REPUBLIC OF IRAQ COMMUNICATIONS AND MEDIA COMMISSION

Transcription

1 REPUBLIC OF IRAQ COMMUNICATIONS AND MEDIA COMMISSION PROPOSED REGULATION FOR LICENSING SATELLITE COMMUNICATIONS STATIONS (VSAT) August 30 th, 2010

2 1 INTRODUCTION Telecommunications plays a critical role in Iraq s economy, in supporting many of the state s development plans and providing services for many industries. The CMC is committed to opening up the telecommunications market, enabling opportunities, encouraging investment and liberalizing communications network and service provision choice for consumers - choice that efficiently and effectively supports their business performance requirements and budgets. VSAT is a wireless, satellite-based system that can support organizations, businesses and other groups, with dispersed offices and remote sites to have internal communications (voice and data) connectivity. It can enable a range of communications purposes and services including the flowing indicative list: i. Broadband Internet ii. National and multi-national networks iii. Broadband data communications iv. Multicast data services v. PSTN infrastructure extension vi. Mobile Operator's backhaul vii. Intergovernmental communications viii. Corporate communications, including inter-office or site (e.g., oil platforms, manufacturing locations) ix. Logistics data x. Traffic data delivery xi. Sales monitoring and stock control xii. Point-of-sale electronic funds Transfer xiii. Bank transactions and ATM (Automated Teller Machine) services xiv. Travel reservation systems xv. Real-time market information xvi. News gathering and distribution xvii. Video monitoring xviii. Telemedicine and medical data transfer xix. Disaster relief support xx. Distance learning xxi. Rural telecommunications There exist more than 350 VSAT operators around the world, with a few global operators providing global coverage and access to teleports with fiber connectivity to all continents. Market trends point to a growing VSAT market both globally and regionally, with Time Division Multiple Access (TDMA) as the predominant technology platform in many industries, and Single Channel Per Carrier (SCPC) remaining used for critical and redundant trunks within enterprise networks. Page 2 of 17

3 The Quality of Service delivered by VSAT operators' results from the performance of delivered and installed VSAT systems, the availability of the satellite link, the guaranteed level of operational maintenance and expertise, and the ability of the VSAT operator to translate connectivity requirements into a solution best adapted to customers expectations. Many Iraq-based users report that the QoS is restricted or poor. SCPC links are the satellite equivalent of a terrestrial leased line connection and enable Dedicated Bandwidth services. The trend regarding SCPC in Iraq is in contrast to global and regional markets where in Iraq the TDMA technology platform followed by DAMA (Demand Assigned Multiple Access) are most commonly used. TDMA VSAT networks use a hub station and small VSAT antennas in a set up in which channels are shared across users. TDMA enables services such as Managed Networks and Internet Access services. DAMA on the other hand is the satellite equivalent of a terrestrial dial-up connection and enables services such as On-Demand Bandwidth. Nevertheless, to support growth and overall development, it is in the country s best interest to attract long-term and experienced providers. Iraq s immediate VSAT requirements for the next 2 to 3 years would be best served by investors that have the know-how and capabilities, enabled by a supportive regulatory environment, to rapidly tap the unfulfilled demand and bring new capabilities to the market. 2 DEFINITIONS I. For the purpose of the VSAT License, the following terms shall have the meanings ascribed hereto: A. Licensee refers to a person, firm, limited liability partnership or corporation who is licensed to install and operate VSAT facilities for corporate communication Traffic. B. Corporate Communication refers to communication between the following entities: i. Holding companies and their subsidiaries; ii. Related companies; and iii. Corporations which have established business relationships with one another. C. The terms Holding companies, Subsidiaries and Related companies shall have the meanings of ownership and other relationship as part of a consortium or partnership. a. With regard to section B-i, a corporation which does not have any shareholding interest in another corporation shall nonetheless be deemed to have an established relationship with that other corporation if there is an existing business relationship established through a consistent course of dealings between the two corporations. b. Such relationships would include, but not be limited to customer, supplier or distributor relationships. CMC would also allow VSAT links to be established between entities for reasons other than for commercial purposes (e.g. Research & Development) provided that the applicant can prove that: c. It has the intention of establishing a relationship with the other party for a reasonable period of time; Page 3 of 17

