!

Report regarding the retail sales practices of Canada’s

large telecommunications carriers

Telecom and Broadcasting Notice of Consultation

CRTC 2018-246

August 30, 2018

 - !2 -

Table of Contents

I. INTRODUCTION/EXECUTIVE SUMMARY…………………………………..….3

II. OUR RETAIL OFFERINGS IN A COMPLEX MARKETPLACE…………...….6

III. ROGERS’ NEEDS BASED APPROACH TO RETAIL SALES……….……....7

a. Our sales methods………………………………………………………………7

b. Our employee training supports the needs based approach……….………8

c. The needs of more vulnerable customers are addressed…………………..9

IV. COMPENSATION AND INCENTIVES TIED TO CUSTOMER

SATISFACTION…………………………………………………………….……..10

V. MONITORING CUSTOMER INTERACTIONS…………………………………12

VI. COMPLAINT RESOLUTION MECHANISMS……………………………….....13

a. Customer Complaints…….……………………………………………….….13

b. Employee/Third Party Complaints………...…………………………………16

VII. CONCLUSION……………………………………………………………………..17
 - !3 -

I. Introduction/Executive Summary

1. Rogers Communications Canada Inc. (Rogers) files this intervention in accordance

with the procedures outlined in Telecom and Broadcasting Notice of Consultation
CRTC 2018-246 (TBNC 2018-246). In initiating this process, the Commission is
responding to the Order in Council (the OIC)1 issued by the Governor in Council on
June 6, 2018, which requires the Commission to make a report, by no later than
February 28, 2019, regarding the retail sales practices of Canada’s large
telecommunications carriers. We look forward to appearing at the public hearing to
consider retail sales practices, which is scheduled to commence on October 22,
2018.

2. The concerns raised in the OIC and in TBNC 2018-246 relating to the retail sales
practices of telecommunications carriers are a priority at Rogers. We take every
complaint seriously and we consistently strive to improve and enhance the quality of
sales and service we provide to our customers. For that reason, we understand the
Governor in Council’s interest in having these issues considered and addressed by
the Commission.

3. Today, Rogers serves close to 13 million wireless, wireline, TV and Internet

customers. Our goal is to deliver the best possible experience to them. We
achieve that by ensuring that the products and services they receive meet their
needs and budgets and by committing to interact with each of our customers in a
manner that is clear, timely and accurate and that uses plain language. Over the
past year, Rogers sales and service agents interacted with customers more than 60
million times. The number of complaints we received during that period of time
regarding the purchase of services involving either a Rogers employee or third party
agent represented less than 0.004% of those interactions.

4. Given the relatively small number of complaints we received, it is clear that the
issues outlined in the OIC and in TBNC 2018-246 are not indicative of a systemic
problem within the Rogers organization. Nor is there any type of organized attempt
to mislead customers or to encourage them to purchase products and services that
they do not want or need.

5. The issues are, rather, a reflection of the complexity that exists within Canada’s
competitive telecommunications and broadcasting distribution industry, where
consumers are offered a wide variety of products, services and plans. Given the
choices available to consumers, there may occasionally be some
miscommunications or misunderstandings. Rogers fundamentally believes,
however, that it is our job to continually improve our sales and service processes so
that our offerings are communicated in a clear, simple and fair manner, to identify
any problems that may arise with those processes and to take swift action if
warranted to resolve concerns to the satisfaction of our customers.

1 Order in Council P.C. 2018-0685.

 - !4 -

6. If we become aware of instances where an agent has become overly aggressive or

has misled a customer, Rogers takes immediate action to address the specific case
and also looks for opportunities to improve our processes, including by enhancing
our training methods, monitoring systems and complaints procedures. We are not
suggesting that there have been no such instances of misleading sales practices.
We are saying, however, that such behaviour is extremely rare at Rogers and that
Rogers does not encourage or support the use of such sales tactics. As noted, our
records indicate that there have been very few complaints made about our sales
practices when compared to the enormous volume of interactions that our sales and
service agents (which includes both employees and third party agents) have with
consumers.

7. Like almost every company in Canada that is engaged in sales, Rogers employs
sales targets to incent our agents to sell our products and services. These targets
are achievable and the methods used by our agents to meet them are fair and
transparent. In fact, we have embedded customer satisfaction metrics into our
agents’ sales performance objectives, in large part, to encourage clear, simple, and
fair sales practices. This applies to every team member, at every level. Rogers has
a zero tolerance policy for unethical or misleading sales practices.

