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Statement on the operation and management of international gateways
Econet Wireless
October 02, 2006

This statement was published in The Herald newspaper on October 03, 2006

In the interest of the public and various stakeholders, Econet Wireless would like to clarify and correct material factual inaccuracies and inconsistencies contained in recent media reports about the operation and management of international gateways as well as the accounting of foreign currency revenues generated from international traffic.

How international traffic flows into and out of Zimbabwe
Operators are interconnected for carrying both outgoing and incoming international traffic through their respective licensed international gateways.

In the case of Econet, it is licensed to carry international traffic only originating and terminating on its own network. In other words, Econet is not allowed to carry international incoming traffic terminating onto Tel*One and does not send its outgoing international traffic through Tel*One.

However, an operator has limited control on the access routes chosen by foreign networks for incoming traffic. The route for inbound traffic is determined by the originating foreign carrier and is a function of termination rates and route quality. Commercially oriented carriers naturally choose least cost routing to minimize costs. Some international incoming traffic is being refilled into licensed operators through grey routes such as Internet Service Providers (ISPs) who are actually customers of Tel*One. Both Tel*One and mobile operators are victims of refilling by these grey routes. These ISPs are clandestinely terminating refilled international traffic into local mobile networks through Tel*One which unwittingly declares this traffic as national calls. The ISPs are paid in hard currency, but pay Tel-One in local currency as the calls are classified as national calls. Tel*One, in turn pays mobile operators in local currency. Econet and Tel*One have been cooperating in the past in identifying the culprits and will continue to urge the regulator to take appropriate punitive action. For example, Econet recently alerted Tel*One to refilling practices by Tel*One’s customer claiming to be a phone shop operator based in Gweru.

Accounting of international traffic volumes and revenue
At the end of each month operators exchange traffic statistics and statements of accounts for both outgoing and incoming traffic with their international partners. Invoices are raised after ensuring variances are within acceptable limits as recommended by the International Telecommunications Union (ITU) and as per the interconnect agreement approved by both POTRAZ and RBZ. Remittance of the net amounts is in accordance with current regulations governing exporters.

It is a regulatory requirement for all telecommunications operators in Zimbabwe to declare international traffic statistics and revenues to monetary authorities with copies being given to POTRAZ. Operators are required to complete PTS1 Form monthly indicating International partner, period of account, payment arrangement, incoming and outgoing traffic volumes and termination rates used.

In addition to the existing systems, Econet has previously recommended all operators to install sophisticated network traffic monitoring systems for traffic management and to monitor fraud. This system, which Econet has since installed, can monitor the flow of incoming and outgoing traffic.

The legal status of international gateways
International traffic is being routed into and out of Zimbabwe in two ways:

a) Legally through licensed telecommunication operators; and

b) Illegally through grey routes (illegal operators).

Licensed telecommunications operators in Zimbabwe, (Econet, Tel*One, Net*One and Telecel), are licensed by law to operate international gateways.

There is thus nothing sinister or illegal about operators running an international gateway. It is a right conferred by the license granted by POTRAZ in terms of existing law. As an example, in compliance with the License provision, Econet only carries international traffic originating and terminating on its own network and does not carry or collect traffic for any other operator in Zimbabwe.

There are, however, other entities who operate illegal international gateways, commonly termed ‘grey routes’. These illegal operators are the ones responsible for refilling. Refilling is a situation where "Operator A" carries international incoming traffic terminating on "Operator B" in the same country and declares the traffic as ‘national’.

Maximising foreign currency inflows from international traffic
Zimbabwe has the potential to earn significant amounts of foreign currency by implementing viable international termination rates. On its part, Econet has made several representations to POTRAZ and RBZ to implement a single minimum international termination rate for incoming international calls to maximize foreign currency inflows into the country and avoid arbitrage opportunities.

It is important to note that the artificially low foreign currency inflows are not due to the existence of multiple international gateways but more to do with the lack of regulated viable termination rates.

The importance of sustainable termination rates was aptly captured in the RBZ Governor’s Monetary Policy Statement issued on 18th December 2003 when the Governor, Dr Gideon Gono, stated as follows:

"25. Telecommunications sector

This sector is key to the developmental aspirations of our country.

In discussions with stakeholders in this sector, it became evident that the country was sitting on foreign currency opportunities yet to exploited.

25.1 International Traffic Termination Rates

(a) Zimbabwe is losing millions of foreign currency earnings through sub-economic termination rates for incoming international traffic.

International traffic is terminating in Zimbabwe at rates which are as low as 3US cents compared to the average international 20US cents.

For traffic terminating in other countries, Zimbabwe therefore pays approximately 7 times more than it is paid for the same volume of traffic terminating in Zimbabwe.

(b) This results in Zimbabwe always being a net payer of scarce of foreign currency

For the 25 months between January 2000 and January 2002 I.T.U. statistics indicate that Zimbabwe lost an opportunity to generate over US$75 million due to the low termination rates for incoming traffic.

(c) It is against this background that a policy is being initiated to curb dumping of international traffic at sub-economic rates which apply across the operators through the Postal and Telecommunications Regulatory Authority of Zimbabwe.

(d) Monetary Policy recommendation is that the minimum termination rate be set at between US20 cents and US 25 cents.

This will stop the continued loss of the much-needed foreign revenue. In other countries like UK, Oftel, the UK regulatory authority, has prescribed International terminating rates.

It is understood that this proposal has previously been tabled to both Government and Confederation of Zimbabwe Industries (CZI)but no progress was made, hence its revival from a Monetary Policy and foreign currency generation perspective."

In addition to the above, Econet’s view is that multiple gateways introduce competition for the benefits of industry, commerce and individual customers. It also provides customers with choice. Multiple gateways are important to our country from a strategic point of view in that, should one gateway face problems the country does not experience a telecommunications blackout as the other gateways can be used.

Conclusion
It is regrettable that the media reports have created an erroneous impression about the legality and legitimacy of international gateways that could have been avoided had efforts been made to seek comment and factual information from telecom operators concerned.

As a leading and key member of the Telecommunications Operators Association of Zimbabwe (TOAZ), Econet is also willing to share and educate interested stakeholders about its operations in particular and of the telecoms sector in general.

The company has and continue to provide valuable input to the relevant regulatory authorities to ensure that the telecom sector plays its crucial role in the economic development of the country. The telecoms sector is key to national recovery efforts being spearheaded by the Government in close partnership with, and the support of the business sector.

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