Telus Intervention

BEFORE THE CANADIAN RADIO-TELEVISION AND
TELECOMMUNICATIONS COMMISSION
TELUS COMMUNICATIONS INC.
Telecom and Broadcasting Notice of Consultation CRTC 2018-246
Report regarding the retail sales practices of Canada’s large telecommunications carriers
Intervention of TELUS
ABRIDGED
August 30, 2018
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TELUS Communications Inc. ABRIDGED TBNC 2018-246
August 30, 2018 TELUS Intervention
Table of Contents
1.0 Introduction and Executive Summary ................................................................................. 1

1.1 The Customers First Initiative and its Impact on Sales .................................................... 1
1.2 Controls are in Place to Ensure Customers Come First ................................................... 3
1.3 Sales are Crucial to Delivering the Promise of a Digital Canada .................................... 4
1.4 Rules Preventing Improper Sales Practices are in Place .................................................. 5
2.0 TELUS Customers First Journey ......................................................................................... 7
2.1 History and Meaning of TELUS’ Customers First Journey............................................. 7
2.2 Practical Examples of Customers First Initiatives ......................................................... 11
2.3 Focus on Customers First Drives Measurable Positive Results ..................................... 17
2.4 Customers First Culture Helps Prevent Misleading and Aggressive Sales Practices .... 20
2.5 TELUS Differentiates Itself on the Unique Customers First Approach ........................ 21
3.0 Sales are key to Driving Adoption of New Technologies ................................................. 21
3.1 Door to Door Engagement is Critical for Rolling out Fibre to the Premises ................. 22
4.0 Sales at TELUS .................................................................................................................. 24
4.1 Sales channels at TELUS ............................................................................................... 25
4.2 Compliance Programs are in Effect on All Sales Channels ........................................... 26
4.3 Selling to Potentially Vulnerable Consumers ................................................................ 33
4.4 Customer Complaints are Addressed and Root Causes are Identified and Corrected ... 35
5.0 Existing rules cover poor sales practices ........................................................................... 38
5.1 Competition Act ............................................................................................................. 39
5.2 Telecommunications Act................................................................................................ 41
5.3 The Wireless Code ......................................................................................................... 42
5.4 Television Service Provider Code .................................................................................. 44
5.5 Tariffs and the Consumer Bill of Rights ........................................................................ 45
5.6 Commission for Complaints for Telecom-television Services ...................................... 45
5.7 No need for additional rules relating to sales of telecommunications services ............. 46
6.0 Improving Access to Justice for Consumers and Discouraging Aggressive and Misleading
Sales Practices ............................................................................................................................... 47
6.1 The Commission should publicly assert its exclusive jurisdiction to regulate
telecommunications and radiocommunication undertakings .................................................... 47
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6.2 CCTS should address individual complaints regarding sales practices ......................... 56
6.3 The Competition Bureau and the Commission should use existing powers to remedy
systemic issues .......................................................................................................................... 58
7.0 Conclusion ......................................................................................................................... 60
APPENDIX 1 – TELUS ANSWERS TO QUESTION SET OUT IN APPENDIX 2 TBNC
CRTC 2018-246 ............................................................................................................................ 62
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1.0 Introduction and Executive Summary
1. TELUS Communications Inc. (“TELUS” or the “Company” hereby files its intervention in
accordance with the procedures set out in Telecom and Broadcasting Notice of Consultation
CRTC 2018-246 (“TBNC 2018-246”). In its intervention, TELUS responds to the questions
raised in TBNC 2018-246 and makes recommendations for future action in respect of the
sales practices of Canada’s large telecommunications carriers.
2. In Appendix 2 to TBNC 2018-246, the Commission sets out a series of “Questions for
discussion in this proceeding.” The first such question reprints the four areas of inquiry set
out in Order in Council P.C. 2018-0685, which triggered this proceeding (the “Four
Questions”). In this intervention, TELUS answers these questions in more detail, in part by
drawing on the story of its Customers First program. TELUS also describes its compliance
programs and other matters relevant to issues raised in TBNC 2018-246.
1.1 The Customers First Initiative and its Impact on Sales
3. In the first of the Four Questions, the Commission asks:
whether the large telecommunications carriers offer their

telecommunications services for sale by engaging, either through
their employees or third parties, in misleading or aggressive sales
practices, such as providing consumers with incomplete, unclear or
misleading information regarding service terms and conditions or
selling them telecommunications services that are unsuitable for
them, and, if so, the prevalence of those practices.
TELUS has programs in place, including its Customers First program and numerous formal
compliance initiatives, aimed at limiting risks flowing from the sale of its products and
services. TELUS takes steps to ensure that its agents communicate with customers directly,
clearly and without pressure. As explained below, where a concern comes to TELUS’
attention (either by proactive monitoring or through a complaint), TELUS makes things right
for the customer and corrects the root cause of the concern.
4. TELUS has a singular focus on the customer throughout the company. The Customers First
program, which started in 2008 and into which TELUS has invested billions of dollars, is
what sets TELUS apart from its competitors. The objective of the Customers First program
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is for TELUS to become the leading company in customer recommendations. If customers

are happy with the service they receive, they are more likely to recommend TELUS, and
customers can only be happy with the service if their needs are placed first. To operationalize
this commitment, TELUS builds top quality networks, sells customers only the products and
services they need and want, provides stress-free support, responds quickly to complaints
(including about sales) and ensures that they are resolved to the customer’s satisfaction,
engages in customer appreciation activities and above all ensures that customers are pleased
in their every interaction with TELUS. The fact that TELUS puts customers first in its
operations is communicated both to customers as a reason to choose TELUS services and to
investors as a competitive advantage.
5. Across the business, TELUS employees and third party contractors are carefully selected
and trained to ensure that all interactions with customers are consistent with the Customers
First program. Sales agents are specifically trained not to close a sale if it would mean
contravening the values behind the Customers First program. From a business perspective,
respectful and transparent engagement with customers in the sales process results in a higher
likelihood that a customer would recommend TELUS as a carrier of choice.
6. Thus, in answer to the first of the Four Questions, as a result of TELUS’ focus on the
customer and its proactive monitoring and compliance efforts, employees and third party
sales agents are trained not to engage in misleading or aggressive sales practices or sell
products or services that are not suitable to the customer. Those practices are not condoned
or tolerated. In addition, TELUS monitors its sales agents to ensure that they provide
complete and clear information regarding all aspects of each product and service, including
terms and conditions. TELUS also ensures that its contracts are short (only two pages),
simple and clear. TELUS did this before it was required and continues to do so to comply
with applicable regulation and, more importantly, to ensure that every customer will be
satisfied and delighted with TELUS services. In rare instances where inappropriate practices
are discovered, remedial action is immediately taken to make things right for the customer
and prevent a recurrence of the conduct.
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1.2 Controls are in Place to Ensure Customers Come First
7. In the second of the Four Questions, the Commission seeks comment on:
The measures or controls that those carriers have in place to monitor,

identify and mitigate the risks that consumers are subject to
misleading or aggressive sales practices.
8. TELUS’ answer is that it has a robust and multi-pronged compliance program that consists
of, among other things, training, monitoring and auditing. TELUS also has many ways of
receiving customer feedback and complaints including by telephone, email, online, at the
door and to any TELUS employee regardless of function. TELUS also has a robust
whistleblowing program that is accessible not only by employees, but by anyone at all
through a third party vendor (EthicsPoint).1
9. To protect its multi-billion dollar investment into Customers First programs, TELUS quickly
responds to complaints, monitors its staff and conducts periodic audits. Where an issue
identified, whether through regular monitoring and auditing or as a result of a customer
complaint, TELUS works with the customer to make things right. After ensuring that the
customer is satisfied with the resolution, the root causes of the issue are addressed. As a
result of TELUS’ strong monitoring program, TELUS has ended business and employment
relationships where it became clear that an employee or third party is not able or not willing
to put TELUS customers first.
10. TELUS also uses compliance programs to ensure that its team members and contractors
comply with the Telecommunications Act, Canada’s Anti-Spam Legislation, the Competition
Act and other applicable laws. TELUS’ compliance program includes centralized policies,
procedures and training intended to ensure and promote compliance with such retail sales-
related CRTC directives as the Wireless Code, the prohibition against 30-day cancellation
policies, contractual and disclosure requirements and other consumer safeguards. The
compliance program also includes monitoring and periodic audits. Consequences for TELUS
members of contraventions of these laws and policies include disciplinary action, up to and
1
TELUS EthicsLine, online: https://secure.ethicspoint.eu/domain/media/en/gui/16533/index.html.
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including suspension and/or dismissal. In addition, a breach of the compliance program by

a third party business partner can result in termination of association.
11. TELUS provides specific training to all sales agents on how best to determine and address
the needs of potentially vulnerable customers. Because of the values TELUS instills in its
team members as well as the training and monitoring of its sales force, outcomes for the vast
majority of consumers have been positive and TELUS has enjoyed a significant
improvement in its key business metrics since it began its Customers First program.
1.3 Sales are Crucial to Delivering the Promise of a Digital Canada
12. Telecommunications sales are important to ensuring that Canadians have access to the latest
technologies and ultimately to delivering on the promise of a digital Canada. TELUS’
customer facing employees and partners acquaint Canadians with the services TELUS offers
that allow them to remain in contact with their families, friends, government and the world
at large. Limits on sales methods, further to those that are already in place, risk slowing down
generational investments in new and transformational next generation technologies.
13. Door-to-door sales are particularly important in launching fibre to the premises. To date,
TELUS has invested over $3 billion to roll out fibre-to-the-premises in more than 100
communities across British Columbia, Alberta and Quebec. As part of this process, TELUS
agents have knocked on millions of doors to educate customers about the benefits of this
new technology. Engaging people at the door allows individual conversations to take place
with almost all members of a community and ensure that they are aware of the services being
offered and understand their benefits. When TELUS agents are seeking permission to install
a fibre line, they note that the line will be installed at no cost and with no obligation to
purchase TELUS services. In communities where fibre is being built, it is particularly
important to ensure that as many people as possible allow access to their properties to install
fibre and ultimately sign up for service that use the fibre line. This defrays building costs
and makes fibre roll-out economically viable. If TELUS is not able to engage people at their
door, fibre roll-out may become impossible in certain high-cost areas.
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1.4 Rules Preventing Improper Sales Practices are in Place
14. In the third of the Four Questions, the Commission seeks comment on:
the consumer protections respecting retail sales practices and

contracts for telecommunications services that are currently in place
to empower consumers to make informed decisions with respect to
their telecommunications services and promote the fair treatment of
consumers in their relationships with telecommunications carriers.
15. TELUS’ answer to this question is that the types of sales practices that are set out in the
Notice of Consultation are already unlawful under existing rules. The Competition Act,
Telecommunications Act, Wireless Code, Television Service Provider Code, tariffs and the
Commission’s Consumer Bill of Rights comprehensively address aggressive and misleading
sales practices in the telecommunications industry.
16. In the fourth and final question, the Commission seeks comment on:
the most feasible and effective ways to strengthen or expand the

scope of existing consumer protections such as those contained in
the Commission’s codes of conduct, or to create new consumer
protections, including codes of conduct relating to new subjects, in
order to further empower consumers to make informed decisions
with respect to their telecommunications services and to further
promote the fair treatment of consumers in their relationships with
telecommunications carriers.
17. TELUS’ answer to this question is that to the extent that there is any room for improvement
to the consumer protection schemes already in place, it is in the areas of education and access
to redress: consumers in some cases lack a simple and cost-effective forum to seek resolution
of their complaints regarding sales practices. The mandate of the CCTS as currently
articulated in the Procedural Code and Participation Agreement wants for clarification.
Under the terms of the Procedural Code, the CCTS does not address “claims of false and
misleading advertising.” At the same time, the CCTS is permitted to address most other
claims regarding forborne retail telecommunications services. While the role of the CCTS
does not encompass and should not be expanded to include all claims of false and misleading
advertising—for example, providers’ television and radio commercials—the Commission
should make clear that the CCTS does have the authority to hear disputes regarding allegedly
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misleading and aggressive sales practices, including specific misrepresentations made by

employees or agents of telecommunications companies to individual consumers at their
doorstep, over the phone, or in a store. These are not representations made to the public at
large but rather are complaints from consumers about discrete incidences of aggressive or
misleading behaviour toward them specifically. The clearest way to formalize this role for
the CCTS is through a code of conduct developed by a CISC working group, as contemplated
by the Participation Agreement.2
18. TELUS also proposes that CCTS report the statistics it collects on complaints regarding sales
practices. The Competition Bureau and/or the Commission can then use those statistics and
other data to identify trends that require regulatory attention. Once such trends are identified,
the regulator – including the Commission and the Competition Bureau – can use existing
tools such as outreach to companies, consumer education and – where warranted –
progressive disciplinary measures.
19. This proposal provides simple, cost-effective and timely remedies to aggrieved consumers
and ensures that systemically poor practices within certain companies are addressed with
education, outreach, reporting and – where necessary – progressive discipline.
20. Critically, no action that the Commission takes will be effective without addressing
persistent unconstitutional intrusions by provincial legislatures. To this effect, the
Commission should state clearly that any concerns or complaints about sales practices are a
matter within the exclusive jurisdiction of Parliament, and that as the federal
telecommunications regulator, the Commission’s rules are binding, of exclusive federal
jurisdiction, and national in scope. This confirmation is needed to ensure that sales standards
are consistent between provinces and industry players, that duplicative and contradictory
regimes do not threaten national application of federal rules, and that the Commission’s
intentions are not thwarted by inconsistent provincial regulatory regimes.
21. With respect to the Commission’s report to be tabled in February 2019, and given that
Customers First is a point of differentiation for TELUS, it would be unfair and harmful to
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Participation Agreement, art. 12(b).
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TELUS if the Commission made broad statements about the industry as a whole, absent
proper context. To the extent that the Commission finds that aggressive or misleading sales
practices occur, the Commission should address that problem—but the Commission should
avoid broad industry-wide declarations where they do not apply evenly across the
respondents to this proceeding. The Commission should also identify best practices and
success stories in addition to setting out its concerns.
22. The remainder of this submission is organized in six parts. Section 2 sets out the details of
TELUS’ Customers First program, Section 3 explains why selling is critical to the promise
of a digital Canada, Section 4 sets out the process of selling and compliance at TELUS,
Section 5 sets out existing rules and regulations governing sales and section 6 contains a
proposal for strengthening consumer protections and ensuring that systemic concerns are
addressed.
2.0 TELUS Customers First Journey
23. TELUS is currently in the 11th year of its Customers First program. Customers First has
become the single most important factor differentiating TELUS from other
telecommunications providers. TELUS has invested billions dollars in numerous Customers
First initiatives, some of which are described below.
24. TELUS believes – and its results show – that a focus on the customer’s needs drives key
metrics including lowering churn,3 increasing customer satisfaction and increasing
likelihood to recommend. This is simply the optimal way of conducting business with
customers. TELUS does not compromise its Customers First principles in order to make a
sale.
2.1 History and Meaning of TELUS’ Customers First Journey
25. In 2008, TELUS decided to reinvent itself as an organization. At the time, TELUS was facing
a competitive market where it had little product differentiation, no pricing advantage, a high
3
Churn is calculated as the number of subscriber units deactivated during a given period divided by the average
number of subscriber units on the network during the period and is expressed as a rate per month.
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and increasing number of cancellations every month, a high number of customer escalations
to the CEO and a low likelihood of a customer recommendation.
26. TELUS understood that products and pricing could be replicated, but customer experience
was a key differentiator. In 2008, the senior leadership of TELUS made Customers First the
number one priority and established the goal to become the most recommended company in
the world. The priority is to genuinely delight customers so that they will recommend
TELUS to others.
27. The Customers First approach was unique in the Canadian telecommunications sector at the
time and remains so today. TELUS has spent billions of dollars on Customers First programs,
and these investments are ongoing. Putting customers first includes offering products that
are right for customers, fair and transparent pricing, customer-friendly sales processes,
network reliability, superior and stress-free technical support, customer appreciation and
every other interaction between TELUS and its customers.
28. TELUS tracks the success of Customers First, using “likelihood to recommend” – the
percentage of customers who would recommend TELUS services – as a key metric. #
# TELUS has also actively refined the

