Answer from the international auditing company Deloitte to the Communications Commission
Answer from the international auditing company Deloitte to the Communications Commission, in a public statement dated October 16, 2020 concerning mandatory access regulation for virtual mobile operators (MVNOs) in Georgia
Statement of MagtiCom
The Communications Commission has completely ignored the conclusion submitted by MagtiCom, which was prepared by the six companies that are in the list of the Top 10 best audit companies in the world (from those six companies two are members of the "Big Four"). The report addresses the issue of regulating the mandatory access of Virtual Mobile Operators (MVNOs) in Georgia, in particular, the audit, analysis and conclusion of the experts of these companies that the mandatory access of the Mobile Virtual Network Operator (MVNO) will have unequivocally negative consequences for Georgia.
MagtiCom expected that the Commission would properly study the above documents and take actions that would not jeopardize state security and would not be detrimental to the further development of both the country and the mobile telecommunications sector.
As the Commission has moved to discuss this issue in public, furthermore doing it by producing unethical and unqualified statements, we are forced to provide additional information to the public - the response of the auditing company Deloitte to the statement of the Communications Commission of October 16, 2020, which once again clearly and unequivocally confirms the inaccuracy of the position of the Communications Commission.
Deloitte answer to GNCC statement
- We have deep understanding on the Georgian mobile market – our analyses and assessments are based on that understanding and are backed by data and facts.
- There is unequivocal evidence that mobile prices in Georgia are affordable and that the retail market is functioning well in general – we believe low portability is a consequence of these relatively low prices in the market and of the choices consumers in Georgia make.
- We see service differentiation (obtained by offering different service quality, coverage and price combinations) as a structural component of the Georgian market. Therefore, any price benchmarking methodology that doesn’t consider service quality and coverage levels or that excludes VEON services will not, in our view, reflect the reality of the Georgian market.
- The Georgian market is not limited to legacy mobile voice services. Analyses from this this sub-segment of the market cannot be, in our view, extrapolated and generalized to the entire Georgian mobile market.
- In addition, COVID has had an un-deniable effect on mobile service providers worldwide given it has imposed restrictions on people’s ability to move and reduced people’s ability to spend. MVNOs will be impacted in a similar way, and investors considering financing new MVNOs ventures will need to take into account the additional risks created by the COVID context.
- Finally, we believe the GNCC might have mis-read or mis-understood some of our statements or points. We have clarified them in this document for the avoidance of any possible doubt.