8. Rogers has put in place a number of mechanisms to ensure the best possible
experience for our customers and to identify any issues that might require action.
These mechanisms include:

• adopting a multi-channel sales methodology, which teaches agents to succeed

by building long-lasting relationships with customers;

• regularly reviewing our calls and sales interactions via call listening and quality
assurance programs and by providing coach back opportunities;

• holding quarterly focus groups to capture feedback;

• hosting best practices training sessions;

• sending our customers confirmation emails after purchase;

• deducting any commission if a customer returns a product or service within a

certain period of time (i.e. Rogers’ claw back policy);

• employing mystery shoppers to monitor the quality of service our customers

receive and their experience at retail stores;

• administering disciplinary actions, up to and including, termination of

employment; and

• conducting quarterly and annual audits of both field and sales incentive
programs.
 - !5 -

9. If there is a complaint from a customer, Rogers makes every effort to resolve it to

the satisfaction of the customer. We have procedures in place that are designed to
reduce the burden on customers who have experienced a problem, by having a
strict escalation process, first to managers, then to the Office of the President and
finally to the Office of the Ombudsman. Rogers is the only telecommunications
carrier in North America to have an Ombudsman to provide an impartial review of
customers' complaints.

10. Our objective in developing and implementing all of these training, monitoring and
complaint mechanisms is to ensure that our number one priority is the needs of
Rogers’ customers. We have a relationship with nearly 13 million Canadians. We
put our customers’ needs first in everything we do and treat them in a fair and
respectful manner. Not only is that the right thing to do, but it is at the core of our
business strategy to develop and maintain positive long-term relationships so that
our business will continue to grow by connecting Canadians to what matters to
them.

11. In response to the four issues highlighted in the OIC and in TBNC 2018-246, we
submit as follows, in respect of Rogers’ sales practices:

• Rogers does not employ misleading or aggressive retail sales practices. We

use a needs-based approach to retail sales that is designed to meet the needs
and budgets of our customers.

• We have implemented various measures and controls that are specifically

designed to monitor, identify and mitigate the risks that consumers could be
subject to misleading or aggressive sales practices. The success of these
measures and controls is evident in the very small number of complaints we
receive annually in comparison to the size of our organization and the millions of
interactions we have with customers each month.

• The consumer protections respecting retail sales practices and contracts that
are currently in place to empower consumers to make informed decisions and to
promote the fair treatment of consumers in their relationships with
telecommunications carriers are sufficient and effective.

• There is no evidence that would support any proposal to strengthen or expand

the scope of existing consumer protections or to create new protections that
would further empower consumers to make decisions with respect to their
telecommunications and broadcasting distribution services. The evidence
submitted by Rogers in this proceeding demonstrates that our customers are
treated in a fair and respectful manner when purchasing the services we offer.

12. For all of these reasons, Rogers believes that the current protections that are in
place – which include the Wireless and TVSP Codes of Conduct, the processes
established under the Commission for Complaints for Telecom-television Services
(CCTS), the Competition Act provisions on marketing and other applicable
 - !6 -

requirements, as well as our own internal complaint, monitoring and training

processes – are sufficient to ensure that customers are treated fairly when they
purchase services from Canadian telecommunications carriers. In our view, the
report issued by the Commission following this proceeding will demonstrate that
there is no public interest or policy rationale that would justify the imposition of
additional regulations relating to retail sales practices in the telecommunications
industry.

II. Our retail offerings in a complex marketplace

13. Rogers operates services on multiple platforms using a variety of technologies and
distribution systems. Our businesses are supported by thousands of frontline staff
who operate within a complex sales and service environment.

14. In this environment, Rogers strives to deliver the best possible experience to our
customers by matching products and services that meet their needs and budget. If
concerns are raised about our sales practices, whether they are identified through
our own ongoing monitoring mechanisms, by customers or by employees, we
immediately take steps to address them. If an instance arises where we have not
met the needs of our customers, we will work with our team to make it right. We
have clear processes in place that enable us to swiftly identify and address any
issues. We believe that the best way to serve our customers is to maintain a
healthy, supportive workplace for our frontline team with the right training, support
and ongoing coaching.

