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Faculty of Business

BTech Tourism Management


Advanced Strategic Management 4
Name: Muresherwa Gift
Student Number: 210226846
Lecturer: Mr. S Ohlhoff
Kulula.com situation analysis

Due Date: 07 June 2013


Plagiarism Declaration
The work attached is my own work, ie. Free of plagiarism. All sources used in this work have been
referenced using the Harvard for Beginners Reference system of in-text and end-of-text
referencing.
Signed..

Date//

Contents
1.
2.
3.
4.

Introduction
About Kulula.com
Low cost model airlines
Resource strength
4.1 Skills and expertise
4.2 Advanced technology
4.3 Market leader as a low cost provider
4.4 Simple fare levels
5 Resource weaknesses and competitive deficiencies
5.1 Problematic internet operation
5.2 No linkages with tourism organisations
5.3 Controversial adverts
6 Market opportunities
7 Potential external threat
8 Porters competitive model
9 Value chain for Kulula.com
10 The generic competitive strategies
10.1
Low-cost provider strategies
10.2
Differentiation strategies
10.3
Best cost provider strategies
10.4
Focus strategies based on low-costs
10.5
Focused strategy based on differentiation
11 Conclusion
12 List of references

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1. Introduction
Marketers must understand the current and potential business environment that the product
or service will be marketed in. This gives an overview of what the market is and strategies to
focus on those segments of the market will be devised. Business owners or entrepreneurs
should gather this information since it provides a basis for planning and decision making.
The analysis of the market and its dynamics gave birth to a concept known as situation
analysis (Lamp et al., 2009:38). Situation analysis is the assessment of the business
internal and external situation focusing on the organisations competitive position, operating,
financial and general affairs.
Douglas Power on his planning skills beliefs, views situation analysis as a set of concepts
which define and interprets the state of the environment of an individual or an organisation
[Planning Skills n.d]. Before developing any given marketing strategy, it is imperative to
conduct some form of analysis looking at both the internal and external environment. Factors
to be considered in this regard are; product situation, competitive situation, distribution
situation, environmental factors both internal and external, opportunity and issue analysis.
The situation analysis helps to identify problem areas and the viability of any business
venture. It enables marketers to diagnose critical areas which could require more focus thus
assist in minimising of risks.
In order to profitably satisfy customers needs and wants, the organisation has to understand
its internal and external situation. The firms capabilities, its customers and the environment
in which it operates in should be well mastered. In addition, marketers should be in a
position to forecast trends in the ever changing environment in which it operates. It has been
noted that when conducting a situation analysis, the following elements has to be assessed;
company, collaborators (distribution), customers, competitors, business environment
[Situation Analysis n.d].
Situation analysis or SWOT analysis as it is sometimes called should not replace the
manager in the decision making process. Its purpose as noted by Ferrell and Hartline (2011:
80) is to empower managers with vital information for more effective decision making. A
detailed situation analysis empowers the marketing manager since it encourages both
analysis and synthesis of information. When conducting a situation analysis, an organisation
has to first look at its history and then objectively assesses its current strengths and
weaknesses relative to its competitors. The planning process should include an analysis of
the potential threats and opportunities posed by the changes in the firms external
environment as viewed by Reid and Bojanic (2010:35).
The situation analysis provides background information crucial in the making of decision
regarding the future direction of the firm. The situation analysis which is referred to as a
situation audit by Gupta and Randhawa (2008:158) is a tool used to determine where the
organisation is at present and to forecast where it will be if current strategies is pursued. It
answers the questions, Where are we now? and How did we get here? A better
understanding of this can be found by studying the organisations background including its
history (Green & Williams, 1996:274).
The situation analysis can be summarised in a diagram as illustrated on fig 1.1 below. The
diagram shows the situation analysis or the SWOT analysis, favourable and unfavourable
scenarios. On the diagram, it is clear that strengths and weaknesses fall under the internal
factors which implies that the organisation has control over them. This is because they are
factors within the firm which give it more advantages than of rival businesses whilst
weaknesses are the companys challenges or shortfalls. Gupta and Randhawa identify
internal factors being influenced directly by the business own strategies and this includes
competition, suppliers and customers. Threats and opportunities are the external factors and
the organisation has little control of them and adapts the company strategies to remain
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Internal
factors

surviving. Pinson and Jinnett (2006:4) argue that businesses do not need experts to start up
but a realistic understanding of strength and weaknesses is imperative.

