PRICE AND THE GENERAL

COMPARATIVE

PRICE

LEVEL

IN

EU27

MEMBER STATES

................ 18

4.2

RELATIONSHIP

BETWEEN AVERAGE MARKET PRICE AND

ARPU

IN

EU27

MEMBER STATES

.............................................................. 19

4.3

AVERAGE

MARKET PRICE AS A PERCENTAGE OF NET WAGE INCOME AND

ARPU............................................................................ 20

4.4

THE

PRICE VARIATION BETWEEN MEMBER STATES IS NOT NORMAL

............................................................................................. 22

5

MNO AND MNO GROUP LEVEL ANALYSIS .................................................................................................................... 23

5.1

MNO

QUALIFICATION AND

MNO

GROUP

CLASSIFICATION RULES

............................................................................................. 23

5.2

OVERVIEW

OF PRICES ACROSS ALL

92

MNOS

IN

EU27

MEMBER STATES

.................................................................................... 24

5.3

CHALLENGER

VERSUS INCUMBENT VERSUS

E5

GROUP

PRICES

................................................................................................... 26

5.4

E5

GROUP MNOS

PRICE AT THE SAME UNCOMPETITIVE LEVEL BOTH WHEN THEY ARE THE MARKET INCUMBENT

(NO.1

OR

2)

AND THE

MARKET CHALLENGER

(NO.3

OR

4) .................................................................................................................................................... 27

6

IMPACT OF MNO SPECIFIC FACTORS ON MEMBER STATE PRICE LEVELS........................................................................ 31

6.1

LOWEST

AVAILABLE PRICE IN

EU27

MEMBER STATES

.............................................................................................................. 31

6.2

AVERAGE

MARKET PRICE IN

EU27

PER MEMBER STATES

.......................................................................................................... 32

6.3

PRICE

LEVEL IMPACT OF NUMBER OF

MNOS,

PRESENCE OF

E5

GROUP

AND PRESENCE OF INDEPENDENT CHALLENGER

MNOS ............. 32

7

IMPACT OF PRICE LEVEL ON PENETRATION AND CONSUMPTION ................................................................................. 35

7.1

WEAK

LINEAR CORRELATION BETWEEN AVERAGE MARKET PRICE AND MOBILE BROADBAND PENETRATION

......................................... 36

7.2

STRONG

LINEAR CORRELATION BETWEEN

EU

MEMBER STATES DISPOSABLE INCOME AND MOBILE BROADBAND PENETRATION

............... 36

7.3

STRONG

NEGATIVE LINEAR CORRELATION BETWEEN AFFORDABILITY OF AVERAGE MARKET PRICE AND MOBILE BROADBAND PENETRATION

37

7.4

MOBILE

DATA CONSUMPTION

............................................................................................................................................ 40

8

TELCOGROUPS' ROLE IN SHAPING MARKET PRICE AND PENETRATION DYNAMICS ....................................................... 42

9

LIST OF EXHIBITS ......................................................................................................................................................... 48

ANNEX 1

MNO TARIFF DETAILS .......................................................................................................................................... 50

ABOUT REWHEEL .................................................................................................................................................................. 53

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1

Introduction

smartphone tariff competiveness and social-

economic development in EU member states

The digital transformation of economies and societies is one of the main drivers of economic recovery in EU member states

. A

ordi g to the Europea Co

issio ’s

Digital to-do

list

1

published in

December 2012, the digital economy is growing at seven times the rate of the rest of the economy and in 2013 one of the top two priorities of Neelie Kroes, the European Commissioner for Digital Agenda is to maximize the digital sector's contribution to Europe's recovery.

The digital transformation, by enabling easy access to knowledge, information, services and markets allows for unprecedented productivity gains and opens entirely new opportunities to businesses, citizens and whole segments of the society, such as government, mass communications, art, or medicine. Ultimately the pace of the digital transformation will play a central role in determining the competitiveness of both the individual EU member states and the European Union as a whole.

Smartphones, thanks to their innovative user interfaces enabling instant and seamless internet access have become the primary personal vehicles of the digital economy. Moreover, thanks to their affordable prices compared to the purchase price of traditional desktop and laptop computers, martphones carry the potential to bridge the digital divide between the wealthier urbanized societies and the poorer, more rural soci

eties of EU’s e

est

e

er states.

If smartphones represent the vehicles then we can regard smartphone tariff plans as the fuel of the digital economy.

As demonstrated by our research, there are alarming differences in the absolute price level and affordability of smartphone tariff plans across the EU27 member states. Moreover, our analysis shows that in the affected

mostly the poorest

member states high prices are already suppressing mobile

internet adoption.

Increasing broadband penetration, mobile internet usage and narrowing the digital divide are among

ke priorit atio s i EU’s Digital Age da. I its push to reate a si gle digital

arket EU has also

recognized the importance of cross country mobile operator pricing and has set an ambitious target for the difference between the roaming and national tariffs to approach to zero by 2015. Although uch convergence between roaming and national tariffs is required for the creation of a single digital market, it is not sufficient. For a single fully functional digital EU market price convergence on national

artpho e tariffs

ust e also a hie ed a ross

e

er states.

