EQUALITY OF ACCESS BOARD BT Group plc · BT Group plc is a public limited company registered in England and Wales. This is the EAB Annual Report for the period ended 31 March 2014

Annual Report 2014BT Group plc

EABEQUALITY OF ACCESS BOARD

705349.indb 4 19/05/2014 11:30

The Equality of Access Board was established on 1 November 2005 as part of the Undertakings offered by BT to Ofcom. We are a committee of the BT Group plc Board although our structure, membership and obligations to Ofcom make us unique.

The Equality of Access Board is a committee of the BT Group plc Board. BT Group plc is a public limited company registered in England and Wales. This is the EAB Annual Report for the period ended 31 March 2014. Unless otherwise stated all facts, statistics, events or developments are correct to the nearest practical date before 22 May 2014. The opinions expressed are those of the EAB, not necessarily those of BT Group plc. The EAB Annual Report is a requirement of the Undertakings given to Ofcom by BT pursuant to the Enterprise Act 2002.

PricewaterhouseCoopers LLP provides independent assurance on key elements of the EAB’s Annual Report and these are indicated by the symbol throughout the report. PwC provides assurance over the completeness and accuracy of the compilation of the summaries of the EAB’s conclusions, the compilation of product KPI information and the consistency of these EAB conclusions with the evidence gathered on its behalf by the EAO including the underlying management information of BT Group.

A reference to a year expressed as 2013/14 is to the financial year ended 31 March 2014 and a reference to a year expressed as 2014 is to the calendar year. This convention applies similarly to any reference to a previous or subsequent year. References to ‘this year’, ‘the year’ and ‘the current year’ are to the financial year ended 31 March 2014. References to ‘last year’ are to the financial year ended 31 March 2013.

Look out for…

10 Further reading Further reading online PwC assurance

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6

Introduction

4

Review of the year

Systems and information sharing have

remained major concerns for the EAB this

year whilst we continue to ensure industry

concerns are properly considered by BT.

We work in a number of different ways to develop our approach and

provide assurance and use our findings to shape our future monitoring

programme. In this section we report on those findings in each of our key

activity areas. Then we give our views on potential future developments

and risks in ‘Outlook for 2014/15’ on page 10.

Assessing milestone delivery

We look at BT’s completion of the last dated major Undertakings

milestone and consider BT’s delivery record. Further details on our

historic monitoring of milestone delivery can also be found in the

‘Undertakings Status Indicators’ section on page 11.

Read more on page

●

Investigating breaches

We assess and give details of breaches of the Undertakings during

the year, including our analysis of the impact and BT remedies.

Read more on page

●

Understanding industry concerns

We consider complaints and issues raised by industry and give details

of our reviews.

Read more on page

●

Risk-based approach to ongoing compliance

We assess how the key risks we identified in 2012/13 were addressed

during 2013/14.

Read more on page

●

Outlook for 2014/15

We give our views on forward-looking risks and continuing

Undertakings obligations.

Read more on page

●


System separation

Separation of IT systems plays a pivotal role in BT’s delivery of and

continuing compliance with the Undertakings. There are several different

systems obligations with which BT must comply. For example, BT has

to keep the systems used by Openreach separate from those used by

the rest of BT so that confidential or commercially sensitive information

cannot be shared inappropriately across organisational boundaries.

It must also move customer records across to the separated systems.

BT must maintain different levels of separation for specific types of

system such as Operational Support Systems (OSS) and Management

Information Systems (MIS). Some of these requirements involve

establishing and maintaining access controls either permanently or

as a temporary expedient until such time as the systems are more

fully separated.

Delivery progress in 2014

There were no new milestones due this year. A requirement that

90% of customer records should be held on separate systems by

31 December 2012 had not been delivered at the time of last year’s

report. We expressed concern about this at the time and Ofcom had

issued a Direction that the requirement be completed by 30 November

2013. BT told us it had met an interim target in April 2013 and met the

migration milestone in October 2013. We subsequently validated that

this was the case.

That completion marked the delivery by BT of the last binding and

time-specific milestone in the Undertakings. It is not the end of the

migration however and BT confirmed to Ofcom, in December 2011,

that it expects, by June 2014 to have migrated 97% of its customers

to EoI products and at least 92% of Customer Side Records to separate

systems. We consider that BT remains on track to achieve these targets

despite the delays to the 2012 target.

The EAB is aware that the customers and services which remain to be

migrated are exclusively in the business sphere, reflecting the fact

that BT found these the most challenging to migrate. This is because

of the scope and complexity of the business portfolio, coupled with

the scale and complexity of the business customers concerned. We have

asked BT to maintain its efforts on separation and equivalence and to

continue to focus on the SME sector since CPs tell us this is an area

of particular sensitivity.

Other systems obligations

The EAO provided Ofcom with a report on those systems listed in

Annex 6 of the Undertakings, which are referred to as ‘core-hybrid’

systems. These are 11 OSS which, it was agreed, could allow access by

both Openreach and the rest of BT because they deal with operational

network elements which it is not practical to separate. Unlike other OSS,

the requirement is to have access controls rather than full separation for

these 11 systems. We carry out checks annually to monitor access by

BT employees and report our findings to Ofcom. Our monitoring during

2014 continues to show that only limited numbers of non-Openreach

employees access the systems and only where there is a demonstrable

operational need.

Review of the year

60

65

80

75

70

90

95

85

100

Non-BT CPs BT CPs

Apr 1

3

May

13

Jun

13

Jul 1

3

Aug

13

Sep

13

Oct 1

3

Nov 1

3

Dec 1

4

Jan

14

Feb

14

Mar

14

Wholesale Broadband Connect provision

Percentage of orders provided on time

6

Introduction

16Undertakings status indicators

The focus of the EAB’s work is increasingly

on monitoring BT’s compliance with the

behavioural aspects of the Undertakings

now that the dated milestones have been

delivered. The section includes a report on

BT’s Undertakings training, the performance

of the Openreach and BT Wholesale

Statement of Requirements processes and

details of Undertakings related complaints

BT has received during the year.

Code of Practice and Training

BT updated its Code of Practice in 2014 and revised the associated

mandatory training. The percentage of staff completing the training

remains an indicator of BT’s continued commitment to, and knowledge

of, the Undertakings.

3

Manager and team member Undertakings

training completion

Information

Sharing

Commercial

Policy

User Access

Controls

Non Eol

Services

Milestone

0

1

2

4

5

51

5

4 3

5

1

1

2012/132011/12

6

3


training completion

Information

Sharing

Commercial

Policy

User Access

Controls

Non Eol

Services

Milestone

0

1

2

4

5

51

5

4 3

5

1

1

2012/132011/12

6

3


training completion

Information

Sharing

Commercial

Policy

User Access

Controls

Non Eol

Services

Milestone

0

1

2

4

5

51

5

4 3

5

1

1

2012/132011/12

6

Undertakings status indicators

Chart as

positional only

Chart as

positional only

Chart as

positional only

Contents

Review of the year

Who we are


2 Chairman’s introduction – a welcome from the EAB Chairman, Phil Hodkinson

3 The EAB in brief – who we are and how we work4 Assessing milestone delivery – an update on BT’s delivery of the

systems separation milestones5 Investigating breaches – an analysis of breaches of the Undertakings7 Understanding industry concerns – the results of our issues

management and complaints-handling processes9 Risk-based approach to ongoing compliance – our assessment of

the top risks during 2013/14 including internal reorganisation, inappropriate information sharing and collaboration systems

11 Outlook for 2014/15• Potential risks for the coming year• Our programme of work for 2014/15

12 The EAB13 The EAO and EAB Secretariat14 Monitoring, reporting and advising15 Stakeholder engagement15 Our view on our governance and resourcing15 Wider governance of the Undertakings15 The EAB and BT’s governance framework15 Our view on BT’s governance of the Undertakings

16 Behavioural dashboard18 Product KPIs22 Delivery of key milestones25 NGA monitoring themes26 PwC’s assurance opinion28 Glossary

Our dashboard includes measures such as training completions. It provides a useful way of assessing how engaged BT employees are with the delivery of the Undertakings.

Find out more about our monitoring processes, our work with stakeholders and more information about our Board members.

An update on BT’s delivery of the systems separation milestones.

We assess key performance indicators published by BT showing the performance of BT’s Equivalence of Input products. These are a useful way of comparing the services provided to Communications Providers within and outside of BT.

We are asked to give our views on how well the governance arrangements supporting the Undertakings are functioning. This section includes a description of these arrangements and our opinion on their effectiveness.

Our assessment of the top risks to BT’s delivery of the Undertakings during 2013/14.


Risk-based approach to compliance

4 9

The EAB

Behavioural dashboard

Overview of our governance

Product KPIs

12

16

15

18

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6 Introduction2 Review of the year

Phil HodkinsonChairman

The continuing relevance of the Undertakings entered into by BT and Ofcom back in 2005 to the overall regulatory UK telecommunications framework today is reinforced by this year’s report from the Equality of Access Board.

Not only has our work during the year focused on BT’s ongoing compliance with the Undertakings and the achievement of the few remaining major systems milestones, but we’ve also increasingly turned our attention to how the benefits to both BT and other Communications Providers (CPs) of the progress achieved to date, will be maintained and furthered going forward.

During the year we were able to confirm that BT had achieved the revised timescales set by Ofcom for the delivery of the missed 2012 milestone for Customer Side Records separation and we expect to be able to confirm shortly that BT has achieved the remaining systems targets due for delivery by 30 June 2014. Whilst no specific milestones have been set beyond 2014, BT has reassured both the EAB and Ofcom that its systems separation programme will continue apace, thus offering the prospect of further benefits to all concerned. We will continue to report on progress in this area which we know is of great importance to CPs, particularly those operating in the small business market where the levels of separation achieved so far are not as extensive as in the consumer market.

BT’s ongoing compliance with the Undertakings, especially in relation to controlling access to confidential information, the provision of new products by Openreach on an equivalent basis, and the training and behaviours of its people, continues to be monitored by the EAB with vigilance. A significant proportion of the breaches in the last 12 months were the consequence of people moves created by internal organisational changes and as such could have been avoided. In response BT has instigated a programme to address the root causes and we therefore expect to report fewer breaches of this nature in the future.

The environment and backdrop against which ongoing compliance with the Undertakings is monitored is of course constantly changing and thus we continue to place great value on our regular meetings with Ofcom, OTA2 and CPs which serve to highlight concerns and trends for us to investigate and take account of in our work. A significant re-organisation of roles and functions within BT during the year, and the industry’s continuing concerns about the Statement of Requirements process and Openreach’s service levels are just a few examples of the issues raised in dialogue with industry.

To supplement this dialogue, in January 2014, the EAO surveyed CPs to get their views on BT’s compliance with the Undertakings and, as before, the exercise provided some useful feedback. CPs continue to hold a wide range of views about BT’s compliance and some raised questions about the future scope of the Undertakings, especially in relation to service levels and the implementation of new technologies. The survey has also identified a number of topics within the current scope that the EAB will consider futher in the coming year.

As announced last year, Edward Astle and Stephanie Liston joined the EAB as independent directors during the last 12 months, and their wealth of industry and regulatory experience has been evident in the quality of deliberations and debate the Board continues to enjoy. I’m also pleased that Emin Gürdenli has agreed to join the EAB as an independent director from 1 May 2014. Emin, who is well known and well regarded within the industry, will replace Dr Peter Radley who retires from the Board after serving since its inception. Like Sir Bryan Carsberg and Stephen Pettit before him, Peter has been instrumental in establishing widespread confidence in the Undertakings and I’d especially like to pay tribute to him for his contribution over so many years. As ever, my thanks also go out to all of my fellow EAB members and colleagues in the EAO for the skill, care and commitment that they bring to their roles.

Phil HodkinsonChairman22 May 2014

Chairman’s introduction

We’ve increasingly turned our attention to how the benefits of the progress achieved to date will be maintained and furthered going forward.

