4. Strategic priorities and lines of action to be pursued in 2016-2018

This Multi-Annual Plan sets out the strategic priorities and areas of action to be pursued in the 2016-2018 three-year period, as well as the actions which will contribute to accomplishing these priorities.

ANACOM's strategic priorities for 2016-2018

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

As with the strategic guidelines for the 2015-2017 Plan, but now in fulfilment of a statutory requirement, ANACOM again submitted its proposed strategic guidelines for the Multi-Annual Activities Plan 2016-2018 to public consultation.

By following this procedure, ANACOM is enhancing transparency and regulatory predictability; by providing all stakeholders with an opportunity to express their views on the strategic guidelines which ANACOM proposes to pursue over the coming years and to suggest new priorities and lines of action, ANACOM is ensuring that the Plan provides a response that is line with market needs.

Contributions were received in response to this public consultation from ten undertakings and the proposals received have been carefully reviewed and considered.

From the proposals received, the majority were accepted and incorporated into the 2016-2018 Plan, as detailed in the consultation report, which has been approved and is published on ANACOM's website.

The principal lines of action to be pursued by ANACOM in the 2016-2018 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 and review, on a timely basis, 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 and report on 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 Contribute to the definition and updating of emergency civil planning policies in the communications sector.
 
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.
 
1.9 Monitor and ensure compliance with the obligations of the operator of the digital terrestrial television (DTT) platform.

1.1 Oversee and review, on a timely basis, 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 the preparation and launch of a public consultation on the review of the conditions applicable to provision of the universal service of electronic communications in its various components, the issue of a draft decision on the specifications governing provision of the universal service and provision of advice to the Government in the context of the launch of the universal service tender procedures. This work also involves 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 auditing the quality indicators reported for the universal postal service. In addition ANACOM will define the quality parameters of the universal postal service to be imposed in 2018-2020, the rules governing pricing of the universal postal service during this period and the postal network density targets to be imposed from 2017.

This line of action also involves an evaluation of levels of compliance with price-cap rules, as determined for the universal service provider of electronic communications (fixed service, public pay-telephones and directory enquiry services) and for the provider of the universal postal service.

1.2 Assess the appropriateness of quality of service levels provided (taking into account transparency and technological neutrality)

This line of action will be accomplished through a series of activities designed to assess the need to define minimum requirements or quality of service indicators in the context of net neutrality, ensuring market transparency.

This line of action also entails work on the development and provision of tools for gauging the quality of access to fixed and mobile Internet services, notably through the NET.mede and NET.mede Pro Tools.

1.3 Monitor the evolution of retail prices in the markets

This line of action covers the oversight of retail prices in relation to the various electronic communications services provided to users, monitoring trends in pricing and updating analyses and reports.

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, ANACOM plans to undertake identification and characterization of the first exceptional audit to be conducted by ANACOM based on received notifications of security breaches and losses of integrity. In this way, ANACOM will proceed to build a base for the future definition of audit procedures and reinforce relationships with electronic communications service providers.

During the year, ANACOM will take stock of the activity of the notification reporting centre in order to identify measures which consolidate this assigned responsibility of ANACOM.

1.5 Contribute to the definition and updating of emergency civil planning policies in the communications sector

Taking into account the new responsibilities assigned to ANACOM in inheriting the assignments and powers conferred on CPEC - Comissão de Planeamento de Emergência das Comunicações (Emergency Communications Planning Committee), it is now a responsibility of ANACOM to contribute to the definition and updating of emergency civil planning policies in the communications sector. In this context, ANACOM will undertake an evaluation of the present situation, both with regard to the guidelines of the Government and in regard to the needs envisaged by organisations and competent authorities, thereby characterising the sector's contribution to this matter of public interest.

This will include an assessment of the sector's readiness, mapping out an action plan for submission to the Government.

1.6 Strengthen effective complaint management mechanisms

The electronic communications sector is marked by a high level of complaints and of litigation between consumers and operators, resulting from the competitive market situation and certain aggressive commercial practices. To improve its capacity for the management of complaints, in 2016, the software tool supporting the handling of complaints will be replaced with a new information system to support this process.

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

Under its new statutes, it is ANACOM's responsibility to develop steps to promote solutions and mechanisms enabling the out-of-court settlement of consumer disputes.

In recognition of their importance for the sector, ANACOM is working on the development of solutions and mechanisms that will help to resolve disputes. In this respect, ANACOM plans to implement a solution in 2016 (to be defined in 2015).