1

http://europa.eu/rapid/press-release_IP-12-1389_en.htm

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It is our conviction that unless European and member state authorities take the necessary corrective measures poorer member states, which are mostly affected, will underperform their wealthier peers in digital and overall economic competitiveness and growth.

The report is structured as follows:

In Section 2 we describe the applied methodology in defining the targeted smartphone tariff basket and collecting the relevant data points from all 92 mobile network operators (MNOs) present in the EU27 member states

In Section 3 we present selected macroeconomic and mobile industry metrics that we used in our analysis and which can be found in the subsequent sections

In Section 4 we present the findings of an EU27 member state level price comparison, exploring the relationship of the price levels and the general macroeconomic metrics like member state Comparative Price Level (CPL) and general mobile industry metrics such as ARPU

In Section 5 we dive one level deeper and look at individual MNO pricing as well as pricing patterns deployed by certain MNOs (e.g. challengers), MNO groups (e.g. incumbents) and MNO market share positions (e.g. no.3 or no.4)

After the MNO level analysis, in Section 6 we return to the member state level and re-explore the EU27 member state price levels presented in Section 4 by highlighting this time the impact of the MNO group dependencies identified in Section 5

In Section 7 we explore possible links between price level and mobile broadband penetration

as reported i EU’s Digital “ ore oard.

Furthermore, we investigate the impact of price level

on mobile data consumption per capita

Finally, in Section 8 we explore the adverse impact caused by the presence of certain operator groups (i.e. E5 Group, Vodafone, Deutsche Telecom, France Telecom) on price level and mobile broadband penetration

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Table 1: Analysis of key factors driving prices and penetration across the EU member states

Source: Rewheel analysis

Factor defining member state clustering rule

Cluster label

Average

penetration

Average of

lowest

available

prices

Average of

average

market

prices

Average of

average

market price

to ARPU %

Number of

uch markets

Average for all EU27 member states

EU27

xx%

€ .

€ .

xxx%

27

There IS Challenger MNO in the market

Ch+

xx%

€ .

€ .

xxx%

14

There is NO Challenger MNO in the market

Ch-

xx%

€ .

€ .

xxx%

13

There are less than 4 MNOs in the market

3MNO

xx%

€ .

€ .

xxx%

15

There are 4 MNOs in the market

4MNO

xx%

€ .

€ .

xxx%

12

Vodafone is present in the market

VF+

xx%

€ .

€ .

xxx%

11

Vodafone is NOT present in the market

VF-

xx%

€ .

€ .

xxx%

16

Deutsche Telekom is present in the market

DT+

xx%

€ .

€ .

xxx%

12

Deutsche Telekom is NOT present in the market

DT-

xx%

€ .

€ .

xxx%

15

France Telecom is present in the market

FT+

xx%

€ .

€ .

xxx%

9

France Telecom is NOT present in the market

FT-

xx%

€ .

€ .

xxx%

18

Vodafone is present and there are only 3 MNOs in the market

VF+,3MNO

xx%

€ .

€ .

xxx%

5

Deutsche Telekom is present and there are only 3 MNOs in the market

DT+,3MNO

xx%

€ .

€ .

xxx%

7

Both Vodafone and Deutsche Telekom is present and there are only 3 MNOs in the market

VF+DT+,3MNO

xx%

€ .

€ .

xxx%

4

MNOs belonging to the "E5 Group" are NOT present in the market

E5-

xx%

€ .

€ .

xxx%

8

MNOs belonging to the "E5 Group" are present in the market

E5+

xx%

€ .

€ .

xxx%

19

There is at least one challenger MNO and no "E5 Group" present

Ch+,E5-

xx%

€ .

€ .

xxx%

7

"E5 Group" is present and there is NO challenger

Ch-,E5+

xx%

€ .

€ .

xxx%

12

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2

List of exhibits

Exhibit 1: International benchmarks for average monthly cellular data usage per smartphone user in 2012. ........................... 8 Exhibit 2: Average mobile data consumption of smartphone users on different volume caps in the UK

June 2012. Sub 2GB

volume caps dramatically deter appetite for smartphone data consumption. ......................................................................... 8 Exhibit 3: 2GB-200min smartphone basket GB allowances across all MNOs in EU27 member states ...................................... 10 Exhibit 4: Comparative Price Level (CPL) 2011 of final consumption by private households including indirect taxes (EU-27 = 100)...................................................................................................................................................................................... 13

Exhibit 5: Real monthly adjusted gross disposable income (2011) of households per capita in PPS ......................................... 14 Exhibit 6: Average monthly net wage income (Take home pay) June 2011 in the member states ........................................... 14 Exhibit 7: Monthly ARPU (2010) in EU27 member states ....................................................................................................... 15 Exhibit 8: Lowest available price in EU27 member states....................................................................................................... 16 Exhibit 9: Average market prices in EU27 member states ...................................................................................................... 17

