Quarterlytics / Technology / Telecommunications Services / B Communications Ltd. / FY2023 Annual Report

B Communications Ltd.
Annual Report 2023

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FY2023 Annual Report · B Communications Ltd.
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 B Communications Ltd.

  2023 Annual Report

Chapter A - Description of the Corporation's Business 

Chapter B - Report of the Board of Directors on the State of the Corporation's business 

Chapter C - Financial Statements 

Chapter D - Additional Details on the Corporation and Corporate Governance Questionnaire 

Chapter E - Report on the Effectiveness of Internal Control 

THIS  DOCUMENT  IS  AN  ENGLISH  TRANSLATION  OF  THE  HEBREW 
VERSION  OF  THE  COMPANY’S  FINANCIAL  STATEMENTS  AND  THE 
MANAGEMENT  DISCUSSION  AND  ANALYSIS  FOR  FISCAL  YEAR  2023 
(THE  “REPORTS”).  THE  HEBREW  VERSION  OF  THE  REPORTS  IS  THE 
BINDING VERSION AND THE ONLY VERSION HAVING LEGAL EFFECT. 
THE ENGLISH TRANSLATION HAS BEEN CREATED FOR THE PURPOSE 
OF CONVENIENCE ONLY. THE APPROVAL OF THE COMPANY’S BOARD 
OF DIRECTORS WAS GIVEN TO THE HEBREW VERSION ONLY AND NO 
SUCH APPROVAL HAS BEEN GIVEN TO THE ENGLISH TRANSLATION. 
THIS ENGLISH TRANSLATION WAS NOT SUBMITTED TO THE ISRAELI 
IS  NOT  REVIEWED  BY  ANY 
SECURITIES  AUTHORITY  AND 
REGULATORY AUTHORITY.

Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Chapter A 

Description of the Corporation's Business 

2023 Periodic Report 

ב 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Chapter A - Description of the Corporation's Business - Table of Contents 

1. 

Description of the general development of the Group's business 

1 

1.1.  Group activity and description of the development of its business .................... 1 

1.2. 

Areas of activity .................................................................................................. 10 

1.3. 

Investments in the corporation's capital and transactions in its shares ............ 10 

1.4. 

Dividend distribution .......................................................................................... 11 

1.5. 

Financial information regarding the areas of activity of the Group ................... 12 

1.6. 

Forecast in relation to the Group  ...................................................................... 20 

1.7.  General environment and the influence of external factors on the group's activities

 ............................................................................................................................ 21 

1.8. 

Bezeq Group business strategy .......................................................................... 32 

1.9. 

Entry into the field of electricity supply ............................................................. 34 

1.10.  Corporate responsibility (ESG) ............................................................................ 35 

2. 

Bezeq – Interior landline communications 

36 

2.1.  General information about the field of activity .................................................. 36 

2.2. 

Products and services ......................................................................................... 41 

2.3. 

Products and services revenue segmentation.................................................... 44 

2.4. 

Customers ........................................................................................................... 44 

2.5.  Marketing, distribution and service.................................................................... 44 

2.6. 

Competition ........................................................................................................ 45 

2.7. 

PP&E and facilities .............................................................................................. 51 

2.8. 

Intangible assets ................................................................................................. 56 

2.9.  Human capital ..................................................................................................... 56 

2.10.  Equipment and suppliers .................................................................................... 59 

2.11.  Working equity ................................................................................................... 60 

2.12. 

Investments ........................................................................................................ 60 

2.13.  Funding ............................................................................................................... 60 

2.14.  Taxation .............................................................................................................. 62 

2.15.  Environmental risks and their ways of management ......................................... 62 

2.16.  Restrictions and supervision of Brezeq’s operations ......................................... 63 

2.17.  Material agreements .......................................................................................... 83 

2.18.  Legal Proceedings ............................................................................................... 85 

2.19.  Targets and Business Strategy ............................................................................ 92 

2.20.  Discussion of risk factors .................................................................................... 93 

3. 

Pelephone - Mobile radio telephone (cellular telephony) 

99 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

3.1.  General information about the field of activity .................................................. 99 

3.2. 

Services and products ....................................................................................... 102 

3.3. 

Products and services revenue segmentation.................................................. 103 

3.4. 

Customers ......................................................................................................... 104 

3.5.  Marketing, distribution, and service................................................................. 104 

3.6. 

Competition ...................................................................................................... 104 

3.7. 

PP&E and facilities ............................................................................................ 105 

3.8. 

Intangible assets ............................................................................................... 107 

3.9.  Human capital ................................................................................................... 110 

3.10.  Suppliers ........................................................................................................... 112 

3.11.  Working equity ................................................................................................. 112 

3.12.  Taxation ............................................................................................................ 113 

3.13.  Environmental risks and their ways of management ....................................... 113 

3.14.  Restrictions and supervision of Pelephone’s operations ................................. 114 

3.15.  Material agreements ........................................................................................ 119 

3.16.  Legal proceedings ............................................................................................. 119 

3.17.  Targets and business strategy .......................................................................... 121 

3.18.  Expected development in the coming year ...................................................... 121 

3.19.  Discussion of risk factors .................................................................................. 121 

4. 

Bezeq International – Internet and international communications services and ICT 
solutions 

128 

4.1.  General .............................................................................................................. 128 

4.2. 

Products and services ....................................................................................... 129 

4.3. 

Revenue ............................................................................................................ 130 

4.4. 

Customers ......................................................................................................... 124 

4.5.  Marketing, distribution, and service................................................................. 124 

4.6. 

Competition ...................................................................................................... 124 

4.7. 

PP&E and facilities ............................................................................................ 127 

4.8.  Human capital ................................................................................................... 134 

4.9. 

Suppliers ........................................................................................................... 136 

4.10.  Taxation ............................................................................................................ 137 

4.11.  Restrictions and supervision of Bezeq International's activities ...................... 138 

4.12.  Legal proceedings ............................................................................................. 139 

4.13.  Targets, business strategy and development prospects .................................. 132 

4.14.  Discussion of risk factors .................................................................................. 140 

5. 

Yes - Multi-channel TV 

145 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

5.1.  General information about the field of activity ................................................ 137 

5.2. 

Products and services ....................................................................................... 140 

5.3. 

Customers ......................................................................................................... 150 

5.4.  Marketing and distribution ............................................................................... 151 

5.5. 

Competition ...................................................................................................... 151 

5.6. 

Production capacity .......................................................................................... 153 

5.7. 

PP&E, real estate and facilities ......................................................................... 153 

5.8. 

Intangible assets ............................................................................................... 154 

5.9. 

Broadcasting rights ........................................................................................... 155 

5.10.  Human capital ................................................................................................... 156 

5.11.  Suppliers ........................................................................................................... 157 

5.12.  Financing ........................................................................................................... 158 

5.13.  Taxation ............................................................................................................ 158 

5.14.  Restrictions and supervision of Yes .................................................................. 158 

5.15.  Material agreements ........................................................................................ 161 

5.16.  Legal proceedings ............................................................................................. 162 

5.17.  Targets and strategy ......................................................................................... 164 

5.18.  Discussion of risk factors .................................................................................. 165 

6. 

Appendix A - The Company 

172 

6.1. 

Financing ........................................................................................................... 172 

6.2. 

Legal proceedings ............................................................................................. 172 

7. 

8. 

Appendix A - Definitions 

Appendix B - Financial Indices and Key Performance Indicators 

175 

180 

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Chapter A - Description of the Corporation's Business 

B.  Communications  Ltd.  (“the  Company")  together  with  the  subsidiary  Bezeq  the  Israeli  Telecommunications 
Corporation Ltd. ("Bezeq") and Bezeq’s wholly owned subsidiaries, whose financial statements are consolidated with 
Bezeq's statements, will be called together in this periodic report - "the Group” or "Bezeq Group".  

For convenience, Appendix A this chapter contains a glossary of terms in relation to the key terms mentioned in it.  

1.  Description of the general development of the Group's business 

1.1. 

Group activity and description of the development of its business 

1.1.1. 

General 

The Company was incorporated in Israel in 1999 under the name Gold E Ltd. and on March 
16, 2010 changed its name to its current name. From its inception until October 2007, the 
Company was fully owned by Internet Gold Ltd., in October 2007 the Company's shares 
were first issued on the NASDAQ stock exchange and in November 2007 the Company's 
shares were listed on the Tel Aviv Stock Exchange under a double listing arrangement. On 
December 2, 2019, the transaction with Searchlight II BZQ LP and a corporation controlled 
by  the  Forer  family  (TNR  Investments  Ltd.)  was  completed,  in  which  control  of  the 
Company  and  Bezeq  was  transferred  to  these  entities,  following  the  liquidation  of 
Eurocom Communications Ltd., in which the holdings in the Company of its subsidiary, 
Internet Gold, were sold. 

On September 9, 2020, the Company announced the voluntary delisting of its shares from 
trading on the NASDAQ Stock Exchange, and as of that date, the Company's securities are 
traded on the Tel Aviv Stock Exchange only and the Company is a “reporting corporation” 
within the meaning of this term in the Securities Law, 5728-1968. ("Securities Law"). 

As of April 14, 2010, the  Company operates in the field of  communication, through its 
holdings in Bezeq shares. 

1.1.2. 

Acquisition of control of Bezeq 

On April 14, 2010, the Company completed an acquisition of 30.44% of the issued and 
paid-up equity and voting rights in Bezeq, in exchange for a total amount of approximately 
NIS 6.5 billion in cash and became the largest shareholder in Bezeq, and as of the financial 
statements  for  the  first  quarter  of  2010,  the  Company  consolidates  Bezeq's  financial 
statements in its own financial statements. 

As of the date of this report, the Company holds approximately 27.19% of Bezeq's issued 
and paid-up equity. 

For  further  details  regarding  the  control  of  the  Company  and  the  control  permit  in 
connection  with  the  Company's  holding  in  Bezeq  shares,  see  Section    רוקמ  !האיגש
.אצמנ אל הינפהה below. 

1.1.3. 

Bezeq Group - General 

radio 

As of the date of publication of this periodic report, Bezeq Group is a major provider of 
communications services in the State of Israel. Bezeq Group performs and provides a wide 
range of Bezeq operations and Bezeq services, including landline interior communication 
services,  mobile 
international 
services 
communication services, and multi-channel television services over satellite and over the 
infrastructure  and  access  services,  call  center  services, 
Internet  (OTT),  Internet 
maintenance  and  development  of 
infrastructure,  providing 
communication services to other communication providers, including wholesale market 
services,  distribution  of  television  and  radio  broadcasts,  supply  and  maintenance  of 
equipment and services in customer premises (network endpoint services). 

communication 

telephony), 

telephone 

(cellular 

Bezeq was established in 1980 as a government company to which Bezeq's activities that 
had taken place up to that date in the Ministry of Communications were transferred, and 
it was privatized  over the years. Since 1990,  the Company has been a  public company 
whose shares are traded on the Stock Exchange. 

Below is a diagram of the structure of the holdings in the Group as of the date of approval 
of this report (March 12, 2023):  

Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

CThe 

ompany

(*)

27.19%

Bezeq Israel Telecommunications Corporation Ltd.

Bezeq 
Online

100%

Yes 

)*(*

Bezeq 
International

Pelephone

100%

100%

100%

Regarding the Company and the control of Bezeq - see Sections 1.1.1, 1.1.2 and   אל הינפהה רוקמ !האיגש

(*) 
.אצמנ in this chapter.  
(**)  On April 23, 2023, the name of Yes was changed from DBS Satellite Services (1998) Ltd. to Yes Television and 

Communications Services Ltd. 

1.1.4. 

Control of the Company 

On December 2, 2019, a debt arrangement was completed between the Company and its 
bondholders, as part of which Searchlight II BZQ LP and a corporation controlled by the 
Investments  Ltd.)  purchased  control  of  the  Company  (and 
Forer  family  (TNR 
consequently, the control of Bezeq). It should be noted that as of the date of the report, 
Bezeq shares are held by the Company directly. 

As of the date of completion of the debt arrangement as stated above, the controlling 
shareholders of the Company are Searchlight II BZQ LP, a limited partnership incorporated 
in  the  Cayman  Islands  ("Searchlight")  and  TNR  Investments  Ltd.  ("TNR"),  a  private 
company  incorporated  in  Israel.  The  final  general  partner  of  Searchlight  is  Searchlight 
Capital  Partners  II  GP  LLC,  a  limited  liability  company  incorporated  in  the  State  of 
Delaware,  which  is  held  by  a  number  of  individuals  including  Eric  Zinterhofer,  Erol 
Uzumeri  and  Oliver  Harmaann,  the  latter  being  among  the  only  ones  to  receive  the 
Company's control permit from the Ministry of Communications. TNR is  wholly owned 
and fully controlled by Mr. David Forer (50%) and Mrs. Michal Forer (50%).  Searchlight 
and TNR are considered controlling shareholders in the Company by virtue of a control 
permit  dated  November  11,  2019  and  by  virtue  of  a  voting  agreement  between  them 
which  gives them a  cumulative holding, as of the date of publication of this report, of 
approximately 78.78% of the voting rights in the Company. 

To  the  best  of  the  Company's  knowledge,  the  shareholders'  agreement  between 
Searchlight and TNR includes, among other things, a provision according to which as long 
as  the  holdings  of  an  "Israeli  factor"  in  Bezeq's  controlling  shareholder  are  required, 
Searchlight  will  grant  TNR  power  of  attorney  regarding  the  amount  of  shares  that  will 
allow TNR to vote at the general assemblies of the Company, an amount of shares equal 
to: (a) the number of shares held by TNR on the effective date of the meeting, or (b) the 
number of shares that reflects 19% of the issued equity and voting rights in the Company 
on the effective date of the meeting, whichever is higher. To the best of the Company's 
knowledge,  the  shareholders'  agreement  includes  additional  provisions,  including  an 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

obligation by Searchlight to refrain from voting for the approval of certain issues without 
the consent of TNR. 

The control permit 

On November 11, 2019, the Minister of Communications, by virtue of his authority and by 
virtue  of  the  Prime  Minister's  authority  (jointly:  "the  Ministers")  transferred  thereto, 
granted Bezeq control permits under Article 4D of the Communications Law and Article 3 
of  the  Communications  Order  (Bezeq  and  Broadcasting)  (Determination  of  Essential 
Service Provided by Bezeq the Israel Telecommunications Coropration Ltd.), 5757-1997 
("Communications Order"), as follows: 

a.  A control permit for corporations is given to the Company, Searchlight corporations, 

and TNR ("Permit for Corporartions"). 

b.  A control permit for individuals to hold means of control in Bezeq and to control it is 
given to Michal Forer, David Forer, Oliver Harmaann, Erol Uzumeri, Eric Zinterhofer, 
and Darren Glatt1 ("Permit for Individuals").  

The Permit for Corporations and the Permit for Individuals will be jointly referred to as 
"the  Control  Permits"  and  the  parties  to  whom  such  permits  were  granted  will  be 
referred to as "the Permit Holders". It should be noted that as of October 11, 2021 and 
in accordance with the amendment to the control permit dated August 22, 2021, Bezeq 
shares are held by the Company directly. 

The Control Permits were issued for the control and possession of means of control in 
Bezeq  at  a  minimum  rate  of not  less  than  25%2.  The  control  permits  allow  the  Permit 
Holders to control Bezeq directly and indirectly, and they also allow Searchlight and TNR 
to make a "joint appointment" of directors, as defined in the Communications Order, in 
Bezeq and the Company. 

The  Control  Permits  also  stipulate  provisions  regarding  the  minimum  holding  rate  in 
Bezeq of an "Israeli entity" as defined in the Communications Order3.  

Preconditions set out in the Control Permits 

The control permit stipulates, inter alia, as follows: 

"3.1.  The Articles of Association of BCOM, Bezeq and its subsidiaries 

must include instructions as detailed below: 

A. 

 The  method  of  appointing  the  directors  set  forth  in  the 
Company's Articles of Association will not be changed without 
the prior written approval of the Minister of Communications; 

B.  The  Company  shall  report  to  the  Ministers  on  a  holder  of  a 
means of control therein holding excess holdings as soon as it 

1   The permit is given to Mr. Darren Glatt for his status in Searchlight in the context of the acquisition of control of the Company. In addition, 

he serves as Chairman of the Company's Board of Directors and as a director in Bezeq. 

2   The minimum rate is defined as 25% of any type of means of control in Bezeq, or a lower rate according to the approval of the Ministers by 
virtue of Article 3 (a2) of the Communications Order. The minimum rate may change if the Minister of Communications becomes convinced 
that the conditions set forth in Article 3 (a3) of the Communications Order are met. 

3   The Control Permits were issued subject to the fact that David and Michal Forer are citizens and residents of Israel, and it is stipulated therein 
that as long as the Communications Order requires the possession of a means of control by an Israeli entity, as defined in the Communications 
Order, TNR and / or Michal Forer and David Forer will not transfer means of control in Bezeq without the prior written approval of the 
Ministers, if such a transfer is sufficient to reduce their holdings, as the case may be, in means of control of any kind in Bezeq to a rate lower 
than  the  minimum  rate  according  to  the  Communications  Order.  It  was  also  determined  that  any  change  in  the  Israeli  citizenship  and 
residency  of  Michal  Forer  and David  Forer  would constitute  a ground for  revoking  the  control  permit.  In July  2020,  after  a hearing,  the 
Ministry of Communications changed the requirement for the holding of a minimum percentage of means of control in a general licensee by 
an  Israeli  entity  and expanded the  discretion of  the  Ministers  to  approve  holdings by  non-Israeli  entities. Following  this,  the  Ministry  of 
Communications amended the licenses of Cellcom and Partner, the intended amendment in the Communications Order applicable to Bezeq 
has been approved by the Government on March 5, 2023. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

becomes aware of the existence of such excess holdings; 

C.  The  Company  shall 

report 

the 
transformation  of  a  shareholder  therein  into  a  stakeholder  in 
Bezeq  within  48  hours  from  the  date  the  Company  became 
aware of the change. 

the  Ministers  on 

to 

3.2. 

 The  Articles  of  Association  of  the  subsidiaries  must  include 
provisions regarding the rights of the Israeli entity, as defined in 
the  Communications  Order,  for  the  appointment  of  directors 
in  accordance  with  Article  4(a)(2)(b)(2)  of  the 
therein, 
Communications Order;" 

In  accordance  with  the  above,  the  Company  amended  its  Articles  of  Association  as 
required. 

On  April  2,  2020,  Bezeq’s  Board  of  Directors  convened  a  general  assembly  of  Bezeq 
shareholders  for  May  14,  2020,  on  the  agenda  of  which  is  the  amendment  of  Bezeq’s 
Articles of Association in the wording requested by the Company, as follows: 

"After Regulation 95 of the Articles of Association, Regulation 95A shall 
be added as follows: 

The  method  of  appointing  the  directors  set  forth  in  the 
95 a. 
Company's  Articles  of  Association  will  not  be  changed  without  prior 
written approval from the Minister of Communications; 

After  Regulation  42,  Regulations  42A  and  42B  shall  be  added  to  the 
Articles of Association as follows: 

The  Company  shall  report  to  the  Ministers  as  defined  in  the 
42 a. 
Communications  Order,  on  a  holder  of  a  means  of  control  therein 
holding excess holdings therein as defined in the Communications Order, 
as soon as it becomes aware of the existence of such excess holdings; 

The  Company  shall 

42 b. 
the 
report 
transformation  of  a  shareholder  therein  into  a  stakeholder  in  Bezeq 
within  48  hours  from  the  date  the  Company  became  aware  of  the 
change." 

the  Ministers  on 

to 

Bezeq's Board of Directors attached to the above summons a recommendation according 
to  which  "it  was  found  that  the  requested  changes  in  the  Company's  Articles  of 
Association are in favor of the Company and all its shareholders”. Of Bezeq that took place 
on  14.5.2020  did  not  approve  the  company's  request  to amend  Bezeq's  regulations  as 
required by the control permit. 

Regarding  the  manner  of  amending  each  of  the  Articles  of  Association  of  each  of  the 
subsidiaries (in order to include in each  Articles of Association the provisions of Article 
4(a)(2)(b)(2) of the Communications Order, regarding the rights of the Israeli entity, as 
defined in the Communications Order, to appoint directors in subsidiaries) - it was agreed 
that  the  amendment  of  the  subsidiaries’  Articles  of  Association  will  be  made  after  the 
amendment of Bezeq’s Articles of Association. 

The lien permit 

On  November  11,  2019,  Reznik  Paz  Nevo  Trust  Ltd.  was  granted,  as  a  trustee  for 
bondholders issued by the Company (“the Trustee") by the Ministers, a permit to hold 
means  of  control  in  Bezeq  by  way  of  encumbrance  on  the  entire  shares  held  by  the 
Company, directly or indirectly, pursuant to Article 4d of the Communications Law and 
Article 3 of the Communications Order ("the Lien Permit"). 

The Lien Permit stipulates that it constitutes a permit for holding or operating means of 

4 

 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

control in Bezeq by way of lien only, and it does not constitute a permit for control or 
transfer of control in Bezeq. In addition, it was determined that the rights granted to the 
Trustee  and  anyone  holding  debentures  in  the  framework  of  which  debentures  were 
pledged to the Trustee for Bezeq should not be considered a transfer of ownership of the 
means of control of Bezeq, but only a lien as collateral. 

In addition, the Lien Permit includes restrictions on the procedures for exercising the lien 
by  virtue  thereof,  taking  into  account,  among  other  things,  the  provisions  of  the 
Communications Order, including provisions according to which the lien will be carried 
out only by appointing a receiver and trustee whose identity has been approved by the 
Ministers according to various parameters specified in the permit. In addition, similar to 
the  control  permits  as  detailed  above  and  the  reuiqred  changes,  the  Lien  Permit  also 
includes  provisions  allowing  the  Ministry  of  Communications  to  revoke  it,  including  in 
circumstances of concern of harming State security or vital public needs and other cases4 
in which, If the Ministers see that there is a real concern of harm to the provision of the 
essential service by Bezeq or the ground for determining it as an essential service, the 
Ministers will be entitled to act as stated in the Communications Order, including the issue 
of provisions and revocation of the permit. 

It  should  be  noted  that  on June  19,  2022,  approval  was  received  from  the  Ministry  of 
Communications to amend the pledge permit in such a way that Bezeq shares pledged by 
the  Company  will  also  be  processed  for  the  benefit  of  the  holders  of  the  Company's 
debentures (series F). For details, see the Company's report of June 20, 2022 [reference: 
2022-01-075823]. 

Amendment to the Communication Order 

On  September  19,  2023,  an  amendment  to  the  Communications  Order  (Bezeq  and 
Broadcasting)  (Determining  an  essential  service  provided  by  "Bezeq",  the  Israel 
Telecommunications Corporation Ltd.), (Amendment), 5783-2023 ("Amendment to the 
Order") was published in the records and entered into force, which allows a controlling 
shareholder, subject to obtaining the approval of the Prime Minister and the Minister of 
Communications  after  consulting  with  the  Minister  of  Defense,  to  transfer  means  of 
control  to  another  party  if,  as  a  result  of  the  transfer,  he  ceases  to  have  control.  The 
Amendment to the Order includes additional amendments to the Communications Order, 
including, among others: 

A.  Adding  an  option  for  the  controlling  shareholder  to  replace  the  Israeliness 
requirement with instructions from the General Security Service by virtue of Article 
13 of the Communications Law. 

B.  Allowing an (Israeli) institutional investor to increase to a holding of up to 7.5% in a 

certain type of control without the need for ministerial approval. 

C.  Repeal  of  Article  7(g)  of  the  Communications  Order  which  establishes  reporting 
obligations, conditions and limitations for any entity that owns 2.5% or more of some 
type of control in a Company in a situation where over 75% of the Company's shares 
will be held by the public. 

1.1.5. 

In  accordance  with  Article  50(a)  of  the  Companies  Law  and  in  accordance  with 
Regulations 119 and 121 (1) of Bezeq’s Articles of Association - the powers of the CEO in 
all  matters  related  to  the  corporations  held,  directly  or  indirectly,  by  Bezeq  (Including 
Pelephone, Bezeq International, Yes, And Bezeq Online) were transferred to the Board of 
Directors.  

1.1.6. 

Mergers, acquisitions and structural changes 

Structural change in the subsidiaries 

Following on from previous resolutions adopted by Bezeq as well as Bezeq's subsidiaries 
- Bezeq International and Yes (in this Section: “the subsidiaries") regarding a structural 
change plan in which Bezeq International's private activities were to merge with and into 
Yes, and the spin-off of Bezeq International’s ICT activities into a new company wholly 

4  Including - inaccuracies in the data submitted in the permit application, failure on the part of the Trustee to provide a report as required or a 
material change in the details provided by the Trustee, and failure on the part of the Trustee  on behalf of the bondholders to apply  for  the 
appointment of a receiver and trustee on the dates determined in the permit. 

5 

 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

owned  by  Bezeq  (“the  merger  /  spin-off  plan").  On  March  16,  2022,  the  Boards  of 
Directors of Bezeq and the subsidiaries decided to cancel the merger / spin-off plan, and 
to approve an alternative plan, according to which Bezeq International's ISP activity in the 
private  segment  will  be  reduced  following  the  abolition  of  the  separation  between 
broadband infrastructure service and Internet access service (ISP) (as described in Note 
12.3 below), and ISP activity will be established in DBS for the purpose of selling "triple" 
packages  to  customers  (“the  alternative  outline"),  while  striving  to  achieve,  as  far  as 
possible,  the  strategic,  business  and  economic  purposes  that  formed  the  basis  for  the 
resolution to promote structural change, inter alia, adapting the activity to the structure 
of the industry and the changing regulation, focusing on increasing revenues and growth, 
and increasing the operational synergy and streamlining. 

According to this alternative outline, the business purposes that were at the basis of the 
spin-off / merger plan will be achieved, as Yes is expected to become a "triple" sales arm 
that combines fiber and television, and at the end of the move Bezeq International will 
become  a  growth-focused  ICT  company.  In  addition,  this  alternative  outline  has  the 
potential for a significant reduction in Bezeq International's expenses and investments in 
the ISP field in parallel with an accelerated reduction in this activity. 

In  June  2022,  following  its  request  to  the  Ministry  of  Communications,  Yes  received  a 
special license for Internet access services (ISP) and began to provide such services while 
focusing  on  the  sale  of  combined  packages  of  Internet  and  television  to  customers. 
Further  to  what  was  stated  in  Section  1.7.4  regarding  the  change  in  the  regulatory 
structure in the field of Bezeq, as of October 2, 2022, instead of the provisions of the said 
license, the provisions of a general permit apply on Yes’s ISP activity. 

