Good day, ladies and gentlemen. Welcome to the MTN update on NIN registration. All participants will be in listen-only mode. There will be an opportunity to ask questions later during the conference. If you should need assistance during the call, please signal for an operator by pressing star then zero. Please note that this call is being recorded. I'd now like to turn the conference over to Thato Motlanthe. Please go ahead, sir. Thanks very much, Claudia. Good afternoon to everybody. Thank you for joining us on this call on a Friday afternoon just to discuss the developments around the NIN-SIM linkage directive in Nigeria. My name is Thato Motlanthe, head of group investor relations for MTN. We have a few of our leadership on the call with us today. I'll just run through them. Ralph Mupita, MTN Group CEO. Tsholofelo Molefe, Group CFO. Karl Toriola, MTN Nigeria CEO. Mudiafe Cadre, MTN Nigeria CFO. Hassan Jaber, MTN Nigeria COO. Adia Sowho, who is MTN Nigeria Chief Marketing Officer. Mazen Mroue, who is the now Group CTIO, but formerly MTN Nigeria COO. We've also got Chima, who manages investor relations in Nigeria. Just for this call, which is scheduled for one hour, Ralph will outline the agenda and context before we get into the nuts and bolts of the issues at hand. Just on that note, let me hand over to Ralph. Thanks, Thato. A very good afternoon from me as well. Thank you all for joining us for this call late Friday here, afternoon in Johannesburg. As Thato mentioned, I'll start off with some context for the call. We have our group and MTN Nigeria colleagues joining me as well, who will unpack some of the detail. In terms of agenda for this call, we'll run through eight items as follows. The first is on the security situation in Nigeria and how it may provide some context to the current state of play. Second would be the background to the directive from the Nigerian Communications Commission, NCC, and what it means. The third area is how we have implemented the directive at MTN Nigeria. Karl will take us through that. We will then provide directional color on the pro forma potential impacts on the business from implementation of the directive. That is topic 4. For topic 5, we will share some insights, again, directional color on the directive’s impact on some of the KPIs. Topic 6, we will talk about how MTN Nigeria provides support to the Nigerian government’s effort to speed up NIN-SIM linkages. On the seventh topic, Karl will just provide some insights into the engagements we have had with our regulators in Nigeria, including the Minister of Communication. Finally, just a reminder of how the NIN registration process actually works. I will begin with the topics 1 and 2 before handing over to Karl for more details on the other issues. The background and context, if you cast your mind back to December 2020, you will recall that the key catalyst for the implementation of the current regulations on NIN-SIM registration was in large part driven by security concerns. On 15th December 2020, the NCC directed all operators to update SIM registration records with valid NINs, with an initial deadline of 30 December 2020. We agreed that this was necessary to build a reliable and sustainable national identity management system, a critical enabler that will deliver multiple benefits to the telecommunications industry and Nigeria as a whole. In the long term, it will aid national economic planning and enhance security, governance, service delivery, and the build-out of a digital ecosystem. You will all recall that this deadline for NIN updates was extended several times over the course of the past year due to logistical challenges in meeting the deadlines and issues encountered during the integration process. As context for now, and some of you may be asking why the registration deadline was not extended this time around. You may have read about the train that was hijacked in northwest Nigeria last week on the 30th of March. Sadly, a number of people from the incident have since been missing. This was then followed by the developments that brought us to where we are today. We believe, and the information we have managed to gather supports this, that this provides further understanding to the decision that has been made by the Federal Government of Nigeria and the directive that came through the NCC. The second item on the agenda is on the current directive itself. It will be useful to run through the sequence of events that have brought us here, which can provide, again, more color. As I mentioned earlier on, the train was hijacked in northwest Nigeria on the 30th. On the 31st of March was the latest deadline for NIN registrations, and the NCC came out with a press release on the 1st of April to urge all citizens and legal residents in Nigeria to use the next few days to submit their NINs as soon as possible. They also directed NIMC to offer enrollment services around the clock also for the next few days. At that stage, they had not defined what would constitute the next few days. On Monday, 4th of April, the NCC issued a further press statement confirming that the Federal Government of Nigeria had determined that the NIN-SIM policy implementation can proceed as machineries had already been put in place to ensure compliance by citizens and legal residents. This also confirmed that the NIN registration deadline would not be extended and that all telecommunications operators in Nigeria would be instructed to bar outgoing calls for telephone lines that had not complied with the SIM linkage policy from the 4th of April 2022. The NCC once again urged affected individuals to link their NINs. The minister once again extended his thanks to telecom operators for their support in achieving the progress to date. MTN Nigeria received a formal letter on the evening of 4th of April, instructing that, A. The company should implement a phased suspension of services to SIMs that are not associated with NINs, with effect