3. Audit of CLSU 2007-2009


Pursuant to the initial audit of the CLSU estimates presented by PTC with respect to the 2007-2009 period, conducted by AXON (then SVP), the auditors identified three aspects which they qualified as "minor occurrences with negligible impact on results" and one situation considered as having material impact on the results - the latter concerning the processing of non-recurring (one-off) costs and revenues related to non-profitable customers in profitable areas. Additionally, the auditors indicated that some difficulties were experienced in the reconciliation of data in terms of traffic and revenue, and explained that, as a result of this situation, PTC may be undervaluing the CLSU, while also reporting that PTC had presented clarifications considered acceptable in respect of the 2007-2009 periods.

Nevertheless, in their report, presented in February 2013, the auditors concluded that "in general, the results and calculations reviewed by PTC are in accordance with the principles, criteria and conditions laid down in the determinations of ANACOM, and the data, assumptions and calculations used are sufficiently appropriate".

Following this audit, and after the hearing of interested parties and market consultation, ICP-ANACOM adopted a decision (20.06.2013), ordering PTC to resubmit new CLSU estimates for the 2007-2009 period, in order to reflect the final results of the SCA for the same years; the decision also determined consideration of non-recurring installation costs/revenues, in annualized form, and correction of a situation relating to the number of access lines in the area model.

Following performance of a new audit by AXON of the CLSU values re-submitted in the meantime by PTC, the company conducted analysis of the implementation of the modifications and corrections ordered by ICP-ANACOM in its decision of 20.06.2013.