Buyback plan of the Company's shares 

For details about the buyback plan of the Company's shares, which was approved by the 
Company's Board of Directors on August 8, 2023, see Regulation 29(a) of the additional 
details report chapter in this periodic report. 

1.1.7. 

Charges  in  connection  with  the  transactions  of  the  former  controlling  shareholder  of 
Bezeq and former officers of Bezeq and the "Case 4000" 

Following  the  investigations  of  the  Securities  Authority  from  June  2017  and  of  the 
Securities Authority and the Israel Police from February 2018 on suspicion of committing 
offenses under the Securities Law and the Penal Law, 5737-1977 ("Penal Law"), in respect 
of  transactions  related  to  the  previous  controlling  shareholder  in  the  Company  and 
former Chairman of Bezeq's Board of Directors, Shaul Elovich ("Elovtich") regarding the 
purchase of Yes shares5 and the provision of satellite communication services to Yes (“the 
Yes Case”), the Ministry of Communications' dealings with Bezeq, as well as the suspicions 
of  the  exercise  of  powers  by  former  Prime  Minister  Binyamin  Netanyahu,  to  advance 
issues concerning the business of Elovich and the economic interests of him and the Bezeq 
Group ("Case 4000") - 

1.1.7.1 

On  January  28,  2020,  an  indictment  was  filed  with  the  Jerusalem  District 
Court in Case 4000, inter alia, against Elovich for various offenses, including 
bribery and deliberate misstatement in an immediate report in connection 
with suspicions of  exercise of  powers by former  Prime Minister  Binyamin 
Netanyahu  to  advance  issues  concerning  the  business  of  Elovich  and  the 
economic interests of him and the Bezeq Group. 

Further to the notice of the Tel Aviv District Attorney's Office (Taxation and 
Economy)  dated  December  23,  2020  regarding  their  consideration  of  the 

5  As of June 24, 2015, Bezeq owns all DBS shares after completing on that date the purchase of Eurocom DBS' entire holdings in DBS (the "Purchase 
Transaction"). Since the final amount of the second conditional consideration in the Purchase Transaction was lower than the sum of the advances 
paid by the Company to Eurocom DBS for said consideration, Eurocom  DBS had to  return the  difference to  Bezeq. In this framework, Bezeq 
submitted to the Tel Aviv District Court a motion for the liquidation of Eurocom DBS due to its inability to return the aforementioned difference, 
and on April 22, 2018, the Tel Aviv District Court issued an order for the liquidation of Eurocom DBS, while a proxy was appointed as a liquidator 
to Eurocom DBS. Also, Bezeq joined as a creditor in the liquidation procedure of Eurocom Communications, the parent company of Eurocom DBS, 
and on December 12, 2022 the debt claim filed by Bezeq was dismissed. Bezeq filed an appeal against the decision. It should be noted that in 
Bezeq's 2018 statements, the write-off of the aforementioned debt balance was completed, so that the postponement of the debt claim is not 
expected to affect Bezeq's results. 

6 

 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

prosecution of Bezeq and its summons to a hearing in Case 4000 regarding 
suspicions  of  the  offense  of  bribery  (an  offense  under  Article  291  of  the 
Penal Law, 5737-1977 ("Penal Law"), along with Article 23 of the Penal Law), 
and  the  offense  of  reporting  with  the  aim  of  misleading  a  reasonable 
investor (an offense under Article 53(a)(4) of the Securities Law) along with 
Section 23 of the Penal Law, on February 1, 2024, an agreement was signed 
between the State of Israel (through the Tel Aviv District Attorney's Office 
(Taxation  and  Economy))  and  Bezeq  for  a  conditional  termination  of 
proceedings under the conditions in accordance with Point B of Chapter 91 
of the Securities Law ("the Settlement"). 

In  accordance  with  the  Settlement,  the  State  of  Israel  will  not  file  an 
indictment  in  Bezeq's  case  in  connection  with  any  of  the  suspicions 
investigated  in  the  investigation  file,  and  this  is  subject  to  the  suspect 
fulfilling its obligations according to the settlement as follows: (1) payment 
of an amount in the amount of NIS 800 thousand; (2) refraining from all A 
statement that is knowingly inconsistent with or contradicts the Settlement 
and the facts that Bezeq admitted as part of the Settlement. 

As part of the Settlement, the State of Israel also informed Bezeq that it had 
decided  to  close  the  investigation  file  regarding  the  Walla  company  (a 
company  that  was  fully  owned  by  Bezeq  at  the  times  relevant  to  the 
suspicions and received a similar notice regarding the consideration of filing 
an indictment against it for suspicions of the offense of bribery). 

As  part  of  the  Settlement,  Bezeq  admitted  the  facts  detailed  in  the 
settlement and these are: 

A. 

In  the  relevant  period,  between  the  years  2012  and  2016,  Shaul  Elovich 
("Elovich")  was  the  controlling  shareholder  of  the  Bezeq  Group.  Walla, 
which during the relevant period was a wholly owned subsidiary of Bezeq, 
operated the "Walla NEWS!" website. 

B.  Elovich and other Bezeq representatives worked with the Director General 
of the Ministry of Communications Shlomo Filber to promote the issue of 
cancelling the structural separation in the Bezeq Group. 

C.  On December 22, 2016, Shlomo Filber ("Filber") sent Bezeq a letter titled 
"Cancellation of the structural separation obligation in the Bezeq Group", 
which was drafted by him in coordination with Bezeq representatives, with 
the knowledge of Elovich and the CEO of Bezeq at that time, Stella Handler 
("Handler")6. The letter included a misleading detail, according to which the 
fact regarding the obligation to hold a hearing prior to the cancellation of 
the  corporate  separation  in  Bezeq  was  omitted,  and  a  misleading 
representation was made, according to which both the cancellation of the 
corporate separation and the cancellation of the structural separation are 
in an advanced stage and have a higher feasibility than in actuality. 

D.  On December 23, 2016, Bezeq reported in an immediate report to the public 
about the transmission of the letter and its contents. This report included 
the misleading detail contained in the Ministry of Communications letter. 
Elovich  and  Handler  knew  that  the 
letter  from  the  Ministry  of 
Communications  contained  the  misleading  detail  and  that  it  would  be 
reported  to  the  public.  The  next  day,  the  Ministry  of  Communications 
published  a  clarification  according  to  which  the  cancellation  of  the 
corporate  separation  will  be  done  after  a  hearing  procedure  and 
subsequently Bezeq published a report clarifying this part of the previous 
report. 

6  It should be noted that, as part of the Settlement, the Company stated that it currently has no knowledge of Elovich's and Handler's real-time awareness 

of any specific detail. 

7 

 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.1.7.2 

It should be noted that, as appears from the settlement, the suspicions against 
Bezeq stem from the actions and/or omissions of Elovich and Handler, who were 
involved in the execution of the acts described in the settlement  and who no 
longer serve at Bezeq. 

For this matter, see also the company's immediate report from February 1, 2024, 
which is included in this report by way of reference. 

On  December  23,  2020,  to  the  best  of  Bezeq’s  knowledge,  an 
announcement by the State Attorney's Office was published, according to 
which,  among  other  things,  the  State  Attorney's  Office  (Taxation  and 
Economics) filed on the same day an indictment against Elovich with the Tel 
Aviv District Court, as well as against former senior officials in Bezeq Group 
and Yes, Or Elovich, Amikam Shorer, Linor Yochelman , Ron Eilon and Mickey 
Neiman in the Yes Case. According to the publication: 

a)  The indictment attributes to the defendants the offenses of aggravated 
obtainment  by fraud, fraud and breach of trust in a corporation, and 
reporting offenses under the Securities Law, in relation to two cases: 
Fraud in relation to the payment of the consideration for the purchase 
of  Yes  shares  by  Bezeq,  and  fraud  in  relation  to  the  conduct  of  the 
independent  committees  established  by  Bezeq  for  the  purpose  of 
examining Bezeq transactions in which Elovich had a personal interest. 

b)  The  State  Attorney's  Office  (Taxation  and  Economics)  entered  into  a 
conditional settlement agreement under the Securities Law with Stella 
Handler, in which Stella Handler admitted the facts according to which 
she was involved in intentional misstatement in Bezeq's statements. In 
accordance with what is stated in the arrangement, the  Yes Case was 
closed in the case of Stella Handler. 

c)  The investigation files in respect of other suspects investigated in the 
cases mentioned above were closed, including against the former VP of 
regulation at Bezeq, as well as against Or Elovich and Amikam Shorer 
(in relation to both - except with regard to the Yes Case ,as indicated in 
the preamble of this section).  

On July 20, 2022, the decision of the Economic Department of the Tel-Aviv-
Yafo District Court was published on the request of some of the defendants 
to drop charges in the case, according to which the second and third charges 
in  the  indictment  were  dropped  (fraud  in  relation  to  the  conduct  of  the 
independent  committees  in  the  "Bezeq-Yes"  transaction  and  the  "Yes-
Space"  transaction)  against  all  the  defendants  in  these  charges:  Elovich, 
former officers of Bezeq - Mr. Or Elovich, Mr. Amikam Shurer and Mrs. Linor 
Yochelman, as well as against the companies accused in the same charges - 
companies  from  the  "Eurocom"  group.  The  decision  also  stated,  among 
other  things,  that  it  is  not  possible  to  accept  Elovich's  claim  that  the 
indictment  does  not  reveal  guilt  in  connection  with  the  first  charge 
(fraudulent  receipt  of  advances  at  the  expense  of  the  second  contingent 
consideration  in  the  Bezeq-Yes  transaction).  It  was  emphasized  in  the 
decision  that  it  does  not  in  any  way  impinge  on  the  civil  aspect,  and  the 
pending  proceedings  in  this  regard  (for  civil  proceedings  against  Bezeq 
and/or  former  Bezeq  officials,  see  Section  1.1.7.5).  On  July  13,  2023,  the 
judgment of the Supreme Court was given in the appeal filed by the State 
against the aforementioned decision, according to which the State's appeal 
regarding  all  respondents  (except  Eurocom  Holdings  (1979)  Ltd.)  was 
accepted  and  the  case  was  returned  to  the  District  Court  for  further 
evidentiary investigation. 

1.1.7.3 

Bezeq does not yet have complete information regarding the investigations 
(mainly regarding the Yes Case), their content, materials and evidence in the 
possession of the law authorities in the matter (although in January 2021, 
Bezeq  received  the  core  of  the  investigation  material  in  connection  with 

8 

 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Case  4000,  although  on  February  1,  2024,  an  agreement  was  signed 
between the State of Israel and Bezeq to terminate proceedings conditional 
). 
on the conditions as detailed in Section
Accordingly, Bezeq is still unable to assess the effects of the investigations, 
their  findings  and  results  on  Bezeq  and  its  financial  statements.  For  this 
matter see Note 1.3 to the 2023 statements.  

.אצמנ אל הינפהה רוקמ

 !האיגש

1.1.7.4 

1.1.7.5 

It should be noted that following the opening of the said investigations, a 
number of civil legal proceedings were opened against Bezeq, Yes, Bezeq's 
officers  in  the  relevant  period,  and  companies  from  Bezeq’s  former 
controlling group, including motions for approval of class actions/derivative 
claims and motions for disclosure of documents before filing a motion for 
approval of a derivative claim. For details regarding these procedures see 
Section2.18 2.18. 

Regarding Yes, which, on November 20, 2017, received a "letter of suspect 
notification"  according  to  which  the  investigation  case  in  which  it  was 
questioned as a suspect was forwarded to the State Attorney's Office  - in 
accordance with the State Attorney's Office's notice received by Yes, after 
the Securities Authority case (Ref. No. 03/2017), in which it was questioned 
as a suspect, was examined by the Attorney General’s Office, it was decided 
on January 11, 2021 to shelf the case against it, without filing an indictment 
therein. 

1.2. 

Areas of activity 

The  Group  has  four  main  areas  of  activity  that  correspond  to  the  corporate  division  among  the 
Group's companies and are reported as business segments in the Company’s consolidated financial 
statements (see also Note 28 to the 2023 statements):  

1.2.2. 

Bezeq – Landline interior communications 

This area mainly includes the activities carried out by Bezeq as an NIO (National Interior 
Operator), including telephony services, Internet  services (including service over fibers 
and  wholesale  BSA  service),  transmission  and  data  communication  services  and 
wholesale services of using Bezeq's physical infrastructure. Bezeq’s activity in the field of 
landline interior communications is described in Section 2 of this report.  

1.2.3. 

Pelephone - Cellular communication ("Mobile Radio Telehpone") 

This  field 
includes  the  provision  of  cellular  radio-telephone  services  (cellular 
communications), marketing of end equipment, installation, operation and maintenance 
of equipment and systems in the field of cellular communications. Pelephone activity is 
described in Section3 of this report.  

1.2.4. 

Bezeq International - Internet, international communications and ICT solutions (“Bezeq 
International services”) 

As of the date of the report, this area includes the provision of Internet services to existing 
subscribers  in  a  private  service  and  does  not  include  the  marketing  of  this  service  to 
new/renewing subscribers. As of the date of the report, Bezeq International focuses on 
business  services,  including  integration  services,  internet  for  businesses  and  more  (for 
international 
structural  change,  see  Section  1.1.6).  Also, 
communication  services,  hosting  and  cloud  services  and  ICT  solutions  ("Bezeq 
International  Services").  Bezeq  International's  activity  is  described  in  Section  4  of  this 
report..  

includes 

field 

this 

1.2.5. 

Yes - Multi-channel TV 

This  field  includes  the  provision  of  digital  multi-channel  TV  broadcasting  services  to 
subscriptions over satellite (DBS) as well as over the Internet (OTT) and the provision of 
value-added  services  to  subscribers  and  Internet  services  (infrastructure  component 
through a wholesale market). Yes’s activity is described in Section 5 of this report.  

It should be noted that in addition, Bezeq's consolidated financial statements include the "other" 
segment, which includes mainly call center services for customers via Bezeq Online, and is immaterial 
in group terms. 

9 

 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.3. 

Investments in Bezeq’s equity and transactions in its shares 

The following is a breakdown of purchases of Bezeq shares in the last two years by the Company: 

Date 

Shares 

Total 
consideration 
(NIS millions) 

Average price 
per share (NIS) 

28.12.2022 

2,530,000 

Approx. 15 

3.4.2023 

2,100,000 

Approx. 10 

28.5.2023 

1,417,995 

Approx. 6.8 

30.5.2023 

2,090,000 

Approx. 10 

28.6.2023 

1,100,000 

Approx. 5 

29.6.2023 

1,100,000 

Approx. 5 

31.1.2024 

3,120,000 

Approx. 15 

5.95 

4.75 

4.77 

4.79 

4.54 

4.57 

4.82 

Further  to  the  amendment  to  the  Communications  Order  (as  specified  in  Section  1.1.4),  which 
allows, among other things, an Israeli institutional investor to increase his holding to up to 7.5% 
by means of a certain type of control in the Company without the  need for the approval of the 
Ministers, in the months of September-October 2023, the entities include Clal Holdings Insurance 
Business Ltd., Harel Investments in Insurance and Financial Services and Ltd., and Migdal Holdings 
Insurance  and  Finances  Ltd.  reported  to  Bezeq  that  they  became  related  parties  after  their 
holdings increased beyond 5% of Bezeq's shares. 

With  the  exception  of  the  above,  in  the  reporting  year  no  investments  were  made  in  Bezeq’s 
equity, and the Group is not aware of any other material transactions made by a related party in 
Bezeq shares off the stock exchange. 

1.4. 

Dividend distribution 

1.4.1. 

Dividend distribution policy in the Company 

The Company has not distributed dividends to its shareholders in the last two years (2022-
2023),  and  as  of  the  date  of  this  report,  the  Company  does  not  have  a  valid  dividend 
distribution policy. 

1.4.2. 

Dividend policy at Bezeq 

On  March  13,  2024,  the  Bezeq  Board  of  Directors  decided  to  update  Bezeq's  dividend 
distribution policy, so that Bezeq will distribute every six months 70% of the semi-annual 
profit  (after  tax)  according  to  Bezeq's  consolidated  statements,  starting  with  the 
distribution for the second half of 2022, which is in view of the trend of improvement in 
the  business  results  and  the  continued  decrease  in  the  extent  of  Bezeq's  debt  and  in 
accordance with Bezeq's forecasts regarding the business results for the following years. 

Also, Bezeq will strive to increase the dividend in the future, subject to maintaining the 
Company's credit rating in the AA group. 

The implementation of the dividend distribution policy is subject to the provisions of any 
law, including the distribution tests set forth in the Companies Law, all in consideration 
of the expected cash flow, Bezeq's needs and obligations, Bezeq's cash balances, its plans 
and condition as they will be from time to time, and subject to the approval of the general 
assembly of Bezeq's shareholders regarding any specific distribution, all as stipulated in 
Bezeq’s Articles of Association. 

The approval of Bezeq's dividend policy does not obligate Bezeq to distribute a dividend 
to Bezeq's shareholders, and any specific distribution will be examined in accordance with 
the  terms  of  implementation  of  the  dividend  distribution  policy  as  stated  above.  In 
addition, the approval of the aforesaid policy does not prevent Bezeq's Board of Directors 
from  periodically  reviewing  the  policy  of  distributing dividends  to  Bezeq  shareholders, 

10 

 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

taking into account, inter alia, the provisions of the law, Bezeq's business situation and its 
equity  structure  and  balance,  its  level  of  debt  and  credit  rating,  and  the  ongoing 
maximization  of  value  to  Bezeq's  shareholders  through  the  regular  distribution  of 
dividends. 

Bezeq's  Board  of  Directors  considers  it  important  to  maintain  the  balance  between 
ensuring Bezeq's financial strength and stability, while maintaining Bezeq's rating in the 
current rating group [AA] over time, and continuing to unlock value for its shareholders 
through regular dividend distribution. Bezeq's Board of Directors was presented, among 
other things, with Bezeq's and the Bezeq Group's forecasts, as well as sensitivity analyzes 
for unforeseen deterioration in Bezeq's and Bezeq Group businesses. After Bezeq's Board 
of  Directors  examined  all  of  the  above,  the  Board  of  Directors  determined  that  this 
decision reflects the correct balance between the abovementioned needs. 

1.4.2.1 

Dividend  distribution  in  Bezeq  -  For  details  regarding  the  dividends 
distribution  carried  out  by  Bezeq  in  2022-2023,  see  Note  20  to  the  2023 
statements.  Bezeq’s  balance  of  distributable  profits  as  of  the  date  of  the 
report  are about  NIS  1,257 million (the said balance consists of surpluses 
accumulated  in  the  last  two  years  in  Bezeq  after  deducting  the  dividend 
amounts paid in the past two years by Bezeq to itsa shareholders). 

Regarding  the  recommendation  of  the  Bezeq  Board  of  Directors  dated 
March 12, 2024 to the general assembly of Bezeq’s shareholders regarding 
the distribution of a dividend in respect of the profits of the second half of 
the year 2023, see Note 12.7 to the consolidated statements for 2023. 

1.5. 

Financial information regarding the areas of activity of Bezeq Group 

All data in sections 0 to 1.5.4 are stated in NIS millions.  

1.5.1. 

2023 

11 

 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Lnadline 
interior 
communica
tion 

Cellular 
communicat
ion (mobile 
radio 
telephone) 

Bezeq 
Internatio
nal 
services 

Multi-
channel TV 
(3) 

Other 

Consolidate
d 

Consolidati
on 
adjustment
s (2) 

Total revenue: 
External 

From other areas of activity in the 
corporation 
Total revenue 

Total attributable costs: 
Variable costs attributed to the area 
of activity (1) 
Fixed costs attributed to the area of 
activity (1) 
Total costs  

Costs that do not constitute 
revenue in another area of activity 
(3) 

Costs that constitute revenue of 
other areas of activity 

Total costs  
Profit from ordinary activities 
attributed to the owner of the 
Cmpany 
Total assets attributed to activity as 
of December 31, 2022 
Total liabilities attributed to the 
area of activity as of December 31, 
2022 

4,157 
255 

2,309 
39 

1,139 
73 

1,308 
1 

190 
2 

- 
(370) 

9,103 
- 

4,412 

2,348 

1,212 

1,309 

192 

(370) 

9,103 

656 

734 

744 

385 

165 

2,305 

1,418 

429 

928 

28 

2,961 
2,913 

2,152 
2,053 

1,173 
984 

1,313 
1,293 

193 
190 

(468) 
(109) 

7,324 
7,324 

48 

99 

189 

20 

3 

(359) 

- 

2,961 
1,451 

2,152 
196 

1,173 
39 

1,313 
(4) 

193 
(1) 

(468) 
98 

7,324 
1,779 

9,311 

2,832 

1,000 

1,231 

9,189 

1,448 

779 

445 

88 

30 

(584) 

13,878 

(211) 

11,681 

(1) The Group companies, which are companies that provide services (as opposed to manufacturing companies), do not maintain a dedicated 
pricing system that distinguishes between fixed and variable costs. The above division was made for the purposes of this report only. Variable 
costs are costs that companies have flexibility in managing and controlling in the short term,a s well as their effect on direct output, compared 
to fixed costs that are not flexible in the short term and do not directly affect output (in this regard, up to one year). The variable costs included 
non-recurring expenses (revenue) that were included in the item of other expenses (revenue) of each company. 

(2) Details of the adjustments to consolidated - transactions between areas of activity. 

(3) See Notes 10 and 28 to the 2023 statements regarding the neutralization of the impairment loss in the multi-channel television segment. The 
impairment loss in this segment is shown in the adjustments. 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.5.2. 

2022 

Lnadline 
interior 
communica
tion 

Cellular 
communicat
ion (mobile 
radio 
telephone) 

Bezeq 
Internatio
nal 
services 

Multi-
channel TV 
(3) 

Other 

Consolidate
d 

Consolidati
on 
adjustment
s (2) 

Total revenue: 

External 
From other areas of activity in the 
corporation 
Total revenue 

Total attributable costs: 
Variable costs attributed to the area 
of activity (1) 

Fixed costs attributed to the area of 
activity (1) 

Total costs  
Costs that do not constitute 
revenue in another area of activity 
(3) 
Costs that constitute revenue of 
other areas of activity 
Total costs  

Profit from ordinary activities 
attributed to the owner of the 
Cmpany 

Total assets attributed to activity as 
of December 31, 2022 

Total liabilities attributed to the 
area of activity as of December 31, 
2022 

3,980 

2,359 

1,183 

1,277 

187 

- 

8,986 

326 
4,306 

40 
2,399 

56 
1,239 

- 
1,277 

6 
193 

)
)

(428
(428

- 
8,986 

606 

852 

759 

382 

159 

2,240 

1,354 

510 

943 

28 

2,846 
2,805 

2,206 
2,114 

1,269 
1,009 

1,325 
1,305 

187 
183 

(484
)
(67)

7,349 
7,349 

41 

92 

260 

20 

4 

)

(417

- 

2,846 

2,206 

1,269 

1,325 

187 

)

(484

7,349 

1,460 

193 

(30)

(48)

6 

56 

1,637 

9,023 

4,080 

760 

1,249 

87 

 )

1,787

(

13,412 

10,468 

1,563 

570 

469 

32 

 )

1,314

(

11,788 

(1) The Group companies, which are companies that provide services (as opposed to manufacturing companies), do not maintain a dedicated 
pricing system that distinguishes between fixed and variable costs. The above division was made for the purposes of this report only. Variable 
costs are costs that companies have flexibility in managing and controlling in the short term,a s well as their effect on direct output, compared 
to fixed costs that are not flexible in the short term and do not directly affect output (in this regard, up to one year). The variable costs included 
non-recurring expenses (revenue) that were included in the item of other expenses (revenue) of each company. 

(2) Details of the adjustments to consolidated - transactions between areas of activity. 

(3) See Notes 10 and 28 to the 2022 statements regarding the neutralization of the impairment loss in the multi-channel television segment. The 
impairment loss in this segment is shown in the adjustments. 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.5.3. 

2021 

Lnadline 
interior 
communica
tion 

Cellular 
communicat
ion (mobile 
radio 
telephone) 

Bezeq 
Internatio
nal 
services 

Multi-
channel TV 
(3) 

Other 

Consolidate
d 

Consolidati
on 
adjustment
s (2) 

Total revenue: 
External 

From other areas of activity in the 
corporation 

Total revenue 
Total attributable costs: 

Variable costs attributed to the area 
of activity (1) 
Fixed costs attributed to the area of 
activity (1) 
Total costs  

Costs that do not constitute 
revenue in another area of activity 
(3) 

Costs that constitute revenue of 
other areas of activity 

Total costs  
Profit from ordinary activities 
attributed to the owner of the 
Company 
Total assets attributed to activity as 
of December 31, 2021 
Total liabilities attributed to the 
area of activity as of December 31, 
2021 

3,845 

2,249 

1,186 

1,270 

271 

- 

8,821 

337 

4,182 

40 

2,289 

51 

- 

1,237 

1,270 

6 

277 

)

(434

)

(434

- 

8,821 

369 

982 

723 

369 

215 

2,065 

1,265 

492 

942 

35 

2,434 

2,389 

2,247 

2,153 

1,215 

944 

1,311 

1,291 

250 

246 

)

(506

(72)

6,951 

6,951 

45 

94 

271 

20 

4 

)

(434

- 

2,434 

2,247 

1,215 

1,311 

250 

)

(506

6,951 

1,748 

42 

22 

(41)

27 

72 

1,870 

9,245 

4,452 

783 

1,293 

100 

 )

1,939

(

13,934 

11,415 

1,753 

566 

474 

37 

 )

1,407

(

12,838 

(1) The Group companies, which are companies that provide services (as opposed to manufacturing companies), do not maintain a dedicated 
pricing system that distinguishes between fixed and variable costs. The above division was made for the purposes of this report only. Variable 
costs are costs that companies have flexibility in managing and controlling in the short term,a s well as their effect on direct output, compared 
to fixed costs that are not flexible in the short term and do not directly affect output (in this regard, up to one year). The variable costs included 
non-recurring expenses (revenue) that were included in the item of other expenses (revenue) of each company. 

(2) Details of the adjustments to consolidated - transactions between areas of activity. 

(3) See Notes 10 and 28 in the 2023 statements regarding the neutralization of the impairment loss in the multi-channel television segment. The 
impairment loss in this segment is shown in the adjustments. 

For explanations about the developments in the financial data presented In sections0 to   אל הינפהה רוקמ !האיגש
.אצמנ aee Section 1 of the Board of Directors’ report on the state of the corporation's affairs ("Board of Directors' 
Report").  