15. The telecommunications and broadcasting distribution industry is particularly

complex. It consists of a large number of competitors, each of whom offers a range
of products and services, packages, promotions and plans, all at varying retail price
points. Some companies offer a handful of select services, while others offer a
complete range of products and services. Some offer bundles, while others do not.
Some have customers who have subscribed to the same package or plan for years
and are transitioning them to new in-market packages. Some offer their products
and services using time-limited incentives and promotions. All of these product and
service offerings are not only constantly changing to respond to new technologies,
customer preferences and competitors’ offerings, but they are also advertised on
multiple platforms and through various types of media.

16. Another unique feature of the telecom and broadcasting distribution market,
particularly for wireless providers and cable distributors, is the myriad of older
legacy plans to which large numbers of customers continue to subscribe.2
Switching from legacy plans to new offers can often pose challenges because
customers typically want to continue to receive the exact same products and
services at the same price. Often our sales agents are asked to construct a product
and service package that can as closely as possible replicate the collection of

2Legacy or “grandfathered” plans refer to older plans that customers subscribe to, but are no longer
offered in the market.
 - !7 -

products and services to which the customer has historically subscribed. New
offerings are often not configured that way and require a change to a customer’s
subscription.

17. Rogers is committed to a clear, simple and fair approach in every customer
interaction. Given the nature of the market in which we sell our products and
services, we are constantly trying to reduce complexities and avoid
miscommunications with consumers. We listen to our customers and our frontline
teams as part of our continuous improvement programs, and this provides insights
that help transform challenges into opportunities. Within this dynamic, if the human
element is considered, mistakes can occur, and Rogers takes steps to make it right
in such instances.

18. Over the past year, Rogers sales and service agents interacted with customers on
more than 60 million occasions, which resulted in a small number of complaints
(2,200) from customers that were sales related. That represents less than 0.004%
of all interactions that our sales and service agents engaged in during the relevant
period.

19. Even so, we view every complaint as an opportunity to improve the quality of sales
and service we provide. Our goal is to receive zero complaints.

III. Rogers’ needs-based approach to retail sales

20. At Rogers, we are constantly improving our sales and service techniques, our
training methods, our monitoring, our complaint resolution processes, our sales
targets and our compensation incentives. Ensuring our sales and service agents
use a needs-based approach to selling products and services informs everything we
do.

(a) Our sales methods

21. Our commitment to customer service is reflected in the size of our frontline teams.
Rogers employs over 20,000 front line employees across Canada in full- and part-
time sales and service positions that support our four brands, Rogers, Fido, chatr
and Cityfone. This includes several thousand customer care employees whose
primary function is to solve service and billing problems for customers, but who also
contribute to overall company sales results if customers wish to order products
during their service interactions. Our third party sales agents, which include
authorized dealers, telesales suppliers and customer service vendor staff, represent
one third of the total front line employees. Additionally, we estimate several
thousand more individuals are selling Rogers products and services through
agreements with third party retailers (eg. Best Buy, Walmart). Our customer care
support centres and third party call centres are exclusively located in Canada.
 - !8 -

These centres handled more than 60 million sales and service related
communications with consumers from July 1, 2017 to July 16, 2018.3

22. At Rogers, we employ a variety of sales methods and channels that are designed to
enable our customers to engage with us in any way they want - whether that is
through online websites, live chats, mobile apps, in store, door-to-door or over the
phone. In ensuring our sales and service agents can be reached in so many ways,
our goal is to make each customer experience seamless and interconnected.

23. Rogers also has a large number of retail touchpoints (corporate stores and partner
retailers). They span 3,269 locations nationwide covering three brands (Rogers,
Fido, chatr). Authorized Dealers make up an additional 465 points of presence and
third party retailers (including Best Buy and Walmart) account for 1,692 stores.

24. Rogers has developed a high-performance culture by investing in sales and service
teams that are focused on meeting our customers’ needs and creating best in class
customer experiences. Our multi-channel sales methodology introduced in 2018,
equips our teams to succeed by teaching agents how to have connected
experiences with customers and build long-lasting relationships. By the end of
2018, all of Rogers’ sales staff will be trained in one consistent methodology.

25. Rogers believes that the best way to serve our customers is to maintain a healthy,
supportive workplace for our frontline team with the right training, support and
ongoing coaching.

(b) Our employee training supports the needs-based approach

26. Rogers’ sales methodology also raises the bar for customer service. Employee
training materials consistently encourage staff to probe for a customer’s needs and
to understand each customer’s lifestyle. We want sales agents to ask discovery
questions so that the wants and needs of each customer can be satisfied. By
emphasizing customer needs, we are ensuring that employee behavior is balanced
and focused on ensuring that those needs match the products and services our
customers acquire.

