Automated Transcript
Mike: Hi, everybody. My name is Mike Mills, Business Director at Gamma.
Dave: And I’m Dave Williams, Group Commercial Director at Gamma.
Mike: Now we’re gonna talk today about… some might say the driest subject in telecoms, but that’s absolutely not the view of some of our partners. It’s probably one of the most important, and that’s regulation. Now I just wanna caveat this with… regulations are highly complex subject and nuanced, and you should definitely take legal advice. This is our opinion rather than absolute regulatory advice. So, what does it mean to Gamma to do it properly, Dave, when it comes to, international telecoms regulations? And how are we keeping our customers protected?
Dave: So I would say, Mike, well, you and I, to be honest, have spent many hours in an evening kicking this around. So it’s funny you asked the question. That doing it properly depends on the expectations of your end customer and the risk appetite of the business you’re in. Now for Gamma, though, those two points are really critical. So firstly, our risk appetite is very low. We don’t want to take risks as a business. You know, you and I have grown up in the business, and you and I don’t want to write bad business on a sort of personal level as much as a business level. Gamma, with its strong UK channel base with SMB and Enterprise customers, the impact of writing bad business outside the UK is not so much the regulatory issues that might arise abroad. It’s the UK reputational impact and the loss of service to really critical customers in our core geography.
Mike: And, actually, we’ve had some very real examples, I think, just this year where partners have called us and said, look, our Spanish numbers are turning off in forty hours. Can you help? And that’s an increasingly common problem, sorry, across the industry.
Dave: Yeah. So doing it properly comes with a cost. There’s levels, of course, of debt that you can go into globally with footprint. And by that, I mean, sort of, you know, boots on the ground, resilient SBCs in every geography, number range holdings interconnects with every, you know, domestic tier one supplier. There’s levels above that which is, you know, trusted interconnects with key suppliers in each geography, a deep understanding of requirements from emergency calling, porting, quality of route type level, which is where we are in most of our core geographies, and overlaid, I think, with an appreciation of the consequences… and we’re not talking necessarily telecoms regulation here. We’re talking tax. We’re talking, you know, compliance outside of just frankly our area of expertise. And so therefore, in order to do things properly, you bring in those competencies. You take advantage of expert knowledge around the world, frankly, as we have been, as you know. And you overlay that with how you wanna do business with your customers. So just probably to recap, I would say we’re not sort of here with a crib sheet of two hundred and fifty countries or whatever it is with sort of tick box. We’re saying, you know, it’s very easy to go out to a geography, establish a partnership, and, you know, route some traffic. It’s very, very difficult to actually stick your neck on the line reputationally and say, we stand behind this as a service, and you can trust us. And that’s where I wanna be.
Mike: Yeah. I think you touched on some really interesting kind of points earlier on. And one of the things that sort of resonates with me is the sort of human cultural element, the sort of each geography and territory is very different culturally to do business in, but also the kind of you know, we need to put our name to a service. Right? And we need to be able to stand behind it. And if you’re not confident in your supply chain, you don’t have the right relationships. I think that’s really, really difficult to try and stand behind. And certainly, you know, I know from experience, we’ve taken our time in doing that and finding the right partnerships and getting the right advice and putting the right sort of robustness under the hood of what we’re trying to do. So, yeah, I think that’s really interesting. In terms of the general market, you know, one of the things I see that is quite conflicting in the cloud communications market is you’ve got, you know, all this global regulation around stamping down on nuisance calling and that kind of relatively heavy handed approach both networks and operators are taking. And then you’ve got the cloud communications market, which is sort of sat in the middle of this trying to circumnavigate. And it’s a really challenging landscape for cloud communication providers to operate in when you’ve got a need for global communication enablement. So you’ve got, you know, cloud platform A wants to sell to customer in territory B. But in order to do that, you in some instances, have to be landed in that territory with a point of presence. What’s your perspective on how communication providers can really make the most and do their best in that tough regulatory environment, getting tougher frankly by the week? And then a customer need and requirement to provide global services as if it’s software. But I’d love your insight and thoughts into that because that’s a topic I talk to customers about nearly every day of the week, and it weighs heavily on their minds. They’re getting squeezed as they’re trying to grow their business by, you know, regional and national regulators.