1.5.4. 

Main results and operational data  

The following is a summary of data on the results of each of the Company's main 
areas of activity in 2022 and 2023.  

14 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.5.4.1 

Bezeq Fixed Lines (Bezeq’s activity as NIO) 

Financial data ( NIS  millions) 

2023 

2022  Q4/ 
2023 

Q3/ 
2023 

Q2/ 
2023 

Q1/ 
2023 

Q4/ 
2022 

Q3/ 
2022 

Q2/ 
2022 

Q1/ 
2022 

Revenue 

Operating profit 

4,412 

4,306 

1,08
7 

1,451 

1,460 

320 

Depreciation and amortization 

1,019 

1,005 

260 

1,084  1,130  1,111  1,057  1,086  1,067  1,096 

310 

258 

418 

256 

403 

245 

293 

266 

388 

252 

393 

248 

386 

239 

Operating profit before depreciation 
and amortization (EBITDA) (1) 

2,470 

2,465 

580 

568 

674 

648 

559 

640 

641 

625 

Net profit 

901 

849 

199 

Cash flow from operating activities 

2,380 

2,230 

584 

192 

586 

261 

602 

249 

608 

153 

628 

235 

427 

243 

541 

218 

634 

Payments for investments in property, 
plant and equipment and intangible 
assets and other investments 

Receipts from the sale of  property, 
plant and equipment and intangible 
assets 

Lease payments 

Free cash flow (2) 

Operating data 

1,122 

1,135 

290 

239 

281 

312 

277 

294 

279 

285 

33 

36 

3 

 - 

1 

29 

9 

8 

5 

14 

158 

138 

46 

37 

35 

40 

35 

34 

33 

36 

1,133 

993 

251 

310 

287 

285 

325 

107 

234 

327 

Number of active telephone subscriber 
lines at the end of the period 
(thousands) (3) 

1,442 

1,503 

1,44
2 

1,454  1,473  1,488  1,503  1,522  1,542  1,563 

Average monthly revenue per 
telephony subscriber (NIS) (ARPL) (4) 

37 

42 

33 

34 

39 

41 

40 

41 

41 

47 

Outgoing usage minutes (millions)  

2,692 

2,949 

652 

Incoming usage minutes (millions) 

3,473 

3,938 

829 

677 

874 

658 

852 

705 

918 

682 

921 

740 

986 

726 

801 

951 

1,080 

Telephony subscriber churn rate (6) 

10.2%  10.9%  2.3% 

2.8% 

2.6% 

2.5% 

2.5% 

2.8% 

2.6% 

3.0% 

Total number of Internet subscribers at 
the end of the period (thousands) (7) 

1,495 

1,504 

1,49
5 

1,500  1,505  1,505  1,504  1,505  1,511  1,519 

Of which are subscribers connected to 
the fiber network at the end of the 
period - wholesale (thousands) (10) 

565 

267 

565 

506 

424 

351 

267 

212 

160 

124 

Of which are Internet lines at the end 
of the period - in retail (thousands) (7) 

1,028 

1,032 

1,02
8 

1,029  1,028  1,031  1,032  1,024  1,021  1,024 

Of which are subscribers connected to 
the fiber network at the end of the 
period - in retail (thousands) (7) 

Internet lines at the end of the period – 
in wholesale (thousands) (7) 

Of which are subscribers connected to 
the fiber network at the end of the 
period - in wholesale (thousands) (7) 
(8) 

Average monthly revenue per Internet 
subscriber (NIS) - retail (ARPU) (9) 

Fiber optic network deployment at the 
end of the period (thousands, 
households available for connection) 
(10) 

367 

198 

367 

335 

289 

246 

198 

157 

118 

93 

467 

472 

467 

471 

477 

474 

472 

481 

490 

495 

198 

69 

198 

171 

135 

105 

69 

55 

42 

31 

123 

114 

125 

124 

122 

120 

117 

116 

113 

110 

2,070 

1,526 

2,07
0 

15 

1,970  1,835  1,689  1,526  1,442  1,308  1,193 

 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Average packet rate for internet 
subscription - retail (Mbps) (5) 

Number of Be routers used by the 
Company's customers (thousands) 

Number of  home internet network 
range enhancers of the Be Spot and Be 
Mesh types (thousands) 

341 

220 

341 

315 

278 

250 

220 

192 

164 

151 

831 

764 

831 

819 

801 

786 

764 

733 

708 

688 

442 

416 

442 

438 

430 

425 

416 

402 

386 

374 

(1)  Operating profit before depreciation and amortization (EBITDA) is a financial index that is not based on generally accepted 
accounting principles. Bezeq presents this index as another index for evaluating its business results since it is an accepted 
index in the Bezeq area of activity which neutralizes aspects resulting from variability in capital structure, various taxation 
aspects and manner and period of amortization of property, plant and equipment and intangible assets. This index is not a 
substitute for indices based on generally accepted accounting principles, and does not serve as a single index for assessing the 
Company’s results of operations or cash flow. Also, the index presented in this report may not be calculated in the same way 
as other indices in other companies. Bezeq‘s EBITDA is calculated as operating profit before depreciation, amortization and 
ongoing  losses  from  impairment  of  property,  plant  and  equipment  and  intangible  assets.  For  the  purpose  of  adequate 
presentation of economic activity, Bezeq presents ongoing losses from impairment of property,  plant and equipment and 
intangible assets in Yes and Bezeq International under the depreciation and amortization item, as well as ongoing losses from 
impairment of broadcasting rights under the operating and general expenses item (in the statement of income). For this matter 
see Note 10 to the financial statements and Section 8 of the chapter on the description of the corporation's business in the 
2023 periodic report. 

(2)  Free cash flow is a financial measure that is not based on generally accepted accounting principles. Free cash flow is defined 
as  cash  arising  from  current  operations  minus  cash  for  the  purchase  /  sale  of  PP&E,  and  starting  in  2018,  with  the 
implementation of IFRS 16, payments for leases are also deducted. Bezeq presents free cash flow as an additional measure to 
evaluate the business results and cash flows since, in Bezeq's opinion, free cash flow is an important liquidity measure that 
reflects the cash that the Company derives from its current operations after investing cash in infrastructure and PP&E and 
other intangible assets.  For this  matter, see  Section 8 of the chapter  describing the  corporation's business  in the periodic 
report for 2023. 

(3)  Inactive subscribers are subscribers whose Bezeq lines have been physically disconnected (excluding a subscriber who has not 

paid his debt to Bezeq on time in the first three months (approximately) of collection proceedings). 

(4)  Calculated according to the average of subscribers for the period. For this matter see also Section 8 of the chapter on the 

description of the corporation's business in the 2023 periodic report. 

(5)  In plans where there is a range of speeds, the maximum speed in the plan is taken into account. 
(6)  Number (gross) of telephony subscribers who abandoned Bezeq Fixed Lines during the period divided by the average number 
of telephony subscribers registered in the period. See also Section 8 of the chapter on the description of the corporation's 
business in the 2023 periodic report. 

(7)  Total  number  of  Internet  subscribers  including  retail  and  wholesale  subscribers.  Retail  –  the  Company’s  direct  Internet 

subscribers. Wholesale - Internet subscribers through wholesale service to other communication providers. 

(8)  In the fourth quarter of 2023, there was a certain decrease in the rate of connecting retail subscribers to the Company's fiber 
network due to a slowdown in contractor activity due to a temporary dispute with the employees’ representatives and due to 
the Iron Swords War (see Section 1.7.9). 

(9)  Revenue from retail Internet services divided by the average number of retail customers in the period. For this matter, see 
also Section 8 of the chapter on the description of the corporation's business in the 2023 periodic report. Starting with the 
second quarter of 2022, the figure also includes revenue from Internet access service (ISP). 

(10) As of the publication date of the report, fiber optic network deployment  - about 2.16 million households are available for 

connection, of which about 619K subscribers are connected to the fiber network (of which 394K retail and 222K wholesale). 

16 

 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.5.4.2 

Pelephone 

Financial data ( NIS  millions) 

2023 

2022 

Q4/ 
2023 

Q3/ 
2023 

Q2/ 
2023 

Q1/ 
2023 

Q4/ 
2022 

Q3/ 
2022 

Q2/ 
2022 

Q1/ 
2022 

Revenue from services 

Of which is revenue from 
interconnect (6) 

Revenue from service net of 
interconnect interconnectivity (6) 

Revenue from the sale of end 
equipment 

1,756 

1,791 

409 

450 

452 

445 

441 

467 

446 

437 

371 

427 

79 

79 

102 

111 

102 

106 

106 

113 

1,385 

1,364 

330 

371 

350 

334 

339 

361 

340 

324 

592 

608 

153 

135 

133 

171 

151 

141 

153 

163 

Total revenue 

2,348 

2,399 

562 

585 

585 

616 

592 

608 

599 

600 

Total revenue net of interconnect 
(6) 

Operating profit 

Depreciation and amortization 

Operating profit before 
depreciation and amortization 
(EBITDA) (1) 

Net profit 

Cash flow from operating activities 

Payments for investments in 
property, plant and equipment, 
intangible assets and other 
investments, net 

Lease payments 

Free cash flow (1) 

Operating data 

Number of postpaid subscribers for 
the end of the period (thousands) 
(2) 

Number of prepaid subscribers for 
the end of the period (thousands) 
(2) 

Number of subscribers for the end 
of the period (thousands) (2) 

Of which are subscribers in 5G plans 
(thousands) (2) 

Average monthly revenue per 
subscriber (NIS) (ARPU) (3) (5) 

Average monthly  revenue per 
subscriber net of interconnect (NIS) 
(ARPU) (6) 

Subscriber churn rate (Churn Rate) 
(4) 

1,977 

1,972 

483 

506 

483 

505 

490 

502 

493 

487 

196 

549 

193 

532 

37 

59 

49 

138 

143 

135 

151 

133 

17 

60 

52 

64 

135 

139 

136 

122 

745 

725 

175 

202 

184 

184 

152 

199 

188 

186 

159 

713 

165 

874 

26 

48 

240 

242 

41 

98 

44 

13 

50 

46 

56 

133 

149 

203 

244 

278 

310 

295 

90 

81 

82 

57 

0 

157 

66 

72 

270 

133 

228 

351 

94 

56 

57 

49 

104 

(33 )

70 

6 

62 

87 

58 

(12 )

47 

61 

131 

145 

2,202 

2,149 

2,202  2,187  2,166  2,159  2,149  2,137  2,122  2,093 

416 

431 

416 

431 

427 

426 

431 

538 

514 

490 

2,618 

2,580 

2,618  2,618  2,593  2,585  2,580  2,675  2,636  2,583 

1,034 

784 

1,034 

961 

898 

834 

784 

738 

677 

605 

56 

57 

52 

57 

58 

57 

57 

58 

57 

57 

44 

 43 

42 

47 

45 

43 

 44  

 45 

 43 

 42 

24.5% 

24.1% 

5.9% 

6.0% 

5.9% 

6.7% 

6.1% 

5.7% 

5.5% 

6.8% 

(1)  For the definition of operating profit before depreciation and amortization (EBITDA) and free cash flow, see Notes (1) and (2) 

in the Bezeq Fixed Lines table.  

(2)  The subscriber data include Pelephone subscribers (net of other operators’ subscribers hosted on Pelephone’s network, and 
net of IoT subscribers) and do not include subscribers connected to Pelephone’s service for six months or more but are inactive. 
Inactive subscribers are subscribers who in the last six months have not received at least one call, did not make at least one 
call  /  message  or  did  not  perform  a  browsing  operation  or  did  not  pay  for  Pelephone’s  services.  Prepaid  subscribers  are 
included in the active subscriber base from the date of performing a charge and are deducted from the active subscriber base 
when no making outbound use for six months or more. It should be noted that a customer may have more than one subscriber 
("line").  The  number  of  subscribers  includes  subscribers  who  consume  various  services  (such  as  data  for  in-vehicle  media 

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

systems), the average revenue from which is significantly lower than the rest of the subscribers. As of the publication date of 
the report, Pelephone has approximately 1.075 million subscribers to 5G plans. 

(3)  The average monthly revenue per subscriber (postpaid and prepaid). The index is calculated by dividing the average monthly 
consolidated total revenue including cellular services, from both Pelephone’s subscribers and other communication operators, 
including revenue received from cellular operators using Pelephone’s network, repair service and extended warranty in the 
period by the average active subscriber base in that same period. See also section 8 of the chapter on the description of the 
corporation's business in the 2023 periodic report. 

(4)  The subscriber churn rate is calculated according to the ratio of the subscribers who disconnected from Pelephone services 
and the subscribers who became inactive during the period to the average of active subscribers during the period. See also 
section 8 of the chapter on the description of the corporation's business in the 2023 periodic report. 

(5)  In the examination carried out by Pelephone of the register of prepaid subscribers during the Q4/2022, it was found that about 
96k  subscribers  were  included  in  the  register  of  subscribers  even  though  they  did  not  meet  the  definition  of  an  active 
subscriber.  Accordingly,  Bezeq  deducted  these  subscriptions  in  a  one-time  manner.  The  subtraction  of  subscribers  as 
mentioned led to an increase of about NIS 2 in ARPU for Q4 and no change in the subscriber churn rate in this quarter. 
(6)  Average monthly revenue per subscriber (ARPU) excluding revenue from interconnect - the reform to change the interconnect 
rates regime that will gradually apply from June 2023 until June 2025 is expected to lead to a decrease in interconnect revenues 
and a decrease in ARPU, which is why Pelephone chose to present the average monthly revenue per subscriber (ARPU) minus 
the component of revenue from interconnect, all in addition to the full ARPU. 

1.5.4.3 

Bezeq International  

Financial data ( NIS  millions) 

2023 

2022 

Q4/ 
2023 

Q3/ 
2023 

Q2/ 
2023 

Q1/ 
2023 

Q4/ 
2022 

Q3/ 
2022 

Q2/ 
2022 

Q1/ 
2022 

Revenue 

1,212 

1,239 

304 

303 

293 

312 

319 

311 

302 

307 

Operating profit (loss) 

39 

(30 )

(11 )

137 

134 

45 

20 

29 

16 

33 

14 

30 

(60 )

35 

17 

32 

17 

29 

(4 )

38 

Depreciation and amortization (NIS 
millions) 

Operating profit (loss) before 
depreciation and amortization (EBITDA) 
(1) 

Net profit (loss) 

Cash flow from operating activities 

Payments for investments in property, 
plant and equipment and intangible 
assets and other investments, net (2) 

Lease payments 

Free cash flow (1) 

Operating data 

176 

104 

34 

49 

49 

44 

(25 )

49 

46 

34 

29 

157 

(32 )

(14 )

210 

45 

17 

36 

13 

57 

13 

19 

(58 )

56 

16 

5 

15 

37 

(5 )

112 

93 

38 

26 

93 

36 

81 

37 

26 

20 

10 

17 

23 

27 

26 

10 

(2 )

9 

1 

9 

28 

10 

(1 )

9 

30 

9 

(27 )

9 

1 

9 

77 

Subscriber churn rate (3) 

45.6% 

46.5% 

9.0% 

11.0
 % 

10.0
 % 

14.7
 % 

15.0
 % 

12.4
 % 

12.9
 % 

7.3% 

(1)  For the definition of operating profit before depreciation and amortization (EBITDA) and free cash flow, see Notes (1) and 

(2) in the Bezeq Fixed Lines table. 

(2)  The section also includes investments in long-term assets. 
(3)  Number  of  Internet  subscribers  who  left  Bezeq  International  during  the  period  is  an  average  of  the  average 
Internet subscribers registered during the period. See also  Section 8 of the chapter on the description of the 
corporation's business in the periodic report for 2023. 

18 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.5.4.4 

Yes 

Financial data ( NIS  millions) 

2023 

2022 

Q4/ 
2023 

Q3/ 
2023 

Q2/ 
2023 

Q1/ 
2023 

Q4/ 
2022 

Q3/ 
2022 

Q2/ 
2022 

Q1/ 
2022 

Revenue 

Operating profit (loss) 

Depreciation, amortization, and 
ongoing impairment 

Operating profit before depreciation, 
amortization and ongoing impairment 
(EBITDA) (1) 

Net profit (loss) 

Cash flow from operating activities 

Payments for investments in property, 
plant and equipment and intangible 
assets and other investments, net 

Lease payments 

Free cash flow (1) 

Operating data 

Number of TV subscribers (thousands) 
(2) 

Of which are IP subscribers (3) 

1,309 

1,277 

316 

328 

336 

329 

330 

315 

316 

316 

94 

8 

166 

199 

33 

29 

35 

41 

26 

46 

0 

0 

0 

50 

57 

46 

(2 )

46 

10 

50 

260 

207 

62 

76 

72 

50 

57 

46 

44 

60 

102 

215 

13 

186 

27 

26 

40 

66 

30 

31 

5 

92 

1 

56 

0 

9 

2 

43 

10 

78 

179 

178 

30 

59 

60 

30 

44 

39 

49 

46 

25 

11 

25 

(17 )

6 

(10 )

7 

0 

6 

(35 )

6 

56 

7 

5 

6 

6 

(36 )

(12 )

6 

26 

574 

579 

574 

576 

579 

580 

579 

575 

567 

564 

392 

329 

392 

377 

364 

348 

329 

307 

280 

253 

Of which are STING subscribers 

120 

104 

120 

116 

111 

108 

104 

101 

94 

89 

Average monthly revenue per 
subscriber (ARPU) (NIS) (4) 

Subscriber churn rate (5) 

Number of subscribers connected to 
the fiber network (thousands) (6) 

182 

183 

175 

182 

185 

185 

181 

182 

184 

186 

13.8% 

12.8% 

3.1% 

3.9% 

3.3% 

3.5% 

3.0% 

3.2% 

2.9% 

3.7% 

37 

7 

37 

29 

21 

14 

7 

2 

(1)  For the definition of operating profit before depreciation and amortization (EBITDA) and free cash flow, see notes (1) and 

(2) in the Bezeq Fixed Lines table. 

(2)  TV subscriber - one household or a small business customer. In the case of a business customer who owns more than a 
certain number of decoders (such as a hotel or a gym), the number of subscribers is adjusted. The number of non-small 
business customers is usually calculated by dividing the total payment received from all non-small business customers by 
the average revenue per small business customer, which is determined once per period.  

(3)  The number of Yes subscribers using Yes+ and STING services transmitted via the Internet (as stated in Sections 5.2.2.1 and 
5.2.2.2 of the chapter describing the corporation's business in the periodic report for 2023). As of the date of publication of 
the report, is about 408K customers, which constitute approximately 71% of all the TV subscribers of Yes. The number of IP 
subscirbers and aforementioned rate also include subscribers who use satellite services in parallel. 

(4)  The average monthly revenue per TV subscriber is calculated by dividing the total Yes revenue (excluding revenue from the 
sale of content to external broadcasters) by the average number of customers in the period. See also Section 8 of the chapter 
on the description of the corporation's business in the 2023 periodic report. 

(5)  The number of DBS  subscribers  who churned from Yes during the period  divided  by the average number of  subscribers 
registered  in  the  period.  See  also  Section 8  of  the  chapter  on  the  description  of  the  corporation's  business  in  the  2023 
periodic report. 

(6)  The number of subscribers connected to the fiber network as of the date of publication of the report is about 44K. 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.6. 

Forecast and short-term ambitions in relation to the Bezeq Group 

1.6.1. 

The following is the Group's forecast for 2024 based on the information currently known 
to the Bezeq Group:  

a.  Adjusted net profit7 for shareholders is expected to be NIS 1.25 billion. 

b.  Adjusted EBITDA8 It is expected to be NIS 3.8 billion. 

c.  CAPEX9 It is expected to be NIS 1.9-1.8 billion. 

Bezeq will report, as required, deviations of ±10% or more from the data specified in the 
forecasts above. 

d.  The scope of the Company's fiber network deployment - reaching approximately 2.5 

million households. 

e.  Financial stability - maintaining high credit rating in the AA group. 

1.6.2. 

Medium-term ambitions 

a.  Adjusted EBITDA - average growth per year in terms of CAGR of about 1.5%-2%, with 

an adjusted EBITDA rate from revenues in the range of 42%-44%. 

b.  CAPEX - decrease to the range of 16%-18% in relation to CAPEX/Sales. 

c.  Adj. EBITDA minus CAPEX - improvement of approximately NIS 400-500 million. 

d.  Free cash flow10 – average annual growth (in CAGR terms) of approximately 7%-9%. 

e.  Use of the Company's fiber network - reaching infrastructure take-up of about 40%. 

f.  Dividend policy - Bezeq will strive to increase the dividend in the future, subject to 

maintaining Bezeq's credit rating in the AA group. 

g.  Financial stability - maintaining high credit rating in the AA group 

h.  ARPU - retail internet subscription - over NIS 140, cellular subscriber - NIS 45-50 (net 

of interconnect) and TV subscriber - approximately NIS 160. 

The Company does not undertake to update on a regular basis or otherwise its ambitions 
or  any  changes  that  will  apply  to  the  ambitions  or  actual  results  in  relation  to  the 
ambitions. 

1.6.3. 

Forward-looking information 

The  Company’s  forecasts  and  ambitions  detailed  in  this  section  are  forward-looking 
information, as defined in the Securities Law. The forecasts and ambitions are based on 
Bezeq's  assessments,  assumptions  and  expectation,  and  among  other  things,  on  the 
Group's  assessments  regarding  the  structure  of  competition  in  the  communications 
market  and  the  regulation  of  the  segment,  on  the  current  economic  situation  in  the 
economy, and accordingly, the on Group's ability to implement its plans for 2024 and in 
the medium-term, as applicable, taking into account the changes in business conditions, 
regulatory  decisions,  technological  changes,  developments  in  the  structure  of  the 
communications market, etc. or insofar as one or more of the risk factors listed in the 
2023. Also, the forecast can change depending on the duration, intensity, and scope of 
the Iron Swords War. 

With respect to Bezeq aspirations, given that it is a reference to the medium term and 
the difficulty of predicting Bezeq results and actual market performance in the medium 
term,  there  is  no  certainty  that  Bezeq  ambitions  will  fully  or  partially  materialize,  and 
deviation between Bezeq results and actual performance may be significant. Moreover, 

7 Adjusted net profit and adjusted EBITDA – net of the other operating expenses / revenue, net item, non-recurring losses / gains 
from impairment / appreciation, and expenses of the equity compensation plan. It should be noted that the adjusted EBITDA 
and the adjusted net profit for 2023 were approximately NIS 3.817 billion and approximately NIS 1.328 billion, respectively. 

8 See Footnote 10. 
9 CAPEX - Payments (gross) for investment in property, plant and equipment and intangible assets. The investments as part of 
the forecast for 2024 include a one-off increase for the benefit of two projects - the establishment of a group server farm and 
upgrading the capabilities of the core networks. It should be noted that the CAPEX for 2023 was approximately NIS 1.708 billion. 

10 For a definition of free cash flow, see Section 7.2.2. 

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ambitions, by nature, do not purport to be predictions and should not be read as such. 

1.7. 

General environment and the influence of external factors on the Group's activities 

The communications industry in the world and in the Israeli economy is characterized by a rapid pace 
of development, and frequent changes in terms of technology, in terms of the business structure of 
the industry and in terms of the regulation applied to it. The main trends and main characteristics of 
the  communications  market  in  recent  years,  which  have  a  significant  impact  on  the  Group's 
operations as a whole, will be described below. 

In view of the diversity in the areas of the Group's communications activities, regulatory and other 
developments may sometimes have a different effect (and even in opposite directions) on various 
areas of activity in the Group and on its risk factors (see Sections 0, 3.19, 4.14 and 5.18), that is - 
changes in regulation and other factors that adversely affect one area may have a positive effect on 
another area. In some cases, adverse effects on areas of activity may be partially offset against each 
other at the group level. 

1.7.1. 

Competition in the communications market 

In the communications market there is lively competition in most areas of the Group's 
activity: 

In the field of Internet services, there is lively competition against companies that own 
infrastructure, including fiber infrastructure for households, as well as against companies 
that offer services through the wholesale market (see Section 1.7.5 and Section 2.16.4). 
In  addition,  the  expansion  of  regional  competition  is  evident  in  the  light  of  giving  the 
possibility to those who do not have a general license to provide fiber Internet services 
through a broadband infrastructure, either independently or through the use of Bezeq's 
passive infrastructures. 

In the field of cellular telephony, the multitude of competitors results in lively competition 
that  results  in  low  prices  and  increased  customer  mobility.  In  the  field  of  landline 
telephony, competition, including from the cellular companies, leads to a decrease in the 
consumption of landline telephony minutes as well as to the churn in landline telephony 
services  (including  an  increasing  number  of  customers  without  a  landline  home  line). 
These phenomena damage the results of the Group. 

In  the  field  of  television  services,  the  increase  in  competition  is  evident  through  the 
transmission of television content (VOD services and linear channels) over the Internet 
(OTT), including by foreign providers such as Netflix, which are not subject to regulatory 
oversight  and  the  same  obligations  as  those  of  multi-channel  public  broadcasting 
providers, as well as reception of "Idan+" channels. 

In  order  to  reduce  the  damage  resulting  from  the  aforementioned,  Bezeq  Group 
companies  take  streamlining  measures  as  well  as  steps  to  improve  the  services  they 
provide and differentiate them from the competition. 

1.7.2. 

Communication groups in the Israeli market 

The  market  is  characterized  by  competition  between  communications  groups  (Bezeq 
Group, Hot Group, Cellcom Group (which includes Golan Telecom, which operates in the 
cellular segment), and Partner Group ,operating simultaneously in several  segments of 
the communications market (landline and mobile telephony, landline and mobile Internet 
services, multi-channel television and international calls)11. 

Cellcom and Hot  own together with the Israel Infrastructure Fund (23% each) and the 
Electric  Company  (30%)  in  IBC,  which  deploys  optical  fiber  infrastructure  and  mainly 
provides services to communication providers (CARRIER'S CARRIER). The communication 
groups market various communication service packages of each group's corporations, so 
that it is possible to offer the customer a comprehensive solution that eliminates the need 
to  contract  simultaneously  with  several  different  suppliers,  as  well  as  to  offer  the 
customer attractive rates for the purchase of each service separately (in some cases with 
a  "cross  subsidy"  between  the  components  included  in  the  basket).  Additionally,  BSA 
wholesale  service  (See  Section  2.16.4.2)  also  allows  operators  who  do  not  own 

11 

In this regard, a "group" is characterized by a close relationship that results from the identicality of shareholders, although 
in some groups there is a corporate, accounting or marketing separation between the entities belonging to the group.  
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infrastructure, including operators who are not part of a telecommunications group, to 
offer a package of unified Internet services to their customers (including infrastructure). 
As of April 3, 2022, Bezeq, as an infrastructure owner, and later also Hot, is allowed to 
provide  private  service  subscribers  Internet  access  service  themselves,  together  with 
their  infrastructure  service,  after  the  obligation  to  separate  infrastructure  service  and 
Internet access service was lifted. 