Exhibit 10: There is no linear correlation between average market price and the general Comparative Price Level in EU27 member states ..................................................................................................................................................................... 18

Exhibit 11: There is weak statistically non-significant correlation between the average market price and ARPU in EU27 member states ..................................................................................................................................................................... 19

Exhibit 12: Average market price as the percentage of monthly net wage income in the member states ............................... 20

Exhibit 13: Average market price as the percentage of market ARPU in EU27 member states ................................................ 21

Exhibit 14: Prices across all MNOs in EU27 member states .................................................................................................... 24 Exhibit 15: Scatter-plot of all MNO offers prices and their GB volume and minute allowances: MNOs offering the highest prices tend to build in less GBs and minutes in their tariffs.................................................................................................... 25 Exhibit 16: Average prices among the challenger MNOs versus incumbent groups MNOs versus E5 Group MNOs .................. 26

Exhibit 17: Average prices of incumbent and E5 Group MNOs in markets where they are the no.3 or no.4 challenger operators. Do MNOs that belong to incumbent groups and E5 Group price competitively as market challengers? ................. 27 Exhibit 18: Focus on pricing applied by smallest market share MNOs in the member states. .................................................. 28 Exhibit 19: Prices of MNOs with the smallest market share in the member states. Are MNOs with incumbent or E5 Group affiliations strategically incentivised in driving smartphone tariff price competition in the markets? ..................................... 29 Exhibit 20:

Lowest available price

in EU27 member states

highlighting markets with challenger MNOs present .................. 30

Exhibit 21:

Average market prices

in EU27 per member states

highlighting markets with challenger MNOs present ........... 31

Exhibit 22: Average price of the lowest available price and average market price across member states with 4 versus 3 active MNOs and E5 Group and independent challenger present vs absent ..................................................................................... 32 Exhibit 23: Mobile broadband penetration

all active users, January 2012 ........................................................................... 34

Exhibit 24: There is weak linear correlation between the average market price and penetration in EU27 member states ...... 35 Exhibit 25: There is a strong linear correlation between disposable income and mobile broadband penetration in EU27 member states ..................................................................................................................................................................... 36

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Exhibit 26: There is a strong negative linear correlation between average market price expressed as the percentage of monthly disposable income and mobile broadband penetration ........................................................................................... 37 Exhibit 27: There is a strong negative linear correlation between average market price expressed as a % of monthly ARPU and mobile broadband and mobile broadband penetration ......................................................................................................... 37 Exhibit 28: There is a negative linear correlation between average market price and penetration, within the cluster of eight poorest member states by monthly net wage income. .......................................................................................................... 38 Exhibit 29: Annual mobile data consumption per capita from selected member states. There is over an order of magnitude difference between the most and the least progressive markets. .......................................................................................... 39

Exhibit 30: Annual growth of per capita mobile data consumption. There is over an order of magnitude difference between the most and the least progressive markets. ......................................................................................................................... 40 Exhibit 31: Price-penetration scatter plot analysis of factors driving prices and penetration across the EU member states, including Vodafone, Deutsche Telekom, France Telecom and general E5 Group associations ................................................. 43

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About Rewheel

Rewheel is an independent strategic advisory specializing in data-centric transformation of mobile operators and markets.

We are headquartered in Helsinki, Finland and our main operating footprint is Europe.

Since 2009 we have advised over 10 European mobile operators, including independent challengers as well as Tier-1 OpCos, regulators, competition authorities, a number of private equity and institutional investors and various mobile-data centric start-ups.

Since the onset of the mobile broadband centric 900, 1800 and 2100 MHz license renewal avalanche in 2011 in Europe we have been providing strategy, spectrum valuation and auction theory advice (together with our world class CCA/SMRA auction theorist partners) to five European spectrum authorisation processes (operator or regulator side depending on country), including new entrants and acquisitions as well as license renewals in multi-band (typically 800, 900, 1800, 2100 and 2600 MHz) auctions.

Our ad isors’ k o

ledge, e perie

e a d i sights o er all important

aspects of successful data-

centric mobile operator business models. Our typical advisory engagements are:

Mobile-data centric operator business planning end-to-end

Mobile data pricing strategies

3G/LTE mobile infrastructure development strategy and investment planning

3G/LTE mobile infrastructure procurement strategy, network infrastructure cost structure competitiveness benchmarking and optimisation (Rewheel is truly network vendor independent)

Spectrum acquisition strategy and NPV valuation

Industry expert advisory to policy makers, regulators and competition authorities

Contact information

For further information regarding this report or Rewheel please e-mail rewheel@rewheel.fi or call

Re heel’s

a agi g part er, o-author

of this report, Antonios Drossos at +358 44 203 2339.

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