Dave: What we’re seeing is that regulators in each geography are getting increasing pressure from their governments, you know, UK’s no exception, to reduce the amount of scam and nuisance calls because if you take the UK, for example, the banks are now having to pay compensation to what they call authorised push payments, which is basically to say, even if you have authorised a payment on your laptop or whatever on your phone, if you’ve been scammed, then they have to give money back. So that’s clearly leading to this industry wide endeavour, which is to try to reduce fraud and scams. And the current sort of thought process across regulators in the UK is no different, is that in order to reduce scams, you need to try to reduce the amount of spoofing that you have where people effectively purport to be somebody else. Your bank, for example.
Mike: Yeah. So that’s presenting a number that’s, for example, isn’t yours but belongs to a bank?
Dave: Well yeah. Good question. So spoofing, technically, is just presenting a number that you own on the device that isn’t attached to that number. Right? So spoofing is a legitimate way of doing business. And, actually, lots of our customers legitimately spoof their numbers to, you know, from a call center or whatever. But in the context of this, we’re talking about maliciously pretending to be someone you’re not. Now in the UK, we’re blocking calls from abroad, both network and presentation numbers now that are presenting UK numbers to UK customers. But in other geographies, those restrictions are in place, but they’re also restricting how many times you’re allowed to suballocate phone numbers. So suballocation is basically saying… you get a number stock from the regulator, and they’re allocated to a network. But as we know in the UK, it’s very common and Gamma takes your number of stocks and allocate them on again to a reseller who may themselves, as part of their service wrap, allocate them again to another sub-reseller. And that’s common and, you know, in the UK, I think, we’re all sort of sitting here thinking, well, that’s led to a very innovative market. It’s not just tier one providers that provide telco services as you know in your business unit, of course. But what’s taking place overseas is the regulators are trying to get closer to understanding the ownership of the phone numbers, which is resulting in restrictions in how far away the regulator was allowed to be to the end user of the service. So sub allocation restrictions. So France, for example, doesn’t allow sub allocation at all. So as of, I’m gonna say, Jan 23, I think, every provider in France now has to, like, allocate numbers that were directly given to them by the regulator. Now you can imagine the chaos of being with something like six root applications. Right. And, of course, there’s not that many numbers knocking around. So France actually had to remove the geographic restrictions so that it effectively had a sort of nomadic concept, and they’re allocating, I think, ten thousand. But even so, you know, for the sort of interesting cloud platform provider solutions that you and I understand from your customer base. Our partners don’t necessarily need ten thousand, but they’re still going to enable voice as a communications channel to our overall global service. Yeah. So it brings with complexity.
Mike: Okay. And I just love your take on the things we’re doing to help our cloud customers to circumnavigate this. I know we’ve been doing a lot of work on, you know, first of all, making sure that we’re a regulated licensed provider in those territories and then making sure that we’re able to support our partners in doing it the right way to provide a risk free or lower risk approach to providing, you know, global pan European services in that nuanced cloud environment.