from the 4th of April. Secondly, that impacted SIMs should be placed on receive only with immediate effect. Third, restore connectivity to impacted SIMs only after the owners link their NINs to the SIMs. I hope this provides some broad context to the latest developments. We believe the government and regulators of Nigeria remain very constructive regarding SIM registration regulations. They are affording subscribers who have not yet linked their NINs time to do so and without instructing a complete disconnection. At this stage, we have not been advised what a phased implementation looks like. We continue our engagements with the authorities in Nigeria. With that as context, let me hand over to Karl, the CEO of MTN Nigeria, to run you through some of the other agenda items that I mentioned earlier. Karl, over to you. Thank you, Ralph. Good afternoon to everyone. We appreciate your time on this call. I'll run through the items 3 to 8 of the agenda outlined by Ralph, namely the implementation of the directive, pro forma impacts, insights on early trends, and support to the government. On the implementation of the directive, getting into how we implemented the directive following the NCC's letter, we implemented the instruction and sought clarification where it was necessary. From the 4th of April, we applied the receive-only instruction to the stipulated subscribers who had not yet submitted their NINs and placed restrictions on the outgoing voice and SMS services. In our request for clarification, the NCC indicated that we should hold off any action on restricting data services until they revert with clarification. We subsequently received clarification on the night of the 5th of April, where the NCC indicated the following. A, only subscribers that have not submitted their NINs shall be barred, and barring is for outgoing calls only. As such, data services and SMS are exempted. B, the basis of the directive is thus based on submission of NINs and not verification, which is done by the National Identity Management Commission, which I'll refer to as NIMC or NIMC. Again, barring is restricted only to outgoing circuit-switched calls. C, unbarring of subscribers who have been restricted should only be upon successful verification of the NIN in line with the Revised National Identity Policy for SIM Card Registration. D, the directive should be implemented on all traffic of subscribers, except SIMs belonging to embassies and diplomatic missions. Based on the clarification, all SIMs registered to embassies and diplomats that had been inadvertently barred were consequently unbarred, and the restriction on SMS was lifted for the affected subscribers who had previously been barred from sending outgoing SMSs. To be clear, the current implementation of the directive affects all subscribers where NINs have not been linked to SIMs, except embassies and diplomatic missions. The restriction is outgoing circuit-switched voice only. This cohort has access to all other services, including data. Consequently, we restricted outgoing voice services for approximately 19 million subscribers on RGS ninety in line with the directive on the 4th of April. The next item is the pro forma impact on subscriber and financials. If I turn to the pro forma impact for more accurate exposures, we consistently disclose our progress in terms of NIN submissions and linkages, and you have seen from the announcements this week that we have provided an update on this. We note that 47 million subscribers had submitted NINs by the 31st of March, and there was quite a few who submitted consequently between then and the 4th of April. This represents about 67% of MTN Nigeria subscribers base and 76% of service revenue. We also note that based on the NCC directive, outgoing voice revenue exposure of the affected subscribers is approximately 9% on an annualized basis. The next item is the key trends since implementing the NCC directive. Let me continue on to the fifth point, which I am on now, which is an insight into the trends we have seen since implementing the directive on the night of Monday the 4th of April. Of course, there are very short-term trends, but if we look firstly at subscriber trends, as mentioned, we restricted approximately 19 million SIMs, while 15 million had submitted their NINs before the directive came into effect on the 4th of April. We are supporting the NIMC with equipment for specifically distributed architecture for NIN verification to eliminate bottlenecks, such that verification can happen at the rate at which we are submitting records. On general traffic trends, we've seen average daily voice traffic decrease, while data traffic has increased slightly so far. We've also seen an increased demand in new SIM connections. You would appreciate that this is still early days, and we anticipate that you would want us to be more specific. However, it is important that we provide information that is useful, and we are unable to do this beyond what we've told you at this stage. It is also important just to note that the headline exposures and information we provided to help you with your analysis may not necessarily reflect how things will evolve in practice. It is still too early in the process to provide a more realistic trend. However, you are assured that management is on top of this issue on a daily basis and is doing what is necessary to mitigate the impact of this directive and to support the regulator to regularize registrations as quickly as possible. Moving on to item six, which is how MTN Nigeria supports the Nigerian government's efforts to speed up the NIN-SIM linkages. MTN Nigeria has been proactive in its support of the Nigerian government's directive to speed up NIN enrollment and linkage with SIMs, and we've leaned into the policy. We have an increased capacity to support NIN enrollment across the country. We've obtained a NIN enrollment license to support the federal government's efforts to ensure that