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 more informed choices, safeguarding their interests and rights. With this in mind, ANACOM publishes a wide range of information on its institutional website and on its consumers' website, which it set up specifically to strengthen its relationship with the consumer public. To this end, both the institutional website and the consumers' website have been improved in terms of content and layout, and will continue to be enriched with useful information and features for different sections of the public, including consumers, so that they can interact with the regulator more easily and quickly.

The information disclosed covers the different products and services, tariffs, sector legislation, ANACOM decisions, statistics on services, trends in complaints, etc.

Meanwhile, and also with a view to protecting the interests of users, ANACOM carries out studies which seek to anticipate user needs, in support of its decision-making. For 2016, ANACOM plans to conduct a study on the needs of users in terms of postal services and another study on the costs of switching operator.

1.9 Monitor and ensure compliance with the obligations of the operator of the digital terrestrial television platform

This line of action will be accomplished through a range of actions. ANACOM will continue to enforce the obligations of providing national coverage with digital terrestrial television and to ascertain the accuracy of the information provided by the network operator, MEO, in particular by using the network of DTT probes. ANACOM will also undertake a quality of service study of digital terrestrial television based on the readings obtained from the network of 386 probes that it has installed across mainland Portugal. Considering the results of this study, ANACOM will assess the need to adapt this probe network.

Strategic Priority 2: Promote open and competitive markets

Lines of action:
 
2.1 Analyse/review relevant electronic communications markets, taking into account the rules adopted at European level, specifically as regards the promotion of competition and giving an incentive to efficient investment.
 
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 the determination of net costs and the financing of its provision.
 
2.5 Oversee and monitor the development of next generation access networks (NGA).
 
2.6 Develop/consolidate the application of rules on access to infrastructure under Decree-Law no. 132/2009 of 21 May, as amended and republished by Law no. 47/2013 of 10 July, and implement the SIC - sistema de informação centralizado (centralized information system).
 
2.7 Define and monitor indicators for market analysis and supervision.
 
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

Analysis of the various relevant markets defined by the European Commission (EC) is vital in order to make a diagnosis of the competitive situation in the electronic communications sector. These analyses entail the review and update of previous analyses, taking into account evolution occurring in the markets concerned; they include definition of relevant markets, identification of any providers with significant market power (SMP) 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 fully 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 2016-2018 three-year period include analysis of market 1¹ (former market 3), market 2² (former market 7) and former market 2³ (origination). Analyses of the following markets are scheduled for completion in 1st quarter 2016: market 3a⁴ and 3b⁵ , and market 4⁶.

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

The conclusions which result from market analyses may determine a review 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 retail markets. This activity seeks to ensure transparency in technical and commercial information, and to achieve non-discrimination and price control.

Every year, ANACOM reviews a number of reference offers in the light of current data, particularly in terms of costing and quality of service, of experience gained and of contributions received from the market. In 2016, reviews will be conducted of the Subscriber line resale offer (SLRO), the Reference Interconnection Offer (RIO), analysis of a possible fibre access offer and re-examination of the pricing of Mainland-Azores-Madeira (CAM) and inter-island circuits. The review of wholesale broadband offers - leased lines reference offer (LLRO), Ethernet leased lines (RELLO), access to ducts (RDAO) and ADSL network - should be completed in 2017, even though the corresponding draft decisions are envisaged for 2016.

2.3  Develop and improve regulatory costing systems and audit their results

Over the period of this activity plan, ANACOM intends to review the SCA - Sistema de Contabilidade Analítica (Analytical Accounting System) employed by CTT and to audit the system for the years 2014, 2015 and 2016/2017.

Auditing will also be conducted with respect to the SCA employed by MEO for the 2015/2016 period and a process instigated to develop an SCA for next generation networks.

Other planned actions are focused on updating MEO's (2016, 2017 and 2018) and CTT's (2016 and 2017) cost of capital as well as updating fixed and mobile termination tariff models, scheduled for 2018.

2.4 Undertake actions associated with the provision of the universal service with market impact, particularly associated with the determination of net costs and the financing of its provision

In 2016, audits will be carried out on the SCA/CLSU - Custos Líquidos do Serviço Universal (Net Costs of Universal Service) submitted by MEO in respect of 2014 and any re-submissions.

ANACOM will carry out auditing in the context of the provision of telephone directories and directory enquiry services, with audits of the figures on retirees and pensioners in the period subsequent to the designation of the universal service provider by public tender and of the operator turnover data used in respect of the universal service compensation fund.