27. Similarly, our employee training materials are focused on developing skills related to
gaining a commitment or approval from customers in order to proceed with an
informed transaction. Informed consent is a critical element of sales and allows
customers the opportunity to acknowledge if they feel comfortable with the
information they received and with the decision they are making. Our sales
methodology reinforces the importance of delivering accurate information as the
means to achieve a successful sales interaction.

28. Rogers provides comprehensive training to frontline agents throughout an

employee’s time with the company. During the initial orientation and at key points

3The period of time between July 1, 2017 and July 16, 2018 is used in this submission because it is the
same time period referenced by the CRTC in its July 16, 2018 Request for Information.
 - !9 -

during their career with Rogers, we provide detailed training on sales and service
methodologies, processes and policies, product information and order entry and
billing systems. This includes a Business Code of Conduct that establishes rules
relating to organizational risks, such as conflicts of interest, ethics, confidentiality
and compliance with laws. Employees are also required to acknowledge their
understanding of this training by digital signature, which is stored in personnel
records. Each year, employees are required to refresh their knowledge of, and
commitment to, the Code of Conduct.

29. In addition to the above, we provide sales and service agents with marketing and
sales materials that reinforce the needs-based sales approach that is embedded in
our employee training. Sales materials are accessible through a variety of methods,
including: (i) web-based tools that provide current information on all Rogers, Fido,
chatr in-market products and services; (ii) an easy-to-use app for retail sales agents
that keeps users up-to-date on the latest Rogers and Fido products and promotions;
(iii) a certification program that includes wireless device agnostic content for
frontline sales agents; and (iv) a weekly communication that highlights
recommendations for key areas of focus leading into that respective sales period.

30. Rogers ensures compliance with employee training and sales materials, proactively,
through quality monitoring, audits of agents, customer surveys, a continuous
improvement program called Centre Ice, mystery shopping, quality assurance
insights, speech analytics and agent coach back processes, and reactively, through
customer and employee complaints, survey response teams, and internal fraud
monitoring.

(c) The needs of more vulnerable customers are addressed

31. Our needs-based sales practices are also designed to ensure we are meeting the
needs of all customers, including those that may be more vulnerable, such as
Canadians with disabilities, seniors and those whose first language is not French or
English.

32. Rogers’ website (www.rogers.com) includes an accessibility services microsite that

supports customers with disabilities. Included on this site are numerous methods of
support we offer to customers with disabilities, including Text911, TTY Message
Relay Service, Video Relay Service and a dedicated star hotline (free call from
Rogers Wireless handsets) and a direct telephone line to our Rogers Accessibility
Service Team. We also implemented “Skip Links” into each of our home page
navigations to make it easier for customers who are visually impaired to access the
content that matters most to them. This allows screen reader programs to skip non-
relevant website material. Further, we have a live online chat service available for
customers to ensure they can always access support and guidance if they have
questions regarding their bill or about purchasing a service.

33. The methods we employ to engage with seniors and those customers who may
have a language barrier do not differ materially from the techniques we use for all
 - 10
! -

other customers. Both groups can access our sales and service staff using any of
the above methods, but because of their unique needs, each group tends to rely on
one or two methods over others.

34. In our experience, seniors rely more on in-person interactions where our staff can
provide live product demonstrations and one-on-one instructions. We train our staff
to be thoughtful and sensitive to each customer’s individual needs. The Rogers
Field Sales team has dedicated staff who support new product orders for seniors’
residences. In most cases, seniors may request these internal team members by
contacting Rogers directly to pre-schedule convenient personalized appointments.

35. English- and French-language materials are available in all provinces. We

simultaneously deliver French- and English-language material to the Quebec
marketplace and make company material available in English and French for all
employees, vendors, shareholders and the general public.

36. As for consumers whose primary language is not English or French, we have
discovered that they often choose online ordering or live chat interactions where the
use of translation tools can easily be integrated to facilitate conversations with
agents. Rogers does, however, employ sales and customer care agents (currently
200) at all hours of the day who speak Cantonese and Mandarin. We also employ a
number of agents who are conversant in other languages and endeavour to make
those individuals available, on an ad hoc basis, to those who are more comfortable
speaking in their primary language.

37. Regardless of the specific needs of each customer that interacts with our sales and
service agents, Rogers strives to ensure that the information we provide is
complete, clear, timely, accurate and uses plain language.

