4. Strategic priorities and lines of action to be pursued in 2015-2017


This Multi-Annual Plan sets out the strategic priorities and lines of action to be pursued in the 2015-2017 three-year period, as well as the work tasks that will contribute to the accomplishment of these priorities.

ICP-ANACOM strategic priorities for 2015-2017

 ICP-ANACOM strategic priorities for 2015-2017.

The Plan also covers activities, which while not priority activities, are essential to the proper performance of ICP-ANACOM's functions, involving the allocation of significant human and financial resources.

For the first time this year, ICP-ANACOM submitted its proposed strategic guidelines to public consultation, providing all interested parties with the opportunity to express their views, suggest new priorities and lines of action and indicate concrete work tasks. For ICP-ANACOM, being open to stakeholder opinion and contributions constitutes good practice and is seen as essential to optimise the setting of priorities, to enhance transparency and regulatory predictability and to ensure an effective response to market needs.

Eleven contributions were received in response to this public consultation, as well as the contribution made by the Chairman of ICP-ANACOM's Advisory Council, advancing important proposals that have been carefully reviewed and considered. 

A large number of the proposals received were accepted and have been incorporated into ICP-ANACOM's Multi-Annual Plan 2015-2017, as referred to in the consultation report (since approved and published on ICP-ANACOM's website).

The principal lines of action to be pursued by ICP-ANACOM in the 2015-2017 period are detailed below, with the specific work tasks that will be undertaken to accomplish them, grouped according to strategic priority for the three-year period.

Strategic Priority 1: Assure and protect the interests of users and citizens

Lines of action:

1.1 Oversee application of the conditions governing universal service provision (electronic communications and postal services) in its various components.

1.2 Assess the appropriateness of quality of service levels provided.

1.3 Monitor the evolution of retail prices in the markets.

1.4 Define and implement actions in the field of security and integrity of electronic communications networks and services.

1.5 Ensure legal compliance and transparency as regards business practices (including in contract terms) prevailing in the market and promote a review of associated procedures.

1.6 Strengthen effective complaint management mechanisms.

1.7 Promote out-of-court dispute resolution in cooperation with relevant authorities.

1.8 Improve information provided to users, giving support to their choices, and enabling them to take more informed decisions and resolve problems with service providers.

1.1 Oversee application of the conditions governing universal service provision (electronic communications and postal services) in its various components

This work involves a number of actions which include an evaluation of levels of compliance with the quality of service parameters and indicators imposed on universal service providers in electronic communications and postal sectors, and also involves auditing the quality indicators reported for the universal postal service.

It also involves an evaluation of levels of compliance with price-cap rules, as determined for the universal service provider of electronic communications with regard to the fixed service and public pay-telephones, and applicable to the tariff charged by the universal postal service provider.

ICP-ANACOM will also oversee compliance with postal network density targets and targets established for the minimum offer of services, as well as evaluate and define, where necessary, exceptional circumstances or geographical conditions that might justify the non-daily collection and delivery of mail covered by the universal service and/or not delivering mail to the addressee's premises.

1.2 Assess the appropriateness of quality of service levels provided

This line of action will be accomplished through a series of studies designed to assess the quality of service provided on mobile networks; these will examine the quality of the voice service, video-streaming and network coverage in mainland Portugal and in the Azores and Madeira, as well as SMS and MMS quality and quality of the voice service, video-streaming and coverage on the CP Alfa Pendular (High-speed rail service).

Furthermore, 2015 will see the launch of Netmede.pro, upgrading a platform launched by ANACOM that consumers can use to check their Internet connection speeds and which will collect indicators and produce reports on broadband Internet quality of service (2016).

ICP-ANACOM will also assess the need to define minimum requirements or quality of service indicators in the context of net neutrality.

1.3 Monitor the evolution of retail prices in the markets

This line of action covers the annual oversight of retail prices in relation to the various electronic communications services provided to consumers, monitoring trends in pricing and updating the report produced in 2014.

1.4 Define and implement actions in the field of security and integrity of electronic communications networks and services

With regard to network security and integrity, ICP-ANACOM plans to launch a process of security auditing, which entails approval of necessary measures, in terms of procedures and other technical aspects, as well as the constitution of an audit team.

1.5 Ensure legal compliance and transparency as regards business practices (including in contract terms) prevailing in the market and promote a review of associated procedures

A review will be made of the Regulamento da Portabilidade (Portability Regulation), with a view to making application of the Regulation more expeditious and more in keeping with market requirements. With this purpose, ICP-ANACOM will identify the amendments to be made and make an assessment of their impact.