Favourable (+)

Unfavourable (-)

Strengths

Minimise or avoid
Weaknesses
Convert weaknesses to
strengths

Match

External
Factors

Opportunities

Threats
Minimise or avoid
Convert threats to
opportunities

Fig 1.1 Illustrates a SWOT matrix indicating how the marketer needs to respond to both
internal and external environment (Piercy: 2002).
An assessment of a companys resource strengths and weaknesses and its external
opportunities and threats is known as the SWOT analysis (Hough, Arthur, Thompson,
Strickland & Gamble, 2011:97). This provides an overview of the companys status in terms
of whether is healthy or unhealthy. The aim of this research is to conduct a situation analysis
for Kulula.com using different analytical tools for example; SWOT, value chain,
benchmarking and competitive strength assessment will be looked at in this assignment.
Both internal and external situations will be analysed in detail.
2. About Kulula.com
Kulula.com is a low cost domestic airline which entered South African market in August
2001. Kulula.com is wholly owned subsidiary of Comair and it was set up as a low cost
airline. The launch of this airline started with Johannesburg Cape Town route and later on
because of increasing demand for a low cost airline, expanded to Durban. This low-cost
provider was launched to offer an easy travel to its clients from booking to boarding the
flight, this aim is imbedded in its name Kulula which means easy in Zulu language. Different
marketing strategies were employed by Kulula.com during its launch and afterwards to
penetrate the market. The most effective tool that was used is the low cost option which
encouraged all people to fly and more importantly those who could not afford to use flights
as a means of travel.
Comair operates under franchise agreement with British Airways which has much industry
experience and knowledge based on the fact that it is an internationally recognised brand.
Comair managed to make profits over the past years despite the adverse environmental
influences therefore as a way to strengthen itself, it set up a low cost airline for the budget
conscious resulting in the birth of Kulula.com.
Kulula.coms brand has been very effectively established and as such awards have been
won for instance the Southern Africas prestigious 2002 Tusk Service Launch of the Year
award and the Airports Company of South Africas Domestic Airline of the Year annual
customer survey award for 2002 (Townsend & Bick, 2011:2). The launch campaign was a
powerful successful strategy leading to an overwhelming demand for a cost effective travel
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for example as highlighted in the case study that there is a shift of business clients now
preferring low-cost airlines to mainstream ones.
3. Low cost model airlines
The international airline industry and in particular, the established airlines got into a heavy
crisis in the aftermath of the September 11th 2001 terrorist attack (Gross & Schroder,
2007:32). This event led to a dramatic drop in demand however, the low cost airlines were
able to record high growth rates as noted by Gross and Schroder (2007:32). The low cost
airlines organises all business activities under the aspect of optimising or reducing costs in
order to achieve strategic success position thus gaining competitive advantages Low cost
airlines cut out all the frills so as to minimise cost of operation. This has an advantage to
consumers since they would pay a lower fare than on a mainstream carrier. The South
African low cost model has been developed from the European low cost approach.
In trying to reduce costs by any means possible, low cost airlines has relied on some of the
following approaches.

Selling of services through few channels mainly directly through the internet or
booking machines (direct self distribution) and through centralised call centres
established at competitive locations.
Offering a paperless operation, in this case a flexible information technology system
is used.
The use of one kind of aeroplane has an advantages or reducing costs since new
aircrafts may mean that the crew including pilots would be required to get training on
how the new aircraft works. Gross and Schoder (2007:35) argue that costs can be
further saved on aircrafts when outsourced or leased planes are used.
Selection of the most appropriate airports
No free meals served on-board

