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Pay TV phase three document - Stakeholders - Ofcom

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<strong>Pay</strong> <strong>TV</strong> <strong>phase</strong> <strong>three</strong> <strong>document</strong> – non-confidential version<br />

identify the parts of Sky’s businesses that these costs should be allocated to in<br />

contrast with other categories such as marketing.<br />

� Administration costs: a retailer will also incur costs in the general administration<br />

of its retail business. These costs include corporate finance, communications and<br />

human resources functions. Sky’s administration costs are largely common<br />

across its entire business.<br />

9.101 Sky’s management accounts relate to its wholesale, retail, and platform functions,<br />

and therefore it is necessary to allocate the above cost categories across these<br />

businesses, as well as to further sub-divisions. The key parts of the business that we<br />

have allocated costs to and the methodology we have used to allocate common<br />

costs, are:<br />

� Wholesale, retail and platform: we have allocated common costs based on the<br />

number of customers served by each function where: for wholesale this is the<br />

number of premium customers served by Sky and Virgin Media; for retail this is<br />

the total number of subscribers to Sky’s retail packages on DSat and ‘Sky by<br />

Wire’; and for platform, this is the total number of customers on Sky’s DSat<br />

platform. Marketing expenditure is a substantial category which in some cases<br />

may be a common cost across different parts of Sky’s functions. If an individual<br />

expense primarily benefits Sky’s retail business, it is appropriate that this cost is<br />

allocated entirely to the retail business. However, if the expense promotes Sky’s<br />

brand more generally, including the Sky Sports and Sky Movies brands, this can<br />

in part be expected to benefit all retailers of Sky’s premium channels. In this case<br />

we would allocate a portion of costs to Sky’s wholesale business, on the basis of<br />

the number of customers served, for recovery through wholesale charges for<br />

premium channels.<br />

� UK and Ireland subscribers: Sky’s management accounts relate to both countries<br />

and we have allocated common costs based on the number of customers served<br />

by Sky in each of the two countries.<br />

� Residential and commercial subscribers: we have allocated common costs for<br />

premium sports on the basis of revenue, acknowledging that one individual<br />

commercial subscriber has a much higher value than a residential subscriber.<br />

� Basic and premium packages: we have taken a pragmatic approach and<br />

allocated common costs on the basis of ‘subscriber product units’ as a measure<br />

of value – where a subscriber taking only ‘basic’ is measured as one unit and a<br />

subscriber taking ‘basic + premium’ is measured as two product units. Other<br />

alternative methods would be to allocate costs purely on the basis of subscriber<br />

numbers, or purely on the basis of revenue. Allocating on the basis of subscriber<br />

numbers would tend to over-allocate costs to basic; for example, marketing costs<br />

are likely to be disproportionately targeted at premium customers, given the<br />

higher likely return on marketing expenditure. Other costs may at least at first<br />

glance seem better suited to allocations by subscriber numbers – subscriber<br />

management, for example. However, even in this example we might expect some<br />

greater effort to be spent on higher-value subscribers, making the correlation less<br />

clear. It might also be argued that we should allocate costs differently for each<br />

individual cost category or cost item. However, the lack of clear correlation<br />

between particular cost categories and appropriate methods of allocation<br />

suggests that overall, although we would not claim that using subscriber units is<br />

perfect, it is an appropriate way of allocating common costs.<br />

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