The ACCC called for responses to its paper about Principles for the public disclosure of record keeping
rule information provided by Australia Post. A Regulatory Accounting Framework (RAF) was issued in March 2005, following legislative amendments giving the ACCC the power to issue record keeping rules to Australia Post. Under the RAF, Australia Post is required to provide annual financial reports to the ACCC for 16 defined ‘service groups’.
The RAF is important because it creates a framework through which Australia Post is more open about its divers operation and how revenue and costs are accounted for and, hopefully, any cross reliances and cross subsidies.
The ACCC has received four submissions. One from Australia Post, one from an association representing post outlets and two from newsagent associations. [Declaration: the ANF submission includes material I prepared for the organisation last year which I was a Director and the United Newsagents of Australia submission was prepared by me.]
My concern relates to the cost of attracting business and achieving each sale in a government owned PostShop compared to any other retailer. I suspect that the Australia Post brand and its exclusive mail related services draw customers into their retail outlets for a significantly lower cost and would like appropriate data to enable analysis of this. I the data reveals a problem then it could support a complaint with the AGCNCO.
It is important that the public is able to determine for itself whether Australia Post is adhering to its obligations of the Act and in particular Sections 14 through 16 relating to the permitted functions. It is my contention that Australia Post is operating significantly outside what is allowed for under the Act.
I see Australia Post leveraging the brand recognition and respect earned through its reserved services into lucrative business for its non reserved services and that this provides an unfair advantage.