4 II. The VSAT link is necessary to meet the applicant s specific communication requirement; and III. The VSAT link will be used for the carriage of the applicant s own Traffic and not for communication between third parties; and IV. The VSAT link will not be used for the carriage of traffic that will be sold commercially to any party. 3 CURRENT STATUS IN IRAQ Since 2003 many companies have setup VSAT service to offer VoIP to customers and plug the gap of lack of telecommunications services. Currently there are large numbers of VSAT operators offering internet service to the public. This is in contrast to the mode of operation adopted by many countries where VSATs manly cater for internal company communications and are prohibited from offering commercial services to the public. provision of telecommunications and internet services to the public in return for a direct or indirect fee, whether the services are provided to all the public or a segment thereof, including the resale of telecommunications services obtained from another person, even if only one person benefits from such a service should be prohibited. The CMC intends to issue regulations to license VSAT use to private companies and corporations for their internal use. The licenses will also prohibit VSAT licensees to: i. Own or operate a telecommunications network used for the provision of telecommunications services to or for the public in return for a direct or indirect fee; ii. Own or operate any other telecommunications network. 4 INTERNATIONAL PRACTICES There are typically four types of services for which VSAT is used, which CMC categorizes for the present purposes as follows: National Reach; National Backhaul; International Gateway; and Private Network. iii. National Reach is the provision of electronic communications to different parts of a country in conditions in which it is not feasible to do so by fiber and possibly as a preferred alternative to microwave connections. Some service providers (to date, typically data providers) use VSAT as their primary network to provide national connectivity. This practice is common in emerging markets, where Internet and other data communications are the most common services, the use of technology neutral licenses by regulatory authorities is facilitating VSAT as a means to enable fixed voice communications. iv. National Backhaul can be provided by VSAT, and this can be attractive for covering distances where fiber and microwaves are not feasible. It can also be a quick fix solution for new entrants seeking a quick entry into the marketplace while their permanent network gets rolled-out. v. International Gateway supported through VSAT. Page 4 of 17

5 vi. Corporate Private Network is one of the more common uses of VSAT, whereby a company connects its offices, subsidiaries and franchises across a country (and in some cases, internationally) for internal communications by way of a VSAT connection. typically this communication is limited to data-oriented for closed user groups only. 5 SCOPE OF LICENSE Companies that wish to establish VSAT networks and links for their own use need to apply for a VSAT License. The License will allow the Licensee to use VSAT networks for Corporate Communication between holding companies and subsidiaries; between related companies; and between companies that have established business relationships with one another only. I. The VSAT Licensees shall: A. Maintain and operate a system comprising a VSAT satellite dish, the VSAT station and associated equipment as authorized in writing by the CMC. B. Install and operate the VSAT dish and associated equipment from the VSAT's endusers premises in Iraq. C. Be responsible for purchasing their own space segments from any Internationally approved satellite operators or Facilities-Based Operator licensed by CMC to provide space segment capacities. II. The VSAT Licensees shall have the following service provision rights: A. The VSAT links must be used for conveyance of the Licensee s own traffic only and not that between third parties. B. Closed User Group telecommunications service provision on a commercial basis for operators holding licenses from the CMC to provide telecommunications services. C. Offering International switched voice Gateway communications or Internet Gateway using VoIP or any form of voice transmission over packet switched data on commercial basis to the public is prohibited as this is the exclusively authorized to the Iraqi Telecom and Postal Company (ITPC). D. VSAT may be used for Call Centre business within Iraq under specific conditions. E. VSAT networks must be owned and operated by the private corporations/ companies for their own internal and corporate communication. III. The VSAT Licensees shall not be allowed to undertake the following: A. Public Telecommunications Services (data, switched circuit voice or Voice over IP). B. International gateway for non-closed User Groups or for any third party entity offering any form of Public Telecommunications Services. C. Interconnection with public telecommunications networks (fixed or mobile) at both ends. Page 5 of 17