In the 2016-2017 period, a new analysis will be made of contract conditions, as occurred in 2014, with the ongoing goal of ensuring the transparency in the information which service providers give consumers.

1.6 Strengthen effective complaint management mechanisms

In the electronic communications sector, complaints are common and there is widespread use of litigation between consumers and operators; this stems from the competitive situation in the market and the adoption of aggressive commercial practices. In 2013, ANACOM received more than 60 thousand complaints, and therefore, in order to improve ICP-ANACOM'S capacity to deal with these complaints, the process used to handle enquiries/complaints from end-users of electronic communications will be reviewed in 2015 and a new computer system installed to support this process.

1.7 Promote out-of-court dispute resolution in cooperation with relevant authorities

ICP-ANACOM recognizes the importance of non-judicial procedures for resolving conflicts and proposes to develop solutions and mechanisms which assist settlement of disputes.

In parallel, and in order to contribute to an improvement in decision-making quality in the arbitration of consumer disputes, ANACOM will work, in liaison with Direção-Geral do Consumidor (Directorate General for the Consumer), to provide information and training related to electronic communications, with a focus on existing arbitration and information centres, as well as other local/regional bodies working in this area (CIAC).

1.8 Improve information provided to users, giving support to their choices, and enabling them to take more informed decisions and resolve problems with service providers

In principle, better informed consumers make better informed choices, and are therefore better equipped to safeguard their interests and rights. With this in mind, ICP-ANACOM publishes a wide range of information on its institutional and consumers' websites. In 2015, the processes of compiling, processing and producing information will be developed in two ways, with new features added to ANACOM's consumers' website and also to the COM.escolha tariff comparison tool, enabling broader comparison of offers and introducing standardised information that will be of use to consumers when interacting with providers of electronic communications services.

Strategic Priority 2: Promote open and competitive markets

Action lines:

2.1 Analyse/review relevant electronic communications markets, taking into account the rules adopted at European level.

2.2 Review wholesale offers arising from obligations imposed on undertakings with significant market power in the various relevant markets.

2.3  Develop and improve regulatory costing systems and audit their results.

2.4 Undertake actions associated with the provision of the universal service with market impact, particularly associated with universal service financing.

2.5 Oversee and monitor the development of next generation access networks (NGA).

2.6 Take an outlook on the market's development and define, review and monitor indicators for analysis and supervision.

2.7 Assess the impact of adopted regulatory measures.

2.8 Monitor and supervise the activities pursued by various agents, enforcing compliance with prevailing rules.

2.1 Analyse/review relevant electronic communications markets, taking into account the rules adopted at European level

Diagnosis of the competitive situation in the electronic communications sector is accomplished through analysis of the various relevant markets identified by the European Commission (EC). These analyses entail the review and update of previous analyses, taking into account the latest and foreseeable evolution in the markets concerned; they include definition of relevant markets, identification of any providers with significant market power and the maintenance, imposition, amendment or withdrawal of regulatory obligations to which these providers are subject.

As a result of these analyses, there may be: situations where certain markets are totally or partially deregulated; situations of geographic differentiation due to the prevalence of distinct competitive conditions in different regions of the national territory; and/or situations which warrant the withdrawal, modification or enhancement of regulatory measures.

The market analyses planned for the period of the Plan include analysis of market 7 and of market 18 of the previous recommendation (in 2015), followed by re-analysis of markets 2, 3, 4, 5 and 6 (2016 and 2017).

2.2 Review wholesale offers arising from obligations imposed on undertakings with significant market power in the various relevant markets

Subsequent to the market analyses, and based on the respective conclusions, or occasionally in parallel, reviews are conducted of relevant wholesale offers (reference offers).  These offers govern conditions of access to networks and services of providers with significant market power by alternative providers in circumstances that enable sustained competition in downstream retail markets. This activity seeks to ensure transparency in technical and commercial information, and to achieve non-discrimination and price control.

Every year, ICP-ANACOM reviews a number of reference offers in the light of current data, particularly in terms of costing and quality of service, in terms of experience gained and of contributions received from the market. In 2015, reviews will be conducted of the Reference Interconnection Offer (RIO), the Subscriber Line Resale Offer (SLRO), the Leased Lines Reference Offer (LLRO) and the Reference Ethernet Leased Lines Offer (RELLO). In addition, ICP-ANACOM will implement any measures imposed subsequent to the analysis markets 4 and 5, taking due account of European Commission's relevant recommendations.