Competitors that are not part of a telecommunications group also operate in the market 
(such as XFONE and MVNO operators in the cellular segment, including Internet providers 
that  provide  service  within  the  wholesale  market.  Also,  as  mentioned,  the  number  of 
small service providers (that are not  part  of a  group) that provide broadband Internet 
services, including infrastructure, has expanded (See Section 1.7.4). 

As  of  the  date  of  the  report,  Bezeq  Group  is  subject  to  stricter  restrictions  on  the 
marketing of service packages than the other communication groups. 

1.7.3. 

Bezeq Group's activity as a communications group 

As  of  the  date  of  the  report,  the  Group  is  subject  to  regulatory  restrictions  related  to 
creating  collaborations  between  the  Group's  companies,  which  include  a  structural 
separation obligation between Bezeq and its subsidiaries, as well as restrictions on shared 
marketing and marketing shared service baskets which include the services of Bezeq and 
its subsidiaries. 

Against  the  background  of  the  challenges  the  Group  faces  and  the  needs  in  the 
communication market environment, in parallel with Bezeq’s activity for the elimination 
of  structural  separation,  a  comprehensive  strategic  plan  for  the  Group  as  a 
communication group is implemented within the complex regulatory constraints imposed 
on the Group (see Section1.7.11).  

1.7.3.1 

Regulatory oversight - structural separation obligation 

In accordance with the Communication Law, the Minister is authorized to 
order  accounting  separation  between  different  services  provided  by  the 
same  group  /  company,  as  well  as  the  power  to  require  the  existence  of 
separate  corporations  for  the  purpose  of  providing  different  services, 
including separation between licensing services and subscriber services, and 
provisions on the implementation of the separation.  

license  stipulates  that  Bezeq  must  maintain  structural 
Bezeq's  NIO 
separation  between  itself  and  its  subsidiaries12.  In  this  context,  full 
separation  between  Bezeq's  management  and  the  managements  of  the 
subsidiaries is required, including everything related to the business system, 
the financial system and the marketing system, and Bezeq is prohibited from 
transferring commercial information to a subsidiary (subject to exceptions). 

The  limitations  of  structural  separation  place  the  Group  in  a  position  of 
competitive disadvantage which  exacerbates over time vis-à-vis the other 
communication  groups  which  are  not  subject  to  restrictions  of  a  similar 
extent.  In  addition,  the  limitations  of  structural  separation  cause  high 
overheads. 

1.7.3.2 

Cancellation of structural separation 

Bezeq’s  position  is  that  it  should  be  cancelled.  It  should  be  noted  that 
following the report of an interdepartmental team for the examination of 
the updating of the structural separation obligations in the Bezeq and Hot 
its 
groups,  which  was  established  by  the  State  and  submitted 
recommendations  to  the  Minister  of  Communications 
in  2020,  the 
separation  that  existed  between  the  infrastructure  service  and  the  ISP 
service  was  cancelled  (for  the  aforementioned  elimination  of  separation, 
see  Section  1.7.5.1)  Bezeq  continues  to  work  with  the  Ministry  of 
Communications for the complete cancellation of the structural separation 
obligation applied to it, and in this framework it reached agreements with 

12   Pelephone, Bezeq International, DBS and Bezeq Online. 

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the employees’ representatives regarding the promotion of the treatment 
of the cancellation of structural separation as detailed in Section 2.9.6. 

1.7.3.3 

Marketing  a  shared  basket  of  services  with  a  subsidiary  and  between 
subsidiaries 

Bezeq was allowed to offer subscribers shared services ("Bundles") with the 
subsidiaries,  subject  to  approval  by  the  Ministry  of  Communications  and 
subject to a number of conditions set forth in the NIO license, including: 

▪ 

The baskets will be "detachable", that is - each service included in them 
will be offered separately outside the framework of a basket of services, 
under the same conditions. 

▪  At  the  time  of  submitting  the  application  for  approval  of  the  basket, 
there  is  a  group  of  services  in  a  similar  format  that  is  marketed  to  a 
subscriber as a package by a licensee who is not a Bezeq subsidiary, or 
there is a group that includes licensees who provide a private subscriber 
with all services included in the shared basket of services. 

▪ 

The  marketing  of  shared  service  baskets  by  the  subsidiaries,  which 
include  Bezeq  Services,  is  also  subject,  according  to their  licenses,  to 
similar  restrictions, 
including  the  requirement  of  "detachability" 
(except for a basket marketed by a subsidiary that includes only Bezeq's 
broadband access service for Internet providers). 

These  restrictions,  and  in  particular  the  "detachability"  obligation,  which 
severely 
limits  the  Group's  ability  to  provide  discounts  on  various 
components  in  the  basket  of  services,  place  the  Group  in  an  inferior 
competitive position relative to competing communications groups that are 
not subject to similar restrictions on the marketing of bundles (except, to 
the best of the Company's knowledge, Hot Group's diminishing limitations). 

Following the amendment of the terms of the merger of the Company and 
Yes in accordance with the decision of April 12, 2021 of the Commissioner 
of  Competition,  Yes  was  allowed  to  sell  communication  packages  that 
include internet  services and television services without  the obligation to 
sell  the  television  services  at  a  detachable  price  that  will  be  uniform  for 
package buyers and those who are not Purchasers of packages - see Section 
2.16.9.3. 

The  Company’s  baskets  with  Yes  -  in  recent  years,  the  Ministry  rejected 
various requests from Bezeq to provide its Internet services together with 
the television services of the subsidiary Yes (including over the Internet). 

1.7.3.4 

Additional  restrictions  on  collaboration  and  preference  between  group 
companies  

There  are  additional  restrictions  on  cooperation  between  Bezeq  and  the 
Group companies both by virtue of competition law and conditions set by 
the  Competition  Commissioner  for  mergers  between  Bezeq  and  Group 
companies, which prohibit discrimination in favor of the Group companies 
in the provision of certain services (see Section 9.2.16), and by virtue of the 
provisions of Bezeq's license, which require it to provide its services equally. 
For additional restrictions see also Section5.14.2.  

Removal of the restrictions on structural separation and other restrictions 
that  apply  to  collaborations  between  the  Group  companies  as  detailed 
above, insofar as they are removed, may create different opportunities for 
the  Group  to  exploit  such  synergies  or  facilitate  the  exploitation  of  such 
synergies. 

1.7.4. 

Changing the regulatory structure - Amendment 76 to the Communications Law 

On July 4, 2022, Amendment 76 to the Communications Law ("Amendment to the Law") 
was published. In accordance with the amendment to the law, which largely entered into 
force on October 2, 2022, the structure of the existing regulation in the field of Bezeq was 
changed, among other things, in such a way that the obligation to obtain a specific license 

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in advance as a condition for the provision of Bezeq service, which was the main tool for 
regulating the provision of communication services in Israel, was abolished, and instead 
the default for the said regulation is through registration in the registry. In this way, the 
Amendment to the Law allows any entity interested in providing a Bezeq service to know 
in  advance  what  the  conditions  are  for  its  activity  and  to  start  operating  without 
requesting  and  without  obtaining  a  license.  The  registry  is  managed  by  the  Director 
General of the Ministry of Communications. The Amendment to the Law established cases 
in which the obligation to obtain a license will still apply when it comes to (a) a Bezeq 
service  provided  through  the  mobile  radio-telephone  system;  (b)  a  Bezeq  service 
provided  through  the  Bezeq  network  whose  number  of  users  or  subscribers  or  the 
number of network terminal points or end points exceeds the number determined by the 
Minister,  with  the  exception  of  Bezeq  service  provided  through  the  aforementioned 
Bezeq network by another licensed provider (the regulations for this matter stipulate that 
a license will be required from those who provide Bezeq service through a landline access 
network13 with at least 100,000 users or through a fixed access network whose number 
of  subscribers  who  receive  Internet  access  service  at  least  500,000);  (c)  Bezeq  service 
provided through a Bezeq network in which one of the following occurs: (1) It includes a 
landline  or  mobile  ground  station  in  Israel  for  communication  with  a  satellite;  (2)  It 
includes a satellite located at the location or using the registered route In the name of the 
State of Israel in the International Telecom Union (ITU); (d) Carrying out a Bezeq operation 
in a landline lightning facility connecting a point in Israel and a point outside Israel (with 
the  exception  of  Judea  and  Samaria).  Also,  a  local  authority  (including  a  municipal 
company  or  a  municipal  subsidiary)  will  not  provide  Bezeq  service  whether  it  requires 
registration in the registry or a license, unless it holds a license and in accordance with 
the terms of the license; The Minister has the authority to determine, with the approval 
of  the  Knesset's  Economic  Committee,  additional  Bezeq  services  that  will  require  a 
license,  as  well  as  additional  service  providers  that  will  be  subject  to  the  licensing 
obligation. Also, the Minister may, due to one or more of the considerations listed above, 
order a Bezeq service provider registered in the registry, that the provision of a  Bezeq 
service thereby will be subject to obtaining a license for every lightning service it provides 
or for a Bezeq service of a type it decides. 

"Bezeq  service"  is  defined  in  an  amendment  to  the  law  as  a  service  provided  to  the 
general public or a part of it through the Bezeq network, which is one of the following: 
data transmission service, Internet access service, telephony service, other service listed 
in the first supplement to the law (as of the date of the report, there is no detail in the 
supplement to the law). 

Further  to  this,  on  October  2,  2022,  regulations  were  published  implementing  the 
regulation format according to which  many of the entities that provide Bezeq services 
today  will  be  transferred  from  regulation  through  a  license  to  regulation  through 
registration in a dedicated registry and in accordance with the regulations. In accordance 
with the provisions of the regulations, they will not apply to certain licensees, including 
the  Company  and  its  subsidiaries  Pelephone,  Bezeq  International,  and  Yes,  except  in 
relation to the ISP service provided by Yes. In parallel, as it appears from the explanation 
of  the  regulations,  the  Ministry  of  Communications  intends  to  map  the  licenses  and 
actively cancel the instructions in the licenses that are regulated in the regulations, as 
well as to examine the justifications for determining different arrangements within the 
licenses.  Regarding  the  obligation  to  disconnect  dormant  subscribers  stipulated  in  the 
regulations, see Section 1.7.7.7. 

On March 29, 2023, a decision was made by the Ministry of Communications (following 
the hearing on November 22, 2022) allowing all authorized providers to use the passive 
infrastructure reciprocally, including the Company's physical infrastructure not only in the 
incentive areas, and this subject to compliance with security instructions, in accordance 
with the instructions as amended in the appendix relevant to the case the service and the 
instruction of the General Manager. 

Also,  as  of  the  date  of  publication  of  the  report,  a  decision  was  not  yet  made  on  the 
hearing "Update the Wholesale Market Regulations and the Service Files - Adaptation to 

13  Access network for this matter - Bezeq devices used to link between a switchboard and a network END point, using a wired 

infrastructure, a wireless infrastructure or a combination of both. 

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the  New  Regulation"  that  the  Ministry  published  on  December  8,  2023,  according  to 
which  the  Ministry  is  considering  amending  the  service  files  of  the  wholesale  services 
(BSA+Telephony;  Mutual  use  of  passive  infrastructures;  Physical  infrastructure  service 
and  Appendix  No.  2  "Documentation  of  Passive  Infrastructure  Works")  so  that  they 
conform to the language of the law after Amendment 76 enters into force, and to the 
language of the new communications regulations that were established pursuant to it. 
According  to  the  hearing,  the  changes  being  considered  are,  among  other  things,  a 
derivative  of  the  wholesale  market  regulations  and  the  elimination  of  distinctions 
according to different types of licenses as well as a change of terms. 

A draft amendment to the usage regulations was also published in December 2022, which 
also  included  adjustments  following  Amendment  76  to  the  law.  As  of  the  date  of  the 
report, the regulations have not yet been amended. 

The effect of the amendment of the Communications Law and regulations on the Group 
companies depends, among other things, on the manner in which they are implemented 
by the Ministry of Communications, including the amendment of the licenses of existing 
license holders. 

Regarding the use of passive infrastructures in a wholesale service, see Section 2.16.4. 

1.7.5. 

Key developments during the report period (including years preceding the report period) 

1.7.5.1 

Unified Internet service 

As  of  April  3,  2022,  Bezeq  markets  and  provides  a  unified  Internet, 
infrastructure,  and  Internet  access  service,  both  on  a  traditional  network 
(copper) and on an advanced network (fiber). From this date, Bezeq is not 
allowed  to  market  a  basket  ("bundle")  that  includes  a  private  Internet 
infrastructure  service  with  Bezeq  International's  or  another  licensee's 
access service. 

The  implementation  of  the  move  and  Bezeq's  ability  to  offer  a  unified 
service have a positive effect on its business. Regarding Bezeq International, 
the  move  resulted  in  a  significant  reduction  in  the  status  of  its  Internet 
customers  and  the  structural  change  described  in  Section  1.1.6,  so  that 
Bezeq  International  does  not  market  Internet  services  to  customers  in  a 
private service, and starting in the second half of 2022, Yes is an authorized 
provider for providing access services to the Internet, and provides Internet 
services  over  fiber  (an  infrastructure  component  through  a  wholesale 
service). The total impact on the Group in the coming years is expected to 
be positive. 

1.7.5.2 

Many small operators 

Following changes in regulation, the number of small service providers that 
provide broadband Internet services including infrastructure has expanded, 
including through eliminating the need for licenses (except for exceptions) 
and moving to the provision of communication services (including but not 
limited to broadband infrastructure) through registration in the registry only 
and  subject  to  the  permit  regulations  by  virtue  of  Amendment  76  to  the 
Communications  Law  (see  Section  1.7.4).  Authorized  providers  as 
mentioned are not required to go through a license issuance procedure in 
order to provide Bezeq service. Also, the conditions that licensed providers 
are subject to according to the permit regulations. 

1.7.6. 

Wholesale market  

Starting from 2015, a model of "wholesale market" has been implemented in Israel, in 
which the owners of the nationwide landline access infrastructures in Israel (Bezeq and 
Hot)  have  been  required  to  allow  other  communications  operators  to  use  their 
infrastructures, at prices not to exceed the maximum rates set in the regulations.  

In this context, the Ministry of Communications established "service portfolios" for the 
various services, in which  the format of the provision of services by the infrastructure 
companies was determined:  

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1.7.6.1 

Wholesale BSA service  

This  service  allows  Internet  service  providers  who  do  not  own  an 
infrastructure to offer their customers a full Internet service that includes 
both an Internet connection service (of the service provider) and an Internet 
infrastructure  service  (based  on  the  Bezeq  or  Hot  network  -  both  on  the 
traditional  network  and  on  the  fiber  network).  Since  the  launch  of  the 
service, hundreds of thousands of customers in Israel have moved to receive 
service through the aforementioned service providers. 

1.7.6.2 

Wholesale passive infrastructure use service 

This service allows providers to use Bezeq's passive infrastructure for the 
passage of communication cables and for certain providers to use dark fiber 
at the rates set in the regulations. For more, see Section 2.16.4. 

Bezeq  was  also  given  the  right  to  use  passive  infrastructures  of  other 
companies,  except  that  their  rates  (except  Hot)  are  not  set  in  the 
regulations. 

1.7.6.3 

Wholesale telephony service 

This service allows service providers who do not own infrastructure to offer 
their  customers  telephony  service  at  wholesale  rates  through  the  Bezeq 
network. Currently there are no customers in the service. For this matter, 
see Section 2.16.4.4.  

The regulatory determinations in relation to the wholesale market as well 
as its implementation and development during the reporting period have an 
impact on a significant part of the Group's activities. For more details about 
the wholesale market services and their regulation, see section2.16.4. 

1.7.7. 

Additional  regulatory  aspects  that are  relevant  to  the  whole  Group  or  to  a  number  of 
companies in it 

1.7.7.1 

Interconnectivity rates 

interconnectivity 

The  Group's  communications  companies  (Bezeq,  Pelephone  and  Bezeq 
International)  pay 
fees  to  other  communications 
operators for calls that end in the networks of those operators and some 
(Bezeq and Pelephone) receive interconnectivity fee payments for calls that 
ended in their networks and from international communication operators 
for  outgoing  and  incoming  calls  to  their  networks.  Interconnectivity  rates 
are  set  as  maximum  rates  by  the  regulator  in  the  interconnectivity 
regulations. Changes in interconnectivity rates have a offsetting effect at the 
Group level in light of their effect on Bezeq's expenses and revenue and the 
subsidiaries in this matter. 

On  June  28,  2022,  an  amendment  to  the  interconnect  regulations  was 
published so that the transfer of interconnection payments for telephone 
calls that end on the networks of mobile radio-telephone and NIO operators 
will be stopped, with a gradual reduction plan over three years as follows 
(in view of historical linking mechanisms, the actual rates as determined by 
regulations are higher): 

(1)  On  June  15,  2023:  for  a  call  ending  on  the  mobile  radio-telephone 
network, a maximum rate of 4 Agorot per minute, and for a call ending 
on  the  NIO  network  0.7  Agorot  per  minute,  and  for  an  outgoing 
international call - depending on the network from which it originated 
(NIO or mobile radio-telephone). 

(2)  On June 15, 2024: for a call that ends on the mobile radio-telephone 
network, a maximum rate of 2 Agorot per minute, and for a call that 
ends on the Mapa network - 0.4 Agorot per minute, and for an outgoing 
international call - depending on the network from which it originated 
(NIO or mobile radio-telephone). 

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(3)  On June 15, 2025, an accompanying arrangement will enter into force 
according  to  which  each  communication  operator  will  bear  its  own 
costs and there will no longer be a transfer of payments between NIO 
and mobile radio-telephone licensees for a mutual connection service 
with regard to call minutes, regarding calls ending in the networks of 
mobile radio-telephone operators, and on Bill and Keep networks, and 
an  international  operator  will  not  pay  for  the  transmission  of  an 
outgoing international call. 

For  incoming  international  calls  to  the  NIO  or  mobile  radio-telephone 
network,  the  payment  to  be  paid  by  an  international  operator  will  be  as 
required by NIO  or mobile radio-telephone respectively (effective from July 
28, 2022). At this point, it is not different from the interconnect rate regime 
in the SMS service 

1.7.7.2 

Limiting the exit fee that a licensee may charge from a subscriber 

In  accordance  with  the  provisions  of  the  Communications  Law,  NIO, 
international operator and broadcasting licensees (including  Bezeq, Bezeq 
International and Yes) are not allowed to charge an exit fee for cancellation 
of contract by a subscriber whose average monthly bill is less than NIS 5,000, 
or deny him a benefit he would have received if he had not terminated the 
contract14.  Cellular  operators  (including  Pelephone)  -  are  not  allowed  to 
charge exit fees from customers who hold up to 100 telephone lines or link 
a contract for the receipt of cellular services to a contract for the purchase, 
rent or borrowing of end equipment ("disconnection"). 

1.7.7.3 

Call centers 

In  the  licenses  of  Bezeq,  Pelephone,  Bezeq  International,  and  Yes, 
instructions  were  set  regarding  the  obligation  to  route  calls  in  certain 
matters  to  a  professional  human  answer,  response  times,  as  well  as 
instructions  regarding  call  center  manning  hours,  recording  and 
documentation of calls, and reporting obligations, and this is further to the 
amendment  to  the  Consumer  Protection  Law  that  deals,  among  other 
things, with the time of waiting for a human answer. 

1.7.7.4 

Consumer legislation and privacy protection laws 

Changes in consumer legislation affect the activities of the Group companies 
on an ongoing basis. In recent years, various amendments to the Consumer 
Protection  Law  and  its  regulations  have  been  approved.  In  addition,  a 
variety of bills for additional amendments to the Consumer Protection Law 
have been brought before the Knesset, which may have an impact, among 
other things, on the terms of the Group's contracting and conduct with their 
subscribers. 

On January 1, 2023, the provisions of the Consumer Protection Law entered 
into force, which prohibit a trader or anyone on his behalf from making a 
marketing appeal to a consumer whose telephone number is registered in 
the database established by the Consumer Protection Authority in order to 
enter  into  a  transaction  (subject  to  exceptions  established  by  law).  In 
accordance  with  the  amendment,  telephone  numbers  of  consumers  who 
wish  to  limit  such  marketing  inquiries  to  them  will  be  recorded  in  the 
database.  The  provisions  of  the  law  may  create  a  limit  on  marketing 
activities and the degree of their effect will depend on the scope of joining 
the database. 

In addition, the activity of the Group companies is affected by the provisions 
of the Privacy Protection Law and its regulations regarding the management 
and  maintenance  of  databases  and  the  security  of  the  information 
contained therein. 

14   With regard to the operators' claim in the hearing held by the Ministry in connection with this directive, according to which discounts or 
benefits stipulated by conditions that the subscriber is required to comply with do not constitute a violation of the directive, the Ministry 
stated that it will examine whether the condition is true and relevant also when the subscriber remains a subscriber with the operator. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

1.7.7.5 

Enforcement and financial sanctions 

The  Communications  Law,  the  Economic  Competition  Law,  the  Securities 
Law, the Consumer Protection Law, the Law for Increasing the Enforcement 
of Labor Law, 5772-2011 and the Telegraph Order entitle the regulators to 
powers of enforcement, supervision and the imposition of significant tiered 
financial  sanctions  for  violations  of  the  said  laws  or  regulations  and 
provisions thereunder. 

In Amendment 76 to the Communications Law, the Director General of the 
Ministry of Communications was given the authority to impose a financial 
sanction  at  a  rate  of  up  to  10  times  the  basic  amount  stipulated  in  the 
Communications  Law  for  violating  a  license  provision  regarding  the 
obligation to deploy an advanced network or provide a service over it. 

For  financial  sanctions  imposed  by  the  Ministry  of  Communications 
regarding  wholesale  services,  see  Section  2.16.4.2  (Footnote  40)  for 
sanctions imposed. 

The Consumer Protection and Fair Trade Authority also makes use of the 
enforcement powers conferred on it by the Consumer Protection Act, and 
from time to time data demands are issued, investigations are conducted 
against the Group companies on suspicion of violating this law and fines are 
imposed. In April 2022, a financial sanction of NIS 6.9 million was imposed 
on Bezeq, for alleged violation of Article 2(a)(1) of the Consumer Protection 
Law,  claiming  that  Bezeq  did  not  supply  thousands  of  consumers  who 
purchased a browsing package of the type TOP 100 with this speed. On April 
2,  2023,  a  judgment  was  issued  in  the  appeal  filed  by  Bezeq  on  the 
imposition of the sanction confirming the agreement of the parties that the 
amount of the financial sanction will be a reduced amount of approximately 
NIS 3.4 million, and accordingly the Consumer Protection Authority returned 
to  Bezeq  a  total  of  approximately  NIS  3.7  million  (including  linkage  and 
interest differences). 

1.7.7.6 

The Centralization Law 

The Centralization Law enacted in 2013 establishes limitations in relation to 
extending  credit  to  business  groups,  separation  between  significant  real 
corporations  and  significant  financial  entities  (Bezeq  and  the  Group 
companies  are  defined  as  significant  real  corporations  according  to  the 
Centralization  Law)  and  consideration  of  economy-wide  centralization 
considerations in the allocation of rights  - limitations on the allocation of 
rights in essential infrastructure to "centralizing factor". For this matter, a 
list of areas that will be considered "essential infrastructure areas" has been 
defined,  including  activities  in  the  area  for  which  certain  communication 
licenses are required. Bezeq and the group companies are included in the 
list  published  by  the  Competition  Authority  and  are  considered  a 
"concentrated  entity".  The  law  may  have  negative  effects  on  the  group's 
ability  to  operate  in  new  areas  of  activity  and  even  on  its  activities  in  its 
existing areas of activity. 

1.7.7.7 

Inactive subscribers 

On  September  10,  2020,  the  Ministry  of  Communications  contacted  the 
telecommunications  operators  (including  Bezeq,  Pelephone  and  Bezeq 
International)  in  a  letter  in  which  it  raised  concerns  that  some  of  the 
subscribers to the operators' services are not using them and are not even 
aware of it. The Ministry recommended recommended to operators to act 
to notify and stop charging subscribers who do not use these services, and 
also requested periodic reports on the matter. It was also  stated that the 
Ministry will consider in the future whether to set binding provisions in the 
matter,  in  case  proactive  actions  will  not  lead  to  a  significant  reduction 
therein.  Regarding  the  handling  and  consequences  of  the  Ministry  of 
Communications' request to Bezeq International, see Section 4.4 and Note 
10.6 to the  2023 statements. On January 14, 2021, a  preliminary request 
was  also  sent  to  Yes  by  the  Cable  and  Satellite  Broadcasting  Council 

28 

 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

regarding "Demand for information about "dormant" subscribers as well as 
about services that subscribers pay for and do not use". In March 2021, Yes 
replied that due notice was given to its subscribers, and that it could not 
provide  the  requested  information  due  in  part  to  the  lack  of  established 
information  in  its hands, due  to  the  Council's  lack  of  authority  in at  least 
some  of  its  requests,  and  due  to  additional  difficulties  inherent  in  the 
Council's application. It should be noted that in the permit regulations that 
apply  to  the  Internet  access  services  of  Yes  (and  not  to  the  other  Group 
companies), there is an obligation to disconnect "dormant subscribers" from 
Internet access services (a subscriber who has not used an Internet access 
service for at least six consecutive months), except in relation to the service 
for a medium-large business subscriber as defined in the regulations. 

1.7.8. 

Restrictions on creating liens on the assets of the Group companies 

For the sake of convenience, the following are references to sections in the 2023 periodic 
report that relate to the restrictions that apply to the Group companies in the lien on their 
assets and the main restrictions:  

1.7.8.1 

1.7.8.2 

Regulatory  restrictions  -  The  Communications  Law,  the  Communications 
Order (applicable to Bezeq) and some of the communications licenses of the 
Group  companies  include  restrictions  on  the  granting  of  rights  to  third 
parties in the assets used to provide the essential service or  in the license 
assets15,  as  the  case  may  be,  including  the  need  to  obtain  regulatory 
approvals  to  create  liens  on  these  assets.  In  some  cases,  for  example 
Pelephone's  mobile  radio  telephone  license  and  Bezeq  International's 
unified license, there are exceptions that allow the creation of liens in favor 
of a banking corporation without the need for advance regulatory approval, 
provided  that  the  lien  agreement  includes  provisions  ensuring  that  the 
exercise of the lien by the banking corporation will not impair the provision 
of the services under the license. In addition, according to the provisions of 
the law and the media licenses, the license and the rights under it are not 
transferable,  and  cannot  be  encumbered  or  foreclosed  (subject  to 
exceptions). See also sections2.16.3.7, 3.14.2 and5.14.1.7.  