Dave: Yeah. So starting again with the UK, the UK is obviously looking at “know your customer checks”. We’re the only on businesses. There’s those sort of know your customer check on a page, use mobile, sort of interesting sort of slant where the scam journeys operate the way we are. Know your customer checks have applied from other geographies for a lot longer. So there’s an increased amount of diligence needed in certain territories. Germany, for example, you need to evidence that your business is located in the region, there’s other sort of passport requirements for domestic services. We will effectively manage those. We have interconnects with, as I said earlier, sort of key strategic partners on a strong, you know, relationship basis. And actually, a lot of this is critical because if something goes wrong, should probably say when, I think we need to be honest here. Right? There’s a very, very complicated ecosystem globally here. And one of the things that I consider us to bring to the table is well, firstly, an openness that things will go wrong somewhere at some point. But, as and when they do go wrong, we know what to do, who to speak to, can act on things quickly. We’ll provide notice as quickly as we physically can. There’ll be no sort of on two days notice, your number’s getting turned off as far as we can manage it. So, yeah, I would say open, honest, frequent communication of what we’re doing, how we’re doing it, why we’re doing it, and lost count of what I said. So I’d say communication is important. I think we obviously took an investment decision to build strategically for our business with Coolwave being our investment vehicle, our network vehicle globally. You know, I think we’ve got a really good core team of engineers, commercial, reg, compliance working on this building. So yeah, PoPs are going in the right places. Licenses are going in all the time. I think we’ve got, what, ten in a hopper now with regulators. We’re working with our suppliers to ensure that the porting and emergency services is working. We’re testing all that. We’re contractually looking at an agency contract. So in the event that there’s a territory where sub allocation’s not allowed, Gamma will almost certainly not be a number range holder unless there’s enough traffic volumes. So we’ll effectively take numbers from a range holder, tier one range. We’ll be the only sub allocator allowed in that network chain, and then we will effectively contract with the end user. And we will do that with our partner being the agent representing the end users. So what that effectively means is, Gamma will take on the KYC checks. We’ll need our partners help to do that. We don’t have any particular interest in that end user. You know? We’re not out to sort of eat everyone’s lunch or anything. But that partner will help us do the KYC, and then we’ll also, because they have the relationship with the end user, they’re able to wrap our charges into the end user’s bill. The key thing about that is we’re really keen, and I think the way this will work is our partners are not able to mark up the services. Fundamentally, if the partner’s marking up the services, they are, for all intents and purposes, regardless what our paperwork says and we all agree is happening, reselling the service.
Mike: And visibly regulated. So that is the eyes of the regulator.
Dave: So, effectively, our world would be at a sort of tri-party order form Gamma, Coolwave, partner, end customer, sensing out who’s doing what. Effectively, we are the voice enablement provider Trusted by that partner acting as an agent for that customer.
Mike: And that’s gonna provide, we’d hope, a high level of certainty because when, you know, from a regulatory point of view, we’re doing it exactly as needed. We’re being clear on roles and responsibilities. There’s no ambiguity in backing that up with a quality supply chain. It’s gonna give us what we need to provide that comfort level. You touched on that a couple of points earlier. I think are really critical in this market. The first one is just expertise. And, you know, I’ve been in this game twenty five years. Gamma’s been doing it twenty. You know, the team behind this and the team that we’ve pulled together is just full of that experience, because this is a horrifically complicated world, and it’s changing all the time. And, you know, for me, when I look at it, that is the human element is, first of all, it’s in our entire DNA as a company, and we’ve been working on client relationships. I’ve had them for twenty plus years with some partners, and, you know, some of them we became friends over the years. I think coupling that with a deep level of expertise is really important here. They need to be able to pick up the phone and say, “we’ve got a problem, help”, and we can communicate openly and transparently. And I think that’s getting lost a lot in the wholesale world today. The wholesale voice market, messaging markets became very transactional as price has been driven to the floor. A lot of that expertise is just missing out how the market you know, we look at a bunch of our competitors, and they’re losing that expertise. And it was… one of the things I’m really passionate about is making sure that if we’re gonna do this, we need the best people at the front end, whether that be regulatory advice, technology, technical people, support people. Because I think that’s the secret sauce here is we’ll do it with a human touch. It’s in, you know, it’s in all of our values. We all wanna do the right thing. But I think that point, I really don’t wanna get lost on the audiences. That’s critical from our perspective.
Dave: And I just come in there. I totally agree. It would be easy just to say that, but I think I hope that anyone watching or listening to this understands the sort of long history of partnership with your cloud. But I think the other critical thing is for Gamma in particular and Coolwave in particular, an issue affecting ten users in Estonia on a Saturday morning actually is an issue which impacts the entire UK business. Other geographies, there’s an end customer on this which has a satellite office, which may or may not be important to another provider, but it’s super important to us in the context of the relationship, the spend, the customer’s overall quality of service and wrap that we’re looking to provide.