every Nigerian has a valid NIN, and as a result, we've deployed more than 4,200 points of enrollment across the country to facilitate the NIN enrollment drive. We continue to expand this network to ensure that enrollment is within reach of all Nigerians. In addition, we provide hardware support to NIMC, specifically additional capacity and distributed architecture for NIN verification to eliminate the bottlenecks and accelerate the bulk verification of NINs collected. Engagements are also going on with the NCC, including through the industry body, ALTON, to ensure that we work together with the authorities to get as many people registered as possible. We have taken the following steps to ensure customers submit and link their NINs. One, regular NIN enrollment and link campaigns are provided to all customers via SMS and digital media channels. Two, we have promotions for bonus offers on NIN submission. Three, we have easy options to submit NINs using USSD, SMS, web, and various digital channels, including our chatbot. Four, banners and easy reference materials are placed on our website and on various social media platforms. Five, customer NIN education is placed on our website, and we communicate this through FAQs, also on radio and other media. Six, NIN submission information on call center IVR in the five major Nigerian languages. Seven, ramping up devices for NIN enrollment across the country. I'll move on to item number seven, which is further information emerging from engagements with NCC and telecom industry bodies in Nigeria. I think it's useful to give some color into our ongoing engagements. MTN, since the introduction of the initial directive in December 2020, has rallied the industry through the industry body, the Association of Licensed Telecommunications Operators of Nigeria, ALTON, to support the federal government's policy on SIM linkage project as reflected in the approved Revised National Identity Policy on SIM Card Registration. This was done with a view to ensuring decision-makers are kept abreast of challenges, particularly the NIMC infrastructural challenges, which has impacted adversely to verification services. The industry adopted a multi-pronged approach engagement strategy, which includes monthly progress reports to the Honorable Minister of Communications and Digital Economy, highlighting progress made on the project and requesting for ministerial intervention on the various challenges. Weekly technical meetings with the NCC and the NIMC to address operational issues on the project. Periodic meetings with the Honorable Minister, heads of NCC and NIMC, executives of ALTON, and the CEOs of mobile network operators to address the major concerns. One-on-one engagements by the CEOs with the Honorable Minister, the NCC, EVC, and the DG of NIMC. MTN has also held several direct engagements with the Minister and other decision-makers. This engagement has yielded results, including, especially, the extensions on various instances for the enforcement of the SIM-NIN linkage that have happened over the past year. The NIMC infrastructure upgrade, which requires budgetary funding, remains a challenge as the needed funds are yet to be released. Notwithstanding, engagements are ongoing with the decision-makers in line with the overall engagement strategy. Again, we are on top of all developments. Perhaps the only surprise was the accelerated decision to issue the directive, which Ralph has indicated was brought on by a flare-up in security issues. I'll move on to my final topic, which is the SIM registration process and how we are mitigating the risks. As a reminder of our SIM NIN registration process, the NCC changed the process for SIM registration, making it mandatory, to use a verified NIN for new SIM acquisitions and other SIM-related transactions such as SIM swaps. This new process requires or mandates that a maximum of four new SIM cards is allowed per NIN. This implies that customers can only have four new SIMs with one mobile network operator. Part of the process is that only certified outlets, as certified by the NCC, will be allowed to carry out SIM sales and activations. Agents that carry out these activities must have a NIN, a BVN, which is a Bank Verification Number, and a senior secondary school certificate as the minimum educational qualification. In addition to the above, we have enhanced our systems and put additional controls in place. These controls include electronic image matching. A live image is matched against the NIMC image and must return true. We have back-office eyeballing, which combines live image plus NIN image matching. Our back office team carries out a second-level check on all SIM registrations before the line is made active. We have quality assurance spot checks, consisting of periodic health checks on SIM activations that are carried out. These controls help to improve the quality of SIM registration, and thus far, MTN Nigeria has over 30,000 certified outlets for SIM registration, and we will continue to expand this number. I've taken us through the points which Ralph spoke to me, talking about. I'll hand over to our Group CFO, Sulu, to provide a little bit around the group context. Thank you. Thank you very much, Karl. Good afternoon to all our investors and stakeholders. Just very briefly on implications and impacts on the group overall. Many of you will know that Nigeria is our largest opco and contributes about 35% to MTN's total group service revenue. The reach through to group is quite important. Based on what Karl has explained earlier, the impact on group service revenue from implementation of the NCC directive is roughly about 3% on an annualized basis, resulting from the suspension to outgoing voice services to the affected subscribers in Nigeria. Again, very important to reiterate the point made by Karl in terms of these being annualized estimates, and there is a lot of work still to be done, as will be discussed, to mitigate the