4. Resource strength
Organisational resources include capabilities involving production, marketing, finance
technology and employees (Needham, Dransfield, Coles, Harris & Rawlinson, 1999:10). By
evaluating these resources, an organisation can easily identify its strengths and
weaknesses. Strengths assist organisations to define core competences, formulate
objectives and formulate strategies to meet objectives. Kulula.coms strategy revolves
around capitalising on its resource strengths in addressing the South African marketing
opportunities. A resource strength is something an organisation is good at doing or an
feature that enhances its competitiveness (Hough et al., 2011:97). The following are
resource strengths for Kulula.com which has been extracted from the case study.
4.1 Skills and expertise
Kulula.com has highly experienced staff at senior level and these play a huge role in the
development and management of Kulula.coms brand.. This offers a proven managerial skill
since many years have been spent working with Comair brand thus effective managerial
work is guaranteed. Service experience on the part of staff is vital in the delivery of quality
service. This notion has been supported by Kushivan (2003:34) who views employees as an
integral part of the service experience. Staffs are used between the two brands, British
Airways and Kulula.com therefore resulting in further reduction of costs such as having to
train staff. In addition pilots are cross-utilised with British Airways thereby reducing costs and
ensuring a safe travel since the pilots already have known skill in flying British Airways
flights.

One of the strengths of Kulula.com lies in its strong and well crafted mission which explicitly
describes its customers as superheroes and assurance of easiness in everything from
booking, paying and flying. In addition, Kulula.com is operated by Comair which is a well
established brand hence it is perceived as perfect.
Kulula.com has a positive image emanating from its association to Comair a British Airways
franchisee. This makes it to enjoy benefits of its brand. Kulula.com managed to get awards
for two consecutive years as the best domestic airline of the years in 2002 and 2003.
4.2 Advanced technology
Most bookings are done via internet which further cuts distribution cost since just a few
intermediaries (travel agents-10% booking are through agents) are involved. Kulula.coms
website is user-friendly making bookings to be easier. Internet booking system enables
Kulula to save its costs; it is the greatest cost saver for the airline. Most airlines use the
complicated reservation programmes such as Amadeus and Galileo which are very
expensive to use. The website now allows customers to purchase other tourism products
such as accommodation, car hire and even restaurants. Internet allows customers to
purchase tickets, check for availability and search information within the comfort zones of
their homes. Online sale of flights helps to keep distribution costs down, a good way to cut
costs.
4.3 Market leader as a low cost provider
It has been generally noted that travellers are price sensitive to airline when it comes to
travel (Kumar, 2010:316). Most often, a low cost carrier stimulates demand for travel even
though prices for other tourism products are increasing. Kulula.com has managed to stand
competitive forces since it was launched at time when the currency was devaluating, a time
when other airlines were increasing their fares and Kulula.com was able to keep its costs as
low as possible. This was a big move for the carrier since it became renowned as the market
leader in low-costs. The ability to cut costs enabled it to attract number of passengers as
compared to mainstream airlines. Despite the rands decline towards the end of 2001,
Kulula.com managed to keep its fares low as compared to other airlines.
4.4 Simple fare levels
Kulula.com does not have complicated fare levels, it only have five as indicated in the case
study. Some mainstream airlines have numerous fare levels, may have up to one hundred
between the lowest and highest fare. This makes in complicated when deciding on which
fare to sell at.
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Resource weaknesses and competitive deficiencies

A resource weakness is something an organisation lacks or does poorly as compared to its


rivals or a scenario that puts it at a disadvantage on the marketplace (Hough et al.,
2011:104).. Weaknesses are seen as limitations or deficiency in resources, skills and
capabilities that seriously impedes effective performance (Rao, Sivaramakrishna & Rao,
2008:159). An organisations competitiveness is affected by internal weaknesses which is
alternatively termed competitive liabilities since they inhibit an organisation from gaining a
distinctive advantage. Below are situations which put Kulula.com at a disadvantage:
5.1 Problematic internet operation
Internet bookings are at times slowed down by internet lines and speed which would
therefore restrict potential bookings. Since the majority of Kulula.coms bookings are done
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via website, the operation speed is not good therefore travel agents find it difficult to use the
website. Most travel agents use Amadeus and Galileo reservations systems which are very
fast as compared to Kulula.coms system hence loss of sales from potential clients.
Kulula.com does not have feeder airline for international travellers, thus it relies on only the
domestic market which is Johannesburg, Durban and Cape Town. If there is someone
coming from other countries, they usually connect to a carrier which is international. This is
because; Kulula.com does not have inter-line agreements with some international carriers.
Kulula.coms main market is domestic, it lacks resources to target the market aimed for by
the mainstream airlines for example SAA; this limits the potential revenue it could get when
such markets are exploited.
5.2 No linkages with tourism organisations
Kulula.com is not linked to any tourism organisations and tourism marketing bodies which
limits its exposure. The number of routes taken is few as compared to some airlines, and this
limits potential revenue from being generated unlike when many routes are considered.
5.3 Controversial adverts
One of Kulula.coms advertisements caused stir and in the case has been labelled as
offending. Looking at the target market for Kulula.com, the young (14-28) and seniors (5580) which form of advertisement indicates that Kulula.coms lack of respect. Additionally, its
mission statement has some parts such as there is no bullshit. which can be viewed as
swearing. In this regard, Kulula.coms marketing campaigns can be viewed as inconsiderate.
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Market opportunities