Provision is also made for compensation of net costs incurred by MEO in the period prior to designation of the universal service provider by public tender and the reimbursement of costs incurred by the provider designated by public tender.

Various actions are still under consideration with regard to the assessment and reimbursement of the postal CLSU, should they apply.

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

In pursuit of this line of action, ANACOM plans to carry out an audit on the equivalence of access to the infrastructure of MEO, particularly with regard to ducts and poles. All the work prior to the choice of auditor and the auditor selection process will take place in 2016, but auditing won't be completed and the final decision taken as regards actions to be undertaken won't take place until 2017.

2.6 Develop/consolidate the application of rules on access to infrastructure under Decree-Law no. 132/2009 of 21 May, as amended and republished by Law no. 47/2013 of 10 July, and implement the SIC - sistema de informação centralizado (centralized information system)

During 2016, ANACOM will seek to define the methodology to be used in determining the remuneration applicable for access to and use of infrastructure suitable for carrying electronic communications networks.

Work will commence at the beginning of the year, and the final decision on the methodology is due to be adopted in the 3rd quarter.

2.7  Define and monitor indicators for market analysis and supervision

ANACOM regularly asks providers for a set of information, defining and monitoring the evolution of a set of indicators that allow it to oversee the market, check compliance with the obligations of providers and produce various analyses. As part of this monitoring activity, and due to the market's evolution, it is sometimes found that there are indicators which are no longer appropriate and which should be discontinued. Furthermore, new indicators may be created whenever deemed necessary (in consultation with stakeholders).

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 ascertained following analysis of complaints received by ANACOM. In 2016, 1,018 enforcement actions are planned, focusing on electronic communications operators and postal operators, in addition to checks on compliance with the rules governing telecommunications infrastructure in buildings and urban settlements (ITED/ITUR). In addition to these actions, ANACOM also undertakes spectrum monitoring actions, as referred to below.

In pursuit of this line of action, with conclusion in 3rd quarter 2016, ANACOM also plans work associated with the transposition of Directive 2014/53/EU of the European Parliament and of the Council of 16 April relating to the making available on the market of radio equipment and repealing Directive 1999/5/EC.

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 Analyze trends in the use of the digital dividend in anticipation of evolutionary scenarios.
 
3.3 Evaluate, on a prospective basis, the development of various radiocommunications services and applications and associated spectrum needs, including new mobile broadband services.
 
3.4 Establish appropriate conditions as regards the management of numbering and conditions governing its use.

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

ANACOM intends to develop and adopt a national strategic plan to cover use of the radio spectrum which, taking into account the international context, establishes medium and long-term guidelines for use of the spectrum.

Albeit on a provisional basis, the plan will be systemised and comprehensive for the entire spectrum and all bands in use, contributing to more transparent and efficient management of public resources.

3.2 Analyze trends in the use of the digital dividend in anticipation of evolutionary scenarios

In pursuit of this line of action, ANACOM will start evaluating prospects for the development of the UHF broadcasting band, considering the national market, the European and national regulatory framework and the most relevant aspects related to the development of services, networks and technologies. This action involves the definition of a strategic framework for the 700 MHz band and its implementation, as well as the elaboration of scenarios as to the future use of the 470-694 MHz band and their implementation.

3.3 Evaluate, on a prospective basis, the development of various radiocommunications services and applications and associated spectrum needs, including new mobile broadband services

In 2016, ANACOM intends to adopt a set of decisions on spectrum allocation, particularly taking into account the development of the different radiocommunications services. First, in late 2016, a decision is planned on the allocation of spectrum designated for fixed wireless access (BWA) and applications, with the definition of an action framework for the spectrum remaining from multiband auction and its implementation.

3.4 Establish appropriate conditions as regards the management of numbering and conditions governing its use

In the 2016-2018 Plan, actions are planned in relation to the PNN - Plano Nacional de Numeração (National Numbering Plan) starting with the formulation of a numbering regulation which updates the main elements of the PNN and defines the services associated with the use of different numbers that comprise this plan.

ANACOM also plans to establish scenarios with regard to the evolution of Mobile Network Codes (MNC) and the definition of rules for the allocation of these codes.

Strategic Priority 4: Promote institutional and technical cooperation

Lines of action:
 
4.1 Ensure active participation at international forum with relevance to the sector (electronic communications and postal services).
 
4.2 Maintain involvement in the Body of European Regulators for Electronic Communications (BEREC).
 
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. 
 