end impact. From a group perspective, the overall impacts are relatively as small at this stage, and of course, we will continue to update all our stakeholders in relevant forums how this evolves. With that brief context, I would like to hand over back to Ralph for concluding remarks. Thanks very much, Karl and Sulu, for providing our investors and stakeholders with a bit more color on this important matter. Before we move to Q&A, I just wanted to reemphasize a couple of points in terms of what we have shared. I think the first is to be super clear that we support the initiatives by the federal government of Nigeria to accelerate SIM registrations given security concerns within Nigeria. We think a much more secure Nigeria is also good for MTN and the broader Nigerian society. I think that point shouldn't be lost in the context of this matter. The second is that the directive is for outgoing voice only. Just to give investors confidence or insight into how we manage risks and compliance with regulation, and we do have on this call Freddy Moolman, our Group CRO and former CEO of MTN Nigeria. We did make a call out this evening to say, "You said outgoing voice calls. Can we just make sure that it is not just the circuit-switched voice, but it's what do we think about Voice over IP?" As Karl has said, we got clarity that it is outgoing circuit-switched voice, data services, and SMSs. We could continue to provide services to our customers. I think that point about our full compliance and full implementation of the directive and our abundance of caution in implementing that directive got us to call the NCC for the avoidance of doubt to think about what is in and what is out of the directive. We have fully implemented the directive, and got reassurance in writing about what services can carry on. The third is, as Sulu has shared, she's financially framed the service revenue impact on a pro forma basis. The impacts, we will provide more detail and color as we go along. Karl gave you some sense of the emerging trends around directionally what's happening to voice as we look at kind of daily recharges. We will provide a lot more detail with the Q1 trading update for MTN Nigeria, which is on the 29th of April 2022. There we'll provide not only quarter one results, but what are the trends we're seeing. We're also in the month of Ramadan in Nigeria. I think investors need to understand that typically in the month of Ramadan, we do see voice grow slightly softer. It's a seasonal trend that is embedded in all our results, we'll provide as much color as we can there on the 29th of April. The fourth point I wanted to raise is we are taking initiatives to support our customers to accelerate their linkages of their NINs to their SIMs. Karl gave us some color on that. I think it's also important to note that we are very deeply engaged with NIMC, the Minister of Communication, Dr. Pantami. We are also engaged with the NCC in figuring out how we can support NIMC with some of the bottlenecks that they have with validation of NIN with support of hardware to ensure that we have a faster process of validation as we send through the NINs that we receive for formal and final validation. With those as summary points, operator, if we can just hand over back to you, and we can take a couple of Q&As. I'll take the Q&As and direct them in the room, depending on the questions that get asked. Okay. Thank you very much, sir. Ladies and gentlemen, if you would like to ask a question, please press star then one on your touch-tone phone or on the keypad on your screen. If you decide to withdraw your question, please press star then two to remove yourself from the list. Again, if you would like to ask a question, please press star then one. The first question comes from Cesar Tiron from Bank of America Merrill Lynch. Please go ahead, Cesar. Yes. Hi, everyone. Good afternoon, and thanks for the call and the opportunity to ask questions. I have four questions if that's okay, but they're really straightforward. The first question, I just wanted to make sure I understand, what is the percentage of the subscribers which we have blocked that actually have a NIN? That's the first one. The second one, assuming they all want to register, how long would it take? Are we talking about weeks or are we talking about months in total? Third question, have you noticed any acceleration in the linkage of NINs and SIM cards over the past couple of days? The fourth one, is there any execution risk? For example, sorry to ask the question, is there any risk that your system fails to detect that one subscriber doesn't actually have this linkage? Thank you so much. Yeah. Cesar, as usual, when we give you a chance to ask one question, you ask many. I think on the percentage of NIN, Karl, unless you want to pick up all the four questions, I'm happy to support you here. Yes, with pleasure, Ralph. The first question was how many subscribers have a NIN. On a broad basis, as of the time we suspended with all the clarifications around the diplomatic SIM cards on a broad basis, approximately 19 million were suspended. The balance had submitted a NIN which is associated with them. 19 to 51 on an approximate basis, is the number of subscribers, 51 being people that have NINs, 19 and some fractions the people that don't have NINs. Now, on how long it will take us to register. This is an evolving matter. Obviously, we've seen quite a surge in demand for people to register their NINs and the subsequent verification which needs to happen. On top of that, we've seen a surge in demand in terms of growth connections for people who just want to register a new NIN. In the context of changing behavior of customers, it is currently difficult to predict that. Also we need to deal with certain limitations around the NIMC capacity, which we are working with them to provide constructively. By the time we do our quarter one earnings release, on the 29th of April, we will have enough