2.3 Develop and improve regulatory costing systems and audit their results

In the 2015-2017 period, ICP-ANACOM plans to review the SCA - Sistema de Contabilidade Analítica (Analytical Accounting System) used by CTT and audit the SCA used by the company for the years 2014, 2015 and 2016/2017. The SCA estimates and the estimates for CLSU - Custos Líquidos do Serviço Universal (net costs of universal service provision) presented by PTC will also be audited, together with any re-submissions relating to 2013 and 2014, in addition to the audit of the SCA used by PTC for 2016/2017.

Other planned actions relate to updating PTC's cost of capital in respect of the years 2015/2016/2017 and a review of the mobile termination rate model. Additionally, there will be a review of the use of the SCA by PT, in accordance with the trends in the market and regulation, and a cost model will be developed for next generation networks.

2.4 Undertake actions associated with the provision of the universal service with market impact, particularly associated with universal service financing

In fulfilling its legal mandate, ICP-ANACOM will pursue a number of actions related to the provision of the universal service, particularly with regard to its financing. Therefore, in 2015, it will be necessary to audit the values resubmitted by PTC in respect of the 2012 CLSU and audit the values in respect of retirees and pensioners for the period subsequent to the designation of the universal service provider by public tender.

Audits will also be conducted on the values reported for the turnover of those operators required to contribute to the universal service compensation fund, and processes developed for the reimbursement of the net costs of universal service provision to PTC for the period 2007-2014. The same will be done for the new universal service provider from 2014.

As regards the universal postal service, the procedures are similar, with net costs determined and where there is reimbursement.

In 2015, ICP-ANACOM will also have to change the methodology used for calculating the CLSU for electronic communications and will likely advise the Government in the context of the launch of the new tender for directories and directory enquiry services.

2.5 Oversee and monitor the development of next generation access networks (NGA)

Upon conclusion of the analysis of markets 4 and 5, appropriate remedies will be defined and implemented, taking due account of the relevant recommendations of the European Commission.

In this context, 2015 will see preparation of a draft transposition of Directive 2014/61/EU of the Parliament and of the Council of 15 May, on measures to reduce the cost of deploying high-speed electronic communications networks, for approval by the Government.

Many aspects of this Directive have already been enacted in Portugal by Decree-Law no. 123/2009. In this context, over the three-year period, ICP-ANACOM will develop work on the implementation of the SIC - Sistema de Informação Centralizado (Centralised Information System), begun in 2014.

2.6 Take an outlook on the market's development and define, review and monitor indicators for analysis and supervision

ICP-ANACOM regularly seeks information from providers and so defines and follows the evolution of a set of indicators; these allow it to monitor the market and oversee compliance with the obligations of providers and produce various analyses. Periodically analysis is made, in the light of market trends, of the need to make changes to the information sought and to the indicators which are monitored; this review process will take place in 2015.

In anticipation of market trends, ICP-ANACOM conducts a range of studies to compile an outlook on new trends in the market and to enable informed decision-making. In 2015, a study is planned on the relationships between OTT (Over The Top) and traditional operators in a context of technological neutrality.

2.7 Assess the impact of adopted regulatory measures

For ICP-ANACOM to improve upon its performance and enhance the quality of the regulatory process, it is very important to assess how the market is impacted by its decisions. With a view to examining the impact of its decisions on a case by case basis, ICP-ANACOM proposes to develop a study of regulatory impact analysis (RIA), with special focus on the development of a comparative analysis of the different approaches taken by different national regulatory authorities (NRA) with regard to RIA programmes.

2.8 Monitor and supervise the activities pursued by various agents, enforcing compliance with prevailing rules

In terms of supervision, a wide range of market enforcement actions are carried out every year, in order to check compliance with prevailing laws and determinations. Some of these actions are scheduled on an annual basis, while in other cases they stem from specific needs perceived following analysis of complaints received by ICP-ANACOM. In 2015, 1.460 enforcement actions are planned, focusing on electronic communications operators and postal operators, in addition to checking on compliance with the rules governing telecommunications infrastructure in buildings and urban settlements (ITED/ITUR).

In the context of frequency management, 1.500 spectrum monitoring actions are planned for 2015.

Within this line of action, ICP-ANACOM will also work on the transposition of Directive 2014/53/EU of the Parliament and of the Council of 16 April on the harmonisation of the laws of the Member States relating to the making available on the market of radio equipment and repealing Directive 1999/5/EC - this work will be completed in 1st quarter 2016.