4.5 Promote cooperation with national and international organisations and ensure coordination of activities in relevant areas. 
 
4.6 Promote the dissemination of legal and regulatory regimes applicable to the sector.
 
4.7 Promote the ITED/ITUR regime.
 
4.8 Promote coordination of the entities involved in the planning, construction and maintenance of infrastructure, including management of the SIC.
 
4.9 Develop communication with society/stakeholders, through seminars,  workshops and presentations on specific topics.

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

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.

For 2016, ANACOM remains committed to making this more participation more efficient in terms of the allocation of human and financial resources by reducing the fees incurred wherever feasible.

4.2 Maintain involvement in the Body of European Regulators for Electronic Communications (BEREC)

In 2016, ANACOM will maintain its involvement in the Body of European Regulators for Electronic Communications (BEREC), while the Chair of ANACOM's Board of Directors, Fátima Barros, will take over as vice-chair of the Body. In 2016, ANACOM will take part in all BEREC Expert Working Groups (EWG) and ad-hoc groups and should take over as chair of two EWGs (End Users and Benchmark) while continuing to hold the chair of one of these groups in 2017 and 2018.

At European level, ANACOM will also be engaged in the negotiation/revision of the new regulatory framework, which will be decisive for the sector in coming years.

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

It is a goal of ANACOM to foster the transfer of knowledge and experiences with other organisations, through groups which work in the field of internationalisation.

In the period covered by this Plan, ANACOM will continue to pursue this objective while maintaining efforts to participate in organisations that bring regulators together in Europe and elsewhere. As such, ANACOM intends to maintain efforts to participate in the working groups of the European Regulators Group for Postal Services (ERGP) and the Radio Spectrum Policy Group (RSPG), the Euro-Mediterranean Regulators Group (EMERG) and the Latin-American Forum of Telecommunications Regulatory Authorities (REGULATEL).

4.4 Actively participate in the platforms of collaboration between Portuguese-speaking countries

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), ANACOM will provide the secretariat of this Association until 2018 and will continue to play an active part in its working groups. ANACOM also plans to support the realisation of workshops and seminars of the ARCTEL training centre and contribute to the completion of studies. At the same time, ANACOM will remain engaged in an important set of activities aimed at bilateral cooperation with CPLP countries.

4.5 Promote cooperation with national and international organisations and ensure coordination of activities in relevant areas

ANACOM continues cooperation activities with other relevant sector bodies on a regular basis, particularly in areas such as spectrum management, consumer protection and communications security. ANACOM engages frequently in collaboration with the Portuguese Armed Forces, Gabinete Nacional de Segurança (National Security Office), CNPD - Comissão Nacional de Proteção de Dados (National Data Protection Commission), ANAC - Autoridade Nacional de Aviação Civil (National Civil Aviation Authority), FCT - Fundação para a Ciência e Tecnologia (Foundation for Science and Technology), DGC - Direção-Geral do Consumidor (Directorate General for the Consumer) and AICEP - Associação dos Operadores de Correios e Telecomunicações dos Países e Territórios de Língua Oficial Portuguesa (Association of Postal and Telecommunications Operators of the Portuguese-speaking Countries and Territories), as well as other bodies.

For the period of this Plan, cooperation activities are planned with FCT and other entities with a view to clarifying the national position on Internet governance, as well as with AICEP-Global with a view to promoting the sector and the transfer of knowledge.

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

During the period covered by this Plan, ANACOM plans to be engaged in a range of dissemination activities arising from regulatory changes.
Firstly, ANACOM will update the regulation of amateur and amateur satellite services, to comply with the new legal framework. This will result in new procedures associated with these radiocommunications services which will require subsequent dissemination.

It will also be necessary to conduct an internal strategic reflection on the regulation of spectrum management, with a view to the future regulatory framework. This process will entail a survey of all relevant rules on radiocommunications that will require adaptation in light of the new legal framework, either because they have become outdated or because they give rise to duplications which cause problems in terms of practical application. ANACOM's objective is to formulate proposals for revision which enable a coherent legal framework. This process will involve the participation of relevant stakeholders.

4.7 Promote the ITED/ITUR regime

Over the course of 2016, ANACOM will conduct a series of initiatives to disseminate the regime established by the new ITED manual (telecommunications infrastructure in buildings) and ITUR manual (telecommunications infrastructure in housing developments, urban settlements and concentrations of buildings). A series of seminars and workshops will be held.