Mike: To bring that to light, this is a real example we had maybe nine months ago. We lost service to one of the largest hotels in the world because the supply chain wasn’t rigorous enough and, you know, it took three days to unpick. They couldn’t take orders. It had a severe knock on impact. That was because we were dealing with a supply chain that was suboptimal and that’s critical here. If I could give people one bit of advice if they’re lucky to do this, let’s just understand the supply chain and, you know, make sure there’s a whole lot of quality providers underneath it, and you’ve got access to as far down the chain as you can get. So, look, I wanna to kind of sort of pivot this slightly and just talk about some of the interesting, challenging political landscapes right now and how you see that impacting on this globalisation piece because, you know, we’ve talked about France being problematic. We’ve got, you know, some interesting geopolitical issues going on globally right now with the US and others. And I think all of that ultimately flows through into regulators and governments and their thinking. What’s your sort of perspective on how the geopolitical landscape is making telecoms have to rethink things?
Dave: Well, I think I said earlier that regulators in their domestic markets are becoming a bit more insular. There’s nothing sort of malicious in that. I think it’s just that they’re seeking to gain controls of things they have within their sort of wheelhouse, and one of those is controlling their number stocks. You know, think things within their gift. I think it’s probably an element of their big sort of domestic tier one providers. I suspect they’re talking to them more than the global cloud IPs. So, you know, in one ear, I suspect they’ve got a sort of narrative which will probably support that sort of localisation and supply, to be honest. But again, it’s just the nature of who they’re speaking to. If you take Ofcom, Ofcom have always had the power to go after a problem actor providing a telephony service regardless of whether or not they’re a range holder. But to my knowledge, they never have. You know? So, yeah, geopolitically, there’s just obviously a global effort, right, to try to reduce bad traffic. You know, I haven’t got numbers in front of me, but we can post them with the podcast. The amount of scams that… telecoms originated scams as a percentage of overall scams is actually not that light. Right. But the value of damage that it does financially and from a monetary basis, you know, telecoms regulated scammed is way, way higher than the proportion of instance. And that’s because, as you can imagine, that you can just get so much more trust over the phone speaking to somebody, and therefore, you end up being kind of more and more convinced. So that’s sort of the world that we’re all trying to work with, and of course, the knock on impact of that is in theory a sort of loss of innovation, more bits of hoops to jump through, rightly or wrongly, and a domestic and regionalisation of control and constraint, which will, I think, ultimately, if we’re not all careful, start to impact upon the sort of globalisation of software. Cloud and all the audio stuff that you and I spend our lives talking about.
Mike: And I think just kinda again, the point on stifling innovation is a really interesting one, and this definitely has the propensity to do that. But I think the kind of devil’s advocate view that I buy into is there’s being creative and innovative and disruptive, but doing it under the kind of guardrails of the relevant regulation and doing it in conjunction with, you know, people buy telco. Telco is a hugely regulated market. But with that regulation, historically, it’s kept certainty, robustness, scale, etcetera, etcetera. And then you’ve got the innovation happening at software level. We definitely see from a Gamma point of view that the room in the middle to be a someone who’s doing it with the robustness and reliability and scale and diligence of the telcos A, listed and B, operating at scale. But being able to fill the gap that exists in the market for someone who’s technically very capable, but very risk conservative, and also being able to be innovative and operate at scale. And I think that’s a big opportunity in the market for anyone that’s prepared to do that, and certainly that’s where we’re putting our investment in focus because that space exists right now.
Dave: It is easy to take a software product and roll it out publicly with very little localisation required. And, actually, it’s actually pretty easy to make a phone call work. I believe.
Mike: Technically.
Dave: It’s technically as easy. And in fact, you know, you and I have had conversations with some of our engineers around this. You know, number presentation settings is a great example. Plug in a number, make it work. But, you know, “you can’t do that, guys. You’ve gotta constrain it. There’s requirements here.” And, actually, I think what’s happening now is there’s an increasing amount of awareness and maybe fear, but certainly conscious awareness of what doing it right means in each territory. And I think one of the things that we can do to help these big hyperscalers, people with global ambitions on a software basis, but perhaps not on a telephony basis. We can plug that gap, I think, and we can sort of take what we know and, you know, implant it into the solution as best we can.