statistical trends and a better understanding of the immediate expansions that are going on with the NIMC to predict that accurately. However, there's a good flow. The third question, I heard one part which said the acceleration of usage, I'm not quite sure I got the end of it. It was if you noticed an acceleration of the linkage in the past couple of days. Of the usage by subscribers, you mean? No. Of the linkage of the NINs with the SIM cards. No, there's a significant amount of submissions through the various channels. Linkage is ongoing. Yes, once your SIM card is blocked from making outgoing calls, there's a massive surge in demand. Of course, the initial massive surge will put disproportionate loads on the NIMC system. To answer transparently, yes, we did see a huge surge, both on the ground and through the electronic channels. Over time, as we start to provide linkage, we expect this to taper off, but it will still be significant for an extensive period of time. On the execution risk, and your question, is it possible that one subscriber sneaks through that doesn't have NIN linkage? Let me be clear. We suspended following the regulation to the spirit and the letter and seeking clarifications wherever there was any iota of doubt. We suspended every SIM card according to directive, for outgoing calls, in entirety. Before we reactivate any such SIM cards, they have to provide a NIN and it has to be verified by NIMC. We put several control systems in place to ensure that there is no error on this. We are very conscious, and we have multiple layers of control, secondary checks and audits to ensure that we don't slip on this, which perhaps Ferdie can speak to a bit later. I'm quite confident that we don't have a risk of those things slipping through the cracks, and I'm very confident we've complied to the letter. Thank you so much. That was very helpful. Yeah. Cesar Tiron, maybe just to, because I'm sure this question will come up as well on the registration. I think what investors need to appreciate is that the bottleneck for SIM NIN registration is really NIMC, because that's the validation and that's where there is an IT capacity bottleneck where we stepped into the breach to say, how can we help even with our own hardware to improve the velocity Of validation going through. That's why it's difficult to, we've seen some of your reports about estimation of timelines, how long will it take. We're not going to do the guessing game here because the real issue there is that's where the bottleneck will be. The sooner we can work with the government, and NIMC, which Karl is very engaged with that, the faster we can actually get to that capacity on the hardware side, the faster we can. I think by the time we come to the 29th of April, we're able to provide you more context, particularly around what have we been able to discuss with NIMC or not. That to me is the real determinant of acceleration. On the fourth point around risks, Freddy, you want to comment? Yes. Thank you. Good afternoon, everybody. Just to give you a sense of comfort, this is not the first time that the opco has had to go through some other suspension process. There are quite a number of standard controls and procedures that have been put in place, as Karl had said. I thought I would perhaps just call out two of them just to give you a view. There is a process in the back end now where we will go and look at the data that is normally created after a call to make sure that subscribers that should have been suspended have not made any call. We also use our internal audit team to do an independent review once suspension has taken place, to make sure that we fully comply with all the requirements. Historically, also, when we have gone through these suspension processes, in the event that there has been leakage, we've always engaged the NCC, the regulator of the moment to pick it up. They're always understanding that these are complex issues. We've always dealt with it in a very responsible manner. Thanks. Thanks, Freddy. Operator, back to you. Thank you. The next question comes from Preshendran Odayar from Nedbank. Please go ahead, Preshendran. Hi. Thanks everyone for the call and the opportunity to ask some questions. I've got three quick ones. Firstly, in your announcement, you mentioned this is the first phase. Do you have any inkling of what the second phases will entail? Second question is, can you just remind us what is the fine? I fully appreciate that you guys have probably learned the hard way about making sure that you are compliant, but what are the fines for non-compliance per subscriber? The last one, maybe I've been watching too much of "CSI" or "Blacklist" on TV, but if the intention of the NCC is to prevent kidnappers using these SIM cards, is that the reason why they're only barring outgoing calls because these traditionally get used as burner phones? Can your technology actually track the baddies if they use it for data or any other services that you still have active on these SIMs? Thanks. Robbie, I think- Yeah. Take those, Karl. It's yours. Okay. Thanks, Preshendran. The first question was, this is the first phase. My view, and I think the view of most of the operators in this industry, is this first phase was implemented to ensure that there's phase load on the public and on the systems to get new registrations up to speed on a large scale. There's no clear indication in terms of what the second phase will be. It could be suspension of data, it could be complete suspension of the SIM cards, but there is no indication of that yet. I think we have to look at things on balance. From 2020 December, when the Honorable Minister initially issued this directive, we've seen a significant amount of extensions, and that was precisely for the purpose to allow people as much time and reduce the load on the systems, for them to get to the point where we are, where we do have 50, 51 odd million subscribers that have NINs. I