likelihood to recommend measurement over the years in an effort to better understand what
influences a customer’s decision to recommend. In addition to likelihood to recommend,
TELUS tracks other metrics, including measures of customer trust, on a quarterly basis.
2.1.1 Customers First Engagement at Every Level of the Organization
29. In 2011, TELUS launched its Customers First Declaration, which begins with “we’re not
perfect, but our employees are deeply motivated to consistently delight our customers.” In
2012, TELUS followed with an introduction of four commitments that guide the actions of
all TELUS staff and contractors:
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TELUS staff and contractors at every level of the organization are expected to live up to the
Customers First commitments with every customer and potential customer interaction,
including in the sales process. Training, monitoring and auditing is in place to make sure that
these commitments are satisfied. Every communication with customers, including during
sales and complaint resolution, is seen as an opportunity to deliver on the Customers First
promise. Importantly, living the Customers First commitments is the responsibility of all
TELUS team members, not just front-line customer facing staff, and at least 50% of the goals
of every TELUS team member must relate to increasing likelihood to recommend. Similarly,
a portion of team member variable compensation is based on achieving Customer First goals.
30. TELUS management and executive leadership team are closely engaged with Customers
First initiatives throughout the organization. This includes:
a) Consistently driving new programs to enhance the end to end customer

experience. This started many years ago with programs to eliminate major
customer pain points like system access fees, contract termination fees, and bill
shock.#
.# The current focus is identifying areas of high

customer effort and eliminating or reducing them;
b) Weekly meetings with a focus on tracking customer experience metrics. This

includes significant focus on #
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.# The goal of tracking and discussing

results is to address trends that compromise the ability to delight a customer;
c) TELUS’ Closer to the Customer program, which has been running since 2010 and
allows team members to experience TELUS roles beyond their own. It gives
TELUS professionals the opportunity to experience front line, customer impacting
roles so that they can leverage this experience in their roles and make better
Customers First decisions;
d) Weekly executive emails and meetings to address root causes of complex

customer escalations; and
e) Monthly executive review of the reliability and health of TELUS’ systems.
31. The Customers First program is part of the onboarding process for all team members.
TELUS onboarding materials include content on Customers First initiatives, as well as a
detailed explanation of why they are important. Management professionals and other team
members are also trained on the meaning of “likely to recommend”, why it matters and why
they should put customers first in all their daily tasks.
32. Frontline customer-facing TELUS team members and contractors are closely engaged with
Customers First program objectives and are trained on how to deliver on these objectives in
their day to day work. For example, door-to-door agents are specifically trained to never
close a sale if it would mean disregarding key Customers First principles. Customer
satisfaction is more important to TELUS than any individual sale and agents are trained to
ensure that customers are left with a positive feeling about TELUS even when they choose
not to purchase a service.
33. Front-line staff who excel at living Customers First commitments are recognized and
rewarded. For example, TELUS’ annual Customers First Champions Gala provides an
opportunity to recognize the exceptional team members who go above and beyond to care
for, listen to and delight our customers, and symbolizes the pinnacle of achievement for
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frontline team members. Importantly, there are no sales performance requirements in order
to receive the privilege of attending the gala. Instead, the most prestigious recognition event
of the year is uniquely focused on recognizing our team members who best serve our
customers. #
.4#
34. It is understood at all levels of the organization that compliance is a part of putting customers
first. TELUS team members appreciate that complying with applicable laws, regulations and
TELUS policies is good for business and goes a long way to ensuring that customers are
satisfied with TELUS products and services. Details of TELUS’ compliance programs are
set out in Section 4.2 of this intervention and in Responses to Requests for Information
TELUS(CRTC)16July18-25 and 31.
2.2 Practical Examples of Customers First Initiatives
35. TELUS has taken concrete steps to ensure that its customers come first in all of its operations.
Some examples of those steps are set out below.
2.2.1 Sales that delight customers
2.2.1.1 Key Principles of Sales at TELUS
36. TELUS sales representatives are trained on TELUS Customers First initiatives and are
trained to operate with key Customer First commitments in mind. For example, the training
curriculum for TELUS’ door-to-door agents includes the following three principles:
 Always enhance the TELUS brand and act with integrity. Agents of TELUS do
the right things even when no one is looking;
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A sample nomination – for a team member who went above and beyond to help a senior customer with a
disability – is attached as Appendix 1-1 to Response to Request for Information TELUS(CRTC)16July18-1.
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 The person engaged is to be left with a positive, pleasant experience, whether they
buy something or not;
 Agents know TELUS offers and are able to articulate value to customers.
37. Door-to-door agents are trained never to close a sale in contravention of these principles.
Agents in other sales channels are trained with similar values. All agents are taught to
determine a customer’s needs and offer products and services to meet those needs. If agents
engage in misleading or aggressive tactics in the sales process, it will result in disappointed
customers, lower likelihood to recommend and increased risk of a customer cancelling
services at the first opportunity. This is a negative business impact for TELUS business. As
a result, there are systems set up to prevent misleading and aggressive sales practices that
are described in more detail in Section 4.2.
2.2.1.2 Clear Rate Plans
38. As part of setting up a transparent sales process, TELUS has taken steps to ensure that its
rate plans are clear and simple and that customers understand exactly what they are paying
for. Rate plan information is always available to customers because TELUS invested in a
mobile app that allows customers to see their current services, manage their accounts and
make certain changes online or through their smartphones. TELUS also simplified its
contracts to two pages (from eight) to ensure that they were more readable and clear to
customers. This was done in 2011, two years before the Commission’s Wireless Code5
decision introduced similar requirements.
2.2.1.3 Cooling Off Period
39. Setting clear rate plans and making rate plan information available both online and in a plain
language contract significantly lowers the risk of misleading sales practices. It is difficult to
mislead a customer when key aspects of the plan are set out on paper and are available to a
customer on demand. However, recognizing that misunderstandings in the sales process are
possible, TELUS provides a “cooling off” period during which customers can cancel
services they feel they do not need without any penalty. Indeed, TELUS’ no-obligation
5
The Wireless Code, Appendix 1 to Telecom Regulatory Policy CRTC 2013-271, s. 1(i) and (ii).
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cancellation policies go well beyond what is required in the Wireless Code and apply to all
services that TELUS offers, not only wireless.
40. TELUS allows customers to cancel services even where TELUS has incurred substantial
customer acquisition costs. For example, #
.# TELUS’ service agreements generated through the door-to-door

order system give the customers the right to cancel without penalty up to 30 days after
installation, far exceeding regulated minimums.
2.2.1.4 Seeking Feedback
41. Another aspect of delighting customers in the sales process is training door-to-door sales
agents to seek feedback on TELUS services to which a person is already subscribed. If a
concern is identified at the door with an existing TELUS service, the agent is required to log
it. The concern then goes into a specialized escalation queue and someone from TELUS
follows up with the customer, usually within # #. This policy means that a sales visit
turns into a customer service touchpoint. Agents seek feedback and escalate issues whether
or not a sale is made.
2.2.1.5 Other Initiatives
42. TELUS has been ahead of the market on customer initiatives in other areas as well. For
example, TELUS introduced real time data monitoring and notifications to provide
customers with information and options to avoid data overage charges. Like plain language
contracts, TELUS did this before it was mandated by the Wireless Code. In fact, the Wireless
Code itself was born of a TELUS initiative: it was TELUS that wrote to the Commission and
asked for the Wireless Code to be enacted.
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2.2.2 Customer-centric Complaint Resolution
43. TELUS is inspired each and every day to do what’s best for customers by ensuring that their
concerns are fully addressed. TELUS takes every customer complaint very seriously and has
operational teams that actively analyze data to get ahead of issues, provide leadership with
proactive updates and recommendations, and has a robust process to deal with complaints
effectively and efficiently. This includes #
# Customer escalations data is shared internally by

TELUS CEO, Darren Entwistle, on a weekly basis in order to reinforce the TELUS
commitment to delight customers.
44. All feedback, including complaints, is central to putting customers first. TELUS strives to
resolve all complaints quickly and to the satisfaction of the customer. Once an individual
issue is resolved, its root causes are analyzed to ensure that other customers do not
experience the same concerns. This proactive approach is a significant aspect of ensuring
that customers are satisfied with their services and freely feel comfortable recommending
TELUS products and services to others.
2.2.3 Customer Service Leadership in Call Centres
45. TELUS also puts customers first in its call centre practices. In 2011, TELUS #
46. #
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# By emphasizing metrics like contact quality, first-call resolution and customer