A companys market opportunities are the industrys opportunities that an organisation is


equipped to capture. The anticipated growth of global tourism means that more people
would need to travel. The growth of tourism in South Africa presents an opportunity for the
travel industry to expand in order to capitalise on the huge travel market. The following are
some identified opportunities for Kulula.com

The success of a low cost carrier in the Unied States and Europe was an opportunity
for Kulula.com to model its low cost approach. Ideas on how the model can be made
feasible in the South African market were taken hence the success of Kulula.com
Changing in peoples lifestyle as stated in the case study is a huge opportunity for
Kulula.com. People are becoming more price sensitive thereby considering using the
most cost effective way of travelling. This presents opportunities to Kulula.com which
is now tasked to develop a low cost, no-frill airline.
A rising buyer demand for budget travel, the business clients or corporate world are
now finding it more important to save cost by using low cost airlines. This presents
opportunity to Kulula.com, there is now high need to develop its primary market and
at the same time satisfying business travellers needs. The primary market for
Kulula.com is the budget conscious group whereas the secondary are income
earners business clientele.
Establishment of the third part affiliates such as links on the website to car rental
companies or hotel groups would increase exposure for Kulula.com brand
Deregulation was an opportunity for Kulula.com since it made it easier for it to enter
the market, the government removed all the restrictions which restricted airlines from
entering the market. this has however brought stiff competition on the market with
threats of new entrants.
The low cost airlines are short-haul hence Kulula.com should consider entering the
regional market to neighbouring countries for example Zambia, Mozambique,
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Botswana, Swaziland, Lesotho and many regional routes. This is because these
routes are shorter distances and only served by the mainstream carriers Kulula.com
would generate revenue before any low-cost carrier does it. In addition, another
opportunity that lay for Kulula.com is the expansion to many domestic routes for
example Bloemfontein, Pretoria, Mpumalanga rather than keeping serving the routes
served by a lot of mainstream carriers.
Another opportunity for Kulula.com is the increasing backpacker market in Australia;
most Australians make use of Kulula.com when they come into the country.
Kulula.com should perhaps consider making partnerships with Australian travel
agents for backpackers so that it get business from them.

Potential external threat

A companys environmental threats are those factors in the external environment that the
firm is not equipped to handle. It is a condition in the general environment that may hinder a
companys efforts to achieve strategic competitiveness (Hitts, Ireland & Hoskisson, 2012:39).
Kulula.com is threatened by the following factors:

Devaluation of the rand threatens Kulula.com in that it becomes more expensive to


buy some aircraft parts since they are purchased using foreign currency and
obtaining this currency would be more expensive thus making it to set its fares a little
bit up.
Increasing fuel cost is a threat to Kulula.com. The Air Transport Association (2013)
states that the price of fuel constitutes to the second major expense for airline. An
increase in fuel price impacts on profitability since it becomes an added cost.
An increase in labour costs threatens not only the airline industry but most industries.
Kulula.com aims to keep costs as low as possible for the low-cost model to work
effectively, however an increase in labour cost when the crew demands increments
in salaries, it end up adding costs. South Africa has recently experienced labour force
in different industries mainly mining and farming demanding more salaries. This
threatens the airline in that it influences workers to go for an industrial actions which
has a detrimental effect on the business.
Weather which is characterised by adverse conditions such as extreme heat, cold,
snow, heavy rain and fog is a major threat for Kulula.com. Kulula.com was heavily
affected by unseasonal weather in 2010 causing more than thirty flights to be
cancelled and delayed in April. (Kulula.com, 2013). This was a result of heavy rain
and fog.
Plague and terrorism not only threatens Kulula.com but the whole aviation industry.
The September 11 terrorist attach will continue to haunt the travel industry therefore
there is high need to intensify security systems for the airline to curb the likelihood of
such. This is a huge expense for Kulula.com and most airlines.
Poor economic conditions around the world
The high unemployment rate in the country is a threat for Kulula.com This is
because, those who can afford to fly have the money to do so, their discretionary
income is high enough to allow for air travel. Because of the high air transport fares
as compared to surface modes, the unemployed then opt to rail or road.
Instability in other nations for exam[le Zimbabwe
Deregulation of the airline industry by the government making it easier for many to
enter poses a huge threat to Kulula.com. The launch of South Africa Airways low
cost carrier in 2006, Mango, SA-Air link, SA-Express brought stiff competition since
each company would be trying to attract a considerable market share and become a
leader. New entrants onto the market exert a threat to the success of a business
since there would be dilution of profits and swallowing up of potential clients by the
entrant.
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8. Porters competitive model