38. In providing service to consumers, Rogers complies with the provisions of the
Wireless Code and the TVSP Code relating to the use of plain language, key
contract terms, disclosure of information, notice periods, alerts and trial periods at
the point of sale. Rogers applies the principles of the Commission’s consumer
codes to all materials, including critical information summaries, agreements and
terms of service (including privacy and acceptable use policies). We also comply
with the provisions on marketing practices in the Competition Act, as well as other
applicable requirements governing the manner in which we market our services,
which provide for monetary penalties.

39. Ensuring that each service a customer receives from Rogers is suitable and
provides them with what they want is central to the mandate of our sales agents.
That is the whole premise underlying our sales methodology.

IV. Compensation and incentives tied to customer satisfaction

40. In developing compensation packages that include targets, commissions, incentives

and bonuses for employees and third parties, Rogers ensures that a balance exists
 - ! 11 -

between our goal of meeting each customer’s needs and creating incentives for our
agents to sell products and services. As outlined throughout this submission,
Rogers’ multi-channel sales methodology emphasizes the importance of knowing
our customers’ needs in order to present the products and services that best suit
their lifestyles. Consistent with this approach, customer satisfaction metrics are
embedded in sales performance objectives and if a customer returns a product or
service within 90 to 130 days (depending on the nature of the product or service),
the sales agent receives zero compensation for that transaction.

41. Rogers’ employees qualify for varying degrees of compensation related to sales
performance depending on their role in the organization. Customer care agents
receive primarily a fixed salary with only a small variable component, whereas a
larger portion of a sales agent’s compensation is based on commissions earned
through sales results.

42. For example, 95% of the salary of a Rogers’ customer care agent is fixed
compensation. Within the remaining 5% variable pay, customer satisfaction metrics
form the majority of performance-based compensation. Furthermore, there are no
set sales targets for customer care employees. For sales agents, their fixed salary
is 70% of their compensation. Within the variable component, sales agents are
compensated by way of direct commissions, bonus pay targets and short-term
incentive programs with a minimum qualifier of customer satisfaction. A sales agent
needs to achieve 60% of their sales target on eligible calls in order to qualify for
commissions. Sales agents are certainly not expected or required to make a sale
on every call, or even on a majority of calls they make.

43. Importantly, Rogers’ compensation structure is weighted for customer satisfaction,

quantity of sales and value of sales. As noted previously, the portion determined by
customer satisfaction represents a significant portion of a sales agent compensation
and is designed to encourage sales agents to always ensure that a customer is fully
satisfied with the purchase he or she is making. In 2017, Rogers adjusted the
compensation structure to increase the emphasis on customer satisfaction within
the variable bucket, as part of our overall company objectives and our customer-first
emphasis.

44. The priority attached to customer satisfaction is also reflected in our company-wide
bonus structure for bonus-eligible employees. Beginning in 2018, 50% of the
corporate performance multiplier in our bonus plan is based on the achievement of
customer metrics. This change to Rogers’ bonus plan was referenced by Rogers’
President and CEO, Joe Natale, in a recent call with investors:

Underscoring all of this is a relentless and extensive focus on customers. I

truly believe what gets measured gets done. So, in 2018, we are placing
50% of our company-wide bonus plan on the achievement of customer
metrics. We will simplify our products and overhaul critical moment of truth
processes, such as residential moves, handset upgrades, service repair,
and price plan changes. We will further enhance our website, mobile, and
 - 12
! -

digital properties for a more reliable, consistent experience across every

customer interaction. Ultimately, we strive to be clear, simple, and fair in
every interaction.4

45. As a final point, it is simply incorrect to conclude that Rogers’ compensation model
for our sales agents and for our third party vendors would encourage unethical
sales practices. The sales targets we have established are entirely reasonable and
attainable, and the incentives and commissions available to our sales agents and
third party vendors have been developed to strongly discourage them from
engaging in misleading or aggressive sales practices.

V. Monitoring customer interactions

46. Rogers has implemented a variety of monitoring tools to ensure that our customers
are being treated fairly and with respect and are getting the quality and level of
service they deserve. We employ a complex monitoring and quality assurance
system that is constantly evolving and being upgraded. It has two streams - one for
sales and the other for customer service agents more generally.

47. With respect to Telesales teams, agent telephone calls are automatically assessed
for quality of service using a speech and data analytics solution. In addition, each
agent is randomly audited every month and is provided with an evaluation on the
accuracy of information and transactions in which he or she has been involved.