satisfaction, TELUS agents spend time serving customers and ensuring customer
satisfaction, not trying to reach a time target. This is just one of the ways that TELUS ensures
that every call to its call centre is value-added for customers.
2.2.4 Leadership in Service of Senior Residents and Non-native English Speakers
47. TELUS also believes that seniors, non-native English speakers and other groups identified
as vulnerable by the Governor in Council and the Commission are important customers
whose needs should be placed first. TELUS strives to deliver excellent service to customers
in those groups and ensure that they recommend TELUS services to others.
48. For example, TELUS developed several innovations in television aimed at senior resident
homes including a special remote control, custom and easy to use on-screen menu and a
curated library of health and wellness content. As part of its Customers First commitment,
TELUS also offers interactive workshops and resources to help Canadians of all ages have
a positive experience as digital citizens. These workshops cover topics including protecting
your online security, privacy, and reputation, rising above cyberbullying, and using
technology responsibly. In the last 12 months, TELUS held 122 such workshops and
educated 3,029 attendees.
49. TELUS also puts Customers First by speaking the customer’s language. With more than
45% of the population in Canadian cities now being born in countries other than Canada or
speaking a language other than English or French, TELUS demonstrates its commitment to
these customers by developing specific products, offers, community investment/charitable
giving, customer support and unique experiences tailored to them. For example, for the
TELUS fibre roll-out, press announcements are made in Chinese, Korean, South Asian and
Filipino media outlets, digital and direct marketing is deployed to reach Chinese and South
Asian customers and tailored TV content is offered to multicultural communities. Customer
service at TELUS is also provided in more than two dozen languages through contact centres
and 17 languages at the door.
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50. These are just a few examples of how the Customers First program works in practice. There
are many other examples that all point to the conclusion that TELUS strives to make each
interaction with every customer and potential customer easy, pleasant and value-added.
2.2.5 Other ways TELUS is focused on the end-to-end customer experience
51. As part of the Customers First strategy, TELUS invests in building the fastest, most reliable
and most extensive wireline and wireless networks and delivering the services and solutions
that Canadians need and want. Over the past five years, TELUS has invested over $3 billion
to bring gigabit-enabled TELUS PureFibre to over 100 communities in British Columbia,
Alberta and Quebec. This investment will provide the quality services that Canadians
deserve, and ensures a better future for Canadian communities. Greater access to and
adoption of broadband internet has been linked to better economic, environmental, and
health outcomes. As part of delivering on its Customers First promise, TELUS is building
gigabit networks to ensure that Canadians can benefit from better economic, environmental,
and health outcomes for years to come.
52. The gigabit-enabled TELUS PureFibre network is among the most advanced
communications infrastructures available in the world today. It enables local healthcare
providers, educators, businesses and technology companies to draw on the technology
needed to reimagine how they deliver existing services and develop entirely new solutions.
TELUS expects that its fibre network will be the backbone of future ‘smart buildings’, ‘smart
cities’ and ‘smart healthcare’.
53. To ensure that that the PureFibre network is available to as many customers as possible, in
areas where fibre is being rolled out TELUS door-to-door agents have knocked on millions
of doors and offered to educate residents about the PureFibre rollout and place a fibre
connection to their home with no obligation to purchase service. As a result, more than
# # homes were connected directly to the TELUS PureFibre Network during the build
roll-out, at a cost of approximately # #. During this phase, door-to-door agents
did not enter into sales conversations. Sales conversations took place only after fibre lines
were installed and permission was given by a resident for an agent to come back to discuss
services offered by TELUS.
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54. #
.#
55. TELUS has also consistently invested in its wireless networks to ensure TELUS customers
enjoy a high quality, reliable experience. TELUS has the largest and fastest wireless network
in Canada, and has won every major mobile network award in 2017 and 2018 – J.D. Power6,
OpenSignal7, PC Mag8, and Ookla9 - in recognition of the strength and commitment of its
wireless infrastructure investments.
56. The TELUS LTE network provides world-leading speed and reliable coverage for 99% of
Canadians, improving lives and powering Canada’s digital economy. As Canadians consume
ever increasing levels of data, TELUS is making necessary investments to increase data
speeds and reduce network latency. TELUS is also leading the way in 5G research and
technology, including piloting 5G technologies in the TELUS Vancouver Living Lab.
2.3 Focus on Customers First Drives Measurable Positive Results
57. The Customers First program was deployed enterprise-wide at TELUS because senior
leadership believed that a singular focus on the customer would drive positive business
results. In particular, the intention was to raise the likelihood of a customer recommending
6
The J.D. Power 2018 Canadian Wireless Network Quality Study, online: http://canada.jdpower.com/press-
releases/jd-power-2018-canada-wireless-network-quality-study. This study measured the number of network
issues among online survey respondents. TELUS ranked #1 in overall network quality in Ontario, B.C.,
Alberta, Saskatchewan and Manitoba and second in Quebec, New Brunswick, Nova Scotia, Prince Edward
Island, and Newfoundland and Labrador.
7
OpenSignal State of Mobile Networks: Canada (February 2018), online:
https://opensignal.com/reports/2018/02/canada/state-of-the-mobile-network. - Telus ranked #1 with superior
download speeds and latency than the competition; TELUS LTE download average of 44.5 Mbps makes it one
of the fastest operators in the world, according to OpenSignal tests. TELUS was also ranked #1 in a follow-up
report by OpenSignal dated August 2018. Online: https://opensignal.com/reports/2018/08/canada/mobile-
networks-update.
8
PC Mag Fastest Mobile Networks Canada 2017, online: https://www.pcmag.com/article/348825/fastest-
mobile-networks-canada-2017. TELUS named Canada’s Fastest Mobile Network, winning on overall
performance, PC Mag population-weighted speed score, and fastest network in Canada’s major cities.
9
Ookla Speed Test, online: http://www.speedtest.net/reports/canada/. TELUS won #1 Mobile Network Speed
in Canada.
17
TELUS to others, which in turn would bring in new customers and help keep existing
customers.
58. Throughout the last 10 years, TELUS has carefully measured those key metrics and has
found that a focus on the customer at every stage of the relationship, including at the sales
phase, has paid off. The chart below shows those metrics from an early year of the Customers
First journey and where they stand today:
2011 2017
TELUS TELUS
Likelihood to Recommend ## ##
Monthly Churn10 1.31%11 0.90%12
59. TELUS’ churn numbers have been going down since its Customers First program started,
and have been under 1% for the last 19 of 20 quarters.13 Average yearly churn has gone from
1.31% to 0.90% between 2011 and 2017, which is very significant as each 0.01% of churn
represents approximately 800 customers. An improvement in churn from 1.31% in 2011 to
0.90% in 2018 means that in an average month, approximately 32,800 customers chose to
stay with TELUS in 2017 that would have left if churn numbers had not changed since 2011.
60. TELUS also now has significantly lower churn than its major competitors. As the following
second quarter 2018 data show, TELUS keeps its clients longer and fewer clients leave
TELUS every month than Rogers and Bell:
10
Average postpaid wireless churn calculated over the entire year.
11
TELUS 2012 Annual Report, p. 64, online:
https://assets.ctfassets.net/rz9m1rynx8pv/3Ii8YZM544YYAyeGu4oioC/a7a47825009ecb04beb1abc6233dbb
db/2012_TELUS_annual_report_EN.pdf
12
TELUS 2017 Annual Report, p. 20, online:
https://assets.ctfassets.net/rz9m1rynx8pv/t4ESxjDOBE0qKoOiU8YmQ/416fb9b2cfbf87be4cfee491ff16eae7/
TELUS_2017_annual_report-for_online.pdf
13
TELUS Q2 2018 Quarterly Report, p. 12, online:
https://assets.ctfassets.net/rz9m1rynx8pv/100oPBgPt288kWmC0eMmYM/5f9cb65ffc0d98ca5060e269eeae2
84f/TELUS_Q2_2018_Quarterly_Report__EN.pdf
18
TELUS Bell Rogers
Likelihood to Recommend ## ## ##
Monthly Churn14 0.83%15 1.10%16 1.01%17
61. The impact of the Customers First program can also be seen when TELUS churn numbers
are compared with those of its major national competitors over time:
62. Lowering churn lowers the importance of acquiring new customers and allows TELUS to
spend fewer resources than its competitors on customer acquisition. Investments associated
with Customers First initiatives have led to industry-leading churn not just on a Canadian
basis, but also on a North American basis.
63. The results of the Customers First program are routinely communicated to TELUS investors
as our Customers First approach sets TELUS apart from our competition not only for
customers but for investors as well. For example, the TELUS 2017 annual report states:
Our leadership in customer loyalty and quality smartphone

loading highlighted the differentiated customer experience we
14
Q2 2018 average postpaid wireless churn.
15
TELUS Corporation Management Discussion and Analysis, Q2 2018, p. 9, online:
https://assets.ctfassets.net/rz9m1rynx8pv/100oPBgPt288kWmC0eMmYM/5f9cb65ffc0d98ca5060e269eeae2
84f/TELUS_Q2_2018_Quarterly_Report__EN.pdf
16
BCE 2018 Q2 Shareholder Report, p. 13, online: http://www.bce.ca/investors/financial-reporting/2018-
Q2/2018-q2-shareholder-report.pdf
17
Rogers Communications Reports Second Quarter 2018 Results, p.1, online: https://1vjoxz2ghhkclty8c1wjich1-
wpengine.netdna-ssl.com/wp-content/uploads/2018/03/Rogers-Q2-2018-Press-Release.pdf
19
strive to provide our customers at TELUS. Indeed, our extensive

product portfolio, pervasive distribution channels and superior
network, supported by our commitment to client service excellence,
resulted in our wireless customers spending more with us in 2017.18
[Emphasis added.]
64. Since 2012, TELUS has also maintained a significant customer service lead over its
competitors as evidenced by complaints to the CCTS. Despite being one of Canada’s largest
telecom providers, TELUS accounted for just 7.5 percent of industry complaints in the 2017-
2018 CCTS mid-year report. In fact, between July 2017 and July 2018, TELUS only had
# # well-founded complaints to CCTS and other regulators.19 This is impressive
considering that TELUS has millions of subscribers. That said, our objective is to reduce the
number of complaints to zero.
65. In contrast, Bell and Rogers, TELUS’ two major national competitors, accounted for nearly
half of all CCTS complaints. The CCTS mid-year report for 2017-2018 contains the
following figures:20
Provider TELUS Rogers Bell

Total Number of Accepted CCTS 511 707 2,275
Complaints
Percentage of Total Complaints 7.5% 10.3% 33.2%
66. On TELUS’ side, these results are the product of a sustained, company-wide commitment to
putting our customers first by taking every customer concern to heart and working to resolve
it. It is also a result of an honest and transparent sales process that leaves customers satisfied
with what they receive instead of disappointed about being misled.
2.4 Customers First Culture Helps Prevent Misleading and Aggressive Sales Practices
67. As a result of TELUS’ focus on the customer, its employees and third party sales agents are
trained and monitored to prevent misleading or aggressive sales practices or the selling of
18
TELUS 2017 Annual Report, p. 11. Online:
https://assets.ctfassets.net/rz9m1rynx8pv/t4ESxjDOBE0qKoOiU8YmQ/416fb9b2cfbf87be4cfee491ff16eae7/
TELUS_2017_annual_report-for_online.pdf
19
See Response to Request for Information TELUS(CRTC)16July18-21 for more information.
20
CCTS Mid-Year Report 2017-2018, p. 2. Online: https://www.ccts-cprst.ca/wp-
content/uploads/2018/04/CCTS-Mid-Year-Report-2017-2018.pdf
20
products or services that are not suitable to the customer. TELUS strives to ensure that
customers are not disappointed after sales interactions and trains and monitors its sales
agents to ensure that they provide complete and clear information regarding all aspects of
each product and service.
68. TELUS does this to comply with applicable rules and, more importantly, to ensure that every
customer will be satisfied and delighted with the TELUS products and services he or she
purchases. In rare instances where inappropriate practices are discovered, remedial action is
immediately taken to make things right for the customer and prevent a recurrence of the
conduct. Where necessary, disciplinary action may be taken against employees – up to and
including dismissal. Where the concern is with a third party, action up to termination of the
business relationship will be taken.
2.5 TELUS Differentiates Itself on the Unique Customers First Approach
69. As explained above, all processes at TELUS including sales are approached from a
Customers First perspective. TELUS has invested billions of dollars over the last decade to
differentiate itself from others in the industry and works hard to protect its investment in part
by ensuring that it is not undone by improper sales practices.
70. With respect to the Commission’s report and given that Customers First is a point of
differentiation for TELUS, it would be unfair and harmful to TELUS if the Commission
were to make broad statements about the industry as a whole, absent proper context. To the
extent that the Commission finds that aggressive or misleading sales practices occur, the
Commission should address that problem—but the Commission should avoid broad
industry-wide declarations where they do not apply evenly across the parties to this
proceeding. The Commission should also identify best practices and success stories in
addition to identifying any concerns.
3.0 Sales are key to Driving Adoption of New Technologies
71. Sales activities are a positive force in the telecommunications industry. Without an effective
sales force, customers would not become familiar with the products and services available
and would not know to purchase the products and services that meet their needs. A strong
21
sales force—especially in person door-to-door sales—is also critical for continued network
investments. In TELUS’ case, a fair, effective, and customer-oriented sales force has
facilitated the rollout of TELUS’ PureFibre fibre-to-the-premises (“FTTP”) service. Sales
are a crucial part of fulfilling the promise of a Digital Canada, and if the ability to sell is
compromised, the economic viability of investment in new technologies is at risk.
3.1 Door to Door Engagement is Critical for Rolling out Fibre to the Premises
72. TELUS has invested approximately $3 billion to date in rolling out PureFibre FTTP facilities
to more than 100 communities across Alberta, British Columbia and Quebec. TELUS has
established very strong relationships and received strong support from municipalities during
the construction and roll-out of PureFibre, including from mayors, municipal leaders and
regional districts throughout British Columbia, Alberta and Quebec. As a result of the
TELUS investment and the good working relationship with municipalities and their
residents, more than # # now have TELUS PureFibre installed.
73. Continuous direct engagement is key to TELUS’ customer experience success and is a
critical part of delivering FTTP service throughout TELUS’ serving area. Direct to Customer
(door-to-door) engagement is particularly important because only at this granular a level can
TELUS effectively communicate with customers and address their needs and concerns
directly and individually. The one-on-one level of engagement required by the TELUS build
process would not be possible by relying on events, marketing campaigns or conversations
in customer-initiated channels such as in-store or by telephone.
74. The first key goal of TELUS’ door-to-door teams is to gain permission from residents to
bring TELUS PureFibre to their homes. TELUS door-to-door representatives have knocked
on millions of doors and offered to inform and educate residents on the PureFibre rollout
and place a fibre connection to their home with no obligation to sign up for service. When
gathering permissions to install a fibre connection, door-to-door agents do not enter into a
sales conversation. Only after PureFibre has been installed and where permission has been
granted by residents will the door-to-door agents enter into a sales conversation.
22
75. In keeping with TELUS’ Customers First objectives, door-to-door engagements are handled
by highly trained agents and are monitored carefully. With every visit to a customer’s home,
the agent’s goal is to:
 Educate the possibilities that only PureFibre can offer the customer;
 Communicate transparently regarding the process of bringing PureFibre to

customers’ home; and
 Reassure the resident that work will be performed correctly and will not cause any
damage to customers’ home.
Importantly, customers at the door are educated about the fact that no cost or purchase is
required in order for fibre to be installed.
76. Once the build is complete, TELUS wants to ensure that residents are happy with process.
The feedback collected during this phase of customer engagement enables TELUS to make
improvements to the fibre roll-out. The majority of this feedback comes from direct
engagement with the customer. Without collecting feedback at the door, TELUS may may
not be able to learn of problems because customers may not reach out.
77. When TELUS installs PureFibre in a community, the approach is to use Direct to Customer
teams to knock every door with the intent of not only educating home owners on the value
of the technology upgrade but also taking the time to explain what that upgrade means to
them individually and as a community.
78. Sales are not permitted during this education phase. The door-to-door team also acts as
support advocates to the residents, asking each household representative if they have any
unresolved issues with TELUS. Where issues are identified, agents submitted support
requests, which were logged into a specialize queue. Every support request is followed up
on – usually within 48 hours – and closed to the customer’s satisfaction. Additionally, the
agent offers the home occupant the option to place a Fibre from the road to the side of the
home at no charge and no obligation to purchase services. Finally, the Direct to Customer
teams ask permission to market TELUS services to the homes at a future date. Products are
only offered for sale if this permission is given and after fibre lines were installed.
23
79. In order to make the PureFibre roll-out economically viable, a critical mass of homes in a
community has to be connected. As a result, TELUS works to ensure that all residents of the
community are aware of the fact that fibre is being built, how it may affect them and the
benefits that it brings. This is also beneficial to individuals in the community as they learn
about the benefits of fibre. The engagement required is different depending on the
community and the individual, which is why one-on-one engagement is key to the viability
of the fibre roll-out program.
80. Fibre roll out is simply not economically possible without the ability to educate customers
about it and sell the resulting services. Approximately # # of new services that use
TELUS PureFibre are sold by door-to-door agents. If this channel were unavailable, sales of
services based on PureFibre would drop by # #. With such a steep drop in the
number of customers signing up, the fibre build program would become economically
unviable in approximately # # of communities in which TELUS plans to build
PureFibre facilities. This would significantly impact the number of individuals, businesses
and organizations to whom next-generation high speed internet would not be available.
Door-to-door engagement is therefore critical to the roll-out of next generation technologies
and for delivering on the promise of a digital Canada.
4.0 Sales at TELUS
81. As noted above, TELUS knows that products and pricing can be replicated, but a team that
puts customers above all else is the ultimate differentiator and the most important value
proposition to its customers. Like all other processes at TELUS, the sales process is designed
to be simple, transparent and above all, customer-friendly. TELUS strives to ensure that
every interaction between an agent and a customer (or potential customer) is positive and
that there will be no disappointment after a sale is made.
82. The sections below describe TELUS sales channels, training of team members and third
parties, and the monitoring, compliance and audit processes that are deployed throughout the
organization and the mechanisms in place for resolution of complaints. TELUS’ overarching
objective is not just complying with the letter of the law, but ensuring that the focus in the
sales process is where it is supposed to be: on the needs of each individual customer.
24
4.1 Sales channels at TELUS
83. There are many channels through which customers can access TELUS. Among others,
TELUS promotes and sells its products in the following ways:
 TELUS’ inbound contact centre;
 TELUS’ outbound telephone sales;
 TELUS’ outbound telephone sales partners;
 TELUS’ door to door sales team (Alberta, British Columbia and Quebec only);
 Third party door to door sales teams partnering with TELUS (Alberta, British
Columbia and Quebec only);
 TELUS’ retail locations;
 TELUS’ brick and mortar retail partners (including third party dealers);
 TELUS’ online presence (telus.com, koodo.com and publicmobile.ca); and
 Special events kiosks such as sporting events, cultural festivals, and fairs.
84. In every channel, TELUS team members and contractors follow the same Customers First
values. TELUS representatives are trained to never rush explanations, ignore questions,
pressure customers to sign an agreement, or take advantage of a customer’s mental state.
TELUS monitors agent activity and undertakes periodic audits to ensure that the Customer
First values are not compromised.
85. #
# This is
another way to encourage agents to focus on quality sales—that is, sales of products,
services and features that customers need and want.
25
4.2 Compliance Programs are in Effect on All Sales Channels
86. TELUS has many controls and measures in place to mitigate the risks of team members and
third party suppliers engaging in misleading or aggressive retail sales practices. Such
controls include:
a) A corporate-wide Customers First commitment, as discussed above;
b) TELUS’ Code of Ethics and Conduct;
c) TELUS’ Supplier Code of Conduct;
d) Onboarding, ongoing training and regular coaching sessions;
e) TELUS’ Ethics Office and EthicsLine; Internal audits and surveys;
f) Programs for compliance with the Telecommunications Act, Competition Act,