Strategic Priority 3: Ensure the efficient management of public resources

Lines of action:

3.1 Define and implement a national strategic plan for use of the radio spectrum.

3.2 Examine, on a prospective basis, trends of radio spectrum use occurring internationally, anticipating evolutionary scenarios (digital dividend).

3.3 Evaluate the development of various services, including broadcasting, and associated spectrum needs.

3.4 Monitor and ensure compliance with the obligations of the operator of the digital terrestrial television (DTT) platform.

3.5 Establish appropriate rules on the allocation, use and management of numbering.

3.1 Define and implement a national strategic plan on use of the radio spectrum

Even though, every year, ICP-ANACOM plans and provides information on allocation of spectrum use by service, it was considered important to prepare a systemised and comprehensive plan, on a provisional basis, for the entire spectrum and bands in use, contributing to the more transparent and efficient management of public resources. This plan, which will be prepared taking into account the international context, will provide medium and long-term guidance on spectrum use.

3.2 Examine, on a prospective basis, trends of radio spectrum use occurring internationally, anticipating evolutionary scenarios (digital dividend)

ICP-ANACOM will begin to assess outlooks on the development of the UHF broadcasting band, taking into consideration the needs of the national market, the European and national regulatory framework, as well as the most relevant aspects in terms of the evolution of services, networks and technologies. This action also entails the definition of a strategic framework for the 700 MHz band and its implementation (with completion expected in mid-2016), and the elaboration of scenarios on the future use of the 470-694 MHz band and respective implementation (with completion expected in 2017).

3.3 Evaluate the development of various services, including broadcasting, and associated spectrum needs

In 2015, ICP-ANACOM will assess the development of various services - fixed, mobile, including private mobile, broadcasting and BWA - to identify the requirements of spectrum use in the relevant bands.

Upon conclusion of this work, ICP-ANACOM will proceed with the designation and provision of spectrum for the corresponding services, taking into account the objectives of regulation established by law, in particular the radio spectrum policy programme, the results of the World Radiocommunication Conference (WRC-15) and the level of national interest in using the spectrum remaining after the BWA auction, after the multi-band auction and other bands of relevant spectrum.

3.4 Monitor and ensure compliance with the obligations of the operator of the digital terrestrial television (DTT) platform

It is one of ICP-ANACOM's functions to verify compliance with the obligations of the operator of the DTT platform, and in this context, the quality of the digital television signal is monitored on a permanent basis. To do this effectively and continuously, almost 400 probes are installed throughout mainland Portugal to provide constant monitoring of the television signal. In 2015, a study on the quality of the DTT service will be carried out based on readings from these probes.

In parallel, ICP-ANACOM will be checking compliance with the network obligations of the platform operator and will commence a study on the evolution of the DTT network and its possible adaptation based on the probe network.

3.5 Establish appropriate rules on the allocation, use and management of numbering

ICP-ANACOM's Multi-annual Plan 2015-2017 sets out a number of actions regarding the PNN - Plano Nacional de Numeração (National numbering plan). Firstly, ICP-ANACOM will re-evaluate the conditions governing the use of geographic numbers and, if necessary, redefine these conditions. Consideration is also given in the Plan to the preparation of a numbering regulation to update the main elements of the PNN, as well as seeking to re-evaluate the need to define the eCall numbering range.

Strategic Priority 4: Promote institutional and technical cooperation

Lines of action:

4.1 Ensure active participation at international forums with relevance to the sector (electronic communications and postal services).

4.2 Increase involvement in BEREC, including taking over the BEREC Chair in 2015 and Vice-chair in 2016.

4.3 Promote the sector at a national and international level and promote cooperation with other regulators.

4.4 Actively participate in the platforms of collaboration between Portuguese-speaking countries, especially ARCTEL.

4.5 Promote cooperation with national and international organisations and ensure coordination of activities in relevant areas (spectrum management, consumer protection, communications security).

4.6 Promote the dissemination of legal and regulatory regimes applicable to the sector.

4.7 Promote coordination of the entities involved in the planning, construction and maintenance of infrastructure, including management of the SIC.

4.1 Ensure active participation at international forums with relevance to the sector (electronic communications and postal services)

ICP-ANACOM provides representation of the Portuguese State at international bodies of the communications sector and on international committees and working groups, where it is charged with advancing Portuguese interests and positions.

ICP-ANACOM's plans for 2015 set out the implementation of a new strategy of participation in international organisations/agencies, making this participation more efficient in terms of the allocation of human and financial resources, reducing, wherever possible, the membership contributions incurred. ICP-ANACOM has been working on this in recent years and in 2015 it will continue to evaluate this possibility for the coming years.