6 D. No third party traffic shall be carried on the licensed VSAT network. Shared use of satellite bandwidth by VSAT licensees is prohibited. E. Different licensees may not share the use of a VSAT dish; each individual licensee must gain access via different dish and different space segments as well as separate cabling to and from the VSAT equipment. F. The transmission of publicly subscribed satellite television and/or sound broadcast signals through the VSAT system are prohibited. 5.1 Classes of VSAT Licenses i. Internet Service Provider The Licensee may sell or distribute internet and data services to its subscribers whether directly or indirectly. This is a non exclusive license and there shall be no limit set for the number of licenses issued under this class of license.. ii. Telecommunications Provider Telecommunications Operators licensed directly by the CMC to offer telecommunications services in Iraq, whether nationally or regionally. This is a non exclusive license and there shall be no limit set for the number of licenses issued under this class of license. iii. Private Corporations Private companies and corporations meeting the license requirements and qualifications set by the CMC in this document. The use of this class of license will be for the exclusive use of the company's internal use and to connect the centers of the company whether inside or outside Iraq. This is a non exclusive license and there shall be no limit set for the number of licenses issued under this class of license. iv. Call Centers Call Centers operating within Iraq and meeting the license qualifications stated in this license. This is a non exclusive license and there shall be no limit set for the number of licenses issued under this class of license. v. Iraqi Telecom and Post Company (ITPC) Special License to operate International Voice (Switched and Internet) gateway services. Conditional that such license shall be managed directly and solely by the ITPC. It is not permitted that this license to be transferred, sold, or sublicensed in whole or in part to any individual company, contractor or subcontractor of any kind without the express permission of the CMC. vi. Individual TV reception only Individual VSAT licenses for TV reception only may be issued to household upon completion of the online application form and registration at the CMC website. TV Reception only licenses are not allowed to transmit data or internet of any kind and may not install transmission equipment in their VSAT equipment. 5.2 Special VSAT licenses I. The CMC may, at its own discretion issue VSAT licenses for Call Centre business within the republic of Iraq under the following conditions. i. The VSAT traffic may be bidirectional; ii. The Call Centre must be certified by the Iraq National Investment Commission; iii. VSAT is to be used solely for Call Centre business; Page 6 of 17

7 iv. There is no interconnection (direct or indirect) of the VSAT traffic to the Public Switched Telecommunication Network (PSTN) or any; fixed, wired or wireless networks. v. There is no interconnection (direct or indirect) of the VSAT to the network of domestic mobile carriers; and vi. There is no sale of any telecommunications services via the VSAT. II. VSAT licenses may be awarded to individuals for the sole reception of unsubscribed (free) public TV signals. i. The licensee is not permitted to receive internet services through the licensed VSAT station. ii. Licensee is required to fill a simplified license application form online. 6 LICENSE DURATION AND TERMINATION I. The duration of the License will be for a period of 3 years, subject to renewal on a 3- yearly basis. II. The license may be terminated under the following conditions: i. Where the licensee requests for variation or early termination of its license, or ii. The CMC may cancel the license due to non compliance with any of the terms of the license. iii. The VSAT link will be terminated with immediate effect should the foreign telecommunications regulatory authority lodge an official objection on the grounds that direct international communications via VSAT infringes upon its own telecommunication regulations III. The license may be renewed only if the licensee had full compliance with the terms of the license for the entire duration of the license. Renewal will be at the discretion of the CMC. 7 RADIO SPECTRUM USE I. The radio spectrum bands to be used are dictated by the bands chosen by the satellite operators selected for VSAT services. The available spectrum is governed by international coordination under ITU/WRC rules. II. VSAT Licensees will have the right to access and use radio spectrum assigned by the CMC spectrum department at the time of licensing. Spectrum may be allocated if required to meet the needs of the service provision. III. Applicants are required to install filters in their receiver system to mitigate potential interference from other services. 8 NETWORK ROLL-OUT AND COVERAGE OBLIGATIONS I. There shall be no roll-out or coverage obligations, other than a requirement to provide VSAT services to any Closed User Group in the Republic of Iraq that requests such services when the request is financially and technically feasible. Page 7 of 17