Canada’s Anti-Spam Legislation and other rules administered by TELUS’ Legal
Services and Government and Regulatory Affairs groups; and
g) Peer to peer coaching tools, by which frontline team members can provide
coaching to each other.
4.2.1 Codes of Conduct
87. All team members are bound by the TELUS Code of Ethics and Conduct,21 which includes
provisions on transparency pertaining to sales and billing. In a section entitled “Ethical Sales
Practices”, it sets out TELUS’ expectation of its team members and contractors: “when
selling to a customer, we provide the customer options that will allow them to make informed
choices on the products and services that best meet their needs.”22 Team members, including
door-to-door sales representatives, who violate the Code of Ethics and Conduct face
immediate disciplinary action, up to and including termination of their employment.
Moreover, as described in the next subsection, TELUS employs robust processes for
21
TELUS Code of Ethics and Conduct, online:
https://assets.ctfassets.net/rz9m1rynx8pv/1inVFzAGAWkyAKacYckS6I/324ef1673cb41902bb98b7e1ae8a8e
e9/TELUS_Code_of_Ethics_and_Conduct_Feb_2018.pdf
22
Ibid, p. 15.
26
customers and team members to escalate any customer concerns such that they can be
immediately investigated and resolved. TELUS records show that there have been no
complaints to its EthicsLine about aggressive or predatory sales tactics in the last year.
88. Some functions within TELUS have codes of conduct specific to the work they do. For
example, the Customer Experience Code of Conduct has specific provisions relating to sales,
including:23
89. TELUS has also established a Supplier Code of Conduct (“Supplier Code”) 24 that is based
upon generally accepted standards of ethical business conduct. TELUS expects its third party
suppliers to comply with the Supplier Code and all applicable laws and regulations wherever
they operate. The Supplier Code is publicly posted on TELUS’ website. The Supplier Code
specifically sets out that suppliers are “expected to maintain high standards of courtesy,
professionalism, ethics and honesty in all their interactions with customers…and comply
with all applicable federal, provincial, state and local laws”.25
23
For a copy of the Customer Experience Code of Conduct, please see response to request for information
TELUS(CRTC)16July18-25, Attachment 25-1.
24
TELUS Supplier Code of Conduct, online:
https://assets.ctfassets.net/rz9m1rynx8pv/2Y4gZ5e2lamM6CwQI6WYYM/8f6c6dcd0314081f97590d2554a0
0c88/2018_Supplier_Code_of_Conduct.ENG.pdf
25
Ibid, p. 2.
27
4.2.2 Onboarding, ongoing training and regular coaching sessions
90. TELUS provides extensive training26 to its team members and third party sales agents as a
control to mitigate unethical conduct. All TELUS team members are also required to take
annual integrity training, including training on whistleblowing.27
91. All contact centre agents are taken through an extensive training curriculum with a special
focus on the customer experience. Classroom training spans #
#. These
training programs reflect the TELUS Customers First commitment and focus on product
knowledge, TELUS services, pricing, and how to have a quality customer experience.
92. Key to TELUS’ understanding of customers’ needs is TELUS’ Confident Conversations

program. Confident Conversations means that sales agents are trained on needs based selling
and a consultative sales approach for our customers. Training is geared toward providing
agents the tools to ask the right questions to determine the right fit for any customer and on
making agents experts in the TELUS product suite. TELUS invests considerable resources
in training agents to sell to customer need as opposed selling to targets.
93. TELUS sales training focuses on quality over quantity. As noted above, TELUS strives for
sales that lead to customers being delighted with services they are receiving, not disappointed
that what was promised is not being delivered or that they are paying for an unneeded service.
To that end, #
#
94. Lastly, all sales interactions are expected to align with expectations outlined in the Code of
Ethics and Conduct. Sales agents are provided specific training on the Code, as well as other
requirements including the Wireless Code.
95. As a result of the careful training and monitoring of its agents, TELUS receives compliments
from customers on their experiences. Examples of positive customer comments about door-
26
For more information on training of TELUS agents, please see Response to Request for Information
TELUS(CRTC)16July18-25.
27
A copy of the 2017 integrity training course can be found at Attachment 6 to Response to Request for
Information TELUS(CRTC)16July18-25.
28
to-door agents can be found at Attachment 5 to Response to Requests for information

96. #
4.2.3 TELUS Ethics Office and EthicsLine
97. The TELUS Ethics Office and EthicsLine are controls that discourage unethical conduct by
TELUS team members and enable the reporting of such conduct. Any team member, third
party employee, customer or member of the public can use the TELUS EthicsLine to report
unethical behaviour. One of the types of issues that can be reported is “pressure to meet
targets in a manner not consistent with TELUS values”.28 The service is administered by
EthicsPoint, a third party specializing in whistleblowing and breach of ethics reporting. The
EthicsLine portal is available online to anyone with an internet connection. A toll-free
number is also available for filing a report by telephone. These reports are confidential and
anonymous in order to promote candour and ensure complainants do not fear any
repercussions.
4.2.4 Audits and Compliance Monitoring
98. TELUS’ Internal Audit department provides independent, objective assessments on

management’s risk mitigation activities and control environment to the Board of Directors,
through the Audit Committee. The principal role of Internal Audit is to evaluate whether
TELUS’ governance, risk management and control processes, as designed and represented
by management, are adequate and functioning in a manner to enable:
28
TELUS EthicsLine, online: https://www.telus.ethicspoint.com
29
 achievement of the organization’s strategic objectives;
 effectiveness and efficiency of operations and programs;
 reliability and integrity of financial and operational information;
 compliance with applicable laws, regulations, policies, procedures and contracts;
 safeguarding of assets; and
 timely identification and mitigation of fraud.
99. Internal Audit also advises senior management regarding the adequacy and effectiveness of
TELUS’ risk management, internal control and governance processes. Internal Audit’s
annual internal audit program is approved by the Audit Committee of the Board of Directors.
100. TELUS’ contact centre agents are subject to a rigorous compliance program. Compliance
analysts and managers monitor #
.# Where the analysis reveals
deficiencies, the agent in question immediately receives remedial coaching. Where the
analysis reveals any unethical behaviour, including misleading or aggressive sales practices,
TELUS dismisses the agent immediately. During the past year, TELUS terminated the
employment of # # contact centre sales agents for unethical sales practices.
101. TELUS’ door to door agents similarly receive ongoing training and coaching. Any
allegations of misconduct are immediately investigated and noncompliance can result in
dismissal. A quality assurance team contacts customers to remind them of their upcoming
installation. During this contact, if a customer discloses any concerns with the sale, the
quality assurance team will provide the information required to the customer or cancel the
installation request as required. These findings are tracked and reported daily and weekly.
102. For retail locations, compliance audits are # #. In

addition, TELUS has an operational performance program that measures business practices
and is designed to minimize business risk, measure program/policy adherence, create
consistent and measurable operational performance nationally and quickly identify coaching
opportunities.
30
103. As described above, multi-layer compliance programs are in effect on all sales channels.
TELUS does so not only to comply with the letter of the law, but to ensure that its Customers
First promise is borne out by transparent, customer-friendly sales process. Employees and
third parties that are identified as not being able to live up to TELUS values are quickly
terminated. In the last six months, TELUS #
#
4.2.5 Telecommunications Act, Competition Act and Canada’s Anti-Spam Legislation

Compliance Programs administered by TELUS’ Legal and Regulatory Affairs
groups
104. TELUS has enhanced its commitment to corporate compliance by establishing a formal
compliance program with respect to TELUS’ obligations under the Telecommunications Act
and Canada’s Anti-Spam Legislation. The Telecommunications Act compliance program
includes centralized policies and procedures and training intended to ensure and promote
compliance with such retail sales-related CRTC directives as the Wireless Code, the
prohibition against 30-day cancellation policies, contractual and disclosure requirements and
other consumer safeguards. TELUS also ensures that its direct selling activities comply with
the Television Service Provider Code.
105. The Telecommunications Act compliance program includes an ongoing training and
communication component including presentations by legal counsel or regulatory advisors,
compliance bulletins and other training tools and communication mechanisms.
106. Monitoring, auditing and reporting mechanisms are vital to the success of any corporate
compliance program. Accordingly, the Telecommunications Act compliance program also
includes monitoring, reporting and verification measures and requires team members to
report instances of non-compliance. Consequences for team members who initiate or
participate in contraventions of the Telecommunications Act or CRTC directives may include
disciplinary action, up to and including suspension and dismissal. In addition, a breach of
the compliance program by a TELUS business partner can result in termination of
association.
31
107. Under its compliance program, TELUS is empowered to conduct audits as a means through
which certain risk management activities are observed and assessed. Compliance audits may
be ad hoc, periodic or event triggered, and are designed to determine whether a contravention
of the law has occurred and, if so, to ensure that such contraventions are addressed.
108. TELUS also strives to inform all team members with a need to know of the restrictions and
requirements imposed by the Competition Act, including those provisions related to
misleading advertising and deceptive marketing practices, in a number of different ways
through our competition law compliance program.
109. As part of the program, TELUS’ Data & Trust Office partners with TELUS Legal Services
and other business units to ensure that processes and controls are created for effective
monitoring of competition law. TELUS Legal Services provides team members with
guidance relating to competition law compliance and education.
110. Competition law training (either via eLearning or face-to-face) is mandatory for identified
TELUS employees and must be completed every other year. Identified employees include
those who have substantive interaction with customers, suppliers, and/or competitors.
TELUS considers team members in sales and marketing roles (among other roles) to be a
high risk area, and accordingly prioritizes such team members for detailed training and
closely monitors training completion.
111. Audits may be conducted to identify whether a violation of the Competition Act has occurred.
It is TELUS’ policy that all personnel have an unfettered ability to report conduct that is
reasonably believed to be in contravention of the Competition Act. Consequences for TELUS
team members that commit violations of the Competition Act may include disciplinary
action, up to and including dismissal.
112. By devoting resources to these compliance activities, TELUS strives to maintain best-in-
class relationships with its customers and potential customers, consistent with TELUS’ own
principles and with applicable laws.
32
4.3 Selling to Potentially Vulnerable Consumers
113. TELUS trains representatives on what makes a customer vulnerable, how to identify
vulnerable customers through specific listening skills, and how to interact with vulnerable
customers. This training program is reviewed with new employees in TELUS’ door to door,
contact centre and retail locations.
114. TELUS representatives are trained on how to ask the right questions and actively listen in
order to identify customer needs, and to paraphrase back to the customer what he or she has
said in order to ensure understanding. TELUS representatives are instructed, where
appropriate, to suggest that the customer bring a relative, friend or other reliable source of
support if the customer is struggling to understand an offer. In all cases, TELUS
representatives are instructed to look for signs that the customer does not understand an
explanation, to provide a clear and simple product presentation, and to seek assistance from
their managers when they are unsure of how to proceed.
115. TELUS representatives are also trained never to rush explanations, ignore questions,
pressure customers to sign an agreement, or take advantage of a customer’s mental state.
This is reflected in TELUS’ sales materials and training programs.
116. In addition, specific safeguards are in effect for each of the classes of vulnerable customers
outlined below.
4.3.1 Customers Potentially Vulnerable due to Age
117. In line with TELUS’ Customers First program, TELUS does not engage in outbound
telephone sales where a customer’s profile indicates he or she is #
.# As explained above, TELUS has also launched TELUS
Wise for seniors, a program to increase internet literacy with seniors, which is delivered to
senior citizens in select multi-dwelling buildings. These educational sessions take place
either monthly or yearly and, in the last year, TELUS held 122 workshops educating 3,029
attendees.
33
4.3.2 Customers Potentially Vulnerable due to a Disability
118. TELUS employs many initiatives to ensure that people with disabilities are able to
participate in the digital economy. This includes, for example, providing devices with built-
in accessibility features, which enable customers to use mobile phones and services easily.
It also means designing TELUS stores and self-service kiosks with accessibility in mind, and
ensuring that TELUS and its brands’ websites meets the latest accessibility standards.
119. In practice, a commitment to accessibility takes many forms, including the following:
 TELUS operates an online portal available to sales agents contains a section

showcasing products and services geared toward customers with disabilities.
TELUS agents are trained to identify customers with disabilities and offer those
products and services from which they believe a customer will benefit.
 In retail locations, representatives are specially trained in supporting customers

with disabilities and how to address their needs. This training includes a reference
guide available to retail employees.29
 On August 1, 2018, TELUS launched its new accessibility website, which sets out
how TELUS embeds accessibility features and principles in everything it does.
The website provides information on accessible devices (including visual,
mobility, cognitive and hearing/speech features) and accessibility services
(including flexible rate plans to hearing and speech assistive technology support).
 TELUS has launched a plan to create Accessibility Centres of Excellence within

its customer-facing channels (web, in-store, and contact centres). The plan
consists of the following:
i. TELUS will identify select stores in major markets to become designated