48. In Rogers’ retail stores and third party retail outlets, Rogers uses a mystery shopper
program to evaluate in-person interactions and agent performance. We employ an
external supplier to provide trained shoppers to evaluate in-store performance. Our
retail outlets are mystery shopped each quarter across all Rogers’ brands. The data
that is collected is used to evaluate sales agents and to find ways to improve
customer service.

49. With respect to field sales, targeted audits are employed to assess agent
effectiveness at meeting customer expectations. Each quarter, a sampling of sales
orders are selected for audit of agent compliance and customer experience. We
also audit newly on boarded third party vendors during the first three months of
engagement to ensure that Rogers’ values are reflected in the interactions they
have with customers. Field sales agents are also required to complete a tailored
Code of Conduct training (specific to in-person interactions) at orientation, which
highlights the expectations regarding ethical sales interactions.

50. For our customer care team, we employ a call-listening quality assurance program
in call centres to assess their effectiveness at delivering information to consumers.
There are two aspects to this call-listening program: the Quality Monitoring Program
(QMP) and the Quality Assurance Insights Program (QAIP).

4 Transcript, Rogers Communications Inc., Q4 2017 Earnings Call, (January 25, 2018) at page 5.
 - 13
! -

51. The QMP is an agent level quality program that spans across Consumer Care,
Business Care and Fido, covering internal and third party agents. The interactions
(which include call recordings or chat transcripts) are randomly selected and the
evaluations are completed based on quality assurance metrics designed for each
work group.

52. The QAIP analyses agent compliance, consumer behavior and company
performance. Data is collected through account investigations and call listening.
Instances where an employee has misinformed a customer is followed up with a
“coach back” email to the agent’s manager and director (depending on the severity
of the behavior). The coach back template includes a summary of the interaction,
the offending actions and corrective measures required to repair the customer’s
experience with Rogers.

53. Rogers supplements these two programs by conducting customer surveys at

regular intervals to measure satisfaction. Survey responses and data captured in
these surveys helps Rogers to devise ways to enhance the customer experience,
improve retention and reduce churn.

54. Rogers previously used the Net Promoter Score (NPS) scoring methodology to
measure customer satisfaction (https://www.netpromoter.com/know/). NPS is a
customer loyalty metric that measures how likely a customer is to recommend a
product or service to a friend or family member. Over the past year, we transitioned
from NPS to two new customer satisfaction survey metrics – Likelihood to
Recommend (LTR) and Own the Experience (OTE). Similarly, the two new metrics
are evaluated using customer survey questions which reflect feedback regarding
agent performance.

55. Customer survey responses to questions related to LTR and OTE are most directly
influenced by the behaviour of the employee with whom our customers interacted.
Results from these survey questions are considered more reliable indicators of
success in our performance in all customer touchpoints. Rogers’ customer survey
results are compiled weekly and shared internally.

56. When customers apply a low score to the questions, Rogers’ Survey Response
Team (SRT) proactively contacts a portion of these customers to discuss and
resolve outstanding concerns.

57. Rogers also leverages the work of our Voice Insights team to identify any issues
and continuously improve. This group is responsible for understanding why
customers are calling and they explore optimization opportunities around call
reduction and churn or complaint risk detection. This program offers near real-time
detection of agent errors by identifying customers who have expressed a complaint
to Rogers and proactively escalate the issue to a team manager for a call back.

VI. Complaint resolution mechanisms

 - 14
! -

58. Rogers’ internal monitoring mechanisms operate in tandem with the more traditional
complaint processes that we employ. Customers and employees can report their
concerns by making a complaint to Rogers.

(a) Customer complaints

59. When a complaint is made that an agent has misrepresented information or

engaged in some sort of misleading sales practice, an escalation team reports the
behavior to a team manager to ensure each error is reviewed and the agent
receives coaching to prevent a recurrence.

60. Rogers firmly believes that our ability to respond effectively to complaints has a
positive impact on our business. We respond to all complaints regardless of subject
matter. We are committed to helping customers and resolving complaints to rebuild
trust in order to ensure that we can maintain a positive long term relationship. We
strive to resolve every complaint efficiently, fairly and effectively, and to look for root
cause issues to make it better for other customers and thereby limit further
complaints.

61. This commitment is evident in the manner in which we escalate and address
complaints and in the fact the Rogers is the only telecommunications company in
North America to have established an Office of the Ombudsman to assist in finding
solutions for complaints that cannot be resolved after all other internal escalation
options have been unsuccessful.