Restrictions under agreements- Bezeq undertook to certain financiers in an 
undertaking not to encumber its assets unless, at the same time, it creates 
in favor of those financing bodies a lien of the same type, rank and amount 
(negative lien), subject to certain exceptions. see also Note 13.3 to the 2023 
statements.  

1.7.9. 

State of War - "Iron Swords 

As of October 7, 2023, the State of Israel is in a state of war in the Gaza Strip, as well as in 
a state of limited hostilities in the northern border area. The state of war creates various 
effects on the Bezeq Group companies, which are reflected on the one hand in an increase 
in demand for some services, in Internet traffic and in the use of landline telephony, and 
on  the  other  hand  in  a  decrease  in  roaming  activity,  a  decrease  in  the  sale  of  cellular 
devices, and the removal/freezing of business lines in areas that are affected by the war. 
Also,  with  the  outbreak  of  the  war,  due  to  the  recruitment  of  employees  to  reserve 
service and a decrease in contractor activity, there was a slowdown in deployment and 
installation activity in the Bezeq network. Also, a number of regulatory moves were made 
as part of the State of Israel's handling of the state of war, including a law to postpone 
payment dates for those entitled and to ease phone call charges, including calls related 
to distance learning. It should be noted that some of the Group companies took their own 
initiative to ease the charges towards localities in the Gaza Envelope and on the northern 
border. 

The  Bezeq  Group  companies,  which  provide,  among  other  things,  essential 
communication services to private, business, and institutional customers, including the 
state  institutions, the security forces, and the health system, are prepared accordingly 

15 

 The assets needed to ensure the provision of services by the licensee.  
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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

and  respond  to  the  various  needs,  including  fault  solving,  increasing  vigilance  and 
preparedness in cyber systems, and assisting the community in various ways. Also, the 
Group companies regularly examine and follow closely the developments related to the 
war. 

At this stage, the effects of the war and its consequences as described above do not have 
a material impact on the activities of the Company and Bezeq Group and their business 
results. Also, the liquidity and financial situation of the Company and Bezeq Group allows 
them  to  function  well  during  the  war.  The  scope  and  duration  of  the  war  and  its 
consequences on the state of the Israeli economy, as well as on Bezeq Group companies, 
are unobservable and difficult to predict, and they depend, among other things, on the 
manner  and  scope  of  the  development  of  the  war  and  the  possibility  of  the  economy 
slipping into recession as a result. In this context, attention is also drawn to the relevant 
risk  factors  detailed  in  Chapter  A  (Description  of  the  Corporation's  Business)  of  the 
periodic report  for the year  2023  (Sections 2.20.11, 2.20.15, 3.19.2.9, 4.14.8, 5.18.1.2, 
5.18.1.4). 

Some  of  the  information  contained  in  this  section  is  forward-looking  information,  as 
defined in the Securities Law, based on estimates, assumptions, and expectations of the 
Company  and  Bezeq  Group  which  may  not  materialize,  or  materialize  in  a  materially 
different way than anticipated, depending, among other things, on the manner and scope 
of the development of the war and the state of the economy as a whole. 

1.7.10. 

Cyber defense management 

The Group companies implement a cyber protection policy that includes security systems 
to protect their infrastructures and systems which are designed to prevent and reduce 
the possibility of the companies' data being exploited by an outside party or an internal 
party maliciously or inadvertently, as well as the possibility of an outside party taking over 
and  managing  network  components  or  abusing 
information  on  the  company's 
infrastructure  and systems.  For  more  details  regarding  each  field  of  activity  and  cyber 
risks see Sections 2.20.12, 3.19.2.8, 4.14.7 and 5.18.3.9. 

Also,  on  May  12,  2022,  the  Bezeq,  Pelephone  and  Bezeq  International  licenses  were 
amended  with  an  amendment  regulating  the  issue  of  preparation  for  cyber  defense 
management. This amendment was replaced on December 26, 2022 by a director's order 
essentially identical to it. The principals of the amendment to the Directorate deal, among 
other  things,  with  the  protection  of  the  communication  network,  maintaining  the 
relevance and up-to-dateness of systems, the licensee's dealing with cyber incidents and 
situations in which the licensee is required to report and share information. 

1.7.11. 

Additional regulatory developments during the reporting period and the main 
restrictions that apply to the Group's areas of activit – for a description on such matters, 
see Sections 2.16, 3.14, 4.11 and 5.14.  

For a description of these matters see Sections 2.16, 3.14, 4.11 and 5.14. 

1.8. 

Bezeq Group business strategy 

Group vision  

Bezeq Group – the largest, leading telecommunications group in Israel, will lead and promote the 
digital revolution in Israel, through advanced infrastructure and services for the private and business 
segments, and strive for continuous improvement in its business results. 

Group strategy 

1.8.1. 

Strategic focus - focus on building infrastructure and growth engines 

A.  Accelerated deployment of fiber optics, including upgrading browsing speeds using 
fiber, and the transition to a unified Internet package will constitute a growth engine 
in Bezeq Fixed Lines. 

B.  Reduction  of  Bezeq 

Internet  activity,  and 
International's  private  segment 
transforming the ISP activity in Yes into a "triple" sales arm that combines fiber and 
television. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

C.  Pelephone will leverage the transition to 5G to increase revenue and ARPU. 

D.  Bezeq International will become a growth-focused ICT company. 

1.8.2. 

Focusing growth strategy by theaters 

A.  Communication,  information  and  content  services  for  households  -  investing  and 
focusing  efforts  on  growing  and  strengthening  the  competitive  position  in  the 
theater,  by  offering  as  wide  a  basket  of  services  as  possible  and  deepening  the 
penetration of households. 

B.  Business  communication  services  -  maintaining  and  strengthening  the  leading 
position in the theater through offering value-added to customers, based on quality 
service and advanced products. 

C.  Cellular  services  -  maintaining  and  strengthening  the  competitive  status,  while 

striving to increase revenues and improve profits. 

D. 

ICT  services  for  businesses  -  investment  in  building  capabilities  that  will  enable 
significant growth. 

1.8.3. 

Additional strategic moves 

The Group will work to locate investments in areas that are tangent and complementary 
to  the  Group's  activities  and  its  competitive  capabilities  (such  as  entering  the  field  of 
electricity supply as detailed in Section 1.9). Initiated investment and acquisition activity 
will enable shareholders to increase their return by entering areas of higher growth than 
that of the activity in the Group's traditional core areas. The diversification of the portfolio 
will allow for the diversification of risk, and the reduction of dependence on regulatory 
risks. 

Beyond the strategic  moves, the  Group strives to strengthen the foundations that will 
enable  continued  growth  in  the  medium  term  -  striving  for  operational  excellence 
through  expanding  the  digital  transformation,  streamlining  the  cost  base,  improving 
market  response  times  and  flexibility  for  changes,  and  striving  to  cancel  structural 
separation.  For  this  purpose,  concrete  multiyear  plans  have  been  determined  for 
implementation in the group companies, which include, among other things, targets for 
reducing expenses and investments. 

Optimal cash flow management – maximizing value to shareholders, while maintaining 
an AA Group credit rating - the Group aims to maintain high credit rating in the AA group 
while adjusting the debt repayment burden to self-generating cash flow and maintaining 
significant liquidity, while distributing dividends to shareholders. 

1.8.4. 

ESG 

In addition, the Bezeq Group strives to be one of the leading companies in the field of 
ESG. 

This section includes forward-looking information, within the meaning thereof under the 
Securities Law, including forecasts, targets, business strategy, assessments, aspirations 
and estimates, both regarding the activities of Bezeq and the companies held by it and 
the markets in which they operate, as well as regarding any other information relating to 
future events or matters whose materialization is uncertain and not under the control of 
the Company ("forward-looking information"). Although the Company believes that the 
information  is  forward-looking  based  on  reasonable  estimates,  the  said  information  is 
subject  to  certain  risks  and  uncertainties.  Forward-looking  information  is  inherently 
subject to risks of non- materialization and is uncertain, and the Company does not in any 
way guarantee that its assessments, expectations, aspirations, plans and objectives will 
be  materialize  in  practice.  Accordingly,  forward-looking  information  should  not  be 
construed as a promise that it will actually materialize. Implementation and / or other 
changes in forward-looking information depend on factors that are not necessarily known 
in advance, and are not necessarily under the Company's control, including risk factors 
and the nature of its operations, developments in the general environment and external 
factors  and  regulation  affecting  its  activities  and  other  factors.  The  results  and 
achievements  of  the  Bezeq  Group  in  the  future  may  differ  materially  from  those 
presented in the forward-looking information presented in this section. 

1.8.5. 

Streamlining moves and promoting the assimilation of synergies between subsidiaries 

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Bezeq’s  subsidiaries  Pelephone,  Bezeq  International  and  Yes  (the  "Subsidiaries")  have 
implemented  and  are  implementing  significant  moves  to  promote  and  assimilate  the 
synergy  between  them,  including  the  signing  of  collective  agreements  which  include 
in  a  similar 
streamlining  and  synergy  procedures;  Maintaining  managements 
composition,  while  streamlining  decision-making  processes,  along  with  savings  in 
expenses;  Implementing  streamlining  measures  and  saving  on  operating  expenses; 
Service sales through the distribution channels of the companies; Implementing a shared 
customer  management  system  (CRM)  over  an  advanced  Cloud  platform;  deepening 
shared procurement and using shared resources. In this matter, see also Section 1.1.4. 

Bezeq  International,  which  is  in  the  process  of  transitioning  to  a  growth-focused  ICT 
company,  is  also  taking  streamlining  measures,  including  the  signing  of  a  collective 
agreement that includes streamlining, as well as streamlining and cost-saving measures. 
Also, reducing the ISP activity at Bezeq International fits in with the synergy in the Group. 

For details on additional strategic objectives in relation to each of the Group companies, 
see Sections0, 0, 4.13 and 0.  

In  respect  of  decisions  by  Bezeq’s  Board  of  Directors  and  Yes’s  Board  of  Directors 
regarding an outline for a gradual transition from satellite broadcasts to transmission via 
the Internet (OTT) see Section5.18 

The assessments described in this section are forward-looking information, as defined in 
the Securities Law, that may be affected by various factors, including future changes in 
the Israeli market in general and in the communications market in particular, strategic 
and other moves to be made in Bezeq and its subsidiaries, regulatory changes, Bezeq's 
competitive position, etc. The above may be affected by the materialization of some of 
the risk factors listed in the Sections 0,3.19, 4.14 and 5.18.  

1.9. 

Entry into the field of electricity supply 

1.9.1. 

Bezeq's entry into the field of electricity supply 

On  January  25,  2024,  Bezeq's  Board  of  Directors  approved  its  entry  into  the  field  of 
electricity  supply  and  its  engagement  with  Powergen  Ltd.  ("Powergen")16,  a  company 
wholly owned by Generation Capital Ltd. which coordinates the fund's energy activities, 
In the non-binding memorandum of understanding regarding strategic cooperation and 
the establishment of a joint venture in the field of electricity supply ("the MOU"). The 
signing  of  the  aforementioned  memorandum  of  understanding  is  in  accordance  with 
Bezeq's  strategy,  which  includes  finding  opportunities  for  expansion  in  areas  that  are 
tangential  and  complementary  to  the  Group's  activities,  and  entering  areas  of  activity 
with  high  growth  from  the  Company's  core  areas  while  diversifying  the  portfolio  and 
reducing dependence on regulatory risks (for this matter, see Section 1.8.2.3). 

1.9.2. 

Background regarding the reform of the electricity sector in Israel 

As part of the reform in the electricity sector in Israel, it was determined in 2018 that the 
supply segment relating to the purchase of electricity and its sale to consumers, including 
determining the price for the consumer, generating bills, etc., will be gradually opened to 
competition. While the distribution activity, at least at the regional level, is almost entirely 
controlled by the Israel Electric Company Ltd. ("IEC") and can anyway be done by only one 
distributor  (a  natural  monopoly),  the  supply  activity  can  be  open  to  competition.  The 
supply segment was open to competition for large consumers and starting in 2021 it will 
gradually  open  up  to  competition  for  domestic  consumers  as  well.  Competition  in  the 
supply  segment  allows  consumers  to  contract  with  a  private  supplier  and  continue  to 
purchase electricity from IEC. According to the decisions of the Electricity Authority, it is 
now possible to transfer customers who have a smart meter installed (a continuous meter 
that allows remote reading of data) from IEC to suppliers who do not possess production 
means,  thus  opening  up  to  market  competition  on  a  very  significant  scale,  as  IEC  is 
prevented from offering discounts to customers until it loses 40% market share in low 
voltage. According to the consulting firm BDO Consulting, the market share that may pass 

16  Powergen Ltd. (formerly Generation Energy Ltd.) coordinates the energy activities of Generation Capital Ltd., corporations under 
its control  possess  electricity  production  facilities  on  a significant scale,  and  it  also  engages  directly and  through corporations 
under its control in initiating projects for the establishment and operation of electricity production and storage facilities. 

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to IEC’s competitors until the year 2030 is estimated at about NIS 10 billion. 

1.9.3. 

Main points of the MOU 

1.9.3.1 

1.9.3.2 

1.9.3.3 

1.9.3.4 

1.9.3.5 

1.9.3.6 

The  MOU  regulates  the  principles  of  cooperation  between  Bezeq  and 
Powergen in the field of electricity supply to household customers and small 
and medium-sized business customers ("Activity Field"). 

For the purpose of the cooperation, a company jointly owned by Bezeq (50%) 
and  Powergen  (50%)  (“the  Venture")  will  be  established,  which  will  hold  a 
supply license to suppliers who do not possess production means, by virtue of 
the regulation published by IEC. 

Bezeq, through the services it will provide to the Venture, will be responsible 
for  marketing,  sales,  acquisition,  and  customer  retention,  as  well  as  for 
providing  account  management  services  to  customers,  including  collection 
services  and  contact  with  the  customer.  Powergen  will  be  responsible  for 
providing  voltage  for  the  benefit  of  the  Venture,  both  through  electricity 
production  and storage  facilities  that belong  to  the  corporations  held  by  it, 
and  through  continuing  to  initiate,  operate,  and  finance  projects  for  the 
establishment and operation of electricity production and storage facilities, by 
itself or through corporations under its control. It is hereby clarified that the 
investments in these projects will be made, directly or indirectly, by Powergen 
Group  only,  and  Bezeq  Group  or  the  Venture  are  not  expected  to  make 
substantial investments in connection with the Venture’s activities. In the first 
period of the Venture’s activity, Powergen will also provide electricity trade 
and optimization services to the Venture, under certain conditions as reflected 
in the memorandum of understanding. 

Powergen  will  offer  the  Venture  the  electricity  it  produces,  directly  and 
indirectly, and the Venture will purchase the electricity from it (under certain 
conditions),  as  long  as  it  is  required,  within  the  framework  of  long-term 
engagements with commitments to purchase the electricity through various 
price-setting  mechanisms.  As  part  of  contracts  with  Powergen  renewable 
energy facilities, the eligibility for "green" electricity production, including the 
eligibility for issuing green certificates, will belong to the Venture. 

Upon the establishment  of the Venture, the parties  will  provide it, in equal 
parts, the amount required to finance its activities in the first year (it will be 
clarified that this is an immaterial amount in relation to the Bezeq Group). 

Each party between Bezeq and Powergen will appoint half of the members of 
the  Venture’s  Board  of  Directors.  The  Chairman  of  the  Venture’s  Board  of 
Directors  will  be  the  CEO  of  Bezeq.  All  decisions  of  the  Venture’s  Board  of 
Directors will be made jointly, but the directors appointed by Bezeq will have 
an excess vote in the Venture’s Board of Directors, mainly on issues such as 
decisions  concerning  transactions  with  Powergen  Group,  the  marketing 
strategy and its implementation. 

1.9.3.7 

Following the signing of the MOU, the parties work to enter into a detailed 
agreement based on the principles detailed in the MOU. 

The launch of the Venture is expected in the second quarter of 2024. In accordance with the business 
plan  included  in  the  MOU,  the  project  aims  to  reach  a  market  share  of  approximately  400,000 
household electricity customers and tens of thousands of business customers by the end of 2030. 

Bezeq's  entry  into  the  field  of  electricity  supply  and  the  entry  into  force  of  the  MOU  require  an 
amendment of the objectives section of Bezeq's Memorandum of Association. On March 3, 2024, the 
general  assembly  of  Bezeq's  shareholders  approved  an  amendment  to  the  aforementioned 
Memorandum of Association.17 

Bezeq  examines  the  expected  accounting  treatment  for  the  Venture  in  its  financial  statements. 
According to what appears at this stage, the treatment will be carried out according to the balance 

17  It is clarified that in accordance with the Companies Ordinance, the approved amendment to Bezeq's Memorandum of Association 
regarding Bezeq's targets, will enter into force within 21 days from the date of the decision at the  asembly, subject to and in 
accordance with the provisions of Article 25 of the Companies Ordinance. 

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sheet  value  method,  and  Bezeq's  share  of  the  Venture’s  profits  (losses)  will  be  recorded  as part  of 
Bezeq's current business activity and presented as part of Bezeq's operating profit and EBITDA. 

Some  of  the  information  contained  in  this  immediate  report  includes  forward-looking  information, 
within its meaning in the Securities Law, 1968-5778 and is based, among other things, on  estimates 
regarding future developments regarding the electricity sector, the behavior and needs of electricity 
customers,  regulatory  policy,  competitors'  marketing  strategy,  etc.  These  estimates  may  not 
materialize, or materialize in a materially different way than projected, among other things, depending 
on the variables mentioned above. 

1.10.  Corporate responsibility (ESG) 

On February 24, 2022, Bezeq's Board of Directors approved the expansion of its activity in the field 
of corporate responsibility (ESG - Environment, Social and Governance), following Bezeq's existing 
activity in the field. In this context, the Board of Directors approved a sustainability vision for Bezeq 
- "Bezeq connects Israel to a sustainable future", as well as setting ESG targets, including long-term 
targets  in  the  field  of  environmental  responsibility  that  include  reducing  net  greenhouse  gas 
emissions to zero by 2050 (Net zero 2050); and in the field of environmental responsibility, increasing 
the rate of representation of women in the management ranks of Bezeq employees to 50% by 2030. 
The Board of Directors also approved, on and around the same date, corporate responsibility policy 
documents on various topics. In February 2023, the application of the aforementioned ESG targets 
was also approved in the subsidiaries Pelephone, Bezeq International and Yes. In March 2023, Bezeq 
joined the gender equality initiative of the UN Women's Organization (WEPs). 

In addition, during 2023, Bezeq continued to cooperate with civil society organizations to reduce the 
digital divide and encourage the volunteering of its employees for the benefit  of a  wide range of 
social goals, as well as investing resources in the continuous improvement of corporate governance 
in the group, which includes the adoption of management norms and the management of advanced 
compliance programs. 

Bezeq publishes corporate responsibility reports in accordance with the reporting standard of the 
Global Reporting Initiative (GRI, and starting in 2022, Bezeq submits a report to the international 
organization CDP, which is engaged in managing a professional system for reporting, documenting, 
and rating the nature of the environmental impact management of various entities. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

2. 

Bezeq – Landline interior communications 

2.1. 

General information about the field of activity 

2.1.1. 

The field of activity and changes that apply to it 

Bezeq  owns  a  general  license  for  the  provision  of  landline  interior  communications 
services and provides a variety of communication services as specified in Section 2.2, the 
main ones being: Internet access and infrastructure services, landline interior telephony, 
transmission and data communication services, Cloud and digital services and wholesale 
services (for wholesale services, see Section2.16.4). 

2.1.2. 

Legislative and regulatory constraints and special constraints 

2.1.2.1 

Communications Law and Bezeq's NIO license 

subject 

to  governmental 

Bezeq's  activities  are 
regulation  and 
comprehensive  supervision  arising  from  its  status  as  a  general  licensee 
under  the  Communications  Law,  subject  to  the  provisions  of  the 
Communications Law, the provisions, regulations, orders and rules enacted 
thereunder  and  the  provisions  of  the  NIO  license  and  other  laws.  In  this 
regard  and  for  the  restrictions  on  Bezeq's  activities  and  changes  in  this 
inter  alia,  regarding  the  determination  of  rates,  structural 
context, 
separation,  approvals  for  new  services  and  service  baskets  as  well  as 
wholesale market see section1.7.3 and section 2.16. 

Additionally, Bezeq has been declared an essential Bezeq service provider 
under  the  Communications  Order.  By  virtue  of  this  declaration,  Bezeq  is 
obligated to provide a number of basic services under the NIO license and 
may not  discontinue or reduce them  without  approval.  The order further 
stipulates restrictions on the transfer and purchase of means of control of 
Bezeq  and  certain  restrictions  on  Bezeq’s  activity.  For  details,  see 
section2.16.3.  

2.1.2.2 

Laws of Economic Competition 

Bezeq has been declared a  monopoly in the main areas of its operations, 
and  it  is  also  subject  to  supervision  and  restrictions  under  the  Economic 
Competition Law (see section2.16.9). 

2.1.2.3 

Environmental law and planning and construction law 

Some of Bezeq's activities involve the use of wireless frequencies and the 
operation of facilities that emit electromagnetic radiation, which are subject 
to the Telegraph Order (see Section 2.16.10), to the Non-Ionizing Radiation 
Law (see Section.אצמנ אל הינפהה רוקמ !האיגש), and to National Outline 
Plan 36 and National Outline Plan 56 (see Section 2.16.11). 

2.1.3. 

Changes in the scope of activity in this field and its profitability and developments in the 
market and in the characteristics of customers 

For key data on the scope of activity in the field of landline interior communications and 
its profitability in 2022 and 2023, See Section 1.5.4.1. The following is a description of the 
main changes in the scope of activity in this field during the reported period18:  

2.1.3.1 

Wholesale  market  -  At  the  beginning  of  2015,  Bezeq  began  providing  a 
wholesale BSA service for service providers, when as of the end of 2023, the 
number of wholesale Internet subscribers on the Company’s network was 
approximately  467K  subscribers,  constituting  approximately  31%  of  all 
Bezeq's Internet subscribers. In this context, it should be noted that within 
these subscribers there are also subscribers that were not on the Company’s 
network in the first place (new or from a competing network). 

Bezeq  also  provides  a  wholesale  service  that  allows  competitors  to  use 
Bezeq's passive infrastructure. 

Regarding the wholesale services, see Section 2.16.4. 

18  

For details of the data as well as subscrber definitions and average revenue, see the notes to the table in Section 1.5.4.1. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

2.1.3.2 

The  field  of  landline  telephony  -  in  recent  years,  the  field  of  landline 
telephony  has  been  characterized  by  a  decrease  in  demand,  which  is 
reflected in a decrease in the rate of landline telephone subscribers and a 
gradual erosion in the number of calls originating in  landline networks. In 
Bezeq's  estimation,  this  trend  is  mainly  due  to the  increase  in  the  use  of 
personal,  cellular,  smart  phones  in  light  of  large-scale  call  packages  that 
cellular companies have marketed  extensively in recent  years and  from  a 
decrease in prices in the field, as well as an increase in the number of calls 
over the Internet (See Section 2.1.4). In 2023, there was a decrease of about 
4% in the number of Bezeq subscribers compared to 2022. 

Diagram - Rate of households without a landline telephone line19  

2.1.3.3 

The field of Internet access - the Internet market saw a significant increase 
in bandwidths and browsing speeds, mainly with the  deployment  of fiber 
infrastructure  and  the  adoption  of  advanced  services  and  value-added 
applications.  Also,  in  recent  years,  the  trend  of  growth  in  terms  of  the 
number of customers continues. During the year 2023, Bezeq estimates that 
the  following  changes  compared  to  2022  will  apply:  an  increase  of 
approximately  1% in the number of landline Internet  subscribers in Israel 
and a decrease of approximately 1% in the total number of Bezeq’s Internet 
subscribers  (decrease  in  both  retail  and  wholesale).  In  terms  of  browsing 
rates, Bezeq provides fiber service at rates of up to 300 Mbs, 600 Mbs, 1 Gb, 
2.5 Gb in the areas where it deploys the fibers (for Beze’qs choice areas see 
Section 2.7.2.2). Bezeq also provides speed at a rate of up to 200 megabytes 
on its copper network 

19   The data were taken from the publications of the Central Bureau of Statistics (Household expenditure survey for 2021 dated 
December 31, 2023. In relation  to the  data for the years  2022-2023 - in accordance with  Bezeq’s assessment  based on 
surveys by the Central Bureau of Statistics from previous years. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Diagram - Distribution of Internet subscribers on Bezeq infrastructure (quarterly, in thousands):  

2.1.3.4 

Data transmission and communication services 

The areas of transmission and communication data for business customers 
and communication providers are characterized, on the one hand, by a rapid 
increase in customers' bandwidth needs, and on the other hand, a decrease 
in the price of a given volume of traffic, which stems from the development 
of  technology  to  increase  bandwidth  at  lower  costs  than in  the  past  (see 
is  a  shift  to  the  use  of  the 
Section  2.6.6). 
telecommunications  providers'  own  infrastructure.  For  this  matter  see 
Section. 

In  addition,  there 

2.1.3.5 

Service packages 

For  an  increase  in  the  rate  of  consumption  of  packages  and  baskets  of 
services,  see  section1.7.1.  Regarding  Bezeq's  shared  service  baskets,  see 
Section 1.7.3. 

2.1.4. 

Technological changes that have a significant impact on this field of activity 

2.1.4.1 

In  the  communications  market,  a  trend  has  been  established  towards  IP-
based  technologies,  which  promote  the  phenomenon  of  "technological 
convergence"  between  the  various  communication  systems  (such  as 
telephony and DATA). There has also been an increase in the penetration of 
integrated  end  devices  that  enable  the  consumption  of  various 
communication  solutions  on  the  same  device  (such  as  cellular  and  Wi-Fi 
services).  These  two,  together  with  the  increase  in  the  availability  of  IP 
protocol-based  technologies  and  the  continuing  trend  of 
increasing 
bandwidth, enable the customer, including the business customer, a wide 
range  of  applications  and  services  on  IP  based  infrastructures,  such  as 
telephony services, including private exchange services, video transmission 
services 
,  TV,  private  networks,  network  services  with  enterprise 
applications on the Internet infrastructure (ERP, CRM, etc.), cloud services 
and services on the cloud. These developments are leading to an increase in 
bandwidth  demand  by  Bezeq's  Internet  infrastructure,  transmission  and 
data  communications  customers.  Technological  developments  and 
declining equipment prices may allow other operators to provide services 
similar to those provided by Bezeq at even lower costs. 