Accessibility Centres of Excellence. Those stores will be used to improve
and test service in order to deliver an unparalleled customer experience.
ii. New sensitivity training and training about products, services and solutions
provided by TELUS and designed for persons with varying abilities.
iii. On the web, TELUS will be conducting customer research to determine and
implement changes that will assist persons of varying abilities to find
solutions and options based on their needs.
29
The guide is attached as Attachment 2-1 to Response to Request for Information TELUS(CRTC)16July18-2.
34
iv. In the contact centres, TELUS is investigating successful strategies for

serving persons with disabilities, with the goal of developing a plan to
incorporate and test new ideas to improve the contact centre experience.
 TELUS offers discounts for consumers with accessibility needs. Customers who
identify as deaf or hard of hearing, or who have a visual disability and use way-
finding and GPS applications, are eligible to receive a $20 monthly discount
applicable to all in-market “Your Choice” wireless plans. These plans include
unlimited nationwide text, picture and video messaging, unlimited data for the use
of the SRV Canada VRS video relay service application, access to 9-1-1, call
display and voicemail, 300 local daytime voice minutes, and unlimited weekend
and evening calls after 6:00 PM.
 TELUS offers TELUS Relay Service, which enables clients who are deaf, hard of
hearing or experience difficulty with speech, and who use TTY, to communicate
with TELUS regarding their accounts.
4.3.3 Customers Potentially Vulnerable due to a Language Barrier
120. TELUS has the capability to serve customers in more than two dozen languages in some of
its channels. As with all other customers, TELUS communication strategy is driven by our
brand promise of putting Customers First by speaking our customer’s language. Given an
increasing number of Canadian residents who speak languages other than English or French,
TELUS continues to evolve and extend its commitment to customers by developing specific
products, through community investment/charitable giving, customer support and unique
experiences tailored to unique multicultural customer needs.
121. As noted above, TELUS also reaches out to ethnic language communities by way of ethnic
media advertising and press releases, attending cultural fairs and exhibitions, via direct
marketing and by using multilingual brand ambassadors.
4.4 Customer Complaints are Addressed and Root Causes are Identified and Corrected
122. TELUS created multiple methods for customers to express concerns about all TELUS-
related issues, including sales. Customers may submit a formal complaint about any matter
– including how they were treated by a sales agent – via phone, email, chat, mail, or at any
TELUS store. TELUS Relay Service (TTY) is available for customers with disabilities who
wish to complain by phone.
35
123. As part of TELUS’ Customers First program, almost any TELUS employee or contractor,
regardless of function, is empowered to escalate a customer concern. Examples include door-
to-door agents, in-store representatives, TELUS agents at a community event, and TELUS
employees and contractors that a customer knows socially.
124. Once a complaint is received, TELUS has the following internal tools and groups to ensure
that complaints are addressed as quickly and efficiently as possible:
 SOS: a resource for any team members (including contractors) to submit an

escalation on behalf of a customer for immediate investigation and resolution;
 Executive Client Relations: a small internal team who handle complaints made
directly to the CEO and the executive leadership team;
 Escalation Management Team: This team handles inbound contact centre

escalations.
125. TELUS takes every customer complaint very seriously and has a robust process for
addressing complaints effectively and efficiently. TELUS team members and managers learn
through every escalation, ensuring that root causes are identified and actions are taken to
prevent a recurrence of the underlying issue. TELUS strives to have every escalation triaged
within # # and make contact with the customer within the same time frame.
126. Team members regularly present escalation case studies to the TELUS Executive Leadership
Team to capture areas of opportunity, prevent recurrence and improve the customer
experience. The Executive Leadership Team takes special note of these reports. Each week,
escalations are shared with all team members by way of an e-mail communication sent by
TELUS’ CEO. One special story is highlighted each week to capture how a customer’s
complaint was addressed and resolved and how TELUS commits to always putting
customers first. Further, team members are asked to review the weekly customer feedback
and experiences and engage with other team members on experiences that are being shared.30
127. Given the strategic importance and significant capital investment that TELUS is making in
fibre-to-the premises facilities, special care has been taken with PureFibre deployment to
30
An example is presented in attachment 11-1 attached to Response to Request for Information
36
increase overall public awareness, acceptance and support from local municipalities. As part
of its collaboration with municipalities, TELUS brings the municipality’s executive leaders
and key staff together to help make sure that the build and related activities (marketing
planning, operations and communications methods) are a fit for their specific community.
TELUS provides PureFibre municipalities with a key TELUS contact and process
information to share with customers so that any complaints can be efficiently actioned and
resolved. TELUS encourages customers to reach out to the TELUS contact directly if there
are any concerns during the project.
128. #
.#
129. #
37
5.0 Existing rules cover poor sales practices
130. Misleading and aggressive sales practices are illegal under existing rules. There are a number
of statutes and regulations that address and prohibit aggressive and misleading sales practices
that are of concern to the Governor in Council and the Commission. This section will set out
the existing regulatory instruments, explain how they apply to sales in the
telecommunications industry and why new laws and regulations governing sales are not
necessary. To the extent that there is a concern, it is one of customer education and access
to redress.
131. As will be explained in the next section, TELUS proposes a two-pronged approach to address
misleading and aggressive sales practices in the industry. First, consistent with the mandate
and purpose of the Commission for Complaints for Telecom-Television Services (“CCTS”),
a new code of conduct can clarify the CCTS mandate with respect to misleading and
aggressive sales practices and ensure that it is able to properly and fairly permit consumers
to seek redress if they have been misled in the sales process or were otherwise subject to
poor sales practices. Second, if trends suggestive of problems are identified, regulators
including the Commission and the Competition Bureau can address them using the range of
available remedial measures including consumer education, outreach to service providers
and – where necessary – progressive discipline.
132. Statutory and regulatory provisions addressing sales practices which already apply to all
TSPs in Canada include the following instruments:
a) Competition Act for all forborne or exempted products and services;
b) Part III of the Telecommunications Act, which has numerous sections regulating
the “offering” (i.e. sales) of telecommunications services;
c) Wireless Code for wireless products and services;
d) Television Service Provider Code of Conduct for television services; and
e) Tariffs and Consumer Bill of Rights for retail services subject to a tariff.
38
133. As explained further below, the Wireless Code and the Television Service Provider Code of
Conduct are administered by the CCTS, which is empowered to resolve consumer
complaints by making certain orders against telecommunications service providers. The
mandate of the CCTS can be clarified through a code of conduct to ensure it is able to
adjudicate consumer complaints with respect to aggressive or misleading sales practices.
5.1 Competition Act
134. Deceptive marketing practices are already prohibited by Part VII.1 of the Competition Act.
The provisions in this section apply to all products and services offered to “the public”,31
that is, Canadian consumers, with the exception of services subject to a tariff.32
135. The provisions of the Competition Act address the concerns of the Governor in Council and
the Commission regarding misleading sales practices of in-store, contact centre and door-to-
door sales. The provisions set out below make false or misleading representations, wherever
and however made, constitute reviewable conduct under the Act:
74.01 (1) A person engages in reviewable conduct who, for the

purpose of promoting, directly or indirectly, the supply or use of a
product or for the purpose of promoting, directly or indirectly, any
business interest, by any means whatever,
(a) makes a representation to the public that is false or misleading in

a material respect […]
74.03 (1) For the purposes of sections 74.01 and 74.02, a

representation that is […]
(d) made in the course of in-store or door-to-door selling to a

person as ultimate user, or by communicating orally by any
means of telecommunication to a person as ultimate user, […]
is deemed to be made to the public by and only by the person who

causes the representation to be so expressed, made or contained […]
31
Competition Act, R.S.C., 1985, c. C-34, ss. 74.01, 74.011, 74.02 and 74.03.
32
CRTC/Competition Bureau Interface, 2001. This document makes it clear that the Competition Act applies
only where the Commission has forborne from regulation. The document states, for example, “[w]here the
Commission has forborne only in part or has exempted or forborne conditionally, the Bureau considers that the
Competition Act would apply to the activities exempted or conditionally forborne from regulation.” Online:
http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/01598.html
39
136. There is also a general prohibition in the Competition Act on supplying products at a higher
price than advertised:
74.05(1) A person engages in reviewable conduct who advertises a

product for sale or rent in a market and, during the period and in the
market to which the advertisement relates, supplies the product at a
price that is higher than the price advertised.
137. Where the above-noted provisions of the Competition Act are breached, it is open to the
Competition Bureau to make an application to the Competition Tribunal, Federal Court or a
provincial Superior Court for an order than the conduct cease, an administrative monetary
penalty of up to $15 million be paid or other appropriate relief.33 As explained below, these
provisions have already been applied to regulate conduct of telecommunications service
providers.
138. In extreme cases, the criminal provisions of the Competition Act may also be used to regulate
aggressive and misleading sales practices. The Competition Act provides that “a
representation to the public that is false or misleading in a material respect” that is made for
the purposes of promoting a product or a business interest by any means (which includes
door-to-door, in store, by telephone or online) an offence34 for which the punishment
includes imprisonment of up to 14 years, a fine or both.35 The Act also gives aggrieved
persons a private right of action if this provision is contravened.36
139. These sections prohibit precisely the type of sales practices that are at issue in this
proceeding. Conduct by salespeople that is misleading or results in unexpected fees that were
not disclosed is expressly and unambiguously prohibited by the Competition Act and subject
to civil and potentially criminal enforcement. Unlike other regulations aimed at specific
services such as wireless or television, these provisions apply to all forborne or exempted
products and services offered by telecommunications carriers and include service bundles.
33
Competition Act, R.S.C., 1985, c. C-34, s. 74.1.
34
Competition Act, R.S.C., 1985, c. C-34, ss. 52 and 52.01.
35
Ibid, s. 52(5).
36
Ibid, s. 36.
40
140. However, the foremost shortcoming of the Competition Act is that its enforcement lies
largely in the hands of the Competition Bureau rather than individual consumers. While there
is a private right of action for breaches of some sections the Competition Act including
criminal misleading representation provisions,37 an individual wishing to avail him or herself
of this action is required to bring an action in court—which is costly, time-consuming, and
generally unsuitable for resolving retail customer complaints. The administrative monetary
penalty and criminal cases are typically investigated by the Competition Bureau, which,
according to the Bureau itself, does not have the resources to take action on every individual
complaint.38 In some respects, the CCTS is empowered to address some of the deceptive
marketing practices that are prohibited by the Competition Act. TELUS’ proposal for a new
code of conduct, detailed below, will improve consumer access to redress in these situations.
5.2 Telecommunications Act
141. Part III of the Telecommunications Act regulates services provided by means of
telecommunications facilities, including any related equipment and incidental services.39 It
therefore captures all telecommunications products and services, including handsets,
modems, wireless data devices, internet services, telephone services and wireless services.
142. Section 24 provides:
[t]he offering and provision of any telecommunications service by a

Canadian carrier are subject to any conditions imposed by the
Commission or included in a tariff approved by the Commission.40
The word “offering” expressly contemplates sales of telecommunications services. There

are numerous regulations and conditions made under section 24 that regulate sales
practices, including the Wireless Code, Consumer Bill of Rights and tariffs. Section 24.1
37
Ibid.
38
Comments of the Commissioner of Competition in response to Public Notice 2007-16, 16 November 2007, at
paras. 13, 15.
39
Telecommunications Act, S.C. 1993, c. 38, ss. 2, 23.
40
Telecommunications Act, S.C. 1993, c. 38, s. 24.
41
similarly regulates sales of telecommunications services by persons other Canadian

carriers.41
143. Section 27 of the Telecommunications Act requires Canadian carriers to charge just and
reasonable rates and not engage in unjust discrimination or give under or unreasonable
preference to any person, including itself.42 This applies to sales practices, and prevents
Canadian carriers from selling products or services at rates that are not just and reasonable.
Section 27(2) regulates discrimination in relation to the provision of a telecommunications
service, such as targeting or misleading elderly, disabled or otherwise vulnerable consumers.
144. As with the Competition Act, these provisions apply to all telecommunications services.
Contravention of these provisions can result in an administrative monetary penalty of up to
$15 million being levied.43
5.3 The Wireless Code
145. Sales of all mobile wireless devices and services to consumers and small businesses are
regulated by the Wireless Code.44 The Wireless Code governs the relationship between
wireless carriers and their customers, is mandatory,45 and contains numerous provisions
relevant to sales practices. As explained below, the Wireless Code prohibits the aggressive
and misleading sales practices at issue in this proceeding in respect of sales of wireless
products and services.
146. First, the Wireless Code requires service providers to communicate with customers in clear,
timely, accurate and plain language.46 This applies to all communications, regardless of
means (oral, written, etc.) and location that a communication takes place. The provisions of
the Wireless Code apply equally in store, at the door, over telephone and online.
41
Ibid, s. 24.1.
42
Ibid, ss. 27(1) and 27(2).
43
Telecommunications Act, S.C. 1993, c. 38, s. 72.001.
44
Appendix 1 to Telecom Regulatory Policy CRTC 2017-200.
45
Wireless Code, Preamble and s. 1(i)(b), Appendix 1 to Telecom Regulatory Policy CRTC 2017-200.
46
Ibid, A(1)(i).
42
147. The Wireless Code also requires that prices paid by a customer be clearly set out in a contract,
including whether those prices include taxes.47 This requirement ensures that a customer
knows exactly how much will be paid at the time the contract is entered into.
148. To make it easier for customers to understand their contracts, the Wireless Code requires
carriers to provide a critical information summary. The critical information summary
includes a complete description of key contract terms, total monthly charge, any one-time
charges and the trial period.48 As with all communications between wireless carriers and
their customers, the critical summary must be written in clear, timely, accurate and plain
language.49 In addition, the summary is required to be clear and concise, written in easily
readable font and not exceed two pages.50
149. The Wireless Code also requires a carrier not to charge for any device or service than has
not been expressly purchased by the customer or authorized user.51
150. These requirements address the issues raised by the Governor in Council and the
Commission in respect of aggressive and misleading sales practices when it comes to
wireless services and devices. Where the provisions of the Wireless Code are followed, there
is no opportunity to mislead a customer: the details of the plan and required payments are
clearly and plainly set out in documents given to the customer and the customer can only be
charged for services that have been expressly purchased.
151. Lastly, the Wireless Code requires carriers to offer a trial period of at least 15 days 52 (30
days where the customer self identifies as having a disability53). If a misrepresentation was
made during the sales process, the customer may simply cancel without any penalties or
payments.
47
Ibid, A(2)(i).
48
Ibid, C(1)(iii).
49
Ibid, A(1)(i).
50
Ibid, C(1)(iv).
51
Ibid, E(4)(i).
52
Ibid, G(4)(i)-(iii).
53
Ibid, G(4)(iv).
43
5.4 Television Service Provider Code
152. The Television Service Provider Code (“TVSP Code”) also contains provisions that prohibit
aggressive and misleading sales practices. The TVSP Code applies to subscription TV
services provided by TV service providers, including when sold as part of a bundle with
telecommunications services such as internet access, home telephone and wireless services.
153. Similar to the Wireless Code, the TVSP Code requires that providers:
a) communicate in plain language, including during telephone calls and in