62. We provide employees with a detailed policy on how complaints should be treated,
when they should be escalated and what the internal procedures are for agents to
follow when escalating complaints. Our agents must follow the internal guidelines
when referring an issue to the next step on the escalation path. This includes the
requirement to offer to escalate the matter to a manager when all attempts to
resolve the concern have failed. A team manager will help the agent identify the
best solution. In the event that the manager is not able to resolve the concern, the
case will be proactively referred to the Office of the President. In the rare instance
that the Office of the President is also unable to resolve the complaint to the
customer’s satisfaction, customers will be notified of their available recourse to the
Commission for Complaints for Telecom-television Services (CCTS) and their option
to be contacted by Rogers’ Office of the Ombudsman.5

63. Rogers’ Office of the Ombudsman provides an impartial review of unresolved

complaints. As part of our corporate focus on simplifying and improving the
customer experience, our Ombudsman’s mandate is to assist in finding solutions for
issues that remain unresolved after all other escalation stages have failed. The
Ombudsman’s secondary function is to make recommendations to Rogers’
Executive Leadership team for systemic changes, which is part of our ongoing
improvement processes.

5 https://www.rogers.com/customer/support/article/office-of-the-ombudsman
 - 15
! -

64. All of these mechanisms for resolving complaints are disclosed and promoted by
Rogers through various means. This includes providing contact information in the
following places: (i) each customer’s service agreement and on our various terms of
service documents; (ii) on the contact links of our websites, where we explain how
customers can share a concern with Rogers or contact the CCTS as an avenue for
unresolved complaints, and describe our Office of the Ombudsman; (iii) each
customer’s invoice; which includes (four times each year) a bill message notification
(or SMS for wireless prepaid subscribers) that promotes the CCTS as an avenue to
pursue unresolved complaints; and (iv) written correspondence to a customer who
has filed a complaint with the Office of the President informing them that we have
referred the case to the Office of the Ombudsman and that they may also raise their
concern with the CCTS.

65. All well-founded complaints received internally over the past year have been
resolved to the satisfaction of our customers. In each case where a complaint has
been made, Rogers has presented the customer with a fair and reasonable solution.
In the few instances in the past where those solutions have been rejected, Rogers
is satisfied that we had explored all reasonable options.

66. With respect to the small number of complaints relating to sales practices that were
filed with the CCTS between July 1, 2017 and July 16, 2018, all were closed and
resolved to the customer’s satisfaction by our Office of the President.6

67. While we respond to every complaint regardless of its source and nature, we also
take steps to limit or prevent the recurrence of complaints by tackling their root
causes. In the event that an employee is found to be in violation of the Code of
Conduct, Rogers administers disciplinary actions, up to and including, termination of
employment.

68. Rogers also has a continuous improvement program called Centre Ice. It is driven
in large part by frontline employees whose purpose is to identify customer impacting
process gaps and improvement opportunities. Our primary objective in establishing
this program is to identify problems that could improve the experience for multiple
consumers.

69. Centre Ice is foundational to our culture of continuous improvement in all customer-
facing touchpoints at Rogers. The significant amount of process improvements and
the direct engagement with empowered employees have contributed to its
popularity and lasting success. Since the inception of this program, Centre Ice has
contributed to more than 1,200 improvements and solutions to process related gaps
and experience issues. Examples include:

• Introduction of “ignite your voice” sessions with our frontline teams and Ignite TV
employee trial participants to capture feedback on every stage of the customer

6A total of 97 complaints were filed with the CCTS in relation to a sales interaction or a dispute regarding
a sales agent or information related to a purchase.
 - 16
! -

journey and created action plans to address issues before we launch to our
customers;

• Improvements to reduce burden on critically ill customers and their families who
require support with power of attorney/legal representation;

• Automatic pop up alert messages in stores with details regarding targeted

customer offers;

• Simplified language regarding wireless warranties following a device repair

experience to help reduce confusion; and

• Customers’ survey responses are now available to frontline managers in near

real time so they can be used immediately for agent coaching.

70. Another internal initiative that was introduced over the past year is Voice of the
Frontline. It encourages our agents to proactively identify potential issues using
three distinct programs: (i) Community, which is a member hub where real-time
feedback is requested for targeted customer experience topics and issues; (ii) Idea
Bank, which is a portal where employees can submit ideas for improving the
customer experience; and (iii) Challenge, which is an idea generation challenge
where employees vote on the quality of ideas.