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

In 2016, ANACOM intends to implement a pilot project involving parties with access to and use of the SIC. Upon completion of the design, development and testing phase of the SIC in 2015, the operational phase will commence in 2016, fulfilling the provisions of
Decree-Law no. 123/2009 of 21 May (as amended and republished by Law no. 47/2013 of 10 July). The SIC was established as a platform with the capacity and availability to serve a community of users.

As such, in light of the lessons learned during the design phase, especially in initial contacts with future users, ANACOM intends to establish a launch and implementation plan for the SIC, during which it will set up and develop the community of groups with access and full use of the system. Simultaneously, its use with real data will enable enhancement of its features.

The management of the SIC begins with the initial acceptance record and should have a duration of one year. In 4th quarter 2016, an assessment will be made of the results obtained and lessons learned.

4.9 Develop communication with society /stakeholders, through seminars, workshops and presentations on specific topics

In pursuit of this line of action, aimed at strengthening ANACOM's relationships with society/stakeholders, ANACOM will hold seminars, workshops and other initiatives that provide opportunity for the exchange of knowledge and experience, and which enable the compilation of input on various relevant topics in a context of greater sector involvement.

For 2016, ANACOM plans to carry out initiatives to disseminate and promote awareness of the law that will transpose the Radio Equipment Directive on the harmonisation of the laws of the Member States relating to the making available on the market of radio equipment.

Strategic Priority 5: Promote internal efficiency and effectiveness

Lines of action:
 
5.1 Implement measures to rationalize expenditure, guaranteeing efficiency.
 
5.2 Improve/de-materialize/simplify internal processes.
 
5.3 Automate procedures and expand the provision of services online.
 
5.4 Improve the efficiency of the data collection process, including through the restructuring of the instruments used.
 
5.5 Implement a training plan structured to ensure the development and excellence of human resources.
 
5.6 Promote an organizational culture that is more open to change.

5.1 Implement measures to rationalize expenditure with guarantee of efficiency

Cost reduction will remain a goal to be pursued by ANACOM. This objective can be achieved in several ways, including: the renegotiation of contracts, reduction in consumption, behaviour change, review and de-materialisation of processes.

The 2016-2018 period will be marked by the implementation of the strategic plan for information systems, which will improve the capacity of ANACOM's existing information systems, increasing their efficiency and significantly reducing associated costs.

5.2 Improve/de-materialize/simplify internal processes

ANACOM is set on achieving further increases in its efficiency, whereby it will continue to launch projects which enable it to streamline processes and procedures and reduce the administrative burden associated with certain work practices. This may result in the release of funds to more added-value functions, while at the same time improving ANACOM's ability to respond to external requests - this will achieve an improvement in quality and response times.

For this purpose, ANACOM plans to set up a system of litigation management indicators and improve the system as it relates to offences. There are also plans in 2016 to update the process management system at ANACOM, which will be continued in subsequent years.

5.3 Automate procedures and expand the provision of services online

In 2016, ANACOM will continue efforts to automate services and expand provision of services online, in particular through the development of new features in computer application to support spectrum management, in terms of electronic licensing. ANACOM will continue the process of making the reports of the annual monitoring plans available to the Direção-Geral da Saúde (General Directorate of Health) and municipalities.

5.4 Improve the efficiency of the data collection process, including through the restructuring of the instruments used

This line of action includes plans to extend the scope of the extranet to encompass all quarterly surveys of the various services, the annual questionnaire and the twice-annual portability survey.

5.5 Implement a training plan structured to ensure the development and excellence of human resources

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, with a focus on training that will improve and develop behavioural, technical and management skills, providing staff with tools that will enhance performance, helping to overcome the challenges that ANACOM is facing. With this objective, the implementation of the new model for employee training will be consolidated and structured to promote the development of skills in a manner more aligned with the needs of the organisation, with a view to the personal development of employees over the course of their careers at ANACOM.

5.6 Promote an organizational culture that is more open to change

During the period of this Plan, ANACOM will continue to promote a culture of dialogue at all levels of the organisation, in order to facilitate the promotion of change.

At the same time, a talent management programme will be launched, entailing a diagnosis of organisational potential with a view to the establishment of a management succession plan.

Meanwhile, ANACOM will continue actions aimed at consolidating an "ANACOM culture" which is more open to society; these actions include social responsibility initiatives, such as actions in support of Social Solidarity Institutions and the development of an internship programme, facilitating the entry of young graduates with high potential into the labour market.