Technological changes can also lead to the cannibalization of services. An 
example of this is a decrease in the consumption of the Group's traditional 
landline  telephony  services  (for  competition  in  the  field  of  telephony 
through the provision of services on Bezeq's Internet infrastructure (VoB), 
see  Section  2.6.3.1).  The  increase  in  the  speedds  of  the  cellular  service 
enables  the  cellular  operators  to  compete  with  Bezeq's  telephony  and 
Internet services, and to market greater bandwidths to their customers  at 
lower prices than in the past. In the Bezeq’s opinion, as of the date of the 
report,  the  increase  in  the  number  of  customers  browsing  the  cellular 
Internet  did  not  materially  affect  the  scope  of  Bezeq's  Internet  activity. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

However, the potential for increase in the use of cellular networks at the 
expense of the use of the Bezeq network exists and may increase with the 
establishment  of  5G  (see  section3.1.5),  since  they  will  also  be  able  to 
provide ultra-fast internet at the customer's home. 

In the business segment, the entry of large global cloud service providers 
into  the  Israeli  market  such  as  AWS,  MICROSOFT,  GOOGLE  may  threaten 
certain services of the Company such as VCLOUD, DR. On the other hand, 
cooperation with them is an opportunity for Bezeq's growth and entry into 
new fields.  

2.1.5. 

The development of SD WAN20 technology and its increasing use in the business sector, 
which  includes  the  integration  of  the  technology  in  the  Company's  communication 
networks, is an opportunity to enrich the business services offered by Bezeq and increase 
its revenues. The critical success factors in the field of activity and the changes that apply 
to them. 

2.1.5.1 

2.1.5.2 

2.1.5.3 

2.1.5.4 

2.1.5.5 

2.1.5.6 

The ability to offer reliable communication systems at a competitive price 
based  on  a  cost  structure  adapted  to  the  frequent  changes  in  Bezeq's 
business environment.  

Regulatory decisions and the ability to deal with them. 

The  ability  to  maintain  innovation  and  technological  leadership  and 
translate  it  into  advanced,  reliable  and  valuable  applications  for  the 
customer in short response times, as well as marketing primacy. 

Preservation of brand values and their adaptation to the conditions of the 
changing competitive environment. 

Effectiveness of sales and service systems. 

Informed pricing policy management, subject to regulatory restrictions. 

2.1.6. 

The main barriers to entry and exit of this field of activity and changes that apply to them 

Activities  in  the  field  of  landline  interior  communications  require  the  receipt  of 
appropriate licenses. For a memorandum of understanding of the bill regarding a change 
in the format of the regulation and  transfer to the issuance of communication services 
through registration in the registry only, see Section.אצמנ אל הינפהה רוקמ !האיגש. 

Traditionally,  the  main  barrier  to  entry  into  this  field  has  stemmed  from  the  need  for 
heavy investments in technological infrastructure and enveloping systems to achieve size 
advantages,  and  high  costs  associated  with  setting  up  marketing,  sales,  collection  and 
customer support systems and brand building. Over the years, the traditional barriers to 
entry into Bezeq's areas of activity have significantly decreased as a result of the following 
factors: technological improvements, declining prices of infrastructure and equipment, 
changes  in  the  rules  of  regulation  (see  sections2.7.2  and    אל  הינפהה  רוקמ  !האיגש
.אצמנ), regulatory relief granted to new competitors, the obligation to allow the use of 
Bezeq (and Hot) infrastructure and services - including within the wholesale market and 
the  use  of  VoB  technology  that  enables  telephony  services  over  another  operator's 
broadband  infrastructure,  without  the  need  for  an  independent  landline  telephony 
infrastructure. 

The  main  barriers  to  exit  stem  from  the  following:  Bezeq's  obligation,  set  forth  in  its 
license, to provide its services on a universal basis (to the general public in Israel, except 
in  relation  to  fiber  as  specified  in  section  .אצמנ  אל  הינפהה  רוקמ  !האיגש);  Its 
subordination  to  the  provisions  of  the  Communications  Order,  regulations  under  the 
Communications Law, as well as provisions under Article 13a of the Communications Law 
regarding  emergency  activities;  Its  commitment  to  some  of  its  employees  employed 
under collective agreements; Large investments that require a long return on investment; 
And  a  commitment  to  repay  long-term  debentures  and  loans  taken  to  finance 

20  SD-WAN  is  a  solution  from  the  software  defined  networking  family  -  implementing  a  network  on  smart  software  over  uniform 
hardware.  In  SD-WAN,  intelligent  central  software  manages  endpoint  routers  at  customer  sites  and  enables  uniform 
communication and information security for the organization with easy and convenient central management. 

38 

 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

investments.  Some  of  these  exit  barriers  are  unique  to  Bezeq  and  are  not  relevant  to 
other operators operating in this field of activity. 

2.1.7. 

Substitutes for products in this field of activity and changes that apply thereto 

Cellular communication services are a substitute product for Bezeq services, both in the 
field  of  telephony,  Including  through  apps  and  in  IP  technologies  such  as  VoB  (see 
Section2.6.5), and in the field of the Internet (see Section 2.6.2), transmission and data 
communication. Technological developments (such as 4G and 5G in cellular, fiber-optic-
based infrastructure, millimeter waves and advanced cable Internet protocols) enable the 
provision of new services at high speeds and at competitive prices. 

2.1.8. 

The structure of competition in this field of activity and changes that apply thereto 

The field of interior landline communications is regulated and supervised by the Ministry 
of Communications, among other things, by allowing communication service providers to 
register as authorized providers operating in accordance with the permit regulations as 
well  as  by  granting  licenses,  in  circumstances  where  a  license  is  required,  to  bodies 
operating in the field.  

In  the  communications  market  there  are  two  licensees  for  the  provision  of  landline 
interior communications services obligated to provide service to  everyone, nationwide 
deployment  and  universal  service,  Bezeq  and  Hot  Telecom.  In  respect  of  the  fiber 
network,  Bezeq  is  obliged  to  provide  service  according  to  choice  areas  -  see  Section 
2.7.2.3): Bezeq, and Hot Telecom. IBC is also obliged to deploy the fiber network, so that 
at the end of 5 years from March 7, 211, 1.7 million households in Israel will be accessible 
to its network21. The three companies compete with each other. At the same time, they 
were  allowed  to  make  mutual  use  of  each  other’s  physical  infrastructure  (except  for 
infrastructure owned by the IEC needed to provide essential service) and other authorized 
provider’s  infrastructure,  so  that  in  fact  the  competition  could  be  through  physical 
infrastructure of another authorized provider, and in practice, today, mainly on Bezeq's 
infrastructure (see Section 2.16.4.4 in this regard). 

Cellcom  and  Partner,  which  have  unique  NIO  licenses  (which  do  not  require  universal 
deployment),  are deploying an independent  fiber network (regarding Cellcom and Hot 
joining IBC, see Section 2.6.3). 

The Internet field is characterized by high penetration rates attributed to the deployment 
of national access infrastructure. In this field, there have been substantial changes in the 
last  two  years:  starting  from  March  2021,  Bezeq  provides  an  Internet  infrastructure 
service on an advanced network - the fiber network deployed by it; As of April 2022, Bezeq 
also aoperates in the unified Internet service, which includes both infrastructure (fiber or 
copper) and a private access service, and it is not allowed to market bundles with other 
access  providers;  Providers  with  a  special  broadband  infrastructure  NIO  license  were 
allowed to deploy landline infrastructure to provide Internet services and to use Bezeq’s 
passive infrastructure in the incentive areas for this purpose. 

Bezeq's  main  competitor  in  the  field  of  services  provided  over  a  traditional  (copper) 
network is Hot. Hot was handed over to provide a unified service in August 2022. Bezeq's 
main competitor in service to communication providers on an advanced fiber network is 
IBC (also owned by Hot and Cellcom), and in fiber Internet services for subscribers Bezeq's 
main  competitors  are  Partner  and  Cellcom.  In  addition,  Bezeq  is  also  exposed  to 
competition from the cellular networks (see Section 2.1.4). 

Access service providers (ISP) became competitors of Bezeq upon the implementation of 
the  wholesale  market  in  2015,  as  they  provide  a  package  of  services  that  includes  a 
broadband Internet access infrastructure through Bezeq infrastructures that they use as 
part of the wholesale services. Starting in the middle of 2021, they can also do so over 
Bezeq’s  fiber network (See also the IRU agreement  between Bezeq and the Partner in 
Section 2.6.3). 

The field of landline telephony is in competition, and Bezeq's competitors, some of them 
within communication groups (see Section 1.7.1), are Hot Telecom, as well as VoB service 

21   The duty of nationwide service for all also applies to holders of general licenses for the provision of mobile radio telephone 
services such as Pelephone, Cellcom and Partner, as well as in the field of internaiotnal operator services - such as Bezeq 
International. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

providers operating under licenses without universal service obligation For several years 
now, without their own self-access infrastructure, as well as the cellular companies. For 
details about wholesale telephony services see Section 2.16.4. 

In the field of wholesale services, Bezeq Hot and IBC compete as infrastructure owners 
committed to providing wholesale services.  Anyone  who deploys in the  incentive area 
(whose license or an administrative order issued to an NIO determines the obligation to 
deploy in the region it won in the tender) is also obligated to provide a BSA wholesale 
service to other authorized suppliers in the same incentive area. 

In the field of data transmission and communication, Bezeq’s main competitors are Hot 
Telecom, Cellcom and Partner, operating within the framework of communication groups 
and offering a complete communication solution to the customer. 

Competition  in  the 
industry  depends  on  various  factors  such  as:  technological 
developments,  regulatory  decisions,  possible  changes  in  the  terms  of  the  licenses  of 
Bezeq and its subsidiaries and the terms of the licenses of their competitors; mergers and 
collaborations  between  companies  competing  with  the  Group  companies;  Possible 
implications of the Centralization Law; Continued development of the wholesale market 
and  the  asymmetry  between  Bezeq's  ability  and  the  ability  of  competitors  to  sell  a 
comprehensive service; The new services that Bezeq will be allowed to provide; The rates 
policy, elimination of the structural separation and the degree of flexibility that will be 
given to Bezeq in offering undetachable service packages, including with subsidiarie. 

For a description of the development of competition, see Sections1.7 and2.6. 

2.2. 

Products and services 

2.2.1. 

General 

Bezeq  provides  a  wide  range  of  communication  services  to  its  business  and  private 
customers as detailed below. 

2.2.2. 

Telephony 

Bezeq's  telephony  services  mainly  include  the  basic  telephone  services  via  the  home 
telephone line, and ancillary services such as: voicemail and caller ID.  

Bezeq also provides its customers with national numbering services for businesses ("1-
800", "1-700"), the calls in which are paid in full or in part by the business.  

Bezeq operates a unified call center, under the code (1344) established by the Ministry of 
Communications also for operators of landline and cellular telephony, as well as a unified 
website free of charge, in addition to Bezeq's 144 service.  

For  the  provision  of  a  resale  service  and  for  wholesale  telephony  service,  see 
section2.16.4.4.  

2.2.3. 

Internet access infrastructure services and ISP 

Bezeq  provides  broadband  internet  services  over  the  fiber  network  in  statistical  areas 
subject to milestones in its license over the copper infrastructure using xDSL technology, 
as  well  as  wirelessly  using  VBAND  technology.  Bezeq's  fiber  infrastructure  allows  for 
signiciantlyhigher speeds than the traditional copper network, and accordingly, thereis 
an increase in the average package rate. In addition to switching customers to Bezeq's 
fiber  network,  Bezeq  is  also working  to  upgrade  customers'  browsing  speeds  over  the 
fiber network. Also, as of April 3, 2022, Bezeq markets and provides a unified internet 
service, infrastructure, and private Internet access (for this matter, see Section 1.7.5.1). 

For details regarding changes in the number of Bezeq Internet subscribers in the average 
monthly revenue per Internet subscriber and in the average package speed, see Section 
1.5.4. For details regarding Bezeq's market share in this field, see Section  רוקמ !האיגש
.אצמנ אל הינפהה.  

The  Internet  service  is  one  of  Bezeq's  main  occupations  and  a  major  route  in  its 
investments  in  technologies,  marketing,  advertising  and  customer  acquisition  and 

40 

 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

upgrade. The average package speed of Bezeq's Internet subscribers.22 

Broadband Internet service is also provided on a subscriber line without telephony at no 
extra charge for the access line. 

Bezeq  is  obligated  to  provide  a  broadband  Internet  access  service  (including  on  an 
advanced fiber network) in a BSA wholesale format to authorized providers, who in this 
way provide their customers with a uniform Internet service, including infrastructure. For 
this service see Section 2.16.4. For the agreement for the provision of the indefeasible 
right-of-use (IRU) service in the BSA fiber service (wholesale market) by Bezeq to Partner, 
see Section 2.6.2.1. 

Diagram  -  Changes  in  the  package  speeds  of  Bezeq  Internet  subscribers  in  the  years  2013-2023 
(Mbps, as of the end of each year)*:  

Up 
to 15 

* In packages where there is a range of  speeds, the maximum speed in the package is taken into 
account 

2.2.4. 

Data transmission and communication services 

Data  communication  services  are  network  services  for  transferring  data  from  point  to 
point, data transfer between computers and various communication networks, services 
for  connecting  communication  networks  to  the  Internet  and  remote  business  access 
services. 

Bezeq  offers  transmission  services,  including  at  high  speeds,  to  communications 
operators, international parites and its business customers in a variety of interfaces (see 
Section2.6.6). 

2.2.5. 

Cloud and digital services 

This  category  includes,  among  others,  virtual  server  services,  cyber  services,  smart 
complexes services, virtual private hub services (IP Centrex), as well as the B144 service 
which  is  Bezeq's  advertising  platform  for  digital  advertising  and  marketing  for  small 
businesses, BCAM, SMS, WiFi. 

2.2.6. 

Other services 

2.2.6.1 

Additional services for communications operators  

Bezeq  provides  services  to  other  communications  operators,  including: 
International  operators;  Hot;  Network  endpoint 
cellular  operators; 

22    Including revenue from service providers in wholesale service.. 

41 

0%50%100%                                         ד 1516 4041 100101 200201 2500 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

operators; Internet Service Providers (ISPs); Interior operators; Palestinian 
communications providers. 

The services that Bezeq provides, as stated, include infrastructure services, 
linking to the Bezeq network, billing and collection services, renting areas 
and providing services in rented properties. 

For  the provision of wholesale services to communications operators and 
infrastructure  also  for 
for  the  possibility  of  using  Bezeq's  physical 
infrastructure owners, see section1.7.4.  

2.2.6.2 

Broadcast services 

Bezeq  operates  and  maintains  radio  transmitters,  among  others,  for  the 
broadcasting  corporation,  Galei  Tzahal  and  a  number  of  regional  radio 
stations.  Bezeq  also  operates  the  DTT  broadcasters  for  the  Second 
Authority.  Bezeq  is  responsible  solely  for  operating  and  maintaining  the 
transmitters for the purpose of distributing the broadcast of the radio and 
television  programs,  and  not  for  the  content  of  the  broadcasts.  For  this 
matter, see also section2.15. 

2.2.6.3 

Contractor work 

Bezeq  performs  construction  and  operation  of  networks  or  sub-networks 
for various customers (such as the Ministry of Defense, radio and television 
broadcasting companies, cellular operators, international communications 
operators, local authorities, municipalities and government bodies). 

2.2.6.4 

Electricity supply license 

On  September  1,  2021,  Bezeq  received  a  license  from  the  Electricity 
Authority to supply electricity without means of production. The Company 
provides services to a small number of customers in accordance with the 
terms of the license. Further to Bezeq entering into an MOU with Powergen 
Ltd. regarding cooperation and the establishment of a joint venture in the 
field of electricity supply (see Section 1.9) subject to all laws, the license for 
electricity supply held by Bezeq will be converted to the benefit of the joint 
corporation. 

2.2.7. 

Sale of end equipment and devices 

As of 2019, Bezeq has been selling smartphones (in addition to other end equipment sold 
thereby). Bezeq has expanded its offering to additional equipment and devices (including 
products not in the field of communications). 

2.3. 

Revenue segmentation of products and services 

The following is data about the distribution of Bezeq’s revenues according to the main products and 
services in its field of activity in the years 2021-2023 (NIS millions):  

 Revenue from Internet infrastructure services 
Rate out of the total Company revenue in the field of 
activity 
Revenue from landline telephony 
Rate out of the total Company revenue in the field of 
activity 
Revenue from transmission and data communication 
services 
Rate out of the total Company revenue in the field of 
activity 
Revenue from Cloud and digital services 
Rate out of the total Company revenue in the field of 
activity 
Revenue from other services and sale of end 
equipment 
Rate out of the total Company revenue in the field of 
activity 

42 

2023 
1,947 
44.13% 

2022 
1,789 
41.55% 

2021 
1,624 
38.83% 

650 
14.73% 

780 
18.11% 

913 
21.83% 

1,163 

1,132 

1,087 

26.36% 

26.29% 

26.0% 

349 
7.91% 

331 
7.69% 

318 
7.6% 

303 

274 

240 

6.87% 

6.36% 

5.74% 

 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Total revenues from the field of landline interior 
communications 

4,412 

4,306 

4,182 

2.4. 

Customers 

Bezeq is not dependent on a single customer, and there is no customer Bezeq's revenues from whom 
constitute 10% or more of its total revenues. Bezeq's revenues are divided into two main types of 
customers: private customers (approximately 48%) and business customers (approximately 52%)23. 
The aforesaid distribution is according to revenue, as detailed in the table below (in NIS millions):  

Revenue from private customers 
Revenue from business customers  
Total revenue 

2.5.  Marketing, distribution and service 

2023 
2,114 
2,298 
4,412 

2022 
2,099 
2,207 
4,306 

2021 
2,071 
2,111 
4,182 

Bezeq  has  marketing,  sales  and  service  systems  for  businesses  and  private  customers,  including 
customer managers for the business segment, integrated sales and service centers throughout Israel, 
technical support centers for private customers and business customers, several points of sale and 
service (Bezeq Store chain of stores) throughout Israel, as well as an online virtual store. 

Bezeq markets its services mainly through advertising in the mass media, telephone sales centers, 
customer  managers  and  through  a  system  of  marketers  that  includes  outsourced  sales  centers. 
Bezeq  has  independent  service  and  sales  channels  on  its website,  in  a  dedicated  application  (My 
Bezeq), and through a computerized voice answering service. 

Also, the internet providers (ISPs) market the Company’s Internet infrastructure as part of a unified 
Internet service based on Bezeq's BSA wholesale service. Note that as of April 3, 2022, they can no 
longer  market  Bezeq's  internet  infrastructure  to  private  customers  in  a  bundle  outside  of  the 
wholesale market. 

2.6. 

Competition 

The  following  is  a  description  of  the  development  of  competition  in  the  field  of  landline  interior 
communications:  

2.6.1. 

Wholesale market (see also section 2.16.4) 

The wholesale market allows telecommunications providers to market Bezeq's internet 
infrastructure on the one hand, and on the other hand to compete with Bezeq using its 
services  and  physical  infrastructure,  at  regulated  maximum  prices  not  determined  by 
Bezeq. 

To  the  best  of  Bezeq's  knowledge,  the  volume  of  wholesale  subscribers  on  the  Hot 
network is not large (see in this regard section 2.16.4). 

2.6.2. 

The field of Internet 

Bezeq estimates that as of the end of 2023 its market share in the Internet infrastructure 
market (retail and wholesale customers) was about 55% (unchanged compared to 2022). 
Also, according to Bezeq, its market share in terms of retail customers as of the end of 
2023 is about 38%24. Also, the proportion of the Company's unified internet customers 
out of its retail customers by the end of 2023 is about 74%. 

Since  March  2021,  Bezeq  ha  been  marketing  an  Internet  infrastructure  service  to 
customers over an advanced network - the fiber network deployed by it, and competes 
with  this  service  against  Partner  (who  also  deployed  its  own  fiber  network  and  also 
entered into an IRU agreement with Bezeq), Cellcom, and Hot. Authorized providers are 

Including revenue from wholesale service providers. 

23  
24     Bezeq’s assessment of its market share in the field of Internet infrastructure services for the end of 2023 is based on the 
number  of  customers  consuming  services  over  the  Company's  infrastructure  (retail  and  wholesale)  and  publications 
regarding the number of Partner and Cellcom subscribers. It should be noted that Hot and smaller companies operating in 
the market are not reporting corporations and their data is not public, accordingly there is difficulty in giving accurate data 
regarding market shares and these are only estimates. 

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also allowed to deploy a broadband Internet infrastructure, including through the use of 
Bezeq’s passive infrastructure, and provide services through it. 

As of April 2022, Bezeq also operates in the unified Internet service, which includes both 
infrastructure  (fiber  or  copper)  and  an  access  service.  Bezeq  may  continue  to  provide 
infrastructure service only (without access service) to existing customers of this service, 
but it cannot market the infrastructure service in a bundle with other access providers. In 
this area, the competition is against service license holders and authorized suppliers. 

2.6.3. 

The field of Internet access 

There is lively competition in the field, as detailed below: 

Competition from Hot Group: 

Hot  has  an  almost  traditional  Internet  infrastructure,  deployed  almost  nationwide, 
through which a variety of communication services can be provided. On July 28, 2019, the 
Minister of Communications adopted the recommendations of the advisory committee 
and  approved  for  Hot  to  provide  its  services  in  areas  lacking  infrastructure  in  a 
technologically  neutral  format,  i.e.  without  being  obligated  to  deploy  a  landline 
infrastructure, but rather be allowed to use any cellular network to provide its services 
with download rates of up to 12/30 Mbps, as well as to provide television service through 
the  Company's  services.  The  adopted  recommendations  set,  among  other  things, 
milestones  for  upgrading  the  network  for  the  cellular  network  alternative,  minimum 
service quality and reporting obligations. 

Hot’s  network  is  currently  a  main  alternative  to  competition  with  the  Company's 
infrastructure in the private segment in regards to traditional networks. An obligation was 
imposed on Hot to provide wholesale services, including the BSA service, and to the best 
of  the  Company's  knowledge,  a  BSA  wholesale  service  over  Hot’s  network  has  been 
marketed simce the middle of 2018. 

During 2021 Hot announced that it launched its new fiber network. Hot and Celcom have 
holdings in IBC (see this section below). 

Competition from IBC 

IBC's license enables the provision of services mainly to license holders. IBC is obliged to 
the deployment so that at the end of 5 years from March 7, 2021, 1.7 million households 
in Israel will be accessible to its network (according to a report on the IBC website, as of 
the end of 2023, over 1.5 million households are already accessible to its network). IBC is 
owned by the  IEC (30%) and by Hot, Cellcom and  the Israel Infrastructure Fund 23.3% 
each. In this framework, to the best of Bezeq's knowledge, Cellcom sold its optical fiber 
infrastructure  to  IBC,  Hot's  investment  agreement  in  IBC  and  the  IRU  agreement 
according to which Hot will acquire the right to use the infrastructure that IBC will build 
were signed. In addition, the Ministry of Communications made an amendment to Hot's 
license, which, among other things, permits the marketing of a shared basket of services 
on  the  IBC  network  as  well  as  an  amendment  to  the  IBC  license,  which  requires  it  to 
submit  for  the  Ministry's  approval  a  shelf  proposal  for  the  purchase  of  the  fiber 
infrastructure service (in IRU format) at a reduced rate, as was done in fact. IBC is a main 
competitor in providing the fiber infrastructure service to service providers. 

As  far  as  Cellcom  is  concerned  -  in  March  2023,  Cellcom  reported  the  signing  of  an 
agreement  with  IBC  in  which  it  undertakes  to  increase  its  commitment  to  purchase 
infrastructure lines from IBC in the IRU agreement to 12.5% and later to 15% of connected 
customer homes. Cellcom also stated that against IBC's obligation to act to expand the 
scope  of  infrastructure  deployment  beyond  its  obligations  according  to  its  license, 
Cellcom undertakes to purchase IRU services only from IBC for a period not less than 3 
years, under certain conditions. 

As far as Partner is concerned - in accordance with its announcement, starting from the 
fourth quarter of 2023, it began to offer its customers internet services over IBC's fiber 
optic network as part of the wholesale market. 

Competition from Partner 

Communications group Partner provides Internet services on its own fiber infrastructure, 
while also using the company's infrastructure within the wholesale market, and within 

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the  framework  of  the  IRU  agreement  signed  between  the  Company  and  Partner  as 
detailed below. 

Competition from small providers 

licenses  were  allowed, 

Holders  of  special 
in  the  decision  of  the  Minister  of 
Communications  dated  October  13,  2020,  to  deploy  broadband  infrastructure  and 
provide services over it (a step that significantly reduced the threshold requirements for 
obtaining a license enabling the provision of broadband infrastructure services). These 
special  licenses  were  limited  to  up  to  8,000  private  subscribers  or  up  to  800  network 
endpoints  of  business  subscribers,  or  up  to  3  years  from  the  date  of  the  decision, 
whichever  is  earlier.25  As  part  of  Amendment  76  to  the  Communications  Law,  which 
changed the format of the regulation, authorized providers without a license were also 
allowed to deploy a broadband infrastructure and provide services  over it without the 
need for a license, but by registering in the registry and operating in accordance with the 
permit regulations. As part of the regulations by virtue of Amendment 76, a threshold is 
set  above  which  a  license  will  be  required  (see  Section  1.7.4).  The  providers  are  also 
authorized to use  Bezeq’s passive infrastructure in the incentive areas after complying 
with security instructions. 