think we'll have quite a bit of time, including a scale-up of the capacity of NIMC, for the majority of the subscribers to get their NINs before any second phase is implemented. To answer unequivocally, there's no indication of a second phase. The second question was fines for non-compliance. The fines, first of all, let me put it into context. We are, of course, unfortunately, the company that had the biggest fine due to SIM registration in 2015. For absolute clarity, the reason why we were fined in 2015 is we received a written instruction, specifically detailing or requesting us to delete subscribers which had registration issues. Fines will only come after non-compliance on a written instruction to delete customers. The fines for non-compliance remains the same as it was in 2015, which is 200,000 naira per subscriber. Back then, that was an odd $1,000. Now, due to currency devaluation, it's $400 and something odd. The next question is if the intention is to prevent kidnappers, is that the reason for outgoing calls, et cetera? I think the Honorable Minister is responsible for identity management registrations, et cetera. His role, and I think his intention, is to ensure as many Nigerians as possible get registered. The decision on how that information is used is really left to the security agencies. We have all the standard set of data, which can be used with the right legal framework and written request to support security agencies in their job. It wouldn't be for me to speculate beyond what the Honorable Minister has stated, in that he wants every Nigerian and every SIM card that is issued in Nigeria to be associated to a National Identification Number. Thank you. Yeah, maybe just to top and tail to your questions, Trish. I come back to the point around phasing is that if your binding constraint is a government agency in terms of the validation, and I say this with the full respect of NIMC themselves, they do have the capacity constraints. Any phasing in terms of either other services or the timelines, it's really a NIMC capacity issue on their ability to validate. That's where the binding constraints, I would argue, would be. As I mentioned earlier on, I think it'll be important to update investors of what is happening in terms of NIMC's own capacity, what the industry has done to enable it to have more servers, et cetera, to be able to go through that. On your question, I think Karl answered your second question on fine for non-compliance, but I thought it'd be helpful for Ferdie to cover two points. One is just to remind you the process in 2015, what happened there, so that we're absolutely super clear. Secondly, what is the notification process? Because there are steps that NCC follows on non-compliance, and Ferdie, I don't know if you want to provide a bit more color on this. Thanks very much. I think I'll start with the process that NCC follows. Firstly, the NCC doesn't just issue fines. In the event that they identify non-compliance, there's a standard process clearly defined in the regulation that they follow. That process consciously allows for communication with the operator to understand why there was non-compliance, and also to give the operator a second opportunity to fully comply. There is a process that is allowed in the event of non-compliance that you can follow and then ensure compliance. The second issue is more in terms of 2015. The reason the fine was issued in 2015 was, in fact, we had gone beyond that process at some point in time, and the regulator had instructed the suspension of about, if I recall correctly, 5 million odd subscribers. The regulator had basically said that these subscribers were not suspended, and hence the fine was issued. What is extremely important in this case is to comply with the regulation which the opco has done. But this part also gives us a sense of comfort that the initial letter, as Karl had said, and Ralph also indicated, that was received by the NCC. We went back for clarity in terms of that actual letter to make 100% sure that we've complied. Thanks. Thank you. Operator? Thank you. The next question comes from Jonathan Kennedy-Good from JP Morgan. Please go ahead, Jonathan. Good afternoon, everyone. Just a brief one on Nigerian revenue guidance was recently upgraded, if I'm not mistaken, to a minimum of 20% over the medium term in NGN. Secondly, in other markets where we've seen similar developments, albeit they are somewhat different, we've seen competitors drop pricing to try and attract subscribers that need to re-register. Is that something you've observed from competitors yet? Are you planning to do anything like that to protect your base? Maybe I can start, Jonathan, on that, Karl can top and tail. On the service revenue guidance, the guidance remains in place. We've had four days of this NIMC registration. We've seen how our Q1 has performed. Obviously, we can't talk about our Q1 is done. That could be seen as selective disclosure, but we'll fully disclose at the end of the month, 29th of April. The guidance remains in place. We will work through seeing how the recharge behavior, the growth connections perform over the next couple of weeks. There isn't, as we said right now, any thought of changing the guidance. I think it's important to note that for us, the guidance is a medium-term guidance. When we think about guidance, we think three to five years what we should get. The next two months, I think, will be important to see how we get through it. As I said, I'm sounding like a stuck record here. I think if the NIMC capacity to validate is materially improved, I think things can turn quite quickly. Karl can probably provide a bit more color on the pricing of what could happen here. I think what is also interesting point to reflect on what happened when we weren't able to actually bring on new subscribers way up to April last year, is we saw relatively disciplined pricing behavior. Remember, there's a voice price war in