promotional material;54
b) clearly explain any offers made to consumers in all communications, including

communications by telephone;55
c) ensure that any written agreements and related documents are written in a way that
is clear and easy for a customer to read and understand;56
d) provide a critical information summary;57 and
e) provide a 30-day trial period for customers who self-identify as having a

disability.58
154. Similar to the Wireless Code, these requirements of the TVSP Code address the issues raised
by the Governor in Council and the Commission in respect of aggressive and misleading
sales practices when it comes to television services, including when offered as part of a
bundle. Where the provisions noted above are followed, there is no opportunity to mislead a
customer: communication must be in plain language, details of the plan and required
payments are clearly and plainly set out in documents given to the customer, and where there
is concern about a disability, the customer may cancel service within 30 days without charge
54
The Television Service Provider Code, Appendix to Broadcasting Regulatory Policy CRTC 2016-1, s. I.1.
55
Ibid, s. II.1.
56
Ibid, s. IV.1.
57
Ibid, s. IX.
58
Ibid, s. VII.
44
if the service is not what was promised by a salesperson or what the customer intended to
receive.
5.5 Tariffs and the Consumer Bill of Rights
155. Sales practices are further constrained by price regulation set out in tariffs which continue to
apply to local telephone services in non-forborne exchanges throughout Canada. There is
little opportunity to mislead a customer where regulation spells out the precise service to be
provided and the price to be charged for that service.
156. Carriers providing retail residential telecommunications services that are subject to a tariff
must also comply with the Statement of Consumer Rights.59 The Statement of Consumer
Rights, sometimes referred to as the Consumer Bill of Rights, sets out the services that must
be provided to people who subscribe to a tariffed service. Provisions of the Statement of
Consumer Rights include the right to receive basic services (such as local calling, 911 and
touch tone dialing), restrictions of when deposits are required and when service can be
disconnected, the right to block 900/976 calls, and certain additional rights for Canadians
with disabilities including message relay service and free directory assistance.60
157. Tariffs and the Consumer Bill of Rights regulate sales by setting out the services that must
be included as part of the price of basic telephone service. There is no room for aggressive
or misleading sales practices when regulations provide not only the price to be charged for
a service (a tariff), but also the exact components of the service that must be provided. To
the extent that there are concerns about improper selling of non-forborne services, the
solution is enforcement of existing tariffs and the Consumer Statement of Rights.
5.6 Commission for Complaints for Telecom-television Services
158. The Commissioner for Complaints for Telecom-television Services (CCTS) has the
authority to “receive complaints from Customers regarding: (i) forborne (unregulated) retail
telecommunications services provided by Participating Service Providers; and (ii) retail
59
Statement of Customer Rights, Telecom Decision CRTC 2006-52 at paras. 14-15. The text of the Statement of
Consumer Rights was revised in Telecom Decision CRTC 2006-78.
60
Appendix to Statement of Consumer Rights, Telecom Decision CRTC 2006-78.
45
residential subscription television services provided by Participating Service Providers”

subject to certain exceptions.61 The CCTS is further empowered to “administer codes of
conduct imposed by the [CRTC], including without restriction the Deposit and
Disconnection Code, the Wireless Code, and the Television Service Provider Code.”62
159. As part of its decision-making power, the CCTS can order a carrier to make an apology,
compensate a customer up to $5,000, undertake to do or cease doing specified activities with
respect to a complainant, or any combination of these orders.63
5.7 No need for additional rules relating to sales of telecommunications services
160. The Competition Act, Telecommunications Act, Wireless Code, TVSP Code and the
Consumer Bill of Rights have existing provisions that regulate the types of sales practices at
issue in this proceeding. No aggressive or misleading sales practice is permissible under the
current rules, and thus no further rules are needed.
161. However, this does not mean that nothing needs to be done to stop misleading and aggressive
sales practices. Steps needs to be taken to ensure that there are efficient, timely and cost-
effective ways to for consumers to seek redress for under rules that already exist, including
the Competition Act. In addition, procedures can to be developed to ensure that repeated or
systemic contraventions of the Competition Act, Wireless Code, TVSP Code and other
relevant regulations are investigated and addressed without the need for individual
consumers to prosecute claims in court.
162. The next section provides a proposal for a hybrid enforcement system that will get consumers
a fast resolution of their individual complaints while ensuring that organizations that
repeatedly or systemically engage in aggressive or misleading sales practice will be
discouraged from doing so.
61
CCTS Procedural Code, s.3.1(a). See also CCTS Participation Agreement, art. 12(a).
62
CCTS Participation Agreement, art. 12(b). See also CCTS Procedural Code, s.4.2 providing that in making a
determination, “the Commissioner will consider any applicable codes of conduct or practice…”
63
CCTS Procedural Code, s. 14.1.
46
6.0 Improving Access to Justice for Consumers and Discouraging Aggressive and
Misleading Sales Practices
163. To ensure that redress is available to individuals subject to improper sales practices and
companies are discouraged from engaging in such tactics, TELUS proposes the following:
 Individual complaints regarding misleading or aggressive sales practices be

addressed by the CCTS pursuant to a new code of conduct that formalizes existing
rules and clarifies the CCTS mandate in this respect; and
 Systemic or repeated contraventions of Part VII.1 of the Competition Act be

addressed by the Competition Bureau and the Commission with remedial tools,
such as consumer education and – where necessary – progressive discipline, that
are already available under the Competition Act and the Telecommunications Act
respectively. The Commission may act as a resource in to the Competition Bureau
under the Letter of Agreement between them.64
164. TELUS further proposes that statistics collected by CCTS from resolving individual cases
be used by the Competition Bureau and the Commission to identify trends, including whether
specific carriers are subject to a disproportionate number of complaints. When a trend is
identified, the Competition Bureau may investigate the presence of a potential systemic
problem which requires action under the Competition Act. Similarly, the Commission can
investigate whether the conduct is sufficiently serious to warrant action and if so, it can
educate consumers, warn carriers, engage in heightened monitoring and reporting, institute
show cause proceedings, and where necessary, levy an administrative monetary penalty
under section 72.001 of the Telecommunications Act.
6.1 The Commission should publicly assert its exclusive jurisdiction to regulate
telecommunications and radiocommunication undertakings
165. To avoid a multiplicity of potentially contradictory sales regulation regimes in different

provinces, the Commission should clearly articulate the state of constitutional jurisdiction in
Canada as determined repeatedly by courts throughout the country, including the Supreme
Court of Canada. Specifically, subsection 92(10) of the Constitution Act, 1867 grants
Parliament exclusive jurisdiction over the regulation of telecommunications and
64
Letter of agreement between the Chairman and Chief Executive Officer of the Canadian Radio-television and
Telecommunications Commission and the Commissioner of Competition of the Competition Bureau, 23
September 2013.
47
radiocommunication undertakings. By using consumer protection legislation to regulate

telecommunications undertakings, some provinces have adopted regulatory regimes that are
(1) constitutionally invalid because the pith and substance of the legislation is about a matter
that is within the exclusive jurisdiction of Parliament; (2) inapplicable by way of the doctrine
of interjurisdictional immunity, and (3) inoperative as a result of the federal paramountcy
doctrine.
166. The Commission ignores unconstitutional provincial intrusion at its peril: unconstitutional
provincial regulation weakens the Commission’s authority, leads to an overly complex
regime, and creates confusion for consumers of telecommunications services because it
ultimately leaves them with a patchwork of standards rather than one clear national code.
This complexity further leads to increased compliance costs for providers and thus
needlessly increases costs to consumers. The Commission should therefore state clearly that
its rules governing the offering and provision of telecommunications services are intended
to be binding, of exclusive federal jurisdiction, and national in scope, with no room for
provincial encroachment. Such a statement is necessary to ensure that sales standards are
consistent between provinces and industry players, that duplicative and potentially
contradictory regimes do not threaten national application of federal rules, and that the
Commission’s intentions are not thwarted by provincial regulators who may desire to
implement a different regulatory regime.
6.1.1 Provincial telecommunications regulation impairs the federal regulatory regime

and imposes significant costs on providers and consumers of telecommunications
services
167. Despite clarity on the lack of provincial jurisdiction over telecommunications, some
provinces have enacted consumer protection legislation purporting to directly regulate
telecommunications services. Examples include the Wireless Services Agreements Act, 2013
in Ontario,65 Part XXII of the Consumer Protection Act in Manitoba titled “Contracts for
66
Cell Phone Services” and Consumer Protection and Business Practices Act in
65
S.O. 2013, c. 8.
66
C.C.S.M. c. 200, ss. 180-211.
48
Newfoundland and Labrador, which purports to apply to “the use of cell phones, residential
phones, internet, cable and satellite television and remote surveillance.”67
168. Unconstitutional provincial regulation comes with significant and deleterious consequences.
Provincial regulations interfere with and impair the federal regulatory regime because they
do not consider the general federal regime’s requirements, the Canadian telecommunications
policy objectives or the Commission’s previous decisions. This leads to confusion for
consumers and increased compliance costs for providers.
169. To begin, an average consumer of telecommunications services will not know which
regulations are enforceable and where his or her rights stand. The provisions in provincial
statutes differ from those in Commission regulations—including for example, the Wireless
Code. Consumers are left with different regulations that provide different and often
conflicting rights. Provincial regulations also contain different remedies from Commission
regulations. For example, the Commission has been very clear that, subject to certain
exceptions, consumers seeking redress against a telecommunications provider in relation to
a forborne service should bring a complaint to the CCTS. However, the Ontario Wireless
Service Agreements Act, for example, provides a private right of action in case of certain
violations. This, in turn, conflicts with subsection 72(3) of the Telecommunications Act,
which bars actions “for a breach of contract to provide telecommunications services” and
“any action for damages in relation to a rate charged by a Canadian carrier” with respect to
breaches of Commission decisions made pursuant to the Telecommunications Act. The
differing and conflicting layers of regulation also increase the complexity and cost of
compliance by requiring providers to answer to regulators in 10 different provinces and three
territories.
170. Finally, a confirmation that regulation of telecom sales is national in scope is also necessary
to uphold the objectives of the Telecommunications Act. In particular, section 7(b) of the
Telecommunications Act provides that one of the objectives of Canadian
telecommunications policy is “to render reliable and affordable telecommunications services
of high quality accessible to Canadians in both urban and rural areas in all regions of
67
S.N.L. 2009, c C-31.1, s.2(1)(iii).
49
Canada”.68 Similarly, section 7(a) sets out an objective “to facilitate the orderly development
throughout Canada of a telecommunications system that serves to safeguard, enrich and
strengthen the social and economic fabric of Canada and its regions”.69 National regulation
of sales of telecommunications services to the exclusion of any provincial regulation is
consistent with these objectives.
6.1.2 The Commission has failed to assert its jurisdiction in the past, but should do so
now
171. The Commission has had the opportunity to make a statement asserting Parliament’s
exclusive constitutional jurisdiction in the past, but has declined to do so and has instead
chosen to expressly accommodate provincial regulatory regimes that are of profoundly
dubious constitutionality. In Telecom Regulatory Policy CRTC 2013-271, The Wireless
Code, the Commission stated that “where the Wireless Code is in direct conflict with a valid
provincial law, the Wireless Code takes precedence.” Then again in Telecom Regulatory
Policy CRTC 2017-200, Review of the Wireless Code, the Commission reiterated that the
Wireless Code takes precedence “if direct conflict with provincial legislation should arise.”70
172. To be very clear, these statements by the Commission are incorrect articulations of Canadian
constitutional law. Provincial legislation that regulates a telecommunications undertaking
will generally be unconstitutional regardless of whether a “direct conflict” exists. The
existence of an “operational conflict” grounds only one prong of the test for paramountcy,
but there is no need for any paramountcy analysis at all, because as set out in greater detail
below, most provincial telecommunications regulation is unconstitutional on other grounds:
it is ultra vires any provincial legislature and is inapplicable under the doctrine of
interjurisdictional immunity.
173. The Commission’s failure to exert its jurisdiction has had direct consequences to TELUS
and other providers. TELUS and other companies have been named in multiple court actions
– including class actions – under regimes that are unconstitutional. A recent example is
Nelson v. TELUS Communications Inc., a proposed class action in which a representative
68
Telecommunications Act, S.C. 1993 c.38, s. 7(b). [Emphasis added.]
69
Ibid, s. 7(a). [Emphasis added.]
70
Review of the Wireless Code, Telecom Regulatory Policy CRTC 2017-200, para. 60.
50
plaintiff relies on Ontario’s Wireless Services Agreements Act. The Quebec Office de la
protection du consommateur (“OPC”) has also commenced prosecutions against TELUS
based on how the Company describes certain rights and obligations in its wireless customer
services agreement. These prosecutions are based on alleged violations of the Quebec
Consumer Protection Act.71 TELUS and other providers have repeatedly and successfully
challenged certain unconstitutional provincial regulatory schemes—most recently a Quebec
law requiring ISPs to block access to certain online gambling websites 72—but the fact
remains that these unconstitutional proceedings continue to raise compliance costs and
ultimately raise the cost of providing services to consumers.
6.1.3 The regulation of telecommunications undertakings is ultra vires provincial