Agreement of indefeasible right-of-use (IRU) of the BSA service between the  Company 
and Partner 

On December 21, 2022, a long-term agreement was signed between Bezeq and Partner 
for  the  provision  of  the  indefeasible  right-of-use  (IRU)  service  in  the  BSA  fiber  service 
(wholesale market) by Bezeq to Partner. In accordance with the agreement, Partner was 
granted a  non-transferable and irrevocable right  of self-use for providing service to its 
customers on 120,000 unspecified Bezeq fiber optic lines at a rate of 1 gigabyte download 
per line, for a period of 15 years starting on January 1, 2023 (beginning of the right to use 
the lines will be in pulses, in a graded manner, over a period of up to five years, it should 
be noted that as of the date of the report, Partner insists on exercising the right of use to 
the  extent  of  approximately  80%).  The  consideration  for  the  provision  of  the  service, 
which  includes  one-time  payments  and  annual  payments,  is  expected  to  reach  a  total 
amount  of  approximately  NIS  one  billion  (approximately  NIS  574  million  for  one-time 
payments, annual maintenance fees at the rate of 4% of the one-time payments for the 
lines for which the right of use will be granted until that year, and with the addition of 
interest and/or linkage differences according to the terms of the agreement), with most 
of  the  consideration  amount  expected  to  be  paid  during  the  first  6  years  of  the 
agreement. The agreement includes the option to increase the number of lines by up to 
48K additional lines under the same conditions, to upgrade rates as well as to extend the 
agreement period for two five-year option periods each with less lines than in the first 
agreement period. Increasing the content of the aforementioned agreement will result in 
a corresponding increase in the total financial scope of the agreement. The agreement 
also includes a price protection mechanism for Partner in a way that weighs the price of 
the  regulatory  line,  starting  from  the  sixth  year  of  the  agreement.  The  agreement  is 
expected  to  increase  the  usability  and  utilization  of  the  Company's  fiber  network,  its 
revenues and profits, as well as its free cash flow (mainly during the first 6 years of the 
agreement),  and  will  create  certainty  regarding  future  revenues  from  the  wholesale 
market  from  the  lines  included  therein.  At  the  same  time,  the  agreement  embodies  a 
discount for a commitment to quantity and period in relation to the wholesale market 
rates. 

Further to the above agreement and the contacts with the Ministry of Communications 
Bezeq  agreed  to  reduce  the  prices  of  individual  lines  in  the  BSA  fiber  service  (at  an 
aggregate rate of up to 1.1 gigabit/second) to a price of NIS 7226 per month (indexed in 
accordance  with  the  current  customary  price  update  mechanism)  with  the  addition  of 
VAT, so that after this price reduction the Ministry will see the agreement as a shelf offer 

25  These restrictions were actually abolished in accordance with Amendment 76 to the Communications Law, and the holders of 

the special licenses became licensed providers operating subject to the permit regulations. 

26  It should be noted that as of the date of the report, the price in the regulations for an individual line with an aggregate rate of 
up to 550 Mbps and the price for an individual line with an aggregate rate of over 550 Mbps and up to 1,100 Mbps is NIS 
79.4 and NIS 88.3, respectively, plus VAT . 

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for anyone interested in it. On December 25, 2023, Bezeq informed the Ministry of its 
decision  not  to  link  the  said  price  to  the  index  in  2024  and  to  leave  it  at  the 
aforementioned NIS 72. Accordingly, the Ministry does not object to the agreement. 

Some  of  the  information  contained  in  this  section  is  forward-looking  information  as 
defined  in  the  Securities  Law  based  on  Bezeq's  assessments,  among  other  things,  in 
relation to the structure of competition and regulation in the field of communication, the 
behavior  of  communication  operators  and  the  behavior  of  consumers,  as  well  as  in 
relation to how a partner will choose to take advantage of the right to use lines in the 
various regions (distinguishing between areas where only the Company's fiber network is 
deployed  and  areas  where  additional  fiber  infrastructure  to  that  of  the  Company  is 
deployed).  Estimates  and  actual  results  may  vary  depending  on  changes  in  the 
aforementioned variables. 

2.6.4. 

Internet service area 

Multiple unified service operators 

The competition in the field of providing a unified Internet service has increased in  the 
last few years, after Bezeq, and later Hot, were also allowed to provide a unified Internet 
service  (see  Section  1.7.5.1);  Holders  of  special  licenses  were  allowed  to  deploy 
broadband infrastructure and provide services on it, licensed providers without a license 
were  also  allowed  to  do  so,  and  gradually,  they  were  also  allowed  to  use  Bezeq’s 
infrastructure and its wholesale services for that purpose. Also, in the incentive areas, the 
winners of the tenders and other providers are allowed to provide service on an advanced 
network, while the Group is prohibited from doing so for five years from the date of the 
determination  of  the  obligation  to  deploy  in  the  winner's  license  or  by  administrative 
order. For this matter see also see Sections 2.16.4 and 2.16.5. 

Partner and Cellcom launched and began marketing the internet service over fiber several 
years before the Company, which gave them an advantage over Bezeq. Bezeq markets 
the service over fiber from March 2021 (and the unified service from April 2022). 

As  of  2015,  the  wholesale  market  allows  Internet  providers  and  related  companies  to 
offer customers service packages that also include Internet infrastructure based on Bezeq 
infrastructure  and  services  in  return  for  payment  (the  Company's  maximum  rates  are 
regulated). 

The  service  providers  are  allowed  to  provide  BSA  service  also  on  the  Company's  fiber 
infrastructure in return for payment (the Company's maximum rates in this segment are 
also regulated). It should be noted that the provider that deploys infrastructure in the 
incentive area (whose license or an administrative order issued to an NIO determines the 
obligation  to  deploy  an  advanced  network  according  to  Article  14d(f)  of  the 
Telecommunications Law) is also obligated to provide BSA service via fiber in the incnetive 
areas. 

The cellular companies have deepened their activities in the internet field on the cellular 
medium both in the private segment and in the business segment. Browsing services are 
provided both from the cellular device and through a cellular modem that connects to 
mobile and stationary computers. 

2.6.5. 

The field of telephony 

The field of private landline telephony is characterized by a decrease in the number of 
owners  of  a  landline  telephone  line  and  a  gradual  erosion  in  the  number  of  calls 
originating from landline networks (see Section2.1.3.2). Bezeq estimates that in 2024 the 
entire telephony market continued to erode at a similar rate to 2023. For this matter, see 
also Section2.4. Since not all competitors in the field are reporting corporations and their 
data is not public, it is not possible to detail the market shares of the competitors in the 
field. 

2.6.5.1 

Competition from additional NIO licensees  

Bezeq and Hot Group have a fixed telephony infrastructure nationwide, and 
there is competition between them, which is reflected, among other things, 
in  the  fact  that  Hot  Group  markets  a  "Triple"  (which  combines  Internet 
infrastructure,  telephony  and  cable  television),  and  possibly  also  cellular 

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services,  especially  for  households.  In  addition,  Hot  Group  markets 
telephony services for business customers. 

In addition, there is competition with licensees for the provision of landline 
interior communications services, including VoB (see Section 2.1.8), which 
provide  the  service  (including  via  "Triple"),  inter  alia,  over  Bezeq's 
broadband access service, including the wholesale BSA service. 

As of July 2017, Bezeq allows holders of unified licenses who are authorized 
to provide NIO services, reselleing telephony service over Bezeq’s network. 
As  of  the  date  of  the  report,  there  is  no  demand  for  service.  For  the 
wholesale telephony service, see Section2.16.4. 

2.6.5.2 

Telephony competition from cellular companies  

Bezeq is of the opinion that  the high  penetration rate of  cellular phones, 
combined  with  low  airtime  rates  compared  to  the  rest  of  the  world, 
packages that include call minutes with no effective limit on a fixed monthly 
fee,  and  diminishing  interconnect  rates  have  made  cellular  telephony  a 
substitute for landline telephony. In Bezeq's estimation, the deepening of 
the  interchangeability between a  landline and a  mobile line is one of the 
main reasons for the decrease in the average traffic per line, and the high 
rate of removal of telephone lines (see section2.1.3).  

In the field of cellular telephony, there is a trend of moving to the use of 
applications  allowing  you  to  make  calls  and  send  text  messages  over  the 
Internet.  

Partner and Cellcom also provide landline NIO services through corporations 
owned  by  them  and  also  sell  service  baskets  that  combine  landline 
telephony, cellular telephony and Internet services.  

2.6.6. 

The field of transmission and data communication 

In this field there is increasing competition, when, mainly Cellcom , Partner and Hot, as 
well as ISP companies operate in this field in addition to Bezeq. 

To the best of Bezeq's knowledge, Cellcom has established a transmission network, which 
is  used  both  for  its  own  needs  and  for  competition  with  Bezeq’s  services  in  the 
transmission  and  data  communications  market.  Partner  also  operates  in  the  field  of 
providing transmission and data communication services, combined with telephony and 
Internet,  to  business  customers  (Regarding  the  sale  of  Cellcom's  network  to  IBC,  see 
Section 2.6.2.1). 

Cellcom and Partner use Bezeq's physical infrastructure as part of the wholesale service 
(see Section0)27, inter alia, in order to compete with Bezeq in this field.  

Operating in this field are also infrastructure owners IBC and Hot. These infrastructure 
owners may use Bezeq's physical infrastructure. In this matter see Sections 0 and2.6.7. 

IBC’s is allowed to provide IPVPN services and broadband data communication lines. 

2.6.7. 

Additional competing infrastructures28 

In  addition,  there  are  currently  a  number  of  infrastructures  in  Israel  that  have  the 
potential to serve as communications infrastructures, which are based on fiber optics and 
mostly owned by companies and government bodies, such as: Israel Railways, Mekorot, 
Oil  Infrastructure  Company  and  Trans-Israel  Highway.  Some  local  authorities  are  also 
trying  to  create  an  alternative  for  laying  pipes  or  fibers  using  their  infrastructures. 
Amendment  76  to  the  Communications  Law  states  that a  service  requested  by  a  local 
authority,  including  a  municipal  company  and  a  municipal  subsidiary  company,  will 
require a license in any case (and not just registration in the registry). It should be noted 
that the amendment of the Communications Law regarding the deployment of fibers and 
the  decision  of  the  Ministry  regarding  the  granting  of  special  licenses  that  allow  for  a 
limited deployment may accelerate the deployment by such bodies. 

27 Unified license owners eligible to provide NIO services are also eligible to receive wholesale service for the use Bezeq’s physical infrastructure.  
28 Beyond Hot and IBC infrastructure. 

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2.6.8. 

Bezeq's preparations and ways of dealing with the growing competition  

Bezeq faces competition in the landline interior Bezeq services in a number of ways: 

Bezeq is working to introduce the high-speed Internet service and to increase the number 
of  its  customers  in  this  field  (see  also  Sections  2.2.3  and2.7.2).  In  March  2021,  the 
Company launched the fiber service on an advanced network deployed in the statistical 
areas (see Sections 2.7.2.2 and 2.6.5). 

2.6.8.1 

2.6.8.2 

2.6.8.3 

2.6.8.4 

2.6.8.5 

As of 2018, Bezeq has been marketing its Be router (in version upgrades over 
the  years).  This  is  an  advanced  router  with  an  innovative  design  and 
advanced  capabilities  that  include,  among  other  things,  Smart  Wi-Fi  that 
enables quality and continuous browsing over the home Internet and Cyber 
protection. The router and services are managed by a dedicated app. Bezeq 
also  markets  products  to  improve  the  reception  range  of  the  Be  spot 
(including a fiber-optimized version) and Be mesh home Internet networks. 
With the advent of Internet services on the fiber, a router was launched that 
improves the reception range that is compatible with the fiber network at 
ultra-fast speeds. 

In May 2023, Bezeq, together with the global company "Nokia", conducted 
an experiment  in which the  ability to provide rates of up to 25 gigabytes 
with  advanced  technologies  was  demonstrated,  and 
it 
announced a future road map for the development of rates and services that 
includes the launch of multi-gig rates of up to 10 gigabytes and WiFi7 in 2024 
and  up  to  25  gigabytes  in  2027,  advanced  WiFi  standards  and  upgrading 
Bezeq's Be router. 

in  parallel, 

Bezeq is constantly working to improve the quality of its services and retain 
its customers, simplify processes and automate and adapt its operations to 
the structure of competition in its areas of activity. 

Bezeq offers to telephony customers packages, consumption-adjusted plans 
and promotions. 

Bezeq is working to reduce its operating expenses and to focus investments 
on  growth  activities  and  as  a  means  of  reducing  maintenance  expenses. 
However, Bezeq's ability to make short- and medium-term adjustments to 
its expenses is limited due to its cost structure, which is mainly rigid short- 
and medium-term costs (mainly depreciation and payroll-related expenses, 
as  well  as  operating  costs, such  as  infrastructure  maintenance  and  rental 
and maintenance of buildings). 

is 

launching  new  communication  services  and  value-added 
Bezeq 
applications (such as BIZFIBER, integration services, etc.), as well as product 
and  service  packages  and  shared  baskets  (similar  to  certain  baskets 
marketed by its competitors, although subject to a detachability limit - see 
Section 1.7.3.1), in order to expand the scope of the use of subscriber lines, 
to respond to customer needs, and to strengthen the image of technological 
innovation.  Bezeq  invests  in  the  improvement  and  modernization  of  its 
infrastructure, to enable the provision of advanced services and products to 
its subscribers. 

Bezeq has launched a number of business services under a branding called 
"Bezeq Business Pro" which includes security services, business networking, 
integration,  and  expansion  of  the  Metro  service  into  a  comprehensive 
package  called  Metro  PRO  and  a  HYPER  CONNECT  service  that  enables  a 
stable  and  secure  connection  to  global  and  local  public  cloud  providers. 
Also, Bezeq is working to upgrade the transmission lines to high rates. 

2.6.9. 

Main positive and negative factors affecting Bezeq's competitive position 

2.6.9.1 

Positive factors  

a.  Quality nationwide infrastructure, through which a variety of services 

are provided. 

b.  Presence in most businesses and households. 

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c.  A well-known and strong brand. 

d.  Technological innovation. 

e.  High  positive  cash  flow,  financial  resilience  and  access  to  financing 

sources 

f.  Extensive service infrastructure and diverse customer interfaces. 

g.  Professional, experienced and skilled personnel. 

2.6.9.2 

Negative factors  

Bezeq believes that various restrictions that apply to it make it difficult for 
it to compete in its areas of activity. The following are the main limitations 
in this regard: 

a.  Limited rate flexibility  

Bezeq  is  limited  in  its  ability  to  offer  differential  rates  on  its  main 
services. 

For  the  hearing  on  the  prevention  of  "margins  reduction"  in  the 
wholesale market, see Section 2.16.4.2. 

b.  Structural separation obligation and limitations in the marketing of joint 

service packages of Bezeq and Group companies; 

For this matter, see Section1.7.3. 

c.  The universal service and fiber deployment obligation 

Bezeq  has  an  obligation  to  provide  service  at  a  uniform  price  to  the 
general  public  in  Israel  (universal  service),  except  in  relation  to 
advanced network (fiber). By virtue of this obligation, Bezeq is required 
to provide services even in non-economic circumstances (subject to the 
possibility  of  obtaining  an  exemption  in  exceptional  circumstances). 
Regarding  the  scope  of  the  obligation  in  relation  to  the  provision  of 
services on an ultra-broadband fiber infrastructure, see Section 2.16.5. 
This  obligation  does  not  apply  to  other  authorized  providers  for  the 
provision of stationary services (except Hot. Regarding Hot and IBC, see 
Section 2.6.2.1), who may offer their services to profitable customers 
only, who constitute a substantial source of revenue for Bezeq. These 
companies  has  carried  out  and  are  carrying  out  an  accelerated 
deployment  of  fibers  in  economically  viable  areas.  In  addition,  Hot, 
which has a universal service obligation, received various reliefs in the 
implementation of full deployment  obligation, significant  exemptions 
and reliefs were granted to IBC, and Bezeq is committed to allowing Hot 
and IBC to use Bezeq's passive infrastructure. (see section2.16.4). 

d.  The nature of end equipment in landline telephony 

End equipment in the field of landline telephony does not have personal 
characteristics.  It  is  also  less  technologically  advanced  compared  to 
cellular end equipment, and the range of advanced services that can be 
consumed through it is limited. 

2.7. 

Property, plant and equipment and facilities 

2.7.1. 

General 

Bezeq's property, plant and equipment include, mainly: infrastructure and equipment for 
interior  communications,  real  estate  assets  (land  and  buildings),  computer  systems, 
vehicles and office equipment. 

2.7.2. 

Infrastructure and stationary interior communications equipment  

2.7.2.1 

Telephony network 

The  infrastructure  of  Bezeq's  telephony  network  consists  of  exchanges 
(used  to  switch  the  calls  and  transfer  them  from  the  origin  to  the 
destination),  a  transmission  network  (through  which  the  connection 

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between the exchanges takes place), data communication networks and an 
access network (connecting the subscriber's endpoint to the switchboard). 
The  infrastructure  connects  to  the  end  equipment  installed  with  the 
subscriber. The connection from the end equipment to the access network 
is based on copper cables, and this copper network forms Bezeq's access 
infrastructure for telephony services (it should be noted that those copper 
cables  also  form  part  of  Bezeq's  Internet  network  as  detailed  below). 
Subscriber management is performed using a Class 5 telephony switch and 
operator relationship management using a Class 4 switch. All switches are 
backed  up  and  survivable  in  different  farms,  as  well  as  all  telephony 
components. 

2.7.2.2 

Data transfer network and transmission 

Bezeq's fiber infrastructure for private customers began to be deployed in 
2020 and enables ultra-broadband rates. As of the publication date of the 
report,  this  network  has  been  deployed  to  approximately  2.16  million 
households  nationwide  that  are  available  for  commercial  connection,  of 
which approximately 619K subscribers have been connected (of which 397K 
are retail and 222K are wholesale). 

This  infrastructure  is  based  on  GPON  technology  and  currently  allows 
bandwidths of up to 2.5Gbs in the downlink channel. 

For  the  amendment  of  the  Bezeq  license  and  the  selection  of  the  fiber 
network deployment areas by it, see Section 2.16.5. 

In parallel with this infrastructure, the NGN network based on fiber optic 
infrastructures  for  street  cabinets  (FTTC)  also  operates,  and  on  an  access 
network based on all copper cables from the street cabinets to the terminal 
point of the network with the subscriber (mentioned in the description of 
the telephony network above. See section 2.7.2.1). Over this network it is 
currently  possible  to  provide  bandwidths  of  up  to  200  Mbs  downlink 
depending on the quality of the copper infrastructure. 

This data transmission network is used by the Internet providers in Israel as 
a dual access network in a wholesale model, based on both xDSL technology 
over copper infrastructure and GPON technology over fiber infrastructure 
to the customers' homes. All access infrastructures are linked at a national 
level through an advanced MPLS network to all providers in Israel and for 
Bezeq's own use. The MPLS network enables the implementation of reliable 
and efficient national connectivity for various uses, at a national level. 

Bezeq  has  two  parallel  MPLS  networks  from  different  equipment 
manufacturers  for  backup  and  survivability  in  different  implementations. 
These  networks  provide,  in  addition  to  the  Internet  service,  IP  Layer  3 
transmission services, cellular backhaul connection services as a service for 
a cellular bundle, as well as metro transmission services (Ethernet Layer 2 
connectivity)  with  a  high  level  of  performance  and  great  flexibility.  The 
services are provided over Bezeq's infrastructure using new and advanced 
communication systems that allow the transfer of large volumes of traffic 
between  sites  for  a  variety  of  applications.  Also,  the  services  include 
advanced options of full Bezeq management or independent management, 
which allow the business customer better control over the management of 
the corporate communication network. 

Since receiving the license to operate as an ISP (see  Section 2.2.3), Bezeq 
has added an ISP Internet provider infrastructure, backed up and survivable 
on  two  sites.  This  infrastructure  includes  an  IP  network,  a  customer 
connection system, a valid IPv4 address sharing system in the CGNAT model 
(address  translation  and  sharing)  with  full  support  for  IPv6  as  well.  The 
network is currently being deployed in 3 more sites in Europe to enable the 
use of content from the global Internet in a flexible and efficient manner. 
Most of the end equipment (equipment installed by the subscriber such as 
routers) is owned by Bezeq and is rented by the customer. The following is 
a description of the development of a number of households available for a 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

commercial connection in Bezeq's fiber network as well as the total number 
of subscribers in Bezeq's fiber network: 

Households abvailable for econenction 
(Homes Passed, thousands) 

2.7.2.3 

Public appeal – closure of the copper networks 

On September 19, 2022, Bezeq accepted a public appeal published by the 
Ministry  of  Communications  regarding  policy  principles  for  closing  the 
copper networks, in which the Ministry reviews the main issues, challenges 
and principles for closing the copper networks and transitioning to networks 
based  on  fiber  infrastructure.  According  to  the  public  appeal,  there  are 
several possible regulatory actions that the Ministry of Communications can 
take  regarding  the  closure  of  the  copper  networks,  among  other  things, 
establishing an outline and milestones for the implementation of the closure 
of the copper networks, and it asked the public and all license holders to 
submit references and positions to the public appeal. Bezeq submitted its 
comments, according to which, in view of the complexity of the issue, the 
handling  and  phases  must  be  separated  between  existing  customers  on 
copper  infrastructure  and  customers  in  new  neighborhoods  and  service 
areas,  in  a  process  that  begins  with  stopping  the  deployment  of  a  new 
copper network and providing solutions for connecting new lines. 

2.7.2.4 

Millimeter waves 

Millimeter  wave  technology  makes  it  possible  to  transfer  wirelessly  a 
significantly larger bandwidth than the technologies that were available in 
the  past.  The  technology  can  be  used  both  point-to-point  and  point-to-
multipoint and is a solution for the final segment, that is, the connection to 
the subscriber's endpoint. Through the use of this technology, it is possible 
to connect (to the access of the Ministry of Communications after approval) 
extensive  areas  relatively  quickly  and  at  lower  costs  compared  to  the 
deployment of a wired infrastructure. 

2.7.3. 

Computing  

Bezeq's  computing  system  supports  four  main  areas:  marketing  and  customer 
management,  Bezeq's  engineering  infrastructure,  Bezeq's  resource  management  and 
lateral systems. 

Bezeq's computer system is large and complex,  it supports critical work processes and 
handles very large volumes of data. This system consists of a large number of systems, 
some are information systems whose development began many years ago, and some of 
which are modern systems developed and implemented in recent years. Most systems 
operate in open computing environments. 

2.7.4. 

Real estate 

2.7.4.1 

General 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Bezeq has real estate assets from four sources: assets transferred to Bezeq 
by the  State in 1984 as part of the asset  transfer agreement  (see  Section 
2.17.2.1), assets the rights in which were acquired by Bezeq after this date, 
assets  that  it  leases  from  third  parties,  and  assets  in  which  Bezeq  has 
received a right-of-use, according to the provisions of the Communications 
Law  and  the  regulations  established  pursuant  to  it,  for  the  purpose  of 
providing Bezeq services and/or performing Bezeq operations, whether or 
not there is a written arrangement of rights. In addition, the Company has 
easements (rights of passage, etc.) in other real estate for the purpose of 
providing Bezeq services (such as for laying cables).. 

The following is a list of Bezeq assets in accordance with the nature of the 
rights in the asset. In addition, Bezeq has easements (passage rights, etc.) in 
other  real  estate  (such  as  for  the  purpose  of  setting  up  transmitters  and 
laying cables): 

The essence 
of the right 

Number 
of assets 

Lot area 
(sqm. 
thousands) 
Approx. 
836 

Built-up 
area (sqm. 
thousands) 
Approx. 83 

Approx. 
301 

Ownership, 
lease or 
right to 
lease 

Possession 
(authorized 
by right / 
right of 
possession 
according to 
law) 
rent 

Various 
rights in 
"concentrat
ion rooms" 

Approx.  
40 

Approx.  
1.5 

Approx. 0.8  

Approx. 
330 

Approx. 31 

Approx. 65 

Approx. 
703 

Irrelevant 

Approx. 27 
(based on 
an estimate) 

Notes 

From  this,  approx..  297  field  assets  in  the  area 
approx. 817K sqm. of plots, approx. 72K sqm. built-
up are assets for communication needs and the rest 
are for administrative needs. 

Properties in Israeli localities in Judea and Samaria, 
all  for  communication  purposes.  There 
is  no 
written series of contractual rights, but in Bezeq's 
opinion this does not create material exposure. 

rooms  and 

Approx.  313  assets,  of  which  a  built-up  area  of 
about 17k sqm. are for communication needs and 
the rest for administrative needs. Approx. 2k sqm. 
built-up of which are sublet. 
These  are  cable 
neighborhood communication needs. 
As for most of the properties, this is a right-of-use 
granted 
the 
Communications  Law  and  regulations  thereunder, 
and there is no written rights arrangement with the 
asset owners. In Bezeq’s opinion and based on past 
experience, this does not create material exposure. 

in  accordance  with 

to  Bezeq 

facilities 

for 

2.7.4.2 

Registration 

As of the date of the periodic report, Bezeq's rights in a significant portion 
of  its  real  estate  assets  are  not  registered  with  the  Land  Registry,  and 
therefore  are  contractual  rights.  Bezeq  is  in  the  ongoing  process  of 
registering in its name the real estate assets that can be registered with the 
Land Registry. 

2.7.4.3 

Settlement agreement regarding the real estate 

On March 10, 2004, an agreement signed on May 15, 2003 between Bezeq 
and  the  Israel  Land  Administration  (now  ILA)  and  the  State  ("Settlement 
Agreement")  regarding  most  of  the  real  estate  assets  which  were 
transferred to Bezeq as part of the transfer agreement signed prior to the 
beginning of Bezeq's business operations was given the validitiy of a ruling. 
The Settlement Agreement stipulated that the assets remaining with Bezeq 
are  in  the  status  of  a  discounted  lease,  and  subject  to  the  signing  of 
individual lease contracts, Bezeq will be entitled to carry out any transaction 
in the assets, as well as improvement operations. The agreement stipulates 
a mechanism for payment to ILA for improvement actions to be performed 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

on  the  assets  (if  any)  beyond  rights  under  plans  approved  until  1993  as 
stipulated in the agreement, at a rate of 51% of the increase in value of the 
asset  following  the  improvement  actions  (when  in  the  event  that  the 
Company also pays an improvement levy for that improvement operation, 
it will be entitled to receive from ILA a refund of half of the payment paid to 
RAMI due to the increase in value or from the improvement levy, whichever 
is the lower). The Settlement Agreement also stipulates that 17 assets will 
be  returned  to  the  State,  through  ILA,  on  various  dates  (until  2010)  and 
under the conditions set forth in the Settlement Agreement. 

As  of  the  publication  date  of  this  periodic  report,  Bezeq  has  returned  15 
properties to Ila. Another property will be returned to Ila during the year 
2024  after  the  completion  of  the  vacating  procedure,  after  Bezeq  has 
received a replacement in accordance with the Settlement Agreement. 