Nigeria as well. Karl, you want to build on that second point? Yes. Thank you, Ralph. I think our first focus in terms of protecting our base market share is on the ease of NIN submission and verification. As Ralph has clearly indicated, that is very much subjected to the capacity of NIMC. We will continue to focus on the ease of the customer journey to submit and verify NINs, while of course, ensuring that we have as many points as possible for registration of new subscribers. We do not follow a race to the bottom of the market, but we'll consistently remain competitive on an overall basis with market development. That on top of Ralph's comment around the outlook, this is a significant challenge is taking management focus, because we think it's important enough for the entire team to be involved in this. Our consistent strategy around Ambition 2025 continues to be executed in parallel to this. We will continue to deliver value around connectivity and the progress around Ambition 2025. I hope I addressed your question, Jonathan. Thanks. Yeah. Thank you very much. Thank you. The next question comes from Kuda Kadungure from Kela Securities. Please go ahead, Kuda. Hi. Thank you. Thank you, guys, for hosting this call. Just two questions from me. The 9% figure you mentioned as the outgoing revenue, as a percentage of group, does that include the impact on incoming revenue from other local operators? Then the second one being with regards the applications that are due, is there a risk of an application failing or getting rejected? Those are my two questions. Sulu, you want to take the first one, and Karl, you want to take the second one? Yeah. Just on the first one, that 9% is actually based on outgoing voice services specifically, not incoming. Yeah, Kuda, we haven't modeled the impacts of incoming. We just took a most conservative view on just saying, all outgoing and not missing off any incoming. Okay. All right. Karl? Yes. If I understood the question well, Kuda, it was, is there a risk of application failing and getting rejected? Yes, there is. It's part of the ongoing process, which we've had since we started reconnecting SIM cards, as an example, in April 2021. Applications go into the NIMC system, and if there is an excessive load, which of course, in initial stage, there will be, they get rejected or no response arrives. Of course, the verification process has to go through and has to pass successfully before we can proceed with associating the NIN for these bad subscribers with the MSISDN. Understood. Operator, back to you. Maybe we take last two set of questions. Okay. Thank you. The next question comes from Nadim Mohamed, from SBG Securities. Please go ahead, Nadim. Good afternoon. Thanks for the opportunity to ask questions. Just two clarification questions on Karl's section. One of the things that was mentioned was that, subscribers were allowed to link four NIN to four SIM cards. Just was wondering if that applied retrospectively, and does it affect a reasonable portion of your base? Secondly, if I heard correctly, there was some additional requirements on the agent network, like having a BVN, et cetera. Just was wondering what percentage of your agent network is currently compliant and, what the plans are to make them all compliant. Thank you. Karl, you want to pick that up? Yes. Thank you, Ralph. The audio was a little bit shaky, but I know the question was around four telephone numbers per network for the NIN. I'm not sure if I'm answering your question because I didn't hear you quite well, but we have systems in place to ensure that customers cannot associate more than four MSISDN on the MTN network to a single NIN. Those systems almost hardwire it such that before you can register a NIN and activate it checks if there's anything more than three registered. If it's three, the last one can be registered. If it's four, it's declined. You have to bring another NIN, another person has to come to register. As I didn't hear the question 100% clearly, I am hoping that I've answered the question. On the agent network, look, since April 2021, I think it was the 27th of April, the regulations around the agents that are allowed to perform these services have been put in place. They must have a Bank Verification Number and NIN themselves, and must have senior secondary school certificate. We put them through training around compliance. Our agents that are operational in the field are meeting the standards and are certified by the NCC. We get our compliance function to regularly check and audit our compliance around this space. We keep good records of all the documentation, qualifications, et cetera, for these agents. It's not a new thing. It's been in place since April. We're scaling it up, of course, to soak up on the capacity demand. We are well-structured and compliant on this field. Thank you. Thank you so much. I was just going to say on the first question, I was just wondering if it's being applied retrospectively or is the limit of four NIN, four SIMs per NIN already in place? It's already in place, I think. It's not retrospective, Karl. Right? That regulation has also been in place since the Revised National Identity Policy for SIM Card Registration. It is valid from when we started registering from April 2021 going forward. All subscribers registered before then are not required to comply with the four MSISDN per NIN. Excellent. Thank you so much for the clarification. It's an important point of clarification because I think that could have been read as if there's going to be an impact for those who have, let's say eight, now you have four, and does that actually impact revenue? Maybe just on that point, this we self-implemented as part of managing SIM registration risks across the markets, that where there are no guidelines around maximum number of SIMs, particularly in markets like S.A., I mean, S.A. has a weaker process, et cetera. We are implementing self-imposed limits on the