4.2 Increase involvement in BEREC, including taking over the BEREC Chair in 2015 and Vice-chair in 2016

In 2015, ICP-ANACOM will have an enhanced role at the Body of European Regulators for Electronic Communications (BEREC) - the chairman of ICP-ANACOM's Management Board, Fátima Barros, takes over as BEREC chair in 2015 and will take office as Vice-chair in 2016. In this capacity, ICP-ANACOM will also coordinate and chair the meetings of the Contact Network (CN) which are held to prepare the plenary meetings.

In addition to its increased involvement in BEREC, as Chair of the Body, Portugal will be able to ensure that the European agenda covers the issues that are most important for the sector's future development.

4.3 Promote the sector at a national and international level and promote cooperation with other regulators

As part of its work, ICP-ANACOM seeks to foster the transfer of knowledge and experiences with other organisations, through groups which work in the field of internationalisation.

Over the 2015-2017 period, ICP-ANACOM will continue to pursue this goal by prioritizing actions of bilateral cooperation, with the strategic redefinition of bilateral cooperation protocols and their subsequent deployment.

ICP-ANACOM also aims to conduct an assessment of the economic impact of its cooperative effort.

It also plans to conclude an agreement with aicep Portugal Global - Trade & Investment Agency and participate actively in the Secretariat of the Euro-Mediterranean Regulators Group (EMERG).

4.4 Actively participate in the platforms of collaboration between Portuguese-speaking countries, especially ARCTEL-CPLP

In the context of its participation in ARCTEL-CPLP - Associação de Reguladores de Comunicações e Telecomunicações da Comunidade dos Países de Língua Portuguesa (Association of Communications and Telecommunications Regulators of the Community of Portuguese Language Countries), ICP-ANACOM plans to contribute actively to the completion of a study on universal service in CPLP countries. In addition to its intense cooperation with CPLP countries on a bilateral basis, ICP-ANACOM is committed to its participation in ARCTEL, promoting the exchange of experiences and disseminating the European regulation model.

4.5 Promote cooperation with national and international organisations and ensure coordination of activities in relevant areas (spectrum management, consumer protection, communications security)

Some areas of ICP-ANACOM's work entail close cooperation with other organisations with relevance to the sector. These areas include spectrum management, communications security and consumer protection, where there is frequent collaboration with the Armed Forces, Gabinete Nacional de Segurança (National Security Office), CNPD - Comissão Nacional de Proteção de Dados (National Data Protection Commission), INAC - Instituto Nacional de Aviação Civil (National Civil Aviation Institute), FCT - Fundação para a Ciência e Tecnologia (Foundation for Science and Technology), DGC - Direção-Geral do Consumidor (Directorate General for the Consumer) and other organisations, including other organisations representing consumers.

In 2015, protocols will be developed with organisations involved in the management of aeronautical services spectrum, with a view to more efficient and effective management, and stemming from the European "Single Sky" regulatory framework.

4.6 Promote the dissemination of legal and regulatory regimes applicable to the sector

During the period covered by this Plan, ICP-ANACOM plans to be engaged in a range of dissemination activities arising from regulatory changes.

With the update of the technical manuals of ITED - infraestruturas de telecomunicações em edifícios (telecommunications infrastructures in buildings) and of ITUR - infraestruturas de telecomunicações em loteamentos, urbanizações e conjuntos de edifícios (Infrastructures for telecommunications in housing developments, urban settlements and concentrations of buildings), in 2015, ICP-ANACOM will need to work to spread information and raise awareness among different economic agents with regard to the new regulations.

Given the need to update the regulation governing the amateur and amateur satellite services, it is expected that legislation in this regard will be published in Q1 2015, so that it will then be important to draft regulation embodying the new procedures associated with these radiocommunication services.

The transposition of Directive 2014/53/EU of 16 April, which should be completed by June 2016, means that two seminars will have to be held that year to disseminate the new legal framework on radio equipment. 

4.7 Promote coordination of the entities involved in the planning, construction and maintenance of infrastructure, including management of the SIC

Under Decree-Law no. 123/2008, the SIC - Sistema de Informação Centralizado (centralized information system) will aggregate all the information contained in communications infrastructure records, as well as the procedures and rules governing the construction of new infrastructure and access to existing infrastructure. Furthermore, infrastructure construction plans will be published, so that operators are able to plan and participate in any works on a basis of cost-sharing, reducing the impact of works on local populations.