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3Review of the year

Revi

ew o

f the

year

Who we are• Equality of Access Board comprising a majority of independent

members and the Equality of Access Office• Established on 1 November 2005 as part of Undertakings

offered by BT to Ofcom• Oversight of the whole of BT in respect of compliance with

the Undertakings

Read more on page 12

What we do• Monitor BT’s compliance with the Undertakings, including

its delivery of major milestones and ongoing compliance• Advise BT on areas where it needs to improve its compliance

with the Undertakings• Report on BT’s progress annually


The EAB in brief

How we work Our stakeholders

IndustryCommunications Providers and industry associations

Advising• Recommendations to BT• Guidance for Ofcom

Monitoring• Formal milestone

delivery programme• Ongoing compliance• Risk-based compliance• Breaches, complaints

and issues• Behavioural measures• Product key performance

indicators

Reporting• Annual review of

compliance reported publicly

• Regular reports to BT Group plc Board

• Bulletin for industry

Stakeholder feedbackCPs OTA2 Ofcom BT

BTAll of BT’s lines of business with a particular focus on Openreach

OfcomStaff and senior management

Completion of milestone deliveryBT achieved its final dated milestone towards the end of 2013.

Read more on page 4

Risk-based approach to complianceWith the completion of the dated milestones, so ongoing compliance takes centre stage.

Read more about our approach to this on page 9

Understanding industry concernsThe EAB continued to use its Quick Checks process to review and report on concerns and issues identified by Communications Providers (“CPs”)and industry bodies.

A full breakdown of the areas covered by Quick Checks is on page 8

2013/14 in brief

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Systems and information sharing have remained major concerns for the EAB this year whilst we continue to ensure industry concerns are properly considered by BT.We work in a number of different ways to develop our approach and provide assurance and use our findings to shape our future monitoring programme. In this section we report on those findings in each of our key activity areas. Then we give our views on potential future developments and risks in ‘Outlook for 2014/15’ on page 11.

Assessing milestone deliveryWe look at BT’s completion of the last dated major Undertakings milestone and consider BT’s delivery record. Further details on our historic monitoring of milestone delivery can also be found in the ‘Undertakings Status Indicators’ section on page 16.

Read more on page 4

Investigating breachesWe assess and give details of breaches of the Undertakings during the year, including our analysis of the impact and BT remedies.

Read more on page 5

Understanding industry concernsWe consider complaints and issues raised by industry and give details of our reviews.

Read more on page 7

Risk-based approach to ongoing complianceWe assess how the key risks we identified in 2012/13 were addressed during 2013/14.

Read more on page 9

Outlook for 2014/15We give our views on forward-looking risks and continuing Undertakings obligations.


Assessing milestone deliverySystem separationSeparation of IT systems plays a pivotal role in BT’s delivery of and continuing compliance with the Undertakings. There are several different systems obligations with which BT must comply. For example, BT has to keep the systems used by Openreach separate from those used by the rest of BT so that confidential or commercially sensitive information cannot be shared inappropriately across organisational boundaries. It must also move customer records across to the separated systems.

BT must maintain different levels of separation for specific types of system such as Operational Support Systems (OSS) and Management Information Systems (MIS). Some of these requirements involve establishing and maintaining access controls either permanently or as a temporary expedient until such time as the systems are more fully separated.

Delivery progress in 2013/14There were no new milestones due this year. A requirement that 90% of customer records should be held on separate systems by 31 December 2012 had not been delivered at the time of last year’s report. We expressed concern about this at the time and Ofcom had issued a Direction that the requirement be completed by 30 November 2013. BT told us it had met an interim target in April 2013 and met the migration milestone in October 2013. We subsequently validated that this was the case.

That completion marked the delivery by BT of the last binding and time-specific milestone in the Undertakings. It is not the end of the migration however and BT confirmed to Ofcom, in December 2011, that it expects by June 2014 to have migrated 97% of its customers to Eol products and at least 92% of Customer Side Records to separate systems. BT has told us that it has achieved these targets despite the delays to the 2012 milestone. The EAO is now carrying out checks in order to validate the achievement.

The EAB is aware that the customers and services which remain to be migrated are exclusively in the business sphere, reflecting the fact that BT found these the most challenging to migrate. This is because of the scope and complexity of the business portfolio, coupled with the scale and complexity of the business customers concerned. We have asked BT to maintain its efforts on separation and equivalence and to continue to focus on the SME sector since CPs tell us this is an area of particular sensitivity.

Other systems obligationsThe EAO provided Ofcom with a report on those systems listed in Annex 6 of the Undertakings, which are referred to as ‘core-hybrid’ systems. These are 11 OSS which, it was agreed, could allow access by both Openreach and the rest of BT because they deal with operational network elements which it is not practical to separate. Unlike other OSS, the requirement is to have access controls rather than full separation for these 11 systems. We carry out checks annually to monitor access by BT employees and report our findings to Ofcom. Our monitoring during 2014 continues to show that only limited numbers of non-Openreach people access the systems and only where there is a demonstrable operational need.

Review of the year

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5Review of the year

Revi

ew o

f the

year

BT review of systems and access controlsWe reported last year on BT’s progress with its review of the compliance status of systems across the company. We had welcomed this review following our concerns about the number of breaches involving non-compliant information sharing. BT’s review covered more than 2,000 systems. It resulted in a consolidated non-trivial breach reported to the EAB in October 2012 which was discussed in detail in last year’s report.

The breach involved issues with 20 systems. The EAB has confirmed that corrective action has been completed on 18 of these. Of the two remaining systems, one is scheduled for replacement and BT is developing improved compliance controls over the other. The EAB will remain vigilant to ensure these are resolved. The EAB was also encouraged by the improvements BT has made to its IT governance as it makes sure, as far as is practical, that no new non-compliances are introduced as the systems estate evolves. These improvements include a development of the system BT uses to check user lists on sensitive systems and which identified potential breaches this year.

External auditPwC performs an audit of the access controls of BT’s systems once every two years. This year’s audit did not identify any concerns over the ongoing effectiveness of these controls.

Our overall view on systemsLast year we expressed our disappointment that BT had not met one of its milestones. This year we are pleased that the milestone has been met and that the increased focus which achieved this has also enabled BT to claim to have met its June 2014 forecast. We are also pleased that BT has corrected most of the systems identified in its compliance review so that they are now working compliantly and with robust day to day access controls. The EAB will remain vigilant in this area. We are concerned at access control failures following reorganisations. The EAB expects to see improvements from BT in this area in the coming year.

Investigating breachesThe EAB assesses any non-compliance with the Undertakings and seeks to understand the impact that this might have on CPs and on BT’s business. We evaluate breaches reported to us by BT as well as those identified through our own investigative work, including issues raised by CPs and through our formal complaints process.

The Undertakings place obligations on BT and the EAB to identify and report on breaches. Following a breach notification from BT under its internal process, the EAO reviews the case and reports to the EAB. The EAB determines whether it is a breach or not, gives its view on the case and either endorses BT’s view of its significance (non-trivial or trivial) or makes a finding of its own. The EAB also considers the appropriateness of BT’s proposed remedial actions. The EAO independently investigates potential breaches either where it has identified something through its own reviews of BT’s compliance, where Ofcom has flagged a particular issue brought to its attention by CPs or trade associations or where a CP makes a formal complaint.

The EAB reviews cases which have been put into BT’s breach process but which BT has found to be a “no breach”. The EAB may overturn BT’s decision and proceed on the basis of a breach finding. It did so this year in respect of the breach concerning wayleaves, which BT had reported as a “no breach”. Separately, in two instances this year, the EAB agreed to exercise its discretion and not make a finding on matters it considered so trivial that it would be disproportionate to pursue a full breach investigation. An example was a case where BT had briefly exceeded a 1% threshold it had agreed for issuing orders for ISDN using the classic, rather the Eol product.

The EAB can also recommend additional actions which can help to mitigate the impact of a breach – particularly when a remedial action cannot be implemented immediately as it requires the development of a new process or systems solution. These are known as ‘consequential’ actions and are also designed to minimise the risk of similar breaches occurring in the future.

In 2013/14, the EAO concluded that ten cases were non-trivial breaches of the Undertakings.

Description Remedy

1 A number of people in BT Global Services had access to a remote test capability on an IT system involved in the repair process, that was not accessible on an equivalent basis by other CPs.

The people involved can now only use the same Knowledge Based Diagnostics test tools as are available to all CPs.

2 In a number of cases, Openreach had administered wayleaves on behalf of BT Wholesale. It was found that this activity should have been offered as a service on an equivalent basis to other CPs.

Openreach now provides this equivalently via an Office Services contract.

3 Differences were found in the way the Openreach Directors’ Service Office handled escalations for two CPs (one of which was a BT CP) compared to all other CPs.

The CPs were moved back to the standard process.

4 A BT manager intervened with Openreach, on behalf of another CP’s end-user, to try and bring forward the installation of a fibre connection.

The people involved have been reminded that BT does not deal directly with the customers of other CPs.

5 As a result of a systems change, CPs using BT Wholesale’s Secure Data Exchange and Distribution System (SDEDS) were able to see information about the broadband customers of other CPs, as well as their own broadband customers.

The system was corrected and a review is currently underway to learn from the incident.

6 Eighteen individuals who moved from BT TSO to BT Business inappropriately retained their BT TSO access to systems which contained BT Wholesale CCI.

Access to the systems was withdrawn.

7 An individual working in the part of BT TSO that supports BT Global Services, was given access to the broadband test tools on the Woosh system. Non-BT CPs are not able to access Woosh in the same way, so this was found to be a breach of BT Wholesale’s obligation to provide broadband on an equivalent basis in Markets 1 and 2.

Access was withdrawn and the individual moved to using the test tools that are provided equivalently to all CPs.

8 A team in BT Global Services had inappropriate access to BT Wholesale CCI as part of a review of the financial performance of BT contracts.

Access to the information was withdrawn, staff have been reminded of their responsibilities and further checks instituted.

9 A new Openreach product was launched but its website said it was not available in Northern Ireland. This was found to be a breach of Openreach’s obligation to supply the same services in Northern Ireland as it does in the rest of the UK.

The website was updated and it was confirmed that the product is available in Northern Ireland.

10 Openreach product information was copied to an uncontrolled internal web site.

The information was removed and an alert added to the site to warn that it is not suitable for Commercial Information.

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Our view on breachesThe number of breaches concluded in 2013/14 was slightly lower than the previous year. We view positively the number of breaches that were self-reported as this appears to show an awareness of the rules and a commitment to compliance.

Several of the breaches have resulted from individuals retaining access to IT systems following reorganisations. BT has improved its detective controls in this area and is reviewing how it can prevent recurrence. There have also been instances where information has been shared inappropriately. We are, as a result, continuing to impress upon BT that behaviour is central to compliance and that the company’s focus on training must be sustained. Our detailed report on behaviours starts on page 16.

Trends and causes of breaches We have carried out a study of the Undertakings breaches that have been found since 2006 with a view to identifying and feeding back to BT our conclusions and to inform our analysis of risks for the future. The results, in overview, are as follows.

2007 2008 2009 2010 2011 2012 2013 2014

Number of breaches per reporting year

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0

18.0

9

18

17

12

6

8

18

17In the first reporting year, there were nine reported breaches. In 2008 this number doubled to 18. Over the next three years from 2008 to 2010 the number of breaches reduced steadily until only six breaches were reported in 2011. Since 2011 the trend has reversed and the number of breaches has risen again to the same level as 2008, with 18 breaches reported in 2013 and 17 reported in 2014. Note that in this trend review the year 2014 refers to the financial year 2013/14 and prior years are expressed similarly, so 2007 refers to 2006/07.

Analysis shows that the percentage of breaches self-reported by BT has remained broadly similar over the years, including during the last four years. Therefore there does not seem to be any evidence to suggest that BT has become any more or less focused on identifying and reporting breaches of the Undertakings. The reason for the increase in the number of reported breaches may therefore simply be that as breaches have coalesced around certain ‘core’ types, they have become easier to identify and report. Nevertheless the overall rise in the number of breaches reinforces the need for continued oversight by the EAB and for it to remain active and vigilant in monitoring and advising BT, particularly as BT enters a world based on ongoing compliance rather than on achieving milestones.