The five forces model depicts five elements which act on a business competitiveness. The
South African airline industry experiences the following competitive forces which were
identified by Michael Porter

Potential entrants-Kulula.com might see other airlines coming into the market for
example Mango 1996, 1-Time though it liquidated and many other low cost airlines in
the country. Foreign carriers including regional ones might also entre,
Bargaining power of suppliers- Aircraft manufacturers, aircraft leasing companies,
labour unions, fuel companies, airports, hotels and local transportation service.
Bargaining power of buyers-in the case of Kulula.com travel agents thought the
power is low, business travellers, leisure travellers, organised group tours.
Substitute products- Alternative travel modes for example, people might choose to
use a bus, Greyhound, Inter-Cape, SA Road-Link or rail transport, private cars
(transportation)
Intra-Industry rivalry-The competitors for Kulula.com are South African Airways low
cost models which are Mango Airlines, South African Air Link, South African Express.

9. Value chain for Kulula.com


Porters 5 forces model, his work on generic strategies, and his theory of a value chain and
the management theories are extremely useful when analysing the airline industry in South
Africa. By redefining the value chain, the low cost airlines have been able to shed significant
costs and change the South African airline industry for the foreseeable future. They have
adopted what Porter refers to as a low cost strategy and this has helped them not only boost
passenger numbers for the industry as a whole, but also enabled them to gain significant
market share, competitive advantages, taking huge number of passengers from the likes of
the national carrier South African Airways and other full service carriers.
The companys value chain comprises of all the activities that a company performs internally
from designing, marketing, distribution and supporting the product (Hough, et al. 2011:110).
These activities create value and in the case of a low cost airline, focus is on activities which
strive to cut costs and at the same time giving value for money. Carefully managing the
value chain can result in competitive advantage and increase returns. The primary activities
in the value chain for Kulula.com include the following;
The value chain categorizes the value adding activities of a firm and value chain analysis is
a method for decomposing the firm into strategically important activities and understanding
their impact on cost and value (Stabell & Fjeldstad, 1998:413). The value chain is divided
into primary and support activities. Primary activities are involved in the physical creation of
the product, the sale of the product to the consumer and after sales service. The support
activities support the primary activities.
Primary activities include: inbound logistics for example receiving, storing and distribution of
inputs operations encompass transforming inputs into the final product or service, outbound
logistics involve getting the product to the buyers, marketing and sales covering bringing the
product to buyers and encouraging them to purchase it, and services including activities to
maintain the products value such as maintenance, repairs, installation, and training.
The support activities include: administrative infrastructure management which deals with
the management systems, human resource management responsible for recruitment,
training, development and rewards, R&D for technological development and procurement
which deals with the acquiring of resources. The value chain can be used to identify how to
pursue a cost leadership strategy by using it to identify and control costs, and also by firms
wishing to adopt a differentiation strategy by using the value chain to identify how and at
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which stages of production value is added. The value chain is shown diagrammatically
below:
Airline Industry Value Chain
Key- Yellow highlight illustrates Support Activities
Green Highlight illustrates Primary Activities

FIRM INFRASTRUCTURE
HUMAN RESOURCE MANAGEMENT
TECHNOLOGY DEVELOPMENT
PROCUREMENT

Inbound
logistics

Operations

Outbound
logistics

MARGIN

Marketing
& Sales

Services

Value Chain of an airline industry, Source Porter (1985:37).