Under the law, it is the responsibility of ICP-ANACOM to design, manage and maintain the SIC, and also to ensure that it is accessible and available, whereas undertakings responsible for infrastructure will collect the relevant information, make it available and keep it up-to-date. Following a tender process in 2014, the first phase of the SIC's implementation is due to be completed in 2015, entailing the development of the geo-referencing platform/system. In 2016 and 2017, the system is expected to be put into operation and use.

Strategic Priority 5: Promote internal efficiency and effectiveness

Lines of action:

5.1 Implement measures to rationalize expenditure, guaranteeing efficiency.

5.2 De-materialise/automate/simplify procedures and expand the provision of services online.

5.3 Invest in training and ensure excellence in human resources.

5.4 Promote an organisational culture that is more open to change.

5.1 Implement measures to rationalize expenditure, guaranteeing efficiency

Cost reduction will remain a constant goal of ICP-ANACOM over the three-year period 2015-2017. Reductions can be achieved in a number of ways, including: through the renegotiation of contracts, reduction in consumption, behaviour change, reviewing and de-materialising processes.

In 2015, a review will be made of ICP-ANACOM's stock of servers with a view to technological consolidation, which will improve the usability of existing information systems at ICP-ANACOM, increasing efficiency and substantially reducing costs.

In 2016, with the same goal, ICP-ANACOM will computerise procedures related to processes of overseeing the equipment market.

5.2 De-materialize/automate/simplify procedures and expand the provision of services online

The improvement of overall efficiency is a priority for ICP-ANACOM; as such, a number of projects will be implemented in 2015 to streamline processes and procedures and reduce the administrative burden associated with certain tasks. This may result in the release of funds to more value-added functions, while at the same time improving ICP-ANACOM's ability to respond to external requests, achieving an improvement in quality and response times.

The actions planned to simplify, dematerialize and automate processes include:

  • Implementation of the 2015-2017 strategic plan for information systems.
  • Development of new features in computer applications to support spectrum management, particularly with regard to updating geo-referenced systems in 2015; meanwhile, the operation of electronic licensing requires analysis with a view to future developments in following years.
  • Consolidation of the electronic billing model that has been already implemented.
  • Extension of the scope of the Extranet to encompass the quarterly collection of data from various services (not yet collected in this way) and data from the annual questionnaires on communications and portability.
  • Computerize procedures related to the processes of equipment market monitoring (2016), speeding up the completion of processes and referral for litigation.

ICP-ANACOM will continue to expand the range of services it provides online, though its institutional website and its Consumers' Website, following the introduction of electronic licensing, in the management and availability of geo-referenced information and the provision of the reports of the annual monitoring plans to the Direção-Geral da Saúde (General Directorate of Health) and municipalities using the extranet.

In the area of spectrum monitoring and control, improvements are expected, arising from the entry of geo-mapping data in the corresponding computer application, which will improve execution of the survey plan.

To facilitate interaction with end-consumers, new features will be developed on ANACOM's Consumers' Website, including availability of standard forms online, which users can use to make submissions to ICP-ANACOM or other entities, in addition to other new features.

5.3 Invest in training and ensure excellence in human resources

ICP-ANACOM recognises how important it is to have staff who are committed to the organisation and its goals, and will make use of the most modern management techniques to promote excellence among its people. Accordingly, it will continue to invest in the quality of its human resources, investing in training that will allow them to improve and develop their skills, providing them with tools that will enhance performance, helping to overcome the challenges that ICP-ANACOM is facing. With this objective, a new model for employee training will be fully implemented in 2015, structured to promote the development of skills in a manner more aligned with the needs of the organisation.

In parallel, a new dynamic will be instilled in the organisation's internal communication, strengthening the "ANACOM culture" and the spirit of belonging to the organisation.

5.4 Promote an organisational culture that is more open to change

Over the period covered by this Plan, ICP-ANACOM intends to implement a culture of dialogue at all levels of the organisation, in order to give impetus to the promotion of change. In this respect, a study of organisational climate will be made in 2015, in order to gather information on employee satisfaction, motivation and their involvement in the organisation's goals, enabling the identification of areas where improvement is needed to contribute to an enhanced social climate.

In parallel, ICP-ANACOM will continue actions aimed at consolidating the "ANACOM culture"; these actions include social responsibility initiatives, such as actions in support of social solidarity and the development of a graduate internship programme, facilitating the entry of young graduates with high potential into the labour market.