Note that the study reviewed the number of breaches in each prior financial year whereas the Annual Report describes breaches up to and including the latest findings, normally at the April EAB. As a result, the number of breaches shown per year in the study may differ from that shown in previous Annual Reports.

In 2013/14 there were seven breach cases which the EAB determined trivial:

Description Remedy

1 BT renewed a customer contract which included bespoke Wavestream Connect circuits. The product should have been replaced with one based on Openreach’s EoI Optical Spectrum Access product.

BT is planning a migration of all remaining Wavestream Connect circuits to the EoI variant. This circuit will be picked up as part of that exercise.

2 A draft paper for an internal Group committee was found to have been copied to a person in BT Wholesale (BTW). The paper contained information about fault rates that was not available to industry and was considered to be Commercial Information.

The paper error was found before submission, withdrawn and corrected. The information was not of interest to the individual in BTW and it had not been forwarded. Individuals concerned were coached on their responsibilities.

3 A team from BT TSO moved to BT Global Services. The team had supported a number of Lines of Business (LoBs) including BTW and accessed an IT system, potentially containing Customer Confidential Information, in doing so. There was a delay before access to the BTW system was withdrawn following the move.

The team was moved from BT Global Services to BTW to allow its support work to continue compliantly.

4 A presentation containing details of an Openreach project not normally shared with CPs was sent to BTW as part of a project report.

The breach was found quickly and the teams involved briefed on the need for care in handling documents.

5 A request from the BT TSO team supporting BT Retail to enhance the resilience of the TV Connect product was agreed without the necessary industry consultation or use of the Statement of Requirements (SoR) process.

A consultation was conducted to establish whether there was wider demand for the enhanced resilience.

6 An individual moved from Openreach to BT Retail but retained inappropriate access permissions to a database holding Openreach CI.

Access to the database was withdrawn.

7 An individual moved from BT TSO to BT Global Services and then to BTW, but retained access to Openreach CCI on an IT system.

Access to the systems was withdrawn.

One further potential breach was under investigation at the time this report was published. We will report on the outcome in our regular bulletin and in the 2015 EAB Annual Report.

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7Review of the year

Revi

ew o

f the

year

Number of breaches per reporting year (by type)

2007 2008 2009 2010 2011 2012 2013 20140

2

4

6

10

8

BrandingInfluencing commercial policyMissed milestoneNorthern IrelandBreach of exemption

Information sharingNon EolOpenreach boundary and control issues

A detailed analysis of breach types shows a persistent and underlying level of breaches relating to inappropriate information sharing and the use of non-Eol systems and processes. In the first few years of the Undertakings this total number of breaches was further increased by additional breaches arising from Openreach boundary issues and failure to achieve certain early delivery milestones. As operational boundaries became more clearly defined, and the number of milestone obligations reduced, the overall level of breaches also declined until 2010.However, in the last two years there has been a significant increase in the number of breaches, mostly relating to information sharing and the use of non-Eol systems and processes. In 2013 this increase was due to eight separate cases where inappropriate information was shared by individuals in emails, presentations and meetings. This shows the continuing need to focus on behavioural and system controls, to prevent such breaches occurring in the future.

In 2014, the continuing higher level of breaches also related to a combination of information sharing and non-Eol systems and processes. The majority of information sharing cases resulted from the establishment of the new BT Technology, Service and Operations (BT TSO) organisation which involved the movement of employees between Openreach, BT Wholesale and downstream lines of business. This led to five breaches involving people with inappropriate access to systems and information, and shows the need for BT to continue to be vigilant when reorganisations of this type take place.

2007

2008

2009

2010

2011

2012

2013

2014

0

4

6

8

2

10

12

14

27

513

611

12

24

53

126

107

Non-trivialTrivial

Number of breaches per reporting year (by triviality)

The trend of non-trivial versus trivial breaches indicates that the proportion of non-trivial cases has increased over time. It could be that, eight years into the Undertakings, the breaches that are being identified represent issues that have taken a while to surface and are therefore more serious. It could also be partially explained by the EAB taking a tougher line on borderline cases where, so many years into the Undertakings, it considers that BT should really have “known better”.

Understanding industry concernsWe keep in regular contact with non-BT CPs and industry associations and hear views on a wide range of issues through both formal and informal channels. This includes formal complaints from CPs and informal feedback via our issues management process.

Industry surveyThe EAB welcomes the views of CPs and industry associations and encourages regular feedback.

In January 2014 the EAO sent out a survey to a range of CPs and industry associations to hear their views on the Undertakings. The aim of the survey was to gain a snapshot of CPs’ perceptions of the Undertakings some eight years after they were agreed and to supplement the EAO’s existing industry engagement. The EAB was grateful to those who responded.

The survey asked respondents to rate how satisfied they were that BT had fulfilled its Undertakings obligations (e.g. completing the formal milestones and offering services equivalently) and that it continued to meet its obligations on an ongoing basis. Respondents were given the options: “very satisfied”, “satisfied”, “not satisfied” or “very dissatisfied” and asked to provide a brief explanation of their answer.

44% of those who expressed a view said they were either “satisfied” or “very satisfied” that BT had fulfilled its obligations. 33% said they were “not satisfied” or “very dissatisfied” and the balance expressed no opinion.

The verbatim responses also elicited interesting perspectives. These included concerns from one CP that Openreach service performance inclines retail customers to stay with BT and from another that the Undertakings had not delivered the “level playing field” which was the objective of the Telecommunications Strategic Review in 2005. One respondent commented that BT had missed the deadlines on many obligations whilst another said that BT had met its Undertakings with integrity and commitment.

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CPs have raised a number of issues and concerns about Openreach’s EAD product so we continue to pay close attention to this high profile, high volume product.

The EAO has continued to monitor and review the performance of EAD following continued increases in the volume supplied. We found that the Openreach operation of the ‘deemed consent’ process (see EAD equivalence above), Excess Construction Charge (ECC) process delays, CP use of the Openreach value added project management service, which is available to all CPs, and the different types of CP orders and different CP requirements all affected the performance that CPs experience. The EAO did not find any evidence that EAD orders were being progressed by Openreach in a non-compliant manner.

Following discussion with Openreach and Ofcom, the EAO assessed whether the Openreach operation of legacy passive optical technology equipment in certain regions of the UK was compliant with the Undertakings. The review established potential concerns which were further investigated through the EAB breach process, where it was established that this older type technology was still used in isolated instances. The EAB exercised its discretion in this instance.

A sample of the other issues, checks and conclusions follows below.

• A CP raised a concern as to whether a BT Local Business’ use of Openreach appointment slots was operating equivalently, in compliance with the Undertakings. The EAO visited the BT Local Business team and gained assurance that Openreach appointment slots were being offered and booked compliantly but identified that the concern had been raised due to inappropriate comments made to a customer by an inexperienced member of the BT Local Business team. The CP who raised the concern was briefed that the EAO had found no non-compliant activity and that the individual who had relayed the information to the customer had been coached.

• A BT BDUK Partnership person, following engagement with the end customer, intervened to bring forward the installation date of two Superfast Broadband orders into two schools. The EAO found that the compliant escalation routes had not been used and the case was put into the breach process. The EAB found this to be a non-trivial breach of the Undertakings.

• A CP concern that 21CN labelling, which could be associated with BT, was being attached to Openreach Ethernet equipment at customers’ premises was reviewed by the EAO. Although no non-compliance was identified, to avoid future confusion, the EAO recommended to Openreach that the labelling was removed from the equipment of the type in question in future and the CP was informed of the EAO findings.

• The EAO reviewed a concern that BT orders that incorporated remote call forwarding could not be transferred to non-BT CPs automatically without causing a break in customer service. Following the review the issue was progressed and assessed in the BT Breach process. The EAB found that the transfer process was operating equivalently in compliance with the Undertakings.

• The EAO reviewed a concern raised by a CP about the transfer of sub 8 channel ISDN30 orders. The EAO was able to confirm to the CP that the transfer issues affected both BT and non-BT CPs, that the process was therefore operating equivalently and that Openreach offered a manual work-around to all CPs where transfers of sub 8 channel orders were required.

Openreach customer serviceOur monitoring of the Undertakings helps ensure that the service provided to other CPs is exactly the same as that provided to BT’s retail operations. The EAB is conscious though, from comments by CPs, that the absolute standard of service provided by Openreach remains their primary concern. Although the absolute standard is not a matter for the EAB we do review performance with Openreach and reflect to them the comments that we receive.

EAD equivalenceWe remain aware that the performance of the Openreach Ethernet Access Direct (EAD) product has continued to be of great interest to CPs. The EAO is continuing to monitor provision performance closely to ensure equivalence.

One area of particular concern has been Openreach’s use of the ‘deemed consent’ process. This is a process whereby Openreach changes its target completion date if an order is delayed for reasons beyond its reasonable control, such as being unable to gain access to the end-user’s premises. CPs are concerned that the process may be operated inconsistently and that this could disadvantage them. The EAO has observed inconsistencies although these are believed to be due, at least in part, to the different policies of CPs towards accepting a deemed consent. Initiatives are in place in Openreach to improve the operation of deemed consent and the EAO is monitoring these.

Further discussion of EAD equivalence can be found in the KPI section on page 19.

Complaints to the EABNo formal complaints were made by CPs under the EAB’s formal procedure this year.

Issues managementWe look into issues raised informally by key stakeholders including BT, non-BT CPs, Ofcom and the OTA2 as part of our ‘Quick Checks’ process. This process allows us to record and track issues and assess rapidly whether they need more detailed, formal investigation.

In 2014 we investigated 20 issues. Of these, 15 were from non-BT CPs following the EAO’s informal complaints process, two were requests for clarification and the remaining three were initiated by the EAO. Five potential breaches were identified through the process in 2014 and in other cases recommendations have been made by the EAO and followed by BT. Common themes are shown in the chart below:

4Copper

10Equivalence of Inputs

2NGA and BDUK

3Ethernet

1Information sharing

EAO Quick Checks reviews 2013/14 themed areas

As in previous years, the theme of equivalence, being at the core of the Undertakings, was the most prevalent in our issues management process. We looked into a number of issues concerning equivalence including whether Openreach’s products and services were supplied on an equivalent basis.

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• A CP raised an equivalence concern about whether functionality in an Openreach testing system was being offered to all CPs on an equivalent basis. Following a review the issue was progressed and assessed in the BT Breach process. The EAB found no breach of the Undertakings.

• During the year Openreach progressed a ‘wires only self-install’ trial with a lead CP. Openreach was able to provide the EAO with assurance that the trial had been open to all CPs, industry briefings had been issued and that details had been briefed at industry forums.

• Following a CP claim that BT was offering its customers a product that involved moving customers onto the non-equivalent legacy platform to provide service during emergency situations, the EAO reviewed whether the product was being offered compliantly. The EAO was able to confirm to the concerned CP that the BT product in question did not involve shifting customer service from the equivalent WLR platform back onto the non-equivalent legacy platform and that BT was offering the product in compliance with the Undertakings.

• Following communication with a customer, Ofcom flagged a concern to the EAO regarding whether leased line (Ethernet) order information had been compliantly shared between BT and Openreach. The EAO reviewed the details of all of the orders that the customer had placed via BT and Openreach and was able to confirm to the customer that all of the orders had been progressed in compliance with the Undertakings.

• Following Openreach service calls with industry, the OTA2 flagged a concern to the EAO that a slide deck, shared with industry on the Openreach website, contained details that were not consistent with the Undertakings. The EAO assessed the slide deck and, although finding no non-compliance, recommended to Openreach that it should be updated to reflect more accurately the information and details that Openreach was relaying to CPs. The slide deck was updated and the review findings reported back to the OTA2.

5Potential breach identified

11No actions recommended,

BT and CP briefed

4Actions recommended to BT

EAO Quick Checks reviews 2013/14 outcomes

Our view on industry concernsWe continue to engage with industry, with BT and with industry bodies in order to identify and respond to industry concerns.