legislatures
174. Various court decisions have established and maintained that Parliament has exclusive
jurisdiction over telecommunications, radiocommunication and broadcasting.73 Most
recently, the Quebec Superior Court held that:
Le contrôle des télécommunications va au cœur de la compétence

fédérale. Le Parlement a mis en place un régime complet, élaboré et
appliqué dans une perspective de protection et de valorisation
d’intérêts nationaux. La compétence du Parlement en cette matière
lui vient des articles 91 (paragraphe introductif), 91 (29) et 92 (10)
a) de la Loi constitutionnelle de 1867.74
175. Under its jurisdiction over telecommunications and radiocommunication, Parliament has the
exclusive power to govern not only the location, construction, and maintenance of the
telecommunication networks and installations, but also to regulate the telecommunication
service providers’ tariffs.75 In this regard, “tariffs” represent the regulated or unregulated
71
C.Q.L.R. c P-40.1.
72
Association canadienne des télécommunications sans fil c. Procureure générale du Québec, 2018 QCCS 3159
[“CWTA”].
73
Rogers Communications Inc. v. Châteauguay (City), 2016 SCC 23, par. 42; Alberta Government Telephones
v. CRTC, [1989] 2 S.C.R. 225, In re Regulation and Control of Radio Communication in Canada, [1932]
A.C. 304; Capital Cities Communications Inc. v. CRTC, [1978] 2 S.C.R.. 141, 160-161; Toronto Corporation
v. Bell Telephone Co. of Canada, [1905] A.C. 52; Québec (Procureur général) c. Québec (Régie des
télécommunications), 1992 CanLII 3743 (QC CA), conf. by [1994] 1 S.C.R.. 878.
74
CWTA at para. 130.
75 M. Ryan, “Telecommunications and the Constitution: Re-Setting the Bounds of Federal Authority” (2010),
89 R. du B. can. 695, p. 726. Also : Bell Canada v. Quebec (CSST), [1988] 1 S.C.R.. 749; Commission du
Salaire Minimum v. Bell Telephone Company of Canada, [1966] S.C.R. 767; Saskatchewan Power
51
contract governing the relationships between the providers and consumers, which
encompasses rates, availability, terms and conditions, and the description of the
telecommunication services that are being provided.
176. To determine the head of power to which a legislative provision should be applied, courts
will examine the pith and substance of the provision. In the examples of provincial
legislation cited above, the purpose and effects of the provisions are without doubt to
regulate telecommunications undertakings, the provision of services to customers and, the
terms and services contained within their service contracts. These activities all fall within
Parliament’s exclusive powers. Since telecommunications services and their tariffs fall
within the core of the federal jurisdiction over telecommunications, no province can adopt
legislative provisions that in pith and substance regulate these matters.76 Therefore, these
provincial provisions are constitutionally invalid, because in pith and substance, the
provinces are legislating in an area that is outside of their powers as set out in section 92 of
the Constitution Act, 1867.
6.1.4 Provincial regulation of telecommunications undertakings is inapplicable under

the doctrine of interjurisdictional immunity
177. Even if a provincial legislature adopts a legislative provision that is in pith and substance
within its jurisdiction under the Constitution Act, 1867, that provision may nevertheless be
inapplicable by virtue of the doctrine of interjurisdictional immunity. Interjurisdictional
immunity prevents laws enacted by one level of government to impair upon the “unassailable
core” of the other level of government’s exclusive jurisdiction.77
178. For over 100 years,78 the doctrine of interjurisdictional immunity has been applied to protect
“essential and vital” parts of federal undertakings. This includes not only the management
of the undertaking, but also the assurance that the undertaking can fulfill its fundamental
Corporation et al. v. TransCanada Pipelines Ltd., [1979] 1 S.C.R. 297, 306 and following; and H. Brun, G.
Tremblay and E. Brouillet, Droit constitutionnel, 6e Éd., Les Éditions Yvon Blais, Cowansville, 2014, 562.
See also: Canadian Western Bank v. Alberta, [2007] 2 S.C.R. 3, para. 57 (“management”).
76
Quebec (Attorney General) v. Lacombe, [2010] 2 S.C.R. 453 and Rogers Communications Inc. v.
Châteauguay (City), 2016 SCC 23.
77
Québec (Attorney General) c. Canadian Owners and Pilots Association, [2010] 2 SCR 536 and Rogers
Communications Inc. v. Châteauguay (City), 2016 SCC 23.
78
[1905] A.C. 52, p. 57.
52
mandate “in what makes them specifically of federal jurisdiction.”79 In this regard, the
power to legislate rules about telecommunications tariffs and services falls within the
“unassailable core” of the exclusive federal jurisdiction over telecommunications.
179. Therefore, provincial laws that regulate the sale of telecommunications services are
constitutionally inapplicable if their effects impair Parliament’s capability to regulate
essential and vital elements of its jurisdiction over telecommunications, such as rates and
services. The various provincial consumer protection laws set out above are thus inapplicable
to telecommunications undertakings because they regulate services provided by
telecommunications providers, matters that have been serially determined to be at the core
of exclusive federal authority.
180. The purpose and the effects of the impugned portions of various provincial consumer
protection laws are to regulate rates, availability, terms and conditions of services provided
by mobile wireless companies to their customers. This is regulation of the core of
telecommunications undertakings. Even if one were to assume that the provincial consumer
protection legislative provisions were valid, they intrude on the core of federal jurisdiction
over telecommunications and radiocommunication regarding, among other things, the
establishment of tariffs. Because the provincial provisions seriously and significantly impair
the core of Parliament’s power over telecommunications and radiocommunication, they are
inapplicable by reason of the doctrine of interjurisdictional immunity.
6.1.5 Provincial regulations of telecommunications undertakings are inoperative by

virtue of the doctrine of paramountcy
181. Finally, the doctrine of paramountcy provides that in certain cases of conflict between a
federal law and a validly enacted provincial law, the provincial law will be inoperative to
the extent of the conflict. The doctrine will apply where the conflict makes it impossible to
comply with both provisions (“operational conflict”) or when the achievement of the
objective of the federal law is frustrated by the application of the provincial provision
(“frustration of purpose”).
79
See notably Bell Canada v. Quebec (CSST), [1988] 1 S.C.R. 749, 762; Canadian Western Bank v. Alberta,
[2007] 2 S.C.R. 3, par. 57.
53
182. In the case of a frustration of purpose, the provincial provision will be declared
constitutionally inoperative when its application frustrates a federal law’s objective.80 When
determining if there is a frustration of purpose, a court will examine the purpose of the federal
legislation and the role assigned to the Commission by Parliament.
183. For telecommunications and broadcasting undertakings, the regime enacted by Parliament
consists of interrelated laws,81 notably the Radiocommunication Act, the
Telecommunications Act, and the Broadcasting Act. These statutes provide the basis for the
regulatory powers granted to the Commission regarding telecommunications and
broadcasting matters.
184. During the parliamentary debates held prior to the adoption of the Telecommunications Act,
the Minister of Communications stated the importance of national regulation of
telecommunications works and undertakings:
Three years ago the Supreme Court of Canada ruled that members
of Telecom Canada fell within federal jurisdiction...We must pull
the correct patchwork of legislation into one bill designed to
encourage efficiency and excellence...
Bill C-62 [The Telecommunications Act] will do exactly that. It will

establish a coherent policy for the entire country that will be
co-ordinated by one regulatory agency, the CRTC.82
185. Important regulatory powers over telecommunications were given to the Commission under
the Telecommunications Act. The setting of rates and tariffs falls within the core of the
CRTC’s duties and expertise.83 Parts III (Rates, Facilities, and Services, notably sections
24, 25, 27, 32 and 37) and IV (Administration) of the Telecommunications Act are prominent
examples of the Commission’s rate setting and other regulatory powers over
telecommunications services. These provisions clearly demonstrate the intent of Parliament.
80
Canadian Western Bank v Alberta, [2007] 2 S.C.R. 3, par. 73.
81
Reference re Broadcasting Regulatory Policy CRTC 2010-167 and Broadcasting Order CRTC 2010-168,
[2012] 3 S.C.R. 489, par. 34.
82
House of Commons Debates, 34th Parliament, 3rd Session, Vol. 14, pp. 18067 and following.
83
MTS Allstream Inc. v. TELUS Communications Company, 2009 ABQB 131, par. 65. See also: B & W
Entertainment Inc. v. Telus Communications Inc., 2004 CanLII 35009.
54
All matters related to service provision for telecommunications fall under the exclusive
jurisdiction of the Commission.
186. The Telecommunications Act provides a coherent and uniform regime to put in place the
national regulatory framework for the provision of telecommunications services, which in
turn furthers national policy objectives such as the provision reliable and affordable
telecommunications services of high quality accessible to Canadians in both urban and rural
areas in all regions of Canada.84
187. The federal regulatory regime is complete and exhaustive. It regulates all aspects of
Canadian telecommunications in order to achieve Parliament’s objective: the
implementation of coherent and uniform national statutory regime. The implementation of
such a regime necessarily depends on a complete federal jurisdiction over tariffs and
services. This complete jurisdiction is required to avoid the application of multiple different
provincial regulations.
188. As such, ensuring the exclusive jurisdiction of the Commission with respect to regulation of
telecommunications services is crucial and essential to its capability to efficiently implement
the intent of Parliament, including the outcomes sought by Parliament in the Canadian
telecommunications policy objectives. Provincial consumer protection legislation that
regulates the provision of wireless services frustrates the purpose of the statutory regime that
governs telecommunications regulation in Canada.
189. For these policy and legal reasons, the Commission should therefore state clearly that its
rules governing the offering and provision of telecommunications services are intended to
be are binding, of exclusive federal jurisdiction, and national in scope, with no room for
provincial encroachment. Anything less will leave consumers with confusion as to applicable
rules, protections and remedies, and will continue to foster higher compliance costs—borne
by consumers—necessary in an environment of multiple, often contradictory, regimes.
84
Telecommunications Act, s.7(b).
55
6.2 CCTS should address individual complaints regarding sales practices
190. As noted above, the legislative tools to address misleading and aggressive sales practices
already exist. In particular, the Competition Act contains specific prohibitions on misleading
sales practices made in the course of in-store, telephone, and door-to-door sales.
191. However, the Competition Bureau, in response to Telecom Public Notice 2007-16, which
led to the creation of the CCTS, noted that it cannot be expected to resolve individual
complaints given its then-current mandate and level of resources. The Bureau suggested that
those complaints should go to CCTS, stating in its submission to the Commission:
[t]he Bureau does not have the mandate or the resources to mediate
each individual dispute between complainants and TSPs, and
instead values intelligence regarding misleading advertising and
deceptive marketing practices issues and trends, so as to allow the
Bureau to focus its limited resources on those broader, systemic
problems which appear to pose the greatest risk for consumers and
competitors. Conversely, the CCTS is capable of resolving such
disputes, and it will have the appropriate industry expertise and
contacts to facilitate that function. Regrettably, the proposal as
framed does not appear to capitalize on the opportunity to address
these misleading advertising and deceptive marketing practices
complaints, or to acquire and share this intelligence.85
192. However, the mandate of the CCTS as currently articulated in the Procedural Code and
Participation Agreement needs clarification. Under the terms of the Procedural Code, the
CCTS does not address “claims of false and misleading advertising.” At the same time, the
CCTS is permitted to address most other claims regarding forborne retail
telecommunications services.
193. While the role of the CCTS does not encompass and should not be expanded to include all
claims of false and misleading advertising—for example, to review providers’ television and
radio commercials—the Commission should make clear that the CCTS does have the
authority to hear disputes regarding allegedly misleading and aggressive sales practices,
including specific misrepresentations made by employees or agents of telecommunications
85
Comments of the Commissioner of Competition in response to Public Notice 2007-16, 16 November 2007,
at para. 15.
56
companies to individual consumers at their doorstep, over the phone, or in a store. These are
not representations made to the public at large—which would be outside the scope of the
CCTS’ mandate—but rather are complaints from consumers about discrete incidences of
aggressive or misleading behaviour toward them specifically.
194. The clearest way to formalize this role for the CCTS is through a code of conduct, as
contemplated by the Participation Agreement.86 The Commission should task a CISC
working group to draft such a code using the process set out in Telecom Regulatory Policy
CRTC 2011-46:
The Commission considers that it is appropriate to distinguish

between voluntary and mandatory codes. With respect to codes
voluntarily developed by industry or the CCTS, the Commission
considers that the CCTS’s current approach, including a vote by
extraordinary resolution to approve codes, remains appropriate.
However, the Commission considers a new approach is needed for
the development and approval of mandatory codes (i.e. codes that
the Commission determines are to be developed and implemented
by TSPs). The Commission considers that, as proposed by some
parties, the appropriate mechanism for the development of
mandatory codes is a CRTC Interconnection Steering Committee
(CISC) working group that includes the CCTS as a participant.
The Commission considers that the development, approval, and