Mike: And, you know, we talk to many of the big software providers very, very regularly where we strategically align to people like Microsoft and AWS. We take our services to market. I think, you know, there’s a reason that schemes like Operator Connect are doing really well because it lets the telco do what the telco’s good at, and it lets the software company do what the software company’s good at. But then I think that’s why they’re becoming more and more popular as it’s “you stay in your lane, we’ll stay in ours”, and actually together, that’s how we win in the market.
Dave: I do.
Mike: But I think the sort of, you know, the interesting market opportunity that we’re definitely seeing is that sort of, you know, way back in the day, if you wanted to have a cloud platform based in, I don’t know, Germany, for example, but you then wanted to deliver a call to Japan, you just do traditional IDD and, you know, long line the call with it, and also implementation of the world’s IP space. And then the cloud platform, you know, decided and made the smart techy changes to change presentation number. Now they’re having to actually land it much closer to territory, provide it locally as a call. So I think in one respect, it’s definitely you know, going back to the geopolitical stuff, it’s definitely, meaning that when calls are delivered in country, they’re being done properly, but it’s causing a huge amount of grief and headache and thought having to be inputted in from the cloud platforms to deliver that in a way that end users expect, because they just want it to work. Right? They wanna, you know so you’ve got an employee in Germany, and he wants to speak to his colleague in Japan, that just needs to work. And then similarly, if a Japanese colleague, wants to talk to another Japanese colleague, that again just needs to work. And they’re having to operate very differently. So I think there’s great opportunity in the market for service providers to really seize on that changing of the old guard into the new world. And I don’t want that lost on people that you know, it’s probably one of the biggest opportunities out there for service providers to monetise this sort of ever changing, ever more complex environment by embracing people that do it properly.
Dave: Yeah. But, of course, what this all means is the sort of the domestic and the sort of regionalisation of compliance is effectively as biased to entry in each job. You know? And it’s not just on a telephony basis. You know? There’s lots of good reason for it. If you take some NIST 2, tax compliance, all the other stuff, all the sort of making it so they’re not allowed to root cause into a geography from those numbers. So I think the sort of the days of a hyperscaler going into a geography and saying, you know, “I’ll just deploy here and everyone can use it”, increasingly looking like they’re behind us. So what I think it ends up being is you end up having to compartmentalise the bits of your solution, and you need to give those sort of chunks of the solution to parties that you trust. And I think if we, and I’m sure there’s lots of our competitors are doing the same thing, but if we can provide that sort of voice slice on a trusted basis, then I think, you know, that’s where we win, and I think that’s where our partners went because we just sort of, we each stick to that thing.
Mike: So, we’ve covered quite a lot in this session. I think the sort of key takeaway is for me, really that kind of doing it properly means, you know, working with the local regulatory frameworks, the best of breed and country providers, you know, doing it so that we can stand behind it and doing it to a level with great people at the front. That means that if and when it goes wrong, you’ve got the best people picking you, best people making the decisions on behalf of you. And, actually, yeah, I think people take one thing away from it, is if you wanna work with a provider that is doing this and giving you that comfort in your business, I think we’re a really safe pair of hands to do that. And, you know, we’re doing this at scale globally and pushing out really aggressively. So, yeah, I think that for me, those would be the the key takeaways. The market’s getting more challenging and working with a provider that, A, does it properly, but B understands the human value of it, both partnerships and then helping you to succeed in a more challenging landscape.
Dave: Yeah. I’d also probably say we’re really open to just having a… I was gonna say thought leadership type of conversation. It’s probably a thought-provoking conversation, but not anything else. But having a conversation around you know, if a partner or their customer has a specific geography in mind, we can either tell them why we’re not there because it’s really hard or what it might mean for us to get there and when. Our road map is as much driven by opportunity as around sort of strategic, sort of painting the world purple. You know? I would definitely say anyone wants to speak to us about opportunities at any given territory, then do reach out, and we’ll be honest with you about what we think about it and then how we can do it.
Mike: Well, look, Dave. That was super insightful. As always, this is a topic that may appear dry at first, but actually, the more you dig into, I think it’s critically important to successful service deployment and global communication enablement. Thanks, everyone, for listening. My name is Mike Mills, and, look forward to speaking to you all soon.