Customer service continues to be a key issue, whether that is the “deemed consent” process or simply Openreach’s delivery and repair performance. The EAB monitors these issues and investigates where there are potential Undertakings concerns. The EAB is aware that Openreach has a number of initiatives to address these concerns and we will continue to encourage BT to engage with industry and we will look into issues as and when they arise.

Risk-based approach to ongoing complianceWe take a risk-based approach to our ongoing compliance work. This is based on findings from our monitoring and on feedback from stakeholders including CPs, Ofcom and BT. Our work and reviews are then planned around these key risks. We evaluate the risk register regularly to make sure that our work continues to cover the most important areas of concern.

During 2012/13 we identified the following risks in terms of BT’s compliance with the Undertakings and these shaped our monitoring work during 2013/14. Further details follow the summary table.

Risk area What we did

1 Compliance of the new Technology, Service & Operations (BT TSO) organisation, including the interfaces from BT LoBs into BT TSO and vice versa.

We reviewed the new BT TSO organisation and how it works with the rest of BT to ensure compliance with the Undertakings.

2 Collaboration systems and social networking sites.

We reviewed BT’s approach to addressing compliance for these types of systems and applications.

3 Inappropriate information sharing.

We identified and reviewed high risk areas based on the breach cases identified during the previous year.

4 Systems implementation to achieve delayed Customer Side Records milestone.

We continued our regular reviews of BT’s progress towards achieving its systems commitments, including attending the Ofcom quarterly roadmap review sessions.

5 Inappropriate influence over commercial policy within the drive for increased end-to-end working.

We undertook a further review of the arrangements put in place as part of BT’s company-wide transformation programme.

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Compliance of the new Technology, Service & Operations (BT TSO)We reviewed the BT TSO organisation, how it was set up, the people moves both in and out, the roles that people perform and the systems that people use. Due to the nature of the work performed by BT TSO in supporting all of the BT lines of business including Openreach, Undertakings compliance is a continuing risk area. The EAO found that information sharing and Undertakings governance and controls that BT had put in place were operating compliantly but recommended that BT should continue to provide the EAO with progress updates on developments for the various strategic system solutions, planned to replace the tactical and manual systems and processes currently used by many BT TSO units.

Collaboration systems and social networking sites We conducted a review of BT’s approach to addressing compliance for these types of systems and applications which included blogs, wiki sites and BT’s enterprise collaboration system (SharePoint).

We found that BT had made the decision to migrate its existing company blog sites and existing wiki sites to its new strategic collaboration tool (SharePoint2013) to reduce costs, centralise governance and improve compliance controls. This migration was in progress at the time of our review.

Our review found that BT’s existing collaboration system contained thousands of individual sites and had grown rapidly since its adoption. BT had already identified potential governance issues with this system and had put in place a programme to address these in the move to SharePoint2013.

We will follow up on all these areas during the coming year.

Inappropriate information sharingInformation sharing continued to be an ongoing risk during the year, with a number of related breach report cases reviewed by the EAO. Individual errors and isolated incidents along with more serious non-compliances where, for example, people moving between BT lines of business retained inappropriate system access, were reviewed and followed up by the EAO. Assurance was gained that self-reporting of non-compliances was encouraged and that the correct governance and follow up action was in place to reduce or prevent the likelihood of future non-compliance. In an organisation as large and complex as BT, inappropriate information sharing remains an ongoing risk.

Systems implementation to achieve delayed Customer Side Records milestoneDuring the year we tracked BT’s progress towards delivery of this delayed milestone. We also conducted an in-depth review of BT’s implementation and tested a substantial number of data records to check that they had been migrated to the new UK business system stack. We concluded that BT had migrated the required figure of 90% in advance of the revised date of November 2013.

BT has also previously informed Ofcom that it will achieve a figure of between 92% and 94% by 30 June 2014. BT has reported that it has now reached those targets. The EAO will carry out its normal review process to validate the completion.

Inappropriate influence over commercial policy within the drive for increased end-to-end workingBT has initiated a culture change programme from its Group centre that, amongst other messages, encourages management to take an “end-to-end” perspective on its business. The EAB believes there is a risk that this focus and involvement in such programmes by people from downstream BT could generate pressure for those involved in associated service improvement programmes to give inadequate attention to information sharing, equivalence and related principles.

The programme was reviewed by the EAO which found no immediate concerns. BT advised that it was aware of the compliance risks and was providing guidance and briefing to people working on the service improvement programmes. The EAO will keep the service improvement programmes under review.

Other Risks and Compliance IssuesEquivalence and Broadband Delivery UK (BDUK)The EAO completed a review of equivalence in the BDUK regions. The review found that all regions are served by multiple retail CPs and that BT and non-BT CPs experience broadly similar performance for provision and repair. The EAO has also engaged with CPs active in these areas to capture any equivalence or Undertakings concerns and follow them up. Issues were resolved around space, power and backhaul.

It is important that the evolution of BT’s organisation takes the Undertakings fully into account and that the established principles do not become diluted.

Western, Eastern and Central London Area (WECLA)The EAO was asked to take on a monitoring role to ensure compliance with the Undertakings following an exemption granted by Ofcom relating to provision of high bandwidth (i.e. above 1 Gbit/s) Ethernet and optical spectrum access services in certain areas of London. The EAO assessed Openreach’s governance and controls to manage WECLA orders and found no concerns.

Our overall view of BT’s compliance in 2013/14Our view is that BT continues to be committed to implementing the Undertakings and to maintaining the behaviours essential to ongoing compliance. We were pleased that the company achieved the milestone delayed from 2012 and that it believes it has achieved the further targets.

The breaches we have seen during the year emphasise the need for continued vigilance in the areas of awareness of the Undertakings and an understanding of their practical application. The fact that many of the breaches were reported as a result of BT initiatives demonstrates awareness of, and continued commitment to, the Undertakings.

We remain cognisant of the risk that BT could become complacent and that the passage of time and completion of milestones could cause attention to the Undertakings to diminish. It remains critical however that all BT employees have a good awareness of the Undertakings and of their responsibilities under them. In addition it is important that the evolution of BT’s organisation takes the Undertakings fully into account and that the principles that have been established do not become diluted.

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Outlook for 2014/15The EAB takes a risk-based approach to planning its forward-looking monitoring plan by evaluating non-compliant incidents and the output from the previous year’s monitoring programme.

Forward-looking risksWe reviewed our risk register in February 2014 and agreed that the following risks are the most material and should direct elements of our work in the coming year. Two of these risks are new to the register. The table contains a summary and further discussion follows.

Description Activity

1 Pace of technology change and deploymentBT is currently introducing technology change in several areas, some of which were not envisaged at the time the Undertakings were agreed. These include wireless local access, fourth generation mobile and an internal cloud computing infrastructure. There is a risk that Undertakings compliance may not be integral to BT’s decision making process before such technical developments go ahead.

• Continue to encourage BT to engage with Ofcom on these matters at the earliest stages.

• Continue to monitor BT’s deployment plans and conduct compliance checks where necessary.

2 Undertakings compliance in Technology, Service & Operations (BT TSO)BT TSO was established in 2013 from a combination of BT Innovate & Design and BT Operate and movement of people to and from other parts of BT, including Openreach. There is a risk that BT TSO, as a single unit servicing all the other LoBs, may inappropriately share information or overstep operational boundaries with Openreach. The EAO has conducted a review of this area and found that whilst information sharing governance is in place, it will need to be continuously maintained and monitored. There have been several breaches of the Undertakings involving BT TSO including, recently, those resulting from reorganisations. These contribute to our focus on this as a risk area.

In addition, BT is spending heavily on investment in strategic priorities including fibre broadband, BT Sport and wireless. There are industry concerns that BT TSO development effort is being focused on these developments resulting in a potential ‘bottleneck’. This gives rise to a potential equivalence concern that BT’s own requirements are being given priority over other CPs.

• Complete detailed substantive testing of information sharing controls.

• Keep BT TSO/Openreach people moves under review.

• Review processes for prioritising BT’s developments in relation to requests from non-BT CPs.

3 Customer Side Records and EOI migrations tailBT has now delivered the final milestone obligations and believes it has achieved the further percentages forecast for June 2014. There may be a remaining ‘tail’ of products and customers which it is not practical or proportionate to migrate. However, BT and Ofcom have yet to discuss where this boundary of OSS migrations might lie. There is, therefore, a risk that the current separation programme will lose impetus and that BT’s plans are not fulfilling its obligation to separate its systems when “reasonably practicable and proportionate” as set out in the Undertakings.

• Conduct a review of the June 2014 milestone delivery.

• Engage with Ofcom to understand its expectations for the end of migrations.

• Review BT’s plans for fulfilling the system separation obligations, the continuation of the system separation programme and how this fits with cloud computing.

4 Collaboration and social networking toolsThe EAB previously identified the risk of inappropriate information sharing on BT’s collaboration tools if appropriate controls were not in place. The EAO has conducted an initial review of this area and found that BT is in the process of migrating its existing blog and wiki sites over to its strategic collaboration tool (SharePoint). BT is looking at implementing compliance monitoring tools on SharePoint in order to reduce the risk of non-compliant information sharing. This process will take several months to achieve and therefore the risk remains ongoing. The EAO proposes to perform a further review of this area during 2014/15.

• Conduct a follow-up review of BT’s plans to address compliance with collaboration systems and social networking applications.

5 Organisational change and end-to-end workingBT continues to go through significant organisational and people change including the split of BT Retail into BT Business and BT Consumer; a change of leadership in Openreach; and the introduction of a significant amount of contract engineering resource. This type of ongoing change creates compliance risks including the potential for reduced levels of staff awareness, the need for more proactive monitoring of user access controls and a potential loss of corporate memory.

In addition, the EAB previously identified that BT’s drive for end-to-end working within its Organisational Health transformation programme could lead to downstream lines of business attempting to influence Openreach’s commercial policy, contrary to the Undertakings. An initial review by the EAO found that the risk is limited to the customer focused stream of the programme which is currently being re-evaluated.

• Review BT’s approach in these areas and conduct compliance checks where necessary.

• Conduct a follow up review on the developing approach for the Customer focused stream of the Organisational Health programme.

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6 Introduction12 Who we are

The Equality of Access Board was established on 1 November 2005 as part of the Undertakings offered by BT to Ofcom. We are a committee of the BT Group plc Board although our structure, membership and obligations to Ofcom make us unique.

Phil HodkinsonChairmanPhil Hodkinson was appointed to the BT Group plc Board on 1 February 2006. He is chair of the Pensions Committee, and a member of the Nominating & Governance Committee and the Committee for Sustainable and Responsible Business. He is a non-executive director of Business in the Community and Travelex, and a trustee of Action Medical Research and BBC Children in Need. He chairs the Community Mark Independent Approvals Panel and is an adviser to the finance committee of Christian Aid.

Phil’s previous roles include senior independent director at Resolution, non-executive director of HMRC, group finance director of HBOS, chairman of Insight Investment and Clerical Medical, and chief executive of Zurich Financial Services UK Life. He is a Fellow of the Institute of Actuaries.

Stephanie ListonIndependentStephanie Liston is Senior Counsel to Charles Russell’s Technology & Communications group. Stephanie is also a non-executive member of the Advisory Board of Orga Systems GmbH. A qualified lawyer in the US and UK, Stephanie served as a Non-Executive Director of the Office of Communications (Ofcom) from 2005 to 2008, a Director of the European Competitive Telecommunications Association (ECTA) from 2000 to 2005 and co-chairman of the Communications Committee of the International Bar Association from 2004-2006. Stephanie co-founded and is a director of Women in Telecoms and Technology (founded in 2000).

Who we are

The EAB has oversight of the whole of BT when monitoring compliance with the Undertakings. It has terms of reference setting out its role, monitoring and reporting remit, its powers, how its members are appointed and its organisation. See www.bt.com/eab for more information.

The Undertakings require that the EAB has five members: three independent members, one BT Group plc non-executive director and one BT senior manager. We have announced one change to the composition of the Board to take effect during the next financial year. The composition of the Board in the reporting period was as follows.