number of SIMs just to mitigate SIM registration risks. Should we take up one last set of course to ensure that those who are in the same time zone as us can have a Friday weekend? Okay. Sorry, can you give us the last set of questions? We'll be back again at the end of the month. Thato is around here as well. Okay. Thank you, sir. The final question comes from Admire Mavhunga from Terra Partners. Please go ahead, Admire. Good afternoon. Thanks for the questions. I'm just reading the same notice that was published. It states that the 47 million subscribers represented 67% of the subscriber base and 76 of service revenue. That would imply that the unregistered SIMs are basically low-value subscribers, because I would have assumed that if a serious subscriber would have been able to do the process in time. Could you just clarify that 9%, in view of the whole value situation of these subscribers, in terms of as well, how they will impact on your mobile money service? The second question has to do with the security situation in the north and northwest of Nigeria. Have you been asked to restrict services or any other measures that could have been impacted because of the security situation there in terms of your business? Thank you. Admire, thanks very much for your questions. Karl, do you want to take them, or you want us to do it due on them? No, with pleasure. Thank you all. Admire, I'm not sure I heard the right pronunciation. Look, we must provide information on a non-prejudiced basis. We'll stick to what is in the sense, I'm sure you can deduce from the numbers yourself, what it means in terms of the segments that are most affected. There are many reasons to get a National Identity Number. One of them is, for example, to renew your passport. You would automatically expect that a lot of the people that will be the first to get NINs would be people in major urban centers that have multiple reasons to get a NIN in place. That the bottom of the pyramid will generally tend to be the last on the line to get NINs registered. Beyond that, as a management team, we're very focused. We've segmented in minute detail exactly where our subscribers are, what segment they belong to, their data usage, voice usage, smartphone penetration, et cetera. I think we'll disclose more information to all investors and analysts at the same time at the end of when we report on quarter three. On the second question, right now there are very few security restrictions in place. There were quite a few somewhere between October and December last year. A lot of those were lifted when the security agencies managed to arrest the activity of terrorism/banditry that was ongoing. There are very few in place. It's hard to predict, just as this train incident wasn't predicted, when the next set of security incidences might occur and we might receive written instruction to shut down for security operations. We comply with these, as long as we receive them in the correct format from the regulator, as our license requires. Right now, there aren't major network restrictions for security reasons, but we don't know how that's going to change in the future. Thank you. Karl, thanks very much. It's coming pretty close to the hour. Maybe just to close, and I thank all the investors and stakeholders who have joined this call. From an MTN Group point of view, we feel it's important to keep you updated, even if we don't know all the facts and the situation is evolving. I think it's important, we felt it's important to talk to you much earlier than waiting for Q1 trading update, so we can tell you what we know and what we don't know. I trust that this call has provided a bit more color. I know you'd have wanted more numbers. You will get a lot more detail, both at the 29th of April Q1 trading update for MTN Nigeria, 6th of May 2022 trading update for Group. We will, beyond giving you how the business has progressed, service revenue, EBITDA, margins, and CapEx, we will provide the trends, post this main restriction to outgoing voice. What trends have we seen in recharges? What is the behavior we're seeing with voice? What's happening with data? As I mentioned earlier on, when we provide you with those trends, please take into consideration that we are in the month of Ramadan. In Nigeria, there's generally a softer trending during the month of Ramadan as our colleagues observe the holy month. We will provide as much as we can on growth connections, recharges, underlying data, and voice. To Jonathan's question, which I'm sure many of you are thinking and I'm not brave enough to answer is, I'm sticking with your guidance. As I said, the guidance is held. Any other information that we can provide, we will let you know. Importantly, what we'll also provide in the call is what work have we done with the government, with the Minister Pantami, NCC, ALTON, and NIMC. That constraint on validation is a real bottleneck towards timing. We won't guess how long it will take on this call because actually nobody knows. We do know where the bottleneck is generally. As long as we are fully compliant and going through the processes, if that bottleneck remains, it does become a binding constraint. We are super focused on finding ways to support the government, NIMC in particular, to capacity itself to more rapidly do the validations, because that will give us a better sense of timing. Jonathan, maybe we'll have something to tell you and others around the timing. Having said that, thank you so much for joining. Any other questions you have that we can share color without selective disclosure, please pass them on to Thato and Chima. Chima is in Nigeria. Thato is here, obviously, the Group. We thank all of you for joining us, and have a wonderful weekend. Thanks so much. Thank you very much, sir. Ladies and gentlemen, that concludes today's conference. Thank you very much for joining us. You may now disconnect your lines.
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