enforcement of mandatory codes would work as follows: (1) The
Commission establishes the minimum criteria for the particular code
to be developed. (2) The Commission requests CISC to develop the
code within a fixed time frame. The CCTS participates in this CISC
process, along with other interested parties. (3) CISC submits a
report (consensus or non-consensus report) on the draft code to the
Commission for review. (4) Following review, the code is finalized
in a Commission decision, as appropriate. (5) The CCTS
administers the code, publishes the code on its website, and reports
on complaints related to violations of that code in subsequent annual
reports.87
86
Participation Agreement, art. 12(b).
87
Review of the Commissioner for Complaints for Telecommunications Services, Telecom Regulatory Policy
CRTC 2011-46, 26 January 2011 at paras. 43-44.
57
195. Once a code is developed, article 12(b) of the Participation Agreement can be amended to
make reference to it.
196. Under this proposal, CCTS’ procedures and remedies would not change, but a formal set of
standards would be put in place to assist the CCTS in adjudicating disputes and make clear
to consumers and providers what exactly their rights and obligations are.
197. This proposal aligns with the recommendation of the Competition Bureau from 2007. By
clarifying and formalizing the mandate of the CCTS with respect to sales practices, it can
help address what the Bureau saw as potential enforcement gap. This will also provide a
central repository of data from which trends and patterns can be determined. For example,
by keeping a record of all complaints relating to misleading or aggressive sales practices, the
Commission and the Competition Bureau will be able to determine if some players in the
telecommunications industry have proportionately more complaints than others and identify
any repeat or systemic issues that necessitate further education or potential disciplinary
action.
6.3 The Competition Bureau and the Commission should use existing powers to remedy
systemic issues
198. As noted above, the sales conduct that is of concern to the Governor in Council and the
Commission is already regulated and prohibited and under TELUS’ proposal will become
further formalized through a code of conduct. If a trend becomes apparent or if a systemic
issue with respect to sales practices is identified, the Competition Bureau and the
Commission have the tools to educate consumer and the offenders, stop such conduct and –
where necessary – discipline the offenders.
199. The Competition Bureau has the power to investigate conduct that constitutes deceptive
marketing and seek redress from the Competition Tribunal or a court88 as provided in part
VII.1 of the Competition Act. The Competition Act provides numerous remedies that the
Competition Tribunal or court can impose where a finding of “reviewable conduct”,
including misleading selling, has been made. Those remedies include an order to: not engage
88
Competition Act, R.S.C. 1985 c. C-34, s. 74.09.
58
in such conduct, name the offending company which – depending on the circumstances –
may lead to reputational/brand damage and expose the company to class action claims,
provide refunds, and/or pay an administrative monetary penalty of up to $15,000,000.89
200. The Competition Bureau has previously taken enforcement action in the telecommunications
industry when systemic issues were identified. For example, in 2011, the Competition
Bureau took action against Bell for selling at prices higher than advertised. This action
resulted in changes its advertising practices and a $10 million administrative monetary
penalty.90 Similar action was taken when it was discovered that employees of a carrier posted
online reviews of a carrier’s app without disclosing their affiliation with the carrier. This
resulted in an enhanced compliance program and a $1.25 million administrative monetary
penalty.91 The Competition Bureau can continue to focus on its enforcement efforts of
systemic issues, consulting the Commission as needed under the agreement between the two
agencies.
201. The Commission also has a role to play in enforcement where a sales practice amounts to a
contravention of section 27(2) or a condition imposed under section 24 of the
Telecommunications Act. Under section 27(2), Canadian carriers cannot unjustly
discriminate against any person92 and intentional targeting of vulnerable consumers and
subjecting them to misleading or aggressive sales may, depending on the circumstances, fall
under that section.
202. The Commission can also investigate and take enforcement action as a result of repeated or
systemic breaches of conditions imposed on under sections 24 and 24.1.93 This includes
repeated or systemic contraventions of the Wireless Code, which prohibits misleading and
aggressive sales of wireless products and services.
89
Ibid, s. 74.1(1)(a)-(d).
90
Competition Bureau reaches agreement with Bell Canada requiring Bell to pay $10 million for misleading
advertising, 28 June 2011. Online: http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/03388.html.
91
Bell Canada reaches agreement with Competition Bureau over online reviews, 14 October 2015. Online:
http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/03992.html.
92
Telecommunications Act, S.C. 1993, c. 38, s. 27(2).
93
Telecommunications Act, S.C. 1993, c. 38, ss. 24 and 24.1. Section 24 gives the Commission the authority to
impose conditions on Canadian carriers and section 24.1 gives the Commission authority to impose conditions
on any person other than a Canadian carrier.
59
203. If the Commission determines that section 27(2) or a condition imposed under sections 24
or 24.1 has been contravened, it can educate consumers, warn carriers, engage in heightened
monitoring and reporting, institute show cause proceedings, and where necessary, levy an
administrative monetary penalty under section 72.001. Section 72.001 gives the Commission
power to order an administrative monetary penalty up to $15 million for contraventions of
most sections of the Telecommunications Act, including 24, 24.1 (including conditions
imposed under those sections) and 27(2). As set out in Compliance and Enforcement and
Telecom Information Bulletin CRTC 2015-111, The Commission can also promote
compliance through outreach, education and undertakings.94
204. Given the existence of substantive rules that make the type of sales conduct that the Governor
in Council and the Commission are concerned about illegal, as well as the tools to address
them on a systemic level, there is no need for regulations or powers to contain new
substantive rules. The only issue to be addressed is access to redress for individual aggrieved
consumers, which is promoted through a new code of conduct reflecting existing
prohibitions, to be administered by the CCTS.
7.0 Conclusion
205. TELUS believes that its competitive advantage is customers who are prepared to recommend
its services. Billions of dollars have been invested to build and maintain that advantage.
TELUS’ experience over the last decade has shown that a focus on the things that customers
need and want will generate a substantial improvement in key business metrics. In a word,
customer satisfaction is good for business.
206. The sales process is an opportunity to show the benefits of adopting new technologies. If it
is done right, the sale will create a satisfied customer. Done wrong, the sale will create a
disappointed customer who will not recommend TELUS. This is why TELUS carefully
trains and monitors its salesforce and works hard to instill Customers First values in every
sales agent.
94
Guidelines regarding the general administrative monetary penalties regime under the Telecommunications
Act, Compliance and Enforcement and Telecom Information Bulletin CRTC 2015-111, paras. 7, 25-27.
60
207. While it is not possible to keep every single customer happy all of the time, TELUS invested
a lot time, effort and money into Customers First programs and has communicated it to
customers and investors. It would create a lot of needless damage if the Commission were
to conclude that TELUS is part of a group of companies that engage in misleading or
aggressive sales practices without a fully tested evidentiary basis and proper context. TELUS
requests that any conclusions made in the Commission’s report be limited to what can be
demonstrated by the evidence.
208. Sales are an important part of ensuring that Canadians know about the new and exciting
services that are offered to them. Door-to-door sales, which allow companies to engage a
critical mass of people one-on-one, are particularly important when new products such as
PureFibre are being launched. In some areas, investments into PureFibre is not viable if door-
to-door engagement is not an option.
209. Misleading and aggressive selling is made unlawful under a number of existing regulations,
including the Competition Act, Telecommunications Act, Wireless Code, Television Service
Provider Code and others. This is not a case of a gap in the regulations: the improper sales
conduct that has been reported in the media is already prohibited. If there is a gap, it is one
of consumer redress, enforcement and education. TELUS’ proposal to implement a code of
conduct formalizing the CCTS’ mandate with respect to aggressive and misleading sales
practices will bridge that gap. Combined with the existing ability of the Competition Bureau
and the Commission enforce current laws, especially on a systemic basis, this proposal will
resolve outstanding issues without doing damage to the industry and threatening investment
in costly new technologies.
61
APPENDIX 1 – TELUS ANSWERS TO QUESTION SET OUT IN APPENDIX 2 TBNC

CRTC 2018-246
TELUS provides the following answers to the Four Questions asked by the Commission in
Question 1 of Appendix 2 to Telecom and Broadcasting Notice of Consultation CRTC 2018-246:
Question 1:
Do the large telecommunications carriers offer their

telecommunications services for sale by engaging, either through
their employees or third parties, in misleading or aggressive sales
practices, such as providing consumers with incomplete, unclear or
misleading information regarding service terms and conditions or
selling them telecommunications services that are unsuitable for
them, and, if so, what are the prevalence of those practices?
Answer:
With respect to TELUS, aggressive and misleading practices are very rare and TELUS works very
hard to ensure that this conduct does not take place. TELUS’ focus on the needs of its customers
as well as its careful tracking of “likelihood to recommend” scores puts the emphasis on selling
the right products to the right customers. As a result of placing customers first, TELUS currently
enjoys the highest likelihood to recommend score and the lowest CCTS complaints among its
peers.
Engaging in aggressive and misleading sales practices would lead to disappointed customers who
would not recommend TELUS. To ensure that aggressive and misleading practices are not used
by sales agents, TELUS carefully trains and monitors its staff and third party contractors, quickly
responds to complaints, makes things right with the customer, and addresses root causes of any
customer dissatisfaction or breach of policy, law or regulation. On the rare occasion that aggressive
or misleading sales practices are detected, TELUS immediately provides remedial coaching and
where it becomes clear that an individual agent or a third party company cannot put TELUS
customers first, TELUS ends its employment or contractual relationships.
Question 2:
What measures or controls do carriers have in place to monitor,

identify and mitigate the risks that consumers are subject to
misleading or aggressive sales practices?
62
Answer:
TELUS has a robust and multi-pronged compliance program that consists of, among many other
things, training, monitoring and auditing to ensure compliance with, among others, the
Telecommunications Act, Canada’s Anti-Spam Legislation, the Competition Act, and regulations
and codes passed under them. TELUS employees also listen in on random phone calls, audit stores
and follow up with people who have been visited by a door-to-door agent to ensure that customers
are not subject to misleading or aggressive sales practices. TELUS employees who contravene
laws or TELUS policies receive coaching or discipline, depending on the circumstances.
There are many ways that TELUS receives customer feedback and complaints, including by
telephone, email, online, at the door and to any TELUS employee regardless of function and works
to make things right for the customer and correct root causes of the problem. TELUS also has a
robust whistleblowing program that is accessible not only by employees, but by anyone on through
EthicsPoint.
Question 3:
What consumer protections respecting retail sales practices and

contracts for telecommunications services are currently in place to
empower consumers to make informed decisions with respect to
their telecommunications services and promote the fair treatment of
consumers in their relationships with telecommunications carriers?
Answer:
Aggressive and misleading sales practices are illegal under a number of binding rules, including
the Competition Act, Telecommunications Act, Wireless Code, Television Service Provider Code,
tariffs and the Consumer Bill of Rights. The Telecommunications Act also contains provisions
prohibiting discrimination, which can apply if vulnerable groups are intentionally targeted for
misleading or aggressive sales practices. The CCTS provides fast and cost-effective remedies for
breaches of some but not all of these instruments.
Question 4:
What is the most feasible and effective ways to strengthen or expand

the scope of existing consumer protections such as those contained
in the Commission’s codes of conduct, or to create new consumer
protections, including codes of conduct relating to new subjects, in
order to further empower consumers to make informed decisions
with respect to their telecommunications services and to further
promote the fair treatment of consumers in their relationships with
telecommunications carriers?
63
Answer:
Existing rules already prohibit aggressive and misleading sales practices. However, to ensure that
redress is available to individuals subject to improper sales practices and companies are
discouraged from engaging in such tactics, the Commission should clarify the mandate of the
CCTS through a code of conduct that reflects these existing rules, to ensure that the CCTS is able
to adjudicate individual consumer complaints with respect to aggressive or misleading sales
practices. Where CCTS statistics or other means reveal trends that require further review by the
Commission or the Competition Bureau, the tools are available under the Telecommunications Act
and the Competition Act respectively. Those tools include consumer and carrier education and –
where necessary – progressive discipline including administrative monetary penalties and criminal
sanctions.
**** End of Document ****
64

Telus Intervention

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Telus Intervention

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BEFORE THE CANADIAN RADIO-TELEVISION AND

TELUS COMMUNICATIONS INC.

Telecom and Broadcasting Notice of Consultation CRTC 2018-246

August 30, 2018

1.0 Introduction and Executive Summary ................................................................................. 1

1.0 Introduction and Executive Summary

1.1 The Customers First Initiative and its Impact on Sales

3. In the first of the Four Questions, the Commission asks:

whether the large telecommunications carriers offer their

is for TELUS to become the leading company in customer recommendations. If customers

1.2 Controls are in Place to Ensure Customers Come First

The measures or controls that those carriers have in place to monitor,

including suspension and/or dismissal. In addition, a breach of the compliance program by

1.3 Sales are Crucial to Delivering the Promise of a Digital Canada

1.4 Rules Preventing Improper Sales Practices are in Place

the consumer protections respecting retail sales practices and

the most feasible and effective ways to strengthen or expand the

misleading and aggressive sales practices, including specific misrepresentations made by

2.0 TELUS Customers First Journey

2.1 History and Meaning of TELUS’ Customers First Journey

# TELUS has also actively refined the

2.1.1 Customers First Engagement at Every Level of the Organization

a) Consistently driving new programs to enhance the end to end customer

.# The current focus is identifying areas of high

b) Weekly meetings with a focus on tracking customer experience metrics. This

.# The goal of tracking and discussing

d) Weekly executive emails and meetings to address root causes of complex

e) Monthly executive review of the reliability and health of TELUS’ systems.

2.2 Practical Examples of Customers First Initiatives

2.2.1 Sales that delight customers

2.2.1.1 Key Principles of Sales at TELUS

2.2.1.2 Clear Rate Plans

2.2.1.3 Cooling Off Period

.# TELUS’ service agreements generated through the door-to-door

2.2.1.4 Seeking Feedback

2.2.1.5 Other Initiatives

2.2.2 Customer-centric Complaint Resolution

# Customer escalations data is shared internally by

2.2.3 Customer Service Leadership in Call Centres

# By emphasizing metrics like contact quality, first-call resolution and customer

2.2.4 Leadership in Service of Senior Residents and Non-native English Speakers

2.2.5 Other ways TELUS is focused on the end-to-end customer experience

2.3 Focus on Customers First Drives Measurable Positive Results

Monthly Churn10 1.31%11 0.90%12

TELUS Bell Rogers

Monthly Churn14 0.83%15 1.10%16 1.01%17

Our leadership in customer loyalty and quality smartphone

strive to provide our customers at TELUS. Indeed, our extensive

Provider TELUS Rogers Bell

2.5 TELUS Differentiates Itself on the Unique Customers First Approach

3.0 Sales are key to Driving Adoption of New Technologies

 Communicate transparently regarding the process of bringing PureFibre to

4.0 Sales at TELUS

4.1 Sales channels at TELUS

 TELUS’ inbound contact centre;

 TELUS’ outbound telephone sales;

 TELUS’ outbound telephone sales partners;

 TELUS’ retail locations;

 TELUS’ online presence (telus.com, koodo.com and publicmobile.ca); and

4.2 Compliance Programs are in Effect on All Sales Channels

a) A corporate-wide Customers First commitment, as discussed above;

b) TELUS’ Code of Ethics and Conduct;

c) TELUS’ Supplier Code of Conduct;

d) Onboarding, ongoing training and regular coaching sessions;