For more information see www.bt.com/eab

Dr Peter Radley IndependentDr Peter Radley is a Fellow of the Royal Academy of Engineering and has worked in the telecommunications industry since 1965, involved in pioneering fibre optics, GSM and Broadband. Between 1991 and 2002 he held positions in Alcatel with global responsibility for technology and marketing and as Chairman and CEO for Alcatel UK. He was a founder of the Broadband Stakeholder Group set up by the UK Government. Since 2002, Peter has been an independent advisor to a number of organisations including the DTI and South East England Development Agency and he is also chairman of technology start-up companies in the broadband, IP and mobile sectors.

Dr Tim Whitley BT senior managerDr Tim Whitley is Managing Director of Research and Innovation and of BT’s Adastral Park research and development facility. He started working for BT in 1981 as an apprentice engineer in North Wales, and has since held roles in areas including optics research, technology consultancy, technical architecture and has served as BT’s Group Strategy Director.

Edward Astle IndependentEdward was Pro Rector Enterprise at Imperial College London from 2008 to 2013. Since 2009 he has also been a Non-Executive Director and member of the Risk & Audit Committee of Intertek, the FTSE 100 international testing and inspecting group. Edward was Executive Director of National Grid plc from 2001 to 2008, responsible for their telecommunications-related businesses (most notably wireless infrastructure); non-executive chair of three telecommunications ventures 1999-2001; Managing Director of BICC Communications (and a director of BICC Group) from 1997 to 1999; and an Executive and Regional Director of Cable & Wireless plc from 1989 to 1997. Previously he held senior business strategy positions in the UK and France. He is Vice Chair of the Shannon Trust.

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Emin Gürdenli Emin has 30 years of experience in telecoms covering R&D, start-up, operations, strategy, JVs and mergers. He now works as an Independent Advisor and Non-Executive, specialising in network operations transformation, business development and partnerships. He is a founding member and the Chairman of Azenby, an independent advisory business for the wireless industry. Emin’s career has included ten years in R&D with BT, start-up experience of building and operating T-Mobile’s network in the UK, and then the last ten years in executive roles within Deutsche Telekom’s T-Mobile International business in Europe, most recently in charge of Network Services in Everything Everywhere. Within the UK mobile industry, Emin is well known for the creation of MBNL, a ‘Network Sharing’ joint venture between T-Mobile and 3UK.

MeetingsDuring 2013/14 the EAB Secretary organised five Board meetings and several informal catch-up conference calls. Minutes of the meetings have been provided to Ofcom and the EAB Chairman regularly reported the EAB’s views to the BT Group plc Board.

Other mattersThe EAB is supported by the EAO and the EAB Secretary on all matters within its remit. The EAO reports regularly to the EAB on the detailed status of BT’s delivery of the Undertakings. It carries out investigations into complaints made by CPs and into possible breaches of the Undertakings on the EAB’s behalf.

Sir Bryan Carsberg remained an independent member of the EAB until 1 August 2013 when he was replaced by Stephanie Liston, and Stephen Pettit served until 1 May when he was replaced by Edward Astle. Dr Peter Radley served as an independent external member until 30 April 2014 when he was replaced by Emin Gürdenli (see left).

How we work

CPs EAO CPs BT

Issues management Complaints Complaints & breaches

EAO monitoring report

Regular & ad hoc BT reports EAB meetings: deliberation & decisions

EAB minutes & overviews

Annual Report

Ofcom briefing

Direct CP views

EAO reviews EAB breaches process EAO assessments

Audit & Validation Plan

Product KPIs

Behavioural measures

Exemptions & variations

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6 Introduction14 Who we are

Approach to monitoring

EAO activity Application

Ongoing compliance A rolling programme testing all other non-milestone related Undertakings obligations. It also includes detailed reviews and ‘spot checks’ of areas identified through risk assessment.

Investigation of key risk areas (e.g. information sharing) through compliance spot checks and full scale reviews.

Breaches and complaints

Investigations of breaches and complaints reported to the EAB by BT and those found by the EAO, as well as complaints received from CPs via its formal complaints process.

Breaches notified by BT, as found by the EAO or complaints reported to the EAB or BT.

The EAB applies similar criteria across all of its monitoring activities:

Blue Undertaking delivered or review completed.

Green Undertaking delivery on track, or in the case of ongoing compliance, review completed with no issues identified.

Amber Undertaking is at risk, or in the case of ongoing compliance, issues identified.

Red Undertaking date has been missed or is in jeopardy, or review has identified major deficiencies or issues.

The EAO Director makes the decision to move the delivery status from Green to Blue before reporting the outcome to the EAB. This applies to both the delivery of milestones and the completion of ongoing compliance reviews. As part of its assurance opinion, PricewaterhouseCoopers LLP (PwC) assesses the EAB’s work across all of these monitoring areas. Those activities referred to in its assurance opinion are marked by throughout the report.

Breaches, complaints and issuesThe EAB considers whether complaints or issues raised by CPs, BT or its own investigations expose breaches of the Undertakings and, if so, whether any breach is trivial or non-trivial. In assessing materiality the EAB will consider all factors including:

• Impact on non-BT CPs• Intent• Duration• Frequency• Seniority of management involved• Repeat offences

The EAB may also agree to cases not being investigated fully where it would be disproportionate to do so, typically where an event is very minor and has no effect.

Matters are also raised informally by key stakeholders including BT, non-BT CPs, Ofcom and the OTA2 as part of our ‘Quick Checks’ process.

Monitoring, reporting and advisingThe EAB monitors BT’s delivery of key Undertakings, reports on progress to Ofcom and industry and offers advice to BT on its compliance with the Undertakings.

MonitoringThe EAB conducts a wide range of monitoring activities to assess BT’s compliance with the Undertakings. On the EAB’s behalf, the EAO monitors BT’s delivery of the milestones listed in the Undertakings.

The EAO also assesses BT’s ongoing compliance with obligations from previous years. It runs an Audit and Validation plan through which it audits BT’s ongoing compliance with specific sections of the Undertakings on a rolling basis.

The EAB also agrees a programme of ongoing compliance reviews based on areas of known or potential risk. In devising the programme, the EAB considers common themes arising from breach cases or issues identified during the EAO’s monitoring work. The EAB also takes account of the findings of relevant internal and external audit reports that have assessed BT’s delivery of the Undertakings, as well as issues raised by stakeholders.

The EAB’s monitoring methodologies are included in the table below:

Approach to monitoring

EAO activity Application

Milestone-based Full scale product validations examining delivery by set timescales. Also covers products due by dates amended by exemptions and variations to the Undertakings.

Current generation products, e.g. WLR3, LLU.

Principle-based Regular monitoring of agreed areas of focus through attendance at working groups and meetings with key stakeholders. Also includes product validations with launch dates at BT’s discretion.

NGN and NGA.

Regular compliance Monthly, quarterly or annually recurring reviews of areas mandated by the Undertakings.

Product KPIs, behavioural monitoring, systems access (e.g. the new obligations in relation to systems).

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The process allows us to record and track issues and assess rapidly whether they need more detailed, formal investigation, for example, through the breaches process.

ReportingThe EAB is required by the Undertakings to conduct an annual review of BT’s compliance with the Undertakings, and upon completion send a report to Ofcom. It is also required to publish a summary report which is to be made available on BT’s website. Currently, the EAB aggregates all of its findings into one report and publishes it alongside the BT Group plc Annual Report.

The EAB is required to report on areas including its views on the governance of the Undertakings, BT’s delivery of major milestones, potential future breaches and the findings of the product KPIs.

The EAB also publishes a regular update about its activities on its website www.bt.com/eab

AdvisingThe EAB advises BT on areas where it needs to improve its compliance with the Undertakings. During 2013/14 we made recommendations to BT on topics such as systems compliance, the Openreach SoR process and end-to-end working.

Stakeholder engagementWe have three sets of stakeholders in the UK: CPs and industry associations, Ofcom and BT.

During 2013/14 the EAB heard the views of industry stakeholders at its meetings and it paid close attention to the output from the EAO’s Quick Checks process. It also heard regularly from the Office of the Telecommunications Adjudicator. The EAO continued to hold meetings with CPs and industry associations as well as attending the Connectivity Services and Copper forum and NGA working groups. The EAO also continued to maintain engagement with CPs in Northern Ireland by attending the Northern Ireland Telecom Stakeholder Forum.

We hold regular meetings with Ofcom. We met members of the Ofcom Board to discuss the 2013 Annual Report in May 2013. An Ofcom Board member attended an EAB meeting in February 2014 and the EAO has monthly meetings with Ofcom policy directors. The EAO has also met the OTA2 regularly to discuss progress and the CEO of the OTA2 attended EAB meetings in July 2013 and February 2014.

The EAB met a range of BT stakeholders during 2014. This included the BT Group Chief Executive and the Group Director, Strategy, Policy and Portfolio. We also received presentations from BT regarding the systems separation obligations in July and November 2013.

Our view on our governance and resourcingThe Undertakings require the EAB to give a view on how well its governance arrangements are functioning and whether it is satisfied with the level of resourcing available.

The EAB has done an externally-facilitated self-assessment of its own effectiveness, the results of which will be reported to the July EAB meeting and included in next year’s report. This is a more extensive assessment than previously, involving individual interviews with members as well as online surveys. Having an external company conduct the surveys and interviews and producing a report introduces an additional degree of rigour and analysis.

The EAB considered a paper at its April meeting on the EAO’s activities for the next year and approved the current resourcing.

Wider governance of the UndertakingsBT has a company-wide responsibility to deliver its Undertakings commitments. The EAB engages with each of BT’s lines of business to monitor compliance with the Undertakings and is required to assess the effectiveness of the governance framework that BT has put in place to support the Undertakings.

Openreach does not report to BT’s Operating Committee to support functional separation of the organisation from the rest of the company. BT’s governance structure to support the delivery of the Undertakings has continued to evolve over the past seven years. During 2013/14 it consisted of:

• The Enterprise Programme Steering Board (PSB): this forum is the most senior governance body within the programme and has a group-wide responsibility for setting policy and direction, managing priorities, resolving risks and issues and ensuring consistency across BT’s business units.

• Workstream Execution Boards: the programme is divided into two key workstreams: UK Business development and UKB Migrations, each of which has its own lead who is responsible for the governance of a portfolio of projects via their own Execution Boards.

• The Undertakings programme: consists of an Undertakings representative in each line of business – monitors progress, plans and issues through a weekly tracking meeting with the leadership team within BT TSO to ensure that any major delivery issues are resolved.

• Breach Review Group: consists of Undertakings and legal representatives across the business and assesses the status of potential breaches.

The Undertakings programme reports into the BT Design Council on a regular basis. It also reports monthly to a meeting of the Chief Executive Officers of two of BT’s lines of business: BT Business and BT TSO.

BT has a responsibility to ensure that its employees have the necessary tools and training to comply with the Undertakings. The company issued a Code of Practice to BT employees in the UK in December 2005. This was updated and re-launched in March 2008, December 2012 and again, to reflect internal reorganisations, in late 2013.

E-learning courses, based on the revised Code, were updated at the end of 2013. These are designed to ensure that BT people are familiar with the Undertakings and their associated responsibilities.

The EAB and BT’s governance frameworkThe EAB conducts reviews of different aspects of BT’s governance of the Undertakings on a year-on-year basis.

As part of our regular monitoring of Next Generation Access the EAO has attended the NGA Trialist Working Group, the NGA Business user forum and Ethernet and Copper Product and Commercial Group meetings to assess if Openreach engagement with industry is operating effectively. We also attend Ofcom’s systems roadmap sessions.

Openreach continues to present its annual operating plan to us on an annual basis.

We noticed in 2013 that we had not received notice of any calls about Undertakings compliance matters to BT’s employee Confidential Hotline. We asked BT to investigate whether there are any particular reasons this should be the case and none were found. At that time, separately, at our suggestion, BT issued a notice to all staff reminding them how to report breaches of the Undertakings. We have reviewed this again with BT and been advised that further briefings have been issued. A number of other, non-confidential, routes are available and promoted for BT people to report Undertakings concerns to BT’s Regulatory Compliance team and there is evidence that these are used in preference to the Confidential Hotline.