Distribution-Kulula.com takes most of its bookings via online system. This enables vast
amounts of cost to be eliminated. The case study states that 90% of bookings are made
online therefore there is no need for a huge workforce to be employed to take bookings. It
has limited the number of travel agents used and still those travel agents make use of
Kulula.coms website for bookings rather than relying on Global Distribution System (GDS)
which most agents use. The website has been made simple and user friendly. Another value
chain activity by Kulula.com is that there are no paper tickets hence cuts cost.
Operations-The South African low cost model is slightly different from that one I the UK in
that Kulula.com uses major airports rather than secondary airports. The main objective is to
make money and cut costs, having this in mind Kulula.com uses primary airports because
they are profitable and well equipped with infrastructure to take its aeroplanes. A short
turnaround time is maintained cut costs, The use of the same plane reduces training costs
for pilots to be trained on how to fly the new model flights also maintenance costs are cut in
that way.
Sales and marketing-Kulula.com has selected its marketing medium during its launch more
carefully rather than focusing into regions where it does not fly to. This enabled cost savings
since marketing efforts were only concentrated in profitable areas or within the target market
regions.
Logistics-this encompasses route selection for example Kulula.com has the Cape Town,
Durban, Port Elizabeth and recently launched the Victoria Falls. Passenger service system,
yield management system (pricing), crew scheduling, aircraft acquisition baggage handling
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system and including services such as car and accommodation reservation are all logistic
value chain activities for Kulula.com.
Service- In trying to enhance experience and improve service delivery, Kulula.com came up
with customer feedback system. This is aimed at using obtained information towards building
up improvement done through complaint and follow-up.
10. The generic competitive strategies
A company can outperform competitors only if it can establish a difference that can preserve,
it must deliver greater value to customers or create comparable value at a lower cost (Porter,
1996:62). Porter suggested that a company may choose three generic strategies to pursue.
These strategies are ways in which business deal with the five competitive forces that make
up a general model strategy, to create a sustainable competitive advantage and hence
higher returns (White, 1986:219). Strategies are distinguished by what the firm is seeking to
achieve, be it being the lowest cost player in the market or part of the market (segment),
having a differentiated product that is of value to customers through a focus strategy.
10.1

Low-cost provider strategies

Kulula.com offers competitively lower costs as compared to mainstream airlines, this


strategy has worked effectively since it has gained a huge share of the domestic market.
10.2

Differentiation strategies

This strategy considers incorporating of differentiating features which causes buyers to


prefer a firms offerings over brands of rivals. Kulula.com differentiates its offering from other
airlines through simplifying everything for example from booking to boarding of the flight. By
making the experience funny and introducing a quite informal system such as on website,
creative advertising and pilots becoming amusing. Cheaper fares, removing of elements that
add costs were all ways of being different.
10.3

Best cost provider strategies

Kulula.com has combined a strategic emphasis on low cost with a strategic emphasis on
differentiation through giving its customers more value for money. This has proved
successful since the airline has exceeded buyers expectation on product attributes and
beating their price expectations even at a time when other carriers are increasing their fares.
In addition, Kulula.com uses its cost advantage to under-price comparable brands such as
SAA. This strategy worked well since consumers were becoming price sensitive hence
customers move from high priced flights to lowly priced carriers and in this case Kulula.com.
10.4

Focus strategies based on low-costs

This is achieved through concentrating on a narrow buyer segment and out-competing rivals
by having lower costs than rivals and being able to serve customers at a lower price.
Kulula.com focuses on a niche market which was not served by most airlines that is those
who could not afford to fly on the mainstream carrier. This market was not catered for and
they relied on surface transport, included in this category are young people, pensioners,
schoolchildren, students, Visiting Friends and Relatives group (VFR) and the budget tourist.
10.5

Focused strategy based on differentiation

Kulula.com concentrates on a very narrow buyer segment and out-competes major carriers
such as SAA. This is achieved through offering its customers customised attributes that
meet their tastes rather than rivals products. Things which add costs have been removed

11

such as free meals. By following an informal approach which most airlines do not offer is
also a strategy focused to the budget traveller.
11 Conclusion
All businesses from large corporations to solely owned small business require a plan in order
to direct their future actions and to make the most use of marketing resources. Green and
Williams (1996:51) note that a business plan has three components which are situation
analysis, objective section and a strategy and action plan. When a business successfully
completes a situation analysis marketing objectives may be established and a strategy
devised to achieve those objectives.

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