8 II. If the Licensee fails to commence services within three months following the award of the license by the CMC then the License could be revoked. III. The licensee will not be entitled to any refund of all or any part of the fees paid for the license. 9 INTERCONNECTION I. Interconnection with public telecommunications providers shall not be permitted. II. Interconnection with other VSAT Licensees shall not be permitted III. Neither shall interconnection between users of different licensed VSAT operations (i.e., Closed User Groups) or within the customer portfolio of the VSAT Licensee be permitted. 10 COMPLIANCE I. In order for an ISP license to be approved, the licensee is required to provide the following: 1. Licensee is a registered entity incorporated/registered in the Republic of Iraq, or a branch of a foreign company registered as a foreign branch licensed to operate in the Republic of Iraq in accordance with the Iraqi Companies Registrations Law. 2. Certificate and proof that substantially all the infrastructure and personnel associated with the operation and provisions of the VSAT communications service shall be located in Iraq. 3. Detailed business plan showing the revenues profit and loss for 5 years of operation 4. Proof of experience and a list of similar ISP work performed by the applicant. 5. Certificate of good standing form previous licensors or regulatory body. 6. Bank statements showing that the applicant bank account for the previous year had exceeded the amounts required to build the proposed network setup,. 7. The applicant for an ISP license shall provide a bank guarantee equivalent $500,000 per province where service will be provided Clearance with other Entities I. For trans-border communication using VSATs, the applicant should obtain the necessary approvals and consent from the relevant authorities at the respective destination countries. The Licensee shall be solely liable for any damage/loss resulting from the termination of the VSAT link(s) due to any from any overseas authority. II. The applicant is required to seek the necessary clearance from other relevant authorities in Iraq concerning the setting up of VSAT facilities and compliance with emission codes and building regulations. These authorities may include, but is not limited to Ministry of Environment, Ministry of Building and construction. Page 8 of 17

9 III. VSAT applicants may seek the approval of the security authorities to obtain the necessary clearances for the type of communications offered by the licensee. IV. Formal approvals from the relevant authorities, including authorization of connections to companies in the VSAT network outside of Iraq, must be obtained prior to submitting application for VSAT License to CMC for consideration Suitability of Sites I. The applicant is responsible for making sure that the site proposed for the VSAT satellite dish is suitable for the operation of the facility. II. In instances where the VSAT dish cannot be erected on the rooftop of the Licensee s premise, CMC can approve, on a case-by-case basis, the installation of the antennae on the ground or at a remote site provided that the VSAT dish is used solely by the Licensee and that the owner of the proposed remote site allows the installation of the VSAT dish Obligations to Customers and Quality of Service I. The Licensee shall provide services to its Customers in accordance with the terms and conditions that comply with the following CMC's Regulatory Framework: a. The tariff procedures b. Service continuity requirements c. Procedures for disconnection and d. Quality of Service (QoS). II. In light of the fact that services will be offered on a commercial basis, the Licensees are required to establish QoS commitments through a Service Level Agreement (SLA) with their customers. III. The SLA should cover at least the following indicative QoS parameters, for each terminal: a. Delivered Bandwidth (shared/dedicated) (in Kbps) b. Committed Information Rate (CIR) (in Kbps) c. Bit Error Rate (BER) on its customer VSAT links d. Latency (in ms) e. Maximum fault detection time during business hours f. Maximum fault detection time outside business hours g. Maximum fault resolution time during business hours h. Maximum fault resolution time outside business hours i. Operational support coverage times (e.g., 24 x 7) j. Logistical issues related to access to terminal for servicing k. Obsolescence terms when applicable (all-in contract) l. Statement of Fare Access Policy and user rights Page 9 of 17

10 IV. In addition, the VSAT Licensees shall: i. Offer solutions supporting dedicated and shared bandwidth access schemes; and ii. Establish a Network Management System function with connectivity monitoring and fault detection capability. V. VSAT Licensees are required to commit (in the SLA with their customers) and meet specific QoS targets based on standard QoS parameters that are commonly used in international best practices. VI. VSAT Licensees shall meet the QoS parameters outlined in Appendix 1 of this regulatory requirements document and provide the CMC with monthly reports of their QoS parameters. 11 LAWFUL INTERCEPTION AND SECURITY I. The VSAT Licensee shall be subject to the same requirements applied to public telecommunications licensees in terms of cooperating with authorized law enforcement authorities and other government bodies concerning national security and public emergencies. II. The Licensee shall cooperate in providing any relevant information that is not collected or stored in the Republic of Iraq by the Licensee, but has been done by the Licensee or on its behalf in the course of providing the communication service. III. This provision applies to information that is the direct result of communications transmitted or received within the territorial jurisdiction of the Republic of Iraq through the facilitation of the Licensee. 12 REPORTING I. The Licensee shall provide the CMC with monthly reports of the SLAs offered to customers, QoS parameters as given in Appendix 1, Satellite service providers, service activity, information on the number of subscribers and any other information on the as requested by CMC from time to time in connection with this License. II. The Licensee shall provide the CMC with monthly reports of the actual bandwidth used the type of transmission provided by the satellite operator. The report shall be issued and certified from the original satellite operator showing the average daily usage and the type service leased; data and /or Internet service during the previous month. III. The Licensee shall be obliged to comply with the technical standards set by CMC which shall include ensuring that the VSAT facility does not interfere with other communication systems or services. Page 10 of 17