Our view on BT’s governance of the UndertakingsThe EAB has considered the effectiveness of BT’s governance framework by looking at factors including the measures in place to detect breaches and address potential breaches and the reporting mechanisms in place to give updates on the Undertakings. We are satisfied that the company has a suitable governance framework in place. We recommend that BT ensures that the Undertakings are fully supported in terms of adequate numbers of compliance officers and ongoing employee engagement.

705349.indb 15 19/05/2014 11:30

6 Introduction16 Undertakings status indicators

The focus of the EAB’s work is increasingly on monitoring BT’s compliance with the behavioural aspects of the Undertakings now that the dated milestones have been delivered. This section includes a report on BT’s Undertakings training, the performance of the Openreach and BT Wholesale Statement of Requirements processes and details of Undertakings related complaints BT has received during the year. Code of Practice and TrainingBT updated its Code of Practice in 2013 and revised the associated mandatory training. The percentage of staff completing the training remains an indicator of BT’s continued commitment to, and knowledge of, the Undertakings.

Subm

itted

1st R

espo

nse

Stag

e

Initi

al Off

er(W

D35/

60)

Stag

e

In D

evel

opm

ent

Stag

e

Deliv

ered

Canc

elle

d

Reje

cted

April 2013 – March 2014Openreach SoR process

0

2

4

6

8

10

12

14

16

BT CP Non-BT CP

1410

5

6

5

7

103

4

5 5

62

5

The EAB is responsible for oversight of the Openreach SoR process. It discharges this through regular monitoring of performance, attendance at the Ethernet industry forum and through monthly calls with Ofcom, the OTA2 and Openreach.

The EAO recommended improvements in transparency by Openreach and, following comments we made in last year’s report, specifically proposed a dedicated session to consider SoRs at the Ethernet Product and Commercial Group. This suggestion has been adopted. The increased transparency and industry engagement has ensured that all SoRs have been openly discussed. The process has also enabled realisation that Openreach prioritises SoRs on the basis of potential commercial return and that, as a result, some SoRs will not necessarily be taken forward. The openness of the discussion around this has led to benefits being considered in a co-operative manner and, in our view, greater understanding for both industry and Openreach.

The EAO regularly attends the NGA Working Group and has gained assurance from Openreach that all new NGA requirements now follow the SoR process.

Overall, although satisfied that BT and Openreach are committed to running equivalent SoR processes, the EAB remains concerned about the Openreach SoR process throughput and delivery rate, particularly for new Ethernet requirements. We will continue to listen to industry feedback on the performance of the SoR process on a regular basis.


Chart as positional only

Pan

BT

BT G

loba

lSe

rvice

s

BT C

onsu

mer

&

Busin

ess

BT TS

O

BT W

hole

sale

BT G

roup

Open

reac

h

Percentage

Manager and team member Undertakings training completion

60

65

70

75

80

85

90

95

100

Manager completions Non-manager completions

705349.indb 16 19/05/2014 11:30


Unde

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ings

stat

us in

dica

tors

Received Pending Rejected Accepted Delivered

April 2013 – March 2014BT Wholesale SoR process

0

5

10

15

20

25

30

BT CP Non-BT CP

2626

03

13

18

5

1

8

4

The chart shows SoRs were delivered for a number of non-BT CPs while fewer were delivered for BT CPs. However the EAB is satisfied that this process is operating equivalently and without issues.

Complaints to BT As in previous years, the EAB continued to receive regular reports from BT of any complaints it received from CPs relating to the Undertakings. BT received 14 complaints to the end of March 2014, which is the same as the previous year. The chart below shows the complaint themes which were most common. The EAO reviews these cases regularly with BT and requests further information on the details of the case where there may be compliance concerns.

9Equivalence

4Undertakings (general)

1Information sharing

A more detailed description of a sample of the complaints received by BT and notified to the EAO follows below, arranged by theme.

Equivalence• A query was received from a CP about orders that were placed by

them and BT Retail on the same day, but BT Retail had a significantly earlier completion date. An investigation identified that the order placed by BT Retail (after the non-BT CP order) was for a working line takeover at the end-user’s new home and the non-BT CP’s order had been for a new provision. These order types have different lead times as they require different activities to be completed. The CP was informed and was content that they now understood why it had looked like there had been non-equivalent activity, but in fact that no equivalence issues were found.

• A complaint was received from a CP that a third-party integrator working on their behalf advised that they did not receive notification from Openreach that an end-user was moving to a new CP. Records for migrations are only kept for a limited time, due to the volume of transactions that are processed and by the time the CP raised the complaint the records had been removed from the Openreach systems. This meant that it was not possible to establish the actual sequence of events.

• In one case, a CP asked for an order to be investigated because BT Retail appeared to have installed a line at short notice when the CP experienced a delay. Investigation showed that the BT order was installed following a delay caused by a fault in the line plant whereas the CP had made and then postponed further appointments.

• A CP who is account managed by BT Wholesale complained that an escalation by their end-user, made via a contact in BT Group, caused BT to bring forward the delivery date of a circuit order. The CP was concerned that bypassing them had allowed the end-user to receive an improved service. An investigation established that the correct escalation process was not followed in this case but that little difference had been made to the delivery date.

• In another case, a CP alleged that by approaching a person in a BT Group central function they were able to escalate a new provision of service. Upon investigation it transpired that, whilst the person from BT did send a request into Openreach, they were advised that the CP should follow the correct procedure to escalate a problem.

• A CP alleged that, in an area where some street cabinets were fibre enabled and some were not, BT Business was able to select which cabinet should serve an end-user. The issue was investigated and it was found that the end-user’s premises comprised a number of buildings which are served by two cabinets. Openreach policy is to provide service from the nearest cabinet. In this case the records confirm that Openreach has complied with this policy and that a CP is not able to choose which cabinet provides service.

• A complaint was received by BT from a CP claiming that BT is transferring assets onto the legacy platform to offer services which are not equivalent. After investigation it was found that the services to which the CP referred are available on an equivalent basis from Openreach.

• Another CP alleged that a cease order was raised by BT Retail on one of the CP’s lines causing a loss of service to the end-user. The complaint was investigated and it was found to be correct. The cessation resulted from a rare combination of system software and records management issues which meant that the normal notification processes were not triggered.

• A customer has complained that an engineer informed him that a specific CP’s service is very poor in their locality because the CP is working from a BT exchange and cannot guarantee continuous internet service as BT customers receive priority. No action was taken as the customer was unwilling to share further information.

Information sharingA CP alleged that BT Wholesale shared information with BT Retail and that this has led to direct marketing to their end-user. BT Retail provided evidence of a pre-existing relationship with the end-user and that a subsequent provision of service by BT followed from contact initiated by the customer.

Undertakings (general)A complaint was received from an Internet Service Provider alleging that a BT advisor gave an end-user information about BT Wholesale charging policy in respect of fibre moves and cessations. An investigation found that this was not the case.

705349.indb 17 19/05/2014 11:30


Product KPIsThe EAB assesses key performance indicators (KPIs) published by BT showing the performance of BT’s EoI products. The KPI charts for each product portfolio compare service provided to CPs within BT to that for non-BT CPs.

The KPIs are shown as line charts with one line representing the product performance experienced by BT CPs and the other the performance experienced by non-BT CPs. If the two lines are consistently different it may indicate that there is an equivalence issue. However, there are several factors that can cause differing performance and these do not necessarily constitute a breach of the Undertakings. Tests are also applied to assess whether any difference is statistically significant. These factors are explained on a product-by-product basis below for selected KPIs.

OpenreachWLR3 analogue provisionDuring the year, WLR3 analogue provision performance has remained broadly similar for BT CPs and non-BT CPs. The WLR3 analogue provision KPI metric comprises the sub-order types New Provides, Migrations and Transfers, which each have different average times to process and are ordered in different volumes by BT CPs and non-BT CPs. This sub-order type and order volume mix can cause performance chart differences. Extensive analysis by the EAB has concluded that there are no indications of failures of compliance with the Undertakings.

WLR3 analogue provision

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

WLR3 analogue repair WLR3 analogue repair performance appears to have generally favoured BT CPs during the year. Whilst continued EAB analysis highlighted no significant equivalence concerns once the different service levels that CPs chose to order were taken into account, the EAB did note that service performance has declined for both BT CPs and non-BT CPs.

WLR3 analogue repair

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3

Percentage of faults repaired on time

60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

LLU SMPF provision (basic provide)Performance appears to have favoured non-BT CPs for parts of the year. Our analysis shows that the mix of order types, including the use of the more complex “simultaneous provide” sub-product, affects the performance chart. We found no indications of failures of Undertakings compliance in this area.

LLU SMPF provision

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

705349.indb 18 19/05/2014 11:30


Unde

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stat

us in

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LLU MPF provisionThe provision performance for MPF appears generally to have favoured non-BT CPs throughout the year. A very high percentage of BT CP orders are ‘multiple orders’ whereas nearly all non-BT CPs’ orders are ‘single orders’. This means that when a BT CP order fails it often results in a multiple customer order failure, whereas non-BT CP orders that fail usually affect only one customer order: this means that the performance chart gives a misleading impression. Following analysis, the EAB have found no indications of failures of compliance with the Undertakings with this product. There are too few BT CP repairs in MPF to make a valid comparison.

LLU MPF provision

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

Ethernet Access Direct provision Ethernet Access Direct (EAD) provision performance appears to have favoured BT CPs throughout the year. The EAB found that the way different CPs required separate order types and order dates to be managed affected performance, together with Openreach use of the ‘deemed consent’ process. When the absolute cycle times for orders are compared (thereby excluding the impact of deemed consent), the skew of the performance statistics towards BT CPs disappears.

There were however also process inconsistencies around ‘deemed consent’ which Openreach is working through, although these have not, to date, been found to be non-compliant. In addition, BT CPs purchased a high volume of the ‘project managed service’ product with some of its orders. The use of project services removes some of the reasons for order failure and this has had the effect of improving BT CP performance. The project managed service is available from Openreach to all CPs on an equivalent basis under its “Project Services” contract. Extensive investigation and analysis by the EAB during the year concluded that there are no significant indications of failures regarding compliance with the Undertakings. Investigation and analysis will continue however during the coming year to maintain assurance. The EAB noted that while service performance improved during the first part of the year, for both BT and non-BT CPs, performance declined during the latter part of the year.

Ethernet Access Direct provision

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

Generic Ethernet Access provision GEA over fibre-to-the-cabinet provision performance has generally favoured BT CPs for most of the year. The performance metric comprises a mix of sub-order types which each have different average times to process. The simultaneous provide sub-order type, which involves the provision of a voice and broadband service at the same time, is ordered in different volumes by different CPs which influences the performance chart. Use by CPs of the SIM2 process, a variation of the simultaneous provide ordering process which incorporates a single Openreach engineering visit, also affects the performance chart. The EAB sees no indications of failures of equivalence and will continue to monitor GEA provision carefully during the coming year.

Generic Ethernet Access provision

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

705349.indb 19 19/05/2014 11:30


BT WholesaleIPstream Connect provisionIPstream Connect provision performance has been broadly similar except in the latter part of the year where it favoured BT CPs. The EAB has found that the Simultaneous Provide order type (where the copper line and the IPstream broadband service are provisioned at the same time) impacted on the overall result. Simultaneous Provides are generally more complicated than standard orders and therefore have a lower provision success rate than other order types. BT CPs have historically consumed a higher amount of Simultaneous provide orders than non-BT CPs but this trend reversed in the latter part of the year. The EAB found no indications of failures of compliance with the Undertakings in this area.

IPstream Connect provision

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

IPstream Connect repairIPstream Connect repair performance appears generally to have favoured BT CPs during the year. BT CPs chose to use the Openreach Broadband Boost diagnostic tool more heavily than non-BT CPs who generally use the BT Wholesale Special Fault Investigation tool, although non-BT CPs generally used diagnostic tools less heavily than BT CPs. This means that the more complex BT CP faults are not captured in the BT Wholesale repair performance figures, which is the reason the charts show performance as favouring BT CPs. Analysis by the EAB concluded that there are no indications of failures of compliance with the Undertakings. The EAB is currently investigating the BT CP drop in performance during March.