71. In view of the above, it is clear that Rogers has implemented a set of efficient and
effective mechanisms to address and resolve customer complaints in a timely and
reasonable manner. In the vast majority of cases, we are able to resolve those
complaints to the satisfaction of the customer. In addition, we are constantly
working to improve our processes with the goal of reducing future complaints and
ensuring that any new complaint is resolved efficiently and effectively.

(b) Employee/third party complaints

72. Rogers encourages team members to share any concerns they may have about
their workplace environment. We believe that all employees should be comfortable
and respected in the workplace. We strive to create and maintain a culture that
operates with the highest standards of integrity and ethical behaviour and are
committed to an organizational culture that promotes open feedback, collaboration
and strong employee engagement. We want and expect our sales and service
agents and third party sales agents to treat all customers fairly and to act in a
manner that fully respects Rogers’ values as a company. At no time, has Rogers
encouraged or condoned any retail sales practices that could be construed as
misleading or aggressive.

73. There are three primary mechanisms in place that enable our employees and third
party agents to make internal complaints regarding sales practices.

74. The first is to raise any concerns with management and human resources (HR)
personnel. We remind employees at regular intervals, including during annual
 - 17
! -

Business Code of Conduct training, that managers and HR personnel are always
available and responsible for receiving and resolving internal employee concerns or
complaints where required.

75. The second mechanism is for those employees who wish to keep their identities
anonymous. We make available a service called STAR hotline, which can be used
to report suspicions or concerns. The hotline is managed by an external vendor 24
hours a day, 7 days a week. Using a third party operator ensures that employees
can feel safe in making complaints and have confidence that should they wish to
remain anonymous they can.

76. All complaints are investigated by our Corporate Investigations (CI) team and/or
HR. Rogers regularly reminds employees of this resource, and provides information
on how to submit a report and what constitutes misconduct, including any treatment
of our customers that is not in line with our values and standards.

77. The third mechanism we employ enables managers to report internal complaints
through a CI Allegation Form. While this process is not anonymous, it does provide
employees with the ability to raise concerns by sending them directly to the CI team
or to senior leadership.

78. In our view, these three mechanisms are effective in enabling employees and third
party agents to voice their concerns about any misleading or aggressive retail sales
practice involving Rogers.

79. Given the availability of these internal mechanisms, Rogers was concerned with the
allegations that were reported in the media earlier this year, which suggested that
Rogers’ sales agents are under pressure to upsell customers, often at the expense
of ethics. At no time has Rogers encouraged or condoned any retail sales practices
that could be construed as misleading or aggressive. The concerns raised do not
reflect our values or sales practices.

80. Rogers recently undertook a large scale review of all sales practices across all
brands and business units. This review included an investigation into all relevant
areas relating to employees and third parties involved in sales, including recruitment
and training, audits and controls, compensation, incentives and performance
management. We concluded that the sales practices referenced in the media do
not represent the way that our sales and service agents interact with customers on
a daily basis.

81. When we do receive internal complaints regarding our sales practices, Rogers has
consistently taken action to prevent recurrences of the issues underlying those
complaints. This action includes termination of an employee or vendor contract,
when an investigation concludes that an employee’s conduct or that of a third party
agent has violated Rogers’ policies and procedures and business code of conduct.
 - 18
! -

82. We also use our continuous improvement process to manage various input sources
such as complaints, call listening, compliance reports and random audits. We then
consolidate the reported issues as a means to ensure the consistent performance
management of employees, and we take action as needed.

VII. Conclusion

83. In closing, the retail sales practices that Rogers’ sales and service agents and our
third party vendors engage in with customers are fair and respectful. We do not
encourage or condone any misleading or aggressive retail sales practices. Our
goal is to build long-term relationships with our customers. Engaging in any sales
practice that would jeopardize those relationships is simply not tolerated.

84. Despite the inherent complicated nature of many of our products and services, and
the large volume of customer interactions, Rogers has experienced very few issues
regarding our sales practices. We have developed and adopted a variety of training
materials, monitoring processes and complaint procedures that are specifically
designed to ensure that our sales and customer care agents (both internal and
external to the company) deliver the best possible experience to our customers by
matching products and services that meet each customer’s needs and budget.
Rogers does not believe, therefore, that there is any public interest or policy
rationale that would justify the imposition of additional regulations relating to retail
sales practices.

85. Rogers appreciates this opportunity to comment on the issues raised in TBNC
2018-246 and the OIC and we look forward to appearing at the public hearing to
address these matters.

**End of Document**