11 13 LICENSING PROCESS I. All applicants for VSAT license are invited to submit their proposals to the Communications and Media Commission (CMC) on the form in Appendix 2. The CMC will consider the VSAT License application on a case-by-case basis and will seek dialogue with each Applicant in order to ensure clear understanding of their proposal. II. Applicants must apply for a VSAT (Satellite Communication Station) License for the establishment and operation of a satellite communication station in Iraq. Applicants should submit their license application via online business licensing service at III. The CMC will notify the Applicant in writing within 14 days of receipt of the application that it has received the application. If no acknowledgement has been returned within this period please contact the CMC to ensure that the application has been received. The CMC reserves the right to request additional information or to seek clarification of information supplied. IV. The CMC will recommend or reject complete and comprehensive license application within 90 days of receipt. If recommended, VSAT license awards will normally be approved within 30 days of recommendation with no more than a further 30 days if necessary. V. The licensing process must, amongst other matters, ensure that licensees are qualified and meet the terms and conditions specified herein, financially sound, technically competent, and capable/willing to comply with the CMC rules and procedures. 14 LICENSE FEES I. VSAT Licensees shall be subject to an initial license fee, an annual license fee and Frequency Fee. A. The Initial License Fee shall follow the principle applied to other licensees offering services on a commercial basis in the Republic of Iraq. The initial license fee for each VSAT installation shall be set as indicated in the table in section B. The "Spectrum Fees" are separately payable to CMC for the allocation and management of frequencies. VSAT Licensees shall pay a Spectrum Fee as published by the CMC spectrum department. Spectrum Fee shall be paid annually proportional to the bandwidth utilized by the licensee under their license agreement. The Spectrum Fee will be assessed by the CMC upon initial license issue and subsequently licensee shall pay Spectrum Fee assessed based on the average usage for the licensee's previous year's bandwidth utilization including any overage fees resulting from the previous year's unpaid Spectrum Fee. The Spectrum Fee for future years will be assessed at the bandwidth utilized by the licensee at end of previous year'. II. The Initial License Fee shall be payable upon approval of the license. III. License fees paid shall not be refunded (whether on a pro-rated basis or any other basis) in the event that the license is cancelled by CMC in the following circumstances: Page 11 of 17

12 IV. The CMC shall not be liable to any damages/losses incurred by the VSAT end-user resulting from the termination of the VSAT link. The licensee will be responsible for any penalties and damages imposed by other countries regulators as a result of misuse of the VSAT links. V. Individual TV reception only licenses shall be free however users are required to apply and obtain a VSAT license after they complete a simple license form Fees for Individual Classes of VSAT Licenses The following Fees shall be payable by the individual classes of VSAT licensees: LICENSE TYPE LICENSE FEE SPECTRUM FEE Internet Service Provider (ISP) $3,000* Actual Bandwidth Usage Telecommunications Provider $3,000* Actual Bandwidth Usage Call Centers $3,000* Actual Bandwidth Usage Private Corporations $2,000 Actual Bandwidth Usage Iraqi Telecom and Post Company (ITPC) Free Free Individual TV reception only Free Free * Per VSAT installation. Licensees have more than one installation either in the same location or in different provinces will pay the license fee per each VSAT installation. Page 12 of 17