IPstream Connect repair

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

IPstream Connect migrationsThe EAB has found that IPstream Connect migration performance has been generally equivalent throughout the year.

IPstream Connect migrations

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3

Percentage of migrations successfully completed

60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

Wholesale Broadband Connect provisionOfcom removed regulatory obligations for WBC in the competitive Market 3 during 2008, therefore the EAB monitors WBC in the regulated Markets 1 and 2. During the year performance appears generally to have favoured non-BT CPs and, as with the IPstream connect product, the EAB has identified that the Simultaneous Provide order type, which is complex and has a lower target timescales success rate than other order types, affected the performance chart. BT CPs raised a higher percentage of Simultaneous Provide orders than non-BT CPs and analysis has shown that when this order type is excluded performance is equivalent.

Wholesale Broadband Connect provision

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

Wholesale Broadband Connect repairPerformance appears generally to have favoured BT CPs throughout the year. As with IPstream repair, analysis has indicated that this is mainly due to a gradual change in the way that the BT Wholesale SFI (Special Fault Investigation) and Openreach Broadband Boost diagnostic tools are being used by CPs. Non-BT CPs choose to carry out preliminary diagnostics rather than report all faults directly to BT Wholesale, while BT CPs report all faults directly to BT Wholesale without preliminary

705349.indb 20 19/05/2014 11:30


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diagnostics, which has the effect of skewing the repair performance chart to favour BT CPs. EAB analysis has indicated no equivalence failings. The EAB noted that repair performance generally deteriorated during the year for both BT CPs and non-BT CPs.

Wholesale Broadband Connect repair

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3


60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

Wholesale Broadband Connect migrationsPerformance has generally remained broadly similar for BT CPs and non-BT CPs during the year. Analysis indicated that performance was impacted by BT CP preference to use the bulk migration process, where multiple orders are migrated one exchange building at a time, resulting in high volume completions and an associated high success rate. Non-BT CPs have the option to use the bulk process but generally prefer to use a singleton migration process. A major project to migrate non-BT CP orders onto the Wholesale Broadband Connect platform affected performance during September and October. The EAO gained assurance that BT CP and non-BT CP performance was equivalent.

Wholesale Broadband Connect migrations

Apr 1

3

May

13

Jun

13

Mar

14

Feb

14

Jan

14

Dec 1

3

Nov 1

3

Oct 1

3

Sep

13

Aug

13

Jul 1

3

Percentage of orders migrated on time

60

65

70

75

80

85

90

95

100

Non-BT CPs BT CPs

Comparative Performance ChartsIn addition to the main product KPIs, the EAB also publishes its opinion on Comparative Performance Charts (CPCs) provided by BT to the EAO. These are independent of the product KPIs and give a view on whether or not BT has an incentive to delay migration to EoI products because of the relative performance of classic products and their EoI successors.

They were instituted in 2009 to address industry concerns following agreement of the OSS variation.

Provision and repair metrics are reviewed for analogue PSTN, ISDN2 and ISDN30 products.

For provision the metrics are:

• Time to install• Early life failures

For repair the metrics are:

• Time to clear faults• Repeat repairs required to clear faults

The EAB’s analysis of the CPC metrics from April 2013 to March 2014 is set out in the table below.

CPC Commentary

Analogue provision The performance levels through the year indicated a potential incentive from an ‘install time’ perspective and a potential disincentive from an ‘early life failure’ perspective to migrating all new analogue telephony provisions to the EoI product. This mixed picture means that it is unlikely for there to be a significant impact on BT’s behaviour.

Analogue repair There appears to be a potential incentive regarding repeat faults and from an overall repair performance perspective to encourage BT to migrate to the analogue EoI product.

ISDN2 provision Performance levels for both provision metrics show no incentive for BT to delay migration to the EoI version.

ISDN2 repair There generally appears to have been a potential incentive regarding repair timescales and potential disincentive from a repeat faults perspective to encourage BT to migrate to the ISDN2 EoI product. This mixed picture means that it is unlikely for there to be a significant impact on BT’s behaviour.

ISDN30 provision Transaction volumes are very low and, while the charts indicate that there is a potential disincentive to ensure all ISDN30 provisions for all end users are processed on EoI systems, it is unlikely for there to be a significant impact on BT’s behaviour.

ISDN30 repair For the majority of the year there has been a potential incentive regarding repair timescales and a potential disincentive from a repeat faults perspective to encourage BT to migrate to an ISDN30 EoI product. This mixed picture means that it is unlikely for there to be a significant impact on BT’s behaviour.

The EAB did not find there to be any clear and consistent incentive for BT to delay migration based on the relative performance of the products. In most cases there was either a mixed picture or no disincentive. For example, the EoI alternative would perform better in one metric but worse in the other metric or both metrics favoured the EoI product. In some cases the CPCs indicated there would be a benefit in a particular metric, generally this is offset by disadvantage in another metric.

On this basis the EAB can provide some reassurance to Ofcom that the metrics it specified indicate that BT is not gaining a clear advantage compared to non-BT CPs by remaining on non-EoI products and systems longer than originally planned.

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BT’s delivery of key milestones to date This table lists our view of the status of all the key Undertakings that were due to be delivered up to 31 March 2014, including those delivered in previous years. The key gives an explanation of the different terms used in the table.


Achieved Not achieved Removed Assurance Concerns On track Replaced

Monitoring the delivery of major productsThe EAB monitors the delivery of major EoI products covered by the Undertakings. Many of those with set delivery dates have been delivered in previous years and the remaining WLR3 obligations were removed in 2009/10.

Undertaking Date due Milestone status Comments

IPstream EoI RFS 31 Dec 2005

Relevant Broadband service using EoI IPstream/IBMC 31 Dec 2006

LLU EoI RFS 30 Jun 2006 Non-trivial breach resulting; BT paid allowances to CPs. The EAB confirmed that the breach was remedied in December 2006.

IPstream using EoI LLU IBMC 31 Dec 2006 Non-trivial breach; BT completed delivery end of August 2007.

WES, BES, WES Backhaul and WEES EoI RFS 30 Sep 2006

Relevant Retail Ethernet Service using EoI WES IBMC 31 Mar 2007

WLR Analogue EoI RFS (informal milestone) 31 Dec 2006 BT paid allowances to CPs.

WLR Analogue EoI RFS 30 Jun 2007

WLR Analogue IBMC 30% target 30 Jun 2008 Milestone reached November 2008.

WLR Analogue IBMC 70% target 30 Jun 2009 Milestone reached September 2009.

WLR Analogue IBMC 100% 30 Jun 2010 Revised obligation included in Information Systems (IS) variation.

WLR ISDN2 EoI RFS 30 Sep 2007 Trivial beach regarding some new end-user orders.

BT’s retail ISDN2 using EoI WLR ISDN2 IBMC 31 Mar 2009 Non-trivial breach; revised obligation included in IS variation.

WLR ISDN30 EoI RFS 28 Feb 2008 (was 31 Dec 2007)

BT’s retail ISDN30 Service using EoI WLR ISDN30 IBMC 31 Dec 2009 Revised obligation included in IS variation.

IPstream Connect available for order; start of BT and CP end-user base migration

31 Oct 2008 Achieved ahead of schedule.

IPstream Connect IBMC and migration of CP end-user base

31 Mar 2009 Achieved ahead of schedule.

GEA over FTTP Not applicable Not applicable Launch review completed by EAB.

GEA over FTTC Not applicable Not applicable Pre launch review completed by EAB.

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Systems separation obligations The EAB monitors the delivery of systems separation through either full physical separation of systems, or through the implementation of user access controls. During 2009/10 there was a variation to the Undertakings that resulted in changes to the delivery dates for systems separation.

OSS separation – User access controls and physical separation


User Access Controls for WLR3, SMPF, MPF and ISDN2 30 Jun 2007 Mostly delivered by the required date, but only fully met in late September 2007 due to a trivial breach.

Operational support systems separation independent external audit of User Access Controls including ISDN2 and ISDN30

30 Jun 2008

Implement physically separate OSS for WLR manual exception tasks

31 May 2009 Non-trivial breach; milestone removed by IS variation.

Additional audit of User Access Controls 30 Jun 2010 Achieved ahead of schedule.

Implement User Access Controls for OSS listed in Annex 6

30 Jun 2010

Implement physically separate access and user access controls for BT people not listed in 5.44.6 (a)

30 Jun 2010

OSS physical separation 30 Jun 2010 Milestone removed as part of IS variation; BT now has to deliver physical separation when “reasonably practicable and proportionate”.

EAB to perform quarterly checks of access to OSS listed in Annex 6 starting in June 2010

From Jun 2010 onwards

Moved to six-monthly in agreement with Ofcom.

Migration to EoI products


At least 90% of BT’s relevant installed end-user base shall be migrated so that the products that this base purchases, that consume the Measured Products, do so on an EoI basis from Openreach

30 Jun 2010

BT to advise Ofcom of the further increased percentage migrations of both the relevant installed end-user base and BT’s Customer Side Records to be achieved by the 30 June 2014

31 Dec 2011 (latest) or six months after completion of business stack migration (if earlier)

BT has informed Ofcom of the following increased percentages: End-user base: 97%; Customer Side Records: between 92% and 94%.

At least 95% of BT’s relevant installed End-user base shall be migrated so that the products that this base purchases, that consume the Measured Products, do so on an EoI basis from Openreach

31 Dec 2012 Validated by EAB.

BT to demonstrate continued significant progress towards migration of business customers as indicated by the percentage migrations previously notified to Ofcom by 31 December 2011

30 Jun 2014 BT advised the EAB that it achieved 97% ahead of the forecast date of 30 June 2014. The EAO is currently validating the achievement.

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Customer records migration


Ready to mass migrate PSTN Customer Side Records 31 Mar 2008

50% of relevant Customer Side Records migrated to physically separate OSS

30 Nov 2008

50% of non-WLR Supply Side Records migrated to physically separate OSS

31 Jan 2010 Non-trivial breach; milestone removed by IS variation.

Ready to mass migrate Customer Side Records relating to Featureline

30 Jun 2009 Non-trivial breach; revised obligation included in IS variation.

90% of relevant Customer Side Records migrated to physically separate OSS

30 Sep 2009 Revised obligation included in IS variation.

90% of non-WLR Supply Side Records migrated to physically separate OSS

31 Jan 2010 Removed by IS variation.

90% of users migrated to physically separate OSS for WLR manual exception tasks

31 Mar 2010 Removed by IS variation.

At least 80% of BT’s Customer Side Records relating to the Measured Products held on Operational Support Systems shared between Openreach and the rest of BT are migrated to at least Level 2 System Separation

30 Jun 2010

BT to advise Ofcom of the further increased percentage migrations of both the relevant installed end-user base and BT’s Customer Side Records that it expects to be achieved by the 30 June 2014

31 Dec 2011 (latest) or six months after completion of business stack migration (if earlier)

BT has informed Ofcom of the following increased percentages that it expects to achieve: End-user base: 97%; Customer Side Records: between 92% and 94%.

Implementation and ongoing application of the obligations in relation to Customer Side Records in section 5.44.2 is subject to an audit commissioned by the EAB on an ongoing basis at least every 24 months from 30 June 2010

30 Jun 2012 (latest)

Initial audit of achievement of 80% migration milestone has been completed.

At least 90% of BT’s Customer Side Records relating to the Measured Products held on Operational Support Systems shared between Openreach and the rest of BT are migrated to at least Level 2 System Separation

31 Dec 2012 BT achieved 87.4% by the target date. This resulted in a non-trivial breach of the Undertakings. The breach was corrected and the milestone achieved in November 2013.

BT to demonstrate continued significant progress towards migration of customers to EoI products as previously forecast to Ofcom by 31 December 2011

30 Jun 2014 BT advised the EAB that it achieved 92% ahead of the forecast date of 30 June 2014. The EAO is currently validating the achievement.

UK Business Stack implementation (non-binding milestones)


Business Stack-Operational Trial Starts 30 Apr 2010

Business Stack-Initial Live Deployment 31 Dec 2010

Business Stack-Trial Migration Begun 31 Mar 2011

Business Stack-Volume Migration Begun 31 Dec 2011

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MIS and other systems separation


Management Information Systems separation 22 Oct 2006 Includes Level 1 separation for Annex 5 systems and Level 2 separation for others.

MIS roadmap 30 Jun 2007

MIS Level 2 separation 30 Jun 2010 BT did not implement Level 2 separation for all its MIS.

Non-OSS and non-MIS Level 1 separation 30 Jun 2010 Although the milestone was achieved, ongoing compliance is high risk due to the simplistic solutions adopted by BT.

NGA related Undertakings


NGA related Undertakings cease to apply to future deployments (conditional)

31 Dec 2010 The number of end-user premises capable of being served by a BT FTTC enabled cabinet has exceeded 500,000 before 31 December 2010.

BT to consult on demand for FTTC Passive Inputs and Backhaul over fibre

31 Dec 2011 Consultation completed, one industry response received.

BT and Ofcom to review NGA Undertakings 31 Dec 2011 No changes to the Undertakings.

NGA monitoring themesWe monitor six areas of compliance for NGA:

NGA theme Status Activity

Consultation and engagement – Openreach is required to consult with industry on key changes and product developments

Openreach continues to engage with industry through working groups and other bodies. New industry requirements are now progressed using the Openreach SoR process and are visible to CPs.

Products – to be designed, launched and CPs’ users migrated to the new product on an EoI basis

The EAB have identified no Undertaking concerns in this area.

Equipment and locations – to ensure that NGA solutions are not made unattractive to CPs, either because of cost or availability of equipment, space or power

We have found that all NGA developments and products use existing Openreach exchange space and power products, and there is also the option for CPs to use their own infrastructure.

Backhaul – to ensure that the NGA product does not preclude or dictate the choice of backhaul for CPs or make the product commercially unattractive because of the cost or limitations of the backhaul solution

Industry raised concerns regarding the availability of backhaul capacity from some smaller more remote BDUK related NGA sites. Openreach confirmed that where this is found to be a bottleneck, capacity will be provided as part of the Openreach infrastructure build.

Passive components – a range of requirements resulting from a variation to the Undertakings, including a requirement to consult with industry and a stipulation that Openreach should use the same components, processes and systems it uses itself for the purposes of its active product

The EAO is not aware of any industry concerns in this area.

Governance – a range of obligations including the use of statement of requirements processes on the same basis for all CPs, appropriate sharing of customer confidential and commercial information and all transactions to be carried out on an EoI basis

Generally NGA governance remains strong. New industry requirements are now progressed using the Openreach SoR process and are visible to CPs and the EAB has identified no concerns in this area.

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Respective responsibilities of the Equality of Access Board and PricewaterhouseCoopers LLP We have been engaged to express an independent opinion on selected aspects of the Equality of Access Board (“EAB”) Annual Report for the year ended 31 March 2014 (the “Report”). The preparation of the Report in accordance with the requirements of the Undertakings given to Ofcom by BT Group plc (“BT” or the “Group”) pursuant to the Enterprise Act 2002 effective 22 September 2005 (the “Undertakings”) is the sole responsibility of the EAB.

There are no generally accepted standards for reporting on compliance with the Undertakings or in respect of related performance measures. The reporting policies adopted by the EAB in forming their opinions expressed within the Report are described in the sections entitled “Monitoring Reporting and Advising” on page 14.

Scope and approach Our engagement was designed to provide assurance on:

• whether, in our opinion, the conclusions reached by the EAB in respect of each of:

– the investigation of breaches set out on pages 5 and 6; – the analysis of breaches by reporting year set out on pages 6 and 7; – the themes and results of quick checks performed in the period as set out on pages 8 and 9;

– the review of key compliance risks as set out in the table on page 9; – the key risks included in the EAB risk register as set out on page 11; and

– the Undertakings status indicators as set out on pages 22 to 25

(the “EAB Conclusions” each indicated by the symbol) are complete and consistent with the underlying management information of the Equality of Access Office (“EAO”) and are consistent with the evidence gathered by the EAO in accordance with the Reporting Policy.

In this regard, we planned our procedures to provide us with reasonable assurance on the completeness and consistency of each of the EAB Conclusions with underlying management information. We obtained an understanding of the relevant controls and procedures applied by the EAB and the EAO to generate, aggregate and evaluate information in respect of the Group’s governance, delivery and ongoing compliance with the Undertakings, including the EAO monitoring and reporting, audit and validation plan, quick checks, exemptions and variations and breaches and complaints processes. We completed tests over data consolidation and reporting in respect of each of the EAB Conclusions only and did not perform testing over the generation of data within the underlying management information systems of the Group or the sufficiency of evidence gathered by the EAO.

• whether, in our opinion, each of the Product Key Performance Indicator charts on pages 18 to 21 showing the WLR3 analogue provision, WLR3 analogue repair, LLU SMPF provision (basic provide), LLU MPF provision and repair, Ethernet Access Direct provision, Generic Ethernet Access provision and repair, IPstream Connect provision, IPstream Connect repair, IPstream Connect migrations, Wholesale Broadband Connect provision, Wholesale Broadband Connect repair and Wholesale Broadband Connect migrations is properly compiled from the underlying management information of the Group. In this regard, we planned our procedures to provide us with reasonable assurance they are properly compiled from underlying management information. We completed tests over data consolidation and reporting only and did not perform testing over the generation of data within the underlying management information systems of the Group.

In addition, we reviewed the minutes of EAB meetings, discussed with employees of the EAO the processes to collate the Report and reviewed the remainder of the Report for consistency with our knowledge of the Group in order to report whether anything came to our attention to indicate that the remainder of the Report is inconsistent with the findings of our work.

We planned and performed our evidence-gathering procedures to obtain a basis for our conclusions in accordance with the International Standard on Assurance Engagements 3000 (Revised) – “Assurance Engagements other than Audits or Reviews of Historical Information”. We have not performed an audit, and therefore do not express an audit opinion in accordance with International Standards on Auditing (UK and Ireland).

We believe that our work provides a reasonable basis for our conclusions.

Considerations and limitations The Group’s governance measures to ensure compliance with the Undertakings represent a set of internal controls and other actions designed to provide reasonable assurance regarding compliance, in all material respects, with each of the Undertakings and to support reporting of compliance with those Undertakings. Further, the EAB’s governance measures to monitor, assess and report on the Group’s compliance with the Undertakings represent a set of internal controls and other actions designed to provide reasonable assurance regarding the assessment of compliance, in all material respects, with each of the Undertakings. Because of the inherent limitations in any set of internal controls, for example the degree of judgement required in applying certain controls, internal controls may not prevent, detect or report non-compliance with the Undertakings. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may have become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Independent Assurance Report to the Equality of Access Board and Ofcom

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This report, including the conclusions, has been prepared for and only for the EAB and Ofcom for the purpose of allowing the EAB to meet its requirements under the Undertakings and for no other purpose. We do not, in giving these conclusions, accept or assume responsibility for any other purpose or to any other person to whom this report is shown or into whose hands it may come save where expressly agreed by our prior consent in writing.

ConclusionsIn our opinion:

• the conclusions reached by the EAB in respect of each of: – the investigation of breaches set out on pages 5 and 6; – the analysis of breaches by reporting year set out on pages 6 and 7; – the themes and results of quick checks performed in the period as set out on pages 8 and 9;

– the review of key compliance risks as set out in the table on page 9;

– the key risks included in the EAB risk register as set out on page 11; and

– the Undertakings status indicators as set out on pages 22 to 25

(the “EAB Conclusions” indicated by the symbol) are properly compiled from the underlying management information of the EAO and are consistent with the evidence gathered by the EAO in accordance with the Reporting Policy; and

• each of the Product Key Performance Indicator charts on pages 18 to 21 showing the WLR3 analogue provision, WLR3 analogue repair, LLU SMPF provision (basic provide), LLU MPF provision and repair, Ethernet Access Direct provision, Generic Ethernet Access provision and repair, IPstream Connect provision, IPstream Connect repair, IPstream Connect migrations, Wholesale Broadband Connect provision, Wholesale Broadband Connect repair and Wholesale Broadband Connect migrations is properly compiled from the underlying management information of the Group.

Based on the work performed, nothing has come to our attention to indicate that the remainder of the EAB Annual Report for the year ended 31 March 2014 is inconsistent with the findings of our work.

PricewaterhouseCoopers LLP Chartered Accountants London

22 May 2014

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Annex 2 Less stringent restrictions related to the Undertakings applied to BT employees

BES Backhaul Extension Service, a legacy product in the Ethernet portfolio

BT CPs BT Wholesale and BT’s downstream businesses BT Global Services, BT Consumer and BT Business (formerly BT Retail)

Business Systems Stack

A collection of inter-related systems which allow BT’s business customers to be served equivalently

BTNI BT Northern Ireland

CCI Customer Confidential Information

CDD Customer Delivery Date

CI Commercial Information

CPs Communications Providers

CPCs Comparative Performance Charts

EAB Equality of Access Board

EAD Ethernet Access Direct, a point-to-point access product in the Ethernet portfolio offering high bandwidth connectivity, linking end-user sites, CP networks and BT exchanges

EAO Equality of Access Office, the team which supports the EAB

EBD Ethernet Backhaul Direct, which provides uncontended access from an access node to a handover point

EMP Equivalence Management Platform, the strategic system underpinning the delivery of EoI products

EoI Equivalence of Inputs, which means that BT provides the same product or service to all CPs on the same timescales, terms and conditions by means of the same systems and processes

FTTC Fibre-to-the-Cabinet, an NGA technology that involves installing fibre to street cabinets and using the existing copper infrastructure from the cabinet into the home

FTTP Fibre-to-the-Premises, an NGA technology that involves installing fibre into homes or premises as an overlay of the copper local loop

GEA Generic Ethernet Access, a product enabling broadband connections over Next Generation Access

IBMC Installed Base Migration Complete, which is the date by which the migration of all of the relevant BT installed customer base to the EoI product or platform is completed

IPstream Connect product supplied by BT Wholesale to enable BT CPs and non-BT CPs to offer broadband services to end-users

ISDN/ ISDN2/ISDN30

Integrated Services Digital Network, a technology allowing voice, internet and video to be delivered via the same dedicated line

KPI Key Performance Indicator

LLU Local Loop Unbundling, the process by which CPs can rent the copper lines between BT’s exchanges and customer premises from Openreach to provide voice and broadband services using their own equipment

MIS Management Information Systems

MPF Metallic Path Facility, a circuit comprising a pair of twisted metal wires between an end-user’s premises and a main distribution frame

NGA Next Generation Access

Non-BT CPs Communications Providers external to BT

OICs Openreach Industry Commitments, a voluntary range of obligations in return for the 2009 variation to the Undertakings

OSS Operational Support Systems

OTA2 Office of the Telecommunications Adjudicator

Passive inputs Products that allow greater access to the underlying infrastructure on BT’s Next Generation Access network with no use of electronics/power

PwC PricewaterhouseCoopers LLP

RFS Ready for Service, which is the date by which an EoI product or service is available for use by other CPs for their new end-users

SMP Significant Market Power

SMPF Shared Metallic Path Facility, access to the non-voiceband frequencies of the Metallic Path Facility

SoR Statement of Requirements, the process by which CPs submit their product requirements to BT

WBC Wholesale Broadband Connect, a next generation copper broadband product

WECLA Western, Eastern and Central London Area

WES Wholesale Extension Service, a legacy product in the Ethernet portfolio

WEES Wholesale End-to-End Service, a legacy product in the Ethernet portfolio

WLR Wholesale Line Rental, a product supplied by Openreach which is used by CPs to offer telephony services using their own brand, pricing structure and billing, but using BT's network

WLR3 An EoI version of Wholesale Line Rental

Glossary

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Documents

EQUALITY OF ACCESS BOARD BT Group plc · BT Group plc is a public limited company registered in England and Wales. This is the EAB Annual Report for the period ended 31 March 2014