13 APPENDIX 1 The table below provides QoS parameters and obligations required from VSAT licensees. QoS Parameters and Obligations Parameter Explanation Measurement Bit Error Rate (BER) Detection time Fault repair time This measures the end to end performance of the link This measures the time it takes for the Network Management Function to detect connectivity failures This measures the time between a reported or detected fault and the service is restored The BER is measured by a BER test device or procedure set up by VSAT Licensee Time is measured by service provider Time is measured by service provider in hours: Area 1 (e.g., main land) Area 2 (e.g., remote locations) Minimum Acceptable Limit Target Limit < 10 E-8 < 10 E-9 < 1 hour < 1 hour The shorter of the two: 1. Time agreed with customer Or: 2. < 8 hours for main land < 24 hours for remote locations The shorter of the two: 1. Time agreed with customer Or 2. < 4 hours for main land < 24 hours for remote locations Throughput and bandwidth utilization versus Committed Information Rate (CIR) Installation time This measures the throughput obtained at each remote site on the uplink and downlink versus CIR level specified in the SLA between service provider and customer. The CIR may be lower than delivered bandwidth in case of shared bandwidth Average time from a valid order received to initiation of service Measured by service provider as a percentage of bandwidth delivered over bandwidth committed Installation time is measured in days between the time the valid order is received and the service is initiated - SCPC with MPLS data services - Star TDMA > 95% > 99% < 5 days - < 20 days < 5 days - < 15 days Page 13 of 17

14 Parameter Explanation Measurement Network availability Billing correctness This parameter provides a measure of the proportion of time that the space and ground segment network is available to customers. It is defined as a proportion of time during which the hub and associated services such as Domain Name Service are operational The time to resolve billing complaints For each hub station, the number of hours during which at least 80% of the booked transponder capacity is operational during the month is determined and divided by the number of hours in the month. Network availability is the average of each hub availability The proportion of bill correctness complaints resolved within - 15 business days - 25 business days Minimum Acceptable Limit Target Limit > 98% > 99.5 % > 50% - > 90% > 90% - > 99% Page 14 of 17

15 APPENDIX 2 VSAT LICENSE APPLICATION All applicants for a VSAT license shall be required to provide business and technical details. All non-technical details are to be completed at the time of the application. All technical details are to be completed at the time of License approval has been given and prior to issuance of the actual license and before the commencement of services. Licensee Information NON-TECHNICAL DETAILS First Name : Middle Name: Last Name Family Name ID #/ Passport Number Nationality Permanent Address Mailing Address Telephone Number Fax Number Address Registered Name Registration Number Registration Date Company Address Mailing Address Main office telephone number Main office fax number address Contact Name (Senior Management level) APPLICANT PERSONAL INFORMATION COMPANY INFORMATION TECHNICAL DETAILS Address Longitude Latitude Site Elevation Above Sea Level (meters) SITE INFORMATION Page 15 of 17

16 COVERAGE Coverage Area (List Locations & Supply Map) Center (Latitude) - dd:mm:ss Center (Longitude) - dd:mm:ss Radius (Kilometers) Satellite Name Satellite Operator Satellite Service Provider Contact Name Contact Address Phone and Service Type SATELLITE NETWORK INFORMATION Transmit Receive Range Center Frequency Bandwidth FREQUENCY Type: Characteristics MODULATION Designation of Emission Spurious Emission (db) Receiver Sensitivity (µv) Output Power Supplied to Antenna (W) STATION 3dB Beam (deg) Receiving System Noise Temperature (Kelvin) Antenna Type Total Peak Power (dbw) Antenna Displacement from Station Location (m) Antenna Gain (dbi) Maximum Isotropic Gain (dbi) Elevation Angle (deg) Azimuth Angle (deg) Site Elevation Above Sea Level (m) Structure Height (m) Building Height (m) Antenna Diameter (m) Polarization (H/V deg) Antenna supplier and Model #: ANTENNA Page 16 of 17

17 BASE BAND EQUIPMENT Demodulator Output Bit Rate Demodulator Channel Capacity Number of 64 Kbps Channels Functional Block Diagram Bandwidth Manufacturer & Type Noise temperature (Kelvin) Frequency Range IF bandwidth (KHz) LNR FEEDER Length (m) Losses (db) DOWN CONVERTOR Type Frequency range Bandwidth DETAILS OF APPARATUS (RF HEAD) Type of Equipment Manufacturer Model Serial Number Type of Equipment Manufacturer Model Serial Number Bit rate Address of system City Name: District #, Street #: Building#, Floor#: DETAILS OF APPARATUS (DIGITAL INDOOR UNIT) Registered Name Company Address Country Name, City Name: District #, Street #: Building#, Floor#: Mailing Address (if Different to above) Main office telephone number Main office fax number Address Contact Name (Senior Management level) DETAILS OF SUPPLIER Page 17 of 17