2.7.4.4 

Real estate exercise 

General 

Subject to the approval of Bezeq’s Board of Directors, Bezeq continues to 
act  for  the  sale  of  assets  that  are  inactive  and  /  or  that  can  be  vacated 
relatively easily and without significant expenses, or that the consideration 
for  them  justifies  the  presentation  of  another  suitable  alternative,  and 
during the last few years Bezeq has sold such assets while registering equity 
gains for these sales, which in some years were substantial. 

Bezeq has completed the sale of most of the assets (in terms of value) that 
met the aforesaid definition and intends to complete the sale of the balance 
of such assets in the coming years. The sale of the balance of such assets 
may yield Bezeq additional capital gains in substantial amounts (although in 
a  significantly  lower  amount  than  the  cumulative  amount  of  equity  gains 
that Bezeq has recorded in recent years for the sale of said assets). 

It should be emphasized that the aforesaid also applies to real estate assets 
for the sale of which a concrete decision has not yet been made and there 
is no certainty as to the timing of their sale, if it is decided to sell them. Also, 
the sale of some assets may involve difficulties, including circumstances of 
lack of demand or various planning constraints. 

In light of the aforesaid, it should be emphasized that Bezeq's assessments 
as  aforesaid  are  forward-looking  information  as  defined  in  the  Securities 
Law,  which  may  not  materialize  or  materialize  in  a  materially  different 
manner  than  anticipated.  These  assessments  are  based,  among  other 
things, on Bezeq's assessments of the value of the real estate assets it owns 
in  relation  to  their  book  value,  since  Bezeq  does  not  have  appraisals  in 
relation  to  some  of  the  assets,  or  Bezeq's  appraisals  are  not  up-to-date, 
therefore,  the  assessments  are  also  based  on  Bezeq's  internal  estimates, 
Bezeq  cannot  anticipate  the  amount  of  consideration  actually  paid  in 
respect of the assets to be sold (if and to the extent that they are sold). 

The asset in Sakia 

On January 21, 2018, Bezeq entered into an agreement for sale of an near 
the  Mesubim  junction  where  Bezeq  had  a  discounted  lease  right  (“the 
Assets”). On May 5, 2019, the transaction was completed, when the total 
consideration received by Bezeq for the asset (including linkage differences 
and interest in accordance with the provisions of the agreement) amounted 
to NIS 511 million, plus VAT. 

On May 21, 2018, Bezeq received a demand from ILA for the payment of a 
permit fee in the amount of NIS 148 million plus VAT, in respect of a property 
improvement plan that was approved prior to the signing of the agreement 
(“the Improvement Plan"). Bezeq filed an appeal on legal grounds to this 
demand  January  20,  2019,  ILA  rejected  all  of  Bezeq's  claims  in  the  legal 
attainment, however, the parties conducted contacts within the framework 
of the dispute resolution mechanism set forth in the Settlement Agreement. 
At the same time, Bezeq submitted an appraisal contention on the Demand. 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

On  August  5,  2018,  Bezeq  received  a  demand  from  the  Or  Yehuda  Local 
Planning and Construction Committee to pay an improvements levy in the 
amount of NIS 143.5 million due to the sale of the  asset by way of a sale 
("the Improvements Levy Demand”). On September 17, 2018, Bezeq filed 
an appeal against the Improvements Levy Demand, and sent ILA a demand 
for  payment  of  the  full  improvements  levy  in  accordance  with  the 
Authority's  obligation  under  the  Settlement  Agreement.  On  January  20, 
2019, ILA rejected Bezeq's demand for payment of the said improvement 
levy. Upon completion of the sale transaction as stated above and receipt 
of the full consideration, Bezeq paid half of the improvements levy in the 
amount of NIS 75 million and provided a bank guarantee for the other half 
of the levy, without detracting from or harming the proceedings that Bezeq 
has taken or will take in order to cause the cancellation or reduction of this 
levy. 

On June 27, 2021, Bezeq filed a lawsuit against ILA with the District Court in 
Tel  Aviv  to  recover  all  of  the  funds  it  paid  as  permit  fees  and  the 
improvement  levy  in  a  total amount  of  approximately  NIS  217  million,  as 
well as to receive declaratory relief according to which ILA must pay Bezeq 
any amount that is forfeited, if any, out of the bank guarantee in the amount 
of NIS 75 million that Bezeq provided to the Or Yehuda Local Planning and 
Construction Committee to guarantee the balance of the improvement levy. 
As  part  of  the  lawsuit,  Bezeq  claimed  that  it  is  not  obligated  to  pay  the 
permit  fee  and  the  improvement  levy  since,  in  accordance  with  the 
provisions of the settlement agreement signed between itself, ILA, and the 
State of Israel, it was entitled to receive the lease contract relating to the 
asset  when  it  is  improved  according  to  the  plan  and  without  paying  the 
permit fee to ILA, and that the liability The payment  of the improvement 
levy applies in accordance with the provisions of the settlement agreement, 
to ILA. 

On January 17 ,2022, the Israel Land Authority filed a letter of defense in 
which  it  argued  that  the  lawsuit  should  be  dismissed  for  the  following 
reasons:  (1)  The payment  of  the permit fee,  which  Bezeq  demands to be 
returned,  was  lawfully  imposed  on  Bezeq,  since  the  Improvement  Plan 
deviated  from  the  limited  rights  granted  to  Bezeq  in  the  settlement 
agreement; (2) With regard to Bezeq's claim to receive from the Authority 
the  improvement  levy  that  Bezeq  paid  to  the  Local  Committee,  the 
Authority's obligation in the settlement agreement to pay the improvement 
levy, on which Bezeq bases its claim, was in relation to the above limited 
rights, and today it is not possible to calculate the share of the improvement 
levy that applies to Bezeq for the deviation from the restricted rights in the 
Improvement Plan. 

It should be noted that the amount of the permit fee that will be imposed 
on the Company at the end of the procedures can also affect the amount of 
the improvement levy that the Company will have to bear. In the Company's 
estimation, the amount of the permit fee and the improvement levy it will 
be  required  to  pay  is  expected  to  be  substantially  lower  than  the  total 
amount of the requirements. therefore, Bezeq recorded an equity gain of 
NIS  403  million.  The  equity  gain  recorded  as  aforesaid  is  on  the  basis  of 
Bezeq's  assessment  regarding  the  amount  of  the  permit  fee  and  the 
improvements levy that it will be required to pay as aforesaid. To the extent 
that Bezeq’s aforesaid estimates do not materialize, the final capital gain will 
range from approximately NIS 250 million to approximately NIS 450 million. 
For this matter see also Note 6.6 to the 2023 statements. 

On January 1, 2023, in an interim decision, the appeals committee dismissed 
Bezeq's claim that at the time the improvement plan was approved, it did 
not  own  rights  for  which  it  could  be  charged  the  improvement  levy.  An 
appeal filed by Bezeq with the District Court was dismissed on October 17, 
2023.  Following  the  aforementioned  interim  decision,  Bezeq's  claims 
regarding the amount of the improvement will be discussed in the appeals 
committee.  It  will  be  clarified  that  the  aforementioned  interim  decision 

54 

 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

does not lead to a change in the Company's estimates regarding the amount 
of  equity  gain  recorded  as  mentioned,  since  Bezeq's  estimates  were  also 
based on the legal situation in the lawsuit against Rami , which as mentioned 
also includes an obligation on the part of ILA in the settlement agreement 
to bear the improvement levy for the asset. 

The information contained in this section regarding Bezeq valuations and 
capital  gains  as  a  result  of  the  sale  of  the  asset  is  forward-looking 
information as defined in this term in the Securities Law, and is based, inter 
alia,  on  the  above  as  well  as  on  Bezeq's  assessments  of  the  Company’s 
claims regarding the payment of the requirements. The information may not 
fully  materialize  as  long  as  the  said  Bezeq  assessments  take  place  in  a 
manner different than expected. 

2.8. 

Intangible assets  

2.8.1. 

Bezeq's licenses 

Bezeq operates under an NIO license, which, among other things, forms the basis for its 
activity  in  the  field  of  landline  interior  communications  (for  a  description  of  the  main 
points of the NIO license, see section2.16.2). Also, the Company has a general NIO license 
for the Judea and Samaria region (see Section 2.16.2.9). 

2.8.2. 

Trademarks 

Bezeq  uses  trademarks  that  characterize  its  services  and  products.  As  of  the  date  of 
publication  of  the  periodic  report,  approximately  160  trademarks  are  registered  in 
Bezeq's name, or are in the process of being registered with the Registrar of Trademarks 
as  well  as  three  samples.  The  main  trademarks  are  Bezeq  –  Bezeq’s  name,  and  "B"  – 
Bezeq’s logo.  

2.9. 

Human capital 

2.9.1. 

Organizational structure and employee base according to organizational structure 

The following is a diagram of Bezeq's general organizational structure as of December 31, 
2023: 

Board of 
Directors

CEO

Group Secretary and 
Internal Compliance 
Office 

Internal 
Auditor

Corporate 
Communication, 
Responsibility, 
Governmnet 
Relations

Legal 
Advisor

Management 
(without directors) 
)34( 

Economu and 
regulation 
Division

Finance 
Division 

Marketing 
and 
Innovation 
Division 

Operation
s and 
Logistics 
Division

Human 
Resources 
Division 

Technolog
y and 
Network 
Division

Business 
Division

Private 
Division

( 

1619

)

( 

779

)

( 

2462

)

Staff divisions) 
)853( 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

2.9.2. 

Number of Bezeq employees and employment frameworks 

The  number  of  employees  at  Bezeq  as  of  December  31,  2023  was  5,432  employees 
(compared to 5,598 employees at the end of 2022). About 93% of Bezeq employees are 
employed  under  collective  agreements  (of  which  approximately  57%  are  permanent 
employees and the rest are non-permanent employees). The rest of Bezeq’s employees 
(approximately 7%) are employed under individual agreements not within the framework 
of the collective agreements. 

For  details  regarding  the  special  collective  agreement  from  December  2006  and  its 
amendments, see Section2.9.4. 

2.9.3. 

Early retirement plans for employees 

During 2023, 83 permanent Bezeq employees retired in accordance with the retirement 
plan in Bezeq. 

On December 13, 2023, as part of the implementation of a streamlining plan and under 
the collective agreement in Bezeq, Bezeq’s Board of Directors approved the retirement 
of  approximately  50  veteran  permanent  employees  during  2024  through  the  early 
retirement track at a total cost of approximately NIS 55 million. In light of the aforesaid, 
Bezeq recorded an expense accordingly in its statements for the fourth quarter of 2023. 

For this matter see also Note 16.5 to the 2023 statements.  

2.9.4. 

The nature of the employment agreements with Bezeq  

The  employment  relationship  with  Bezeq  is  regulated  in  collective  agreements  signed 
between Bezeq and the representatives of Bezeq employees and the Histadrut, and in 
individual agreements. Bezeq employees are also subject to extension orders for certain 
general collective agreements, such as cost of living increase agreements. 

The following are the main points of the special collective agreement between Bezeq, the 
employees’ organization and the Histadrut from December 2006 and the amendments to 
it that have been signed over the years (all together will be referred to in this section as 
"the Agreement"), which regulates labor relations in the Company: 

According  to  the  Agreement,  all  existing  agreements,  arrangements  and  practices  at 
Bezeq on the eve of the signing of the Agreement, including the wage linkage mechanism 
for  the  public  sector,  will  continue  to  apply  only  to  Bezeq's  veteran  permanent 
employees, to whom the Agreement applies, subject to changes explicitly included in the 
Agreement. The employment of existing and new temporary  employees will be carried 
out on the basis of monthly / hourly wage agreements based on a market wage model by 
occupation, with high managerial flexibility. The Agreement set limits on certain types of 
future  organizational  changes,  as  well  as  a  mechanism  for  notification,  dialogue  and 
arbitration with the employees’ organization in the event of organizational changes. 

According to the Agreement, during the period of validity of the Agreement, two directors 
from  among  the  employees  will  serve  on  Bezeq's  Board  of  Directors29  which  will  be 
proposed by the employees' organization (subject to the approval of their identity by the 
Chairman of the Board and their election to the general  assembly). The directors from 
among the employees are not entitled to payment for their office as directors and do not 
participate  in  Board  of  Directors  discussions  dealing  with  the  terms  of  employment  of 
senior executives. 

The  Agreement  defined  the  status  of  "new  permanent  employee",  whose  terms  of 
employment are different from Bezeq's veteran permanent employee (according to the 
collective  agreement):  his  salary  model  is  in  accordance  with  Bezeq's  salary  policy  in 
accordance with market wages. Upon termination of his employment with Bezeq, he will 
be entitled to an increased severance track only (in accordance with seniority). 

29   At the beginning of 2016, the employees' representation announced that it agrees that as long as up to 15 directors serve 
on Bezeq’s Board of Directors, one representative from among the employees will serve on the Board, and as the number 
of directors exceeds 15, another representative from among the employees will serve on the Board. 

56 

 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

The period of the agreement is until December 31, 2025 and the period of the retirement 
arrangement in the collective agreement is until December 31, 2026. 

As part of the retirement arrangements (as in effect as of the date of publication of the 
report  and  as  arranged  as  part  of  the  amendment  dated  December  16,  2020  to  the 
collective  agreement)  Bezeq  may,  at  its  discretion,  terminate  the  work  of  up  to  80 
permanent  employees  (including  employees  with  the  status  of  "new  permanent 
employee")  in  any  year  (and  this  is  in  addition  to  the  retirement  quota  of  about  300 
permanent  employees  that  was  not  realized  according  to  the  agreement,  whose 
employment Bezeq could terminate at the end of the agreement period).. 

For a list of other material agreements in the field of labor relations, see section 2.17.3. 

Further to the move to amend the Communications Order regarding the possession of 
means of control in Bezeq (see Section 1.1.2) and to the negotiations conducted between 
Bezeq  and  the  employees’  organization  to  amend  the  Bezeq  collective  bargaining 
agreement  following  that,  on  September  18,  2023,  an  amendment  (No.  7)  (“the 
Amendment")  to  the  agreement  was  signed,  and  this  after  Its  approval  by  Bezeq's 
authorized  institutions,  including  the  approval  of  the  general  assembly  of  Bezeq's 
shareholders on September 14, 2023. 

The following are the main points of the amendment: 

1.  Maintaining Bezeq's financial resilience, including, maintaining the status of a public 
company,  Bezeq's  current  credit/debt  rating,  and  a  percentage  of  holdings  in 
Pelephone that will not be less than 50.01%. 

2.  Making a dividend distribution to Bezeq's shareholders subject to the law and while 
maintaining Bezeq's current  credit/debt  rating, while  regarding a  distribution that 
does not meet the profit test only - the consent of the employees’ organization will 
also be required. 

3.  Payment  of  a  special  bonus  to  Bezeq  employees  in  the  amount  of  NIS  75  million, 
most of which is conditional on the dates and conditions set forth in the amendment 
depending on the change in the percentage of holdings of the current control permit 
holders in Bezeq (or the expiration/cancellation/transfer of the control permit) ("the 
Conditions"). 

4. 

5. 

If the Conditions are met, Bezeq will pay a monthly supplement of NIS 2,400 linked 
to  the  Consumer  Price  Index,  and  the  Company  will  pay management  fees  to  the 
pension fund for veteran permanent retirees who have retired or will retire from the 
Company as of July 1, 2023. 

If the Conditions are met and in the absence of a controlling interest in Bezeq, the 
employees’  organization  has  the  right  to  appoint  an  additional  (second) 
representative  from  among  the  employees,  if  the  number  of  Board  of  Directors 
members  exceeds  eleven  (11)  (including  external  directors  and  a  director  from 
among the employees). 

6.  The validity of the amendment is from July 1, 2023 until December 31, 2025, when 
in relation to some of the arrangements a later validity is determined as detailed in 
the  Amendment.  The  Amendment  exhausts  all  the  claims  of  the  parties  and  the 
parties  will  maintain  industrial  peace  in  the  matters  regulated  therein  during  its 
period of validity, and in any matter related to changes in the holdings of the present 
control permit holders even after the expiration of its period of validity. 

Nothing in this section and in the fact of signing of the Amendment is sufficient to testify 
that Bezeq has any information regarding a possible change of control. 

2.9.5. 

Officers and employees of Bezeq's senior management 

As of the date of publication of the periodic report, Bezeq has 8 directors, of which three 
are external directors, one independent director (who is not an external director) and 4 
directors  who  are  not  independent  directors  (including  one  director  from  among  the 
employees). In addition, Bezeq has 11 senior management members.  

Senior  management  members  are  employed  under  personal  agreements  that  include, 
but  are  not  limited  to,  pension  coverage,  payment  of  target-based  bonuses  and  early 
notice period upon retirement.  
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For details regarding compensation for officers, see Section 7 of Chapter D of this periodic 
report and Note 29 of the 2023 statements. 

On  December  10,  2020,  Bezeq’s  Board  of  Directors  approved  an  equity  compensation 
plan (“the Plan") by virtue of which options may be assigned which, as of the date of the 
Board of Directors' approval, represented approximately 2.94% of Bezeq's fuully diluted, 
issued and paid-up equity after exercise. On December 12, 2020 an outline based on the 
plan  (as  amended  on  January  1,  2021,  May  9,  2022  and  December  27,  2023)  was 
published (“the Outline"). The Company makes assignments from time to time by virtue 
of the Outline to office holders and/or employees in the company and its subsidiaries. 

On April 18, 2022, the general assembly of the Company's shareholders approved, among 
other things, an updated compensation policy for a period of three (3) years, effective as 
of January 1, 2022, which includes, among other things, clarifications regarding the return 
of  compensation given on the basis of erroneous financial information, an adjustment 
that  allows  the  awarding  of  performance-dependent  variable  compensation  to  the 
Chairman of the Company's Board of Directors, as well as wording corrections and other 
technical  corrections.  For  more  details  on  the  updated  compensation  policy,  see  the 
immediate report on assembly convening dated March 23, 2022, which is included in this 
report by way of reference. 

Also, on April 20, 2023, the general assembly of Bezeq's shareholders approved, among 
other  things,  various  amendments  to  Bezeq's  compensation  policy,  so  that  the 
compensation policy which  includes such amendments will be in effect for a period of 
three years from the date of the approval. The amendments include, among other things, 
the application of the compensation policy to the Chairman of the Board of Directors, as 
well as the possibility of linking wages to the consumer price index, reflecting expenses 
and  related  conditions,  adjustment  period  grant  and  a  signature  grant  to  officers.  For 
more  details  on  the  updated  compensation  policy,  see  Bezeq's  immediate  report 
(amendment) on the convening of the meeting dated April 4, 2023 included in this report 
by way of reference. 

For the capital compensation plan - see Note 26 to the 2023 statements. 

On November 1, 2023, Mr. Gil Sharon, who serves as  Chairman of the Bezeq  Board of 
Directors, announced his desire to embark on a new path and end his tenure as director 
and Chairman of the Board of Directors of Bezeq (and Bezeq's subsidiaries) within three 
months, at a date to be agreed between the parties and with an orderly transfer of duties. 
Following this, in December 2023, the Bezeq Board of Directors decided to approve the 
appointment of the director Mr. Tomer Raved to serve as the Chairman of the Board of 
Directors of Bezeq and its subsidiaries, starting on January 1, 2024. The terms of office of 
Mr. Raved were approved by the general assembly of Bezeq's shareholders on February 
5, 2024. For this matter, see the report convening a special general assembly of Bezeq's 
shareholders dated December 28, 2023 and the meeting results report dated February 5, 
2024, which are included in this report by way of reference. 

On  February  25,  2024,  the  CEO  of  Bezeq,  Mr.  Guron,  announced  his  desire  to  end  his 
tenure, and he is expected to end his term of office on March 31, 2024. In March 2024, 
the Company's Board of Directors decided to appoint Mr. Nir David, VP of the Company's 
Business Division, as the Company's CEO, and he is expected to begin his term on April 1, 
2024. 

2.9.6. 

Agreements with the employees’ representatives regarding the promotion of treatment 
for the cancellation of structural separation 

As part of Bezeq's activity to cancel the obligation of structural separation between it and 
its subsidiaries (see Section 1.7.3) and in order to promote its activity on an issue that is 
of utmost importance to Bezeq Group, Bezeq has turned to its employees’ representation 
office ("Employees’ Representation") with a request for its commitment to assisting and 
promoting the successful completion of the move, at this stage in regards to the activity 
to cancel the structural separation between Bezeq and "Yes". Following this, on March 3, 
2024,  the  Employees’  Representation, 
in  coordination  with  the  Yes  employees’ 
representation, announced its agreement to Bezeq's request to agree to the move while 
reaching  agreements  between  the  parties  that  include  sharing  and  updating  the 
Employees’ Representation about Bezeq's activities on the subject, including: 

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Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

2.9.6.1 

Notification  and  consultation  with  the  Employees’  Representation  before 
any step that constitutes a structural change within the process. 

2.9.6.2 

Regulating the consequences of the steps in the process on Bezeq and Yes 
employees in a collective agreement (or another agreed upon way), while 
any step with such consequences will not be carried out unilaterally before 
it is settled in a reasonable and fair manner between the parties, while such 
negotiations will also include requirements for settling economic exchanges 
in favor of the employees. 

2.9.6.3 

Applying the arrangement with the required changes to any similar move 
that Bezeq will take in the future in relation to other subsidiaries. 

Bezeq believes that the involvement of the Employees’ Representation of the Company 
and  Yes  will  add  to  and  contribute  to  its  efforts  to  cancel  the  structural  separation 
between the two companies. 

2.10.  Equipment and suppliers 

2.10.2. 

Equipment 

Most of the equipment used by Bezeq is: swithcboards, communication cabinets (MSAG), 
copper cables, optical cables, transmission equipment, data communication systems and 
equipment,  servers,  routers  and  Internet  modems.  Bezeq  purchases  most  of  the 
equipment  needed  for  its  communications  infrastructure  from  Israeli  companies 
associated  with  manufacturers  of  communications  equipment  around  the  world.  In 
addition, Bezeq purchases hardware and software from a number of suppliers. 

2.10.3. 

Rate of purchase from major suppliers and the form of contact therewith 

Bezeq sees as a "major supplier", for the purposes of Article 23 of the First Schedule to 
the Prospectus Details Regulations, a supplier whose scope of Bezeq's annual purchases 
exceeds 10% of the Bezeq’s total annual purchases. 

During 2023, Bezeq had no major supplier as defined above. 

2.10.4. 

Dependence on suppliers 

Most  of  the  equipment  purchased  in  the  fields  of  data  communications,  switching, 
transmission  and  radio  systems  is  unique  equipment  and  the  possibility  of  receiving 
support for it throughout all its years of operation other than from the manufacturer is 
limited. In view of the importance of the manufacturer's support in certain systems used 
by Bezeq, Bezeq believes that it may be dependent on the following suppliers: 

Supplier name 
Nokia  Solutions  and  Networks 
Israel Ltd. 

Juniper Networks 
Cisco / BroadSoft 
Dialogic Networks (Israel) Ltd. 

Adtran Holdings Ltd. 
DELL 

VMware 

Hits Telecom Ltd. 
F5 Networks, Inc 

Field 
Metro transmission and NGN network access systems 
GPON equipment  for the deployment of fiber by the 
Company. 
Metro transmission 
Subscriber switches 
Transition  switchboards  for  linking  operators  to  the 
Bezeq switching network 
Network access systems - NGN 
Hardware and solutions for backups, restorations and 
infrastructure  survivability,  storage 
system  and 
equipment 
Infrastructure  for  most  of  the  server  virtualization 
system 
Be Router 
ISP service (Carrier-grade NAT router) 

Agreements  with  suppliers  on  which  Bezeq  may  have  a  dependency  as  stated  in  this 

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section usually include a warranty period for a period of time and under the conditions 
set forth in the agreements, followed by another period of maintenance or support. If 
necessary,  Bezeq  may  enter  into  an  agreement  with  the  supplier  for  the  provision  of 
support  and  maintenance  services  for  an  additional  period  of  time.  As  a  rule,  these 
agreements  will  include  various  remedies  to  Bezeq  in  the  event  of  a  breach  of  the 
agreement by the supplier. Usually, at the time of contracting with these providers, the 
contract is long term. 

2.11.  Working equity 

For details regarding Bezeq's working equity, see Section 1.4 of the Board of Directors' Report.  

2.12. 

Investments 

For information on investments in investee companies, see Note 12 to the 2023 statements, and 

also see Sections 3 and 4 of Chapter D of the periodic report.  
Funding 

2.13. 

2.13.1. 

The average and effective interest rate on Bezeq’s loans 

As of December 31, 2023, Bezeq is not financed by short-term credit (less than a year). 
The following is the distribution of long-term loans (including current liabilities):  

Loan 
period 

Source of 
funding 

Long-
term 
loans 

Banks 

Banks 

Non-
banking 
sources * 
Non-
banking 
sources 

The 
principal 
amount 
(NIS 
millions) 

799 

700 

3,070 

2,504 

Currency or 
linkage 
type 

NIS 
unlinked 

NIS 
unlinked 

NIS 
unlinked 

CPI-linked 
NIS 

Average 
interest 
rate 

3.62% 

6.71% 

Type of interest 
rate and 
change 
mechanism  

Fixed 

Variable on 
the basis of 
the short-
term loan 
interest rate 
per year ** 

Fixed 

3.06% 

3.30% 

Fixed 

1.40% 

1.44% 

Effective 
interest rate 

Interest rate 
range in 
2021 

3.54% 

6.85% 

3.20%
-
.95%4
- 
5.78%
6.78% 

2.79%
-
.00%4

0.58%
-
.20%2

*  In  January  2024,  debenture  series  11  and  13  were  expanded  in  the  amount  of  NIS  one  billion  par  value 

(approximately NIS 892 million). 

** Prime interest rate – 5.75% (as of February 2023) 

For more details about Bezeq loans, see Note 13 to the 2023 statements. 

2.13.2. 

Credti receipt limitations 

2.13.2.1 

Limitations included in Bezeq loans 

See Note 14 to the 2023 statements. As of the date of  publication of  the 
statements and as of the date publication of of this periodic report, Bezeq 
meets all the restrictions that apply to it.  

2.13.2.2 

Restrictions of the Bank of Israel related to a single borrower and a group of 
borrowers 

The directives of the Supervisor of Banks in Israel include restrictions on the 
liability  of  a  borrower  and  a  group  of  borrowers  towards  the  banks.  The 
Supervisor of Banks’ instructions may from time to time influence the ability 
of banking corporations to grant additional credit to Bezeq. Regarding the 
authorization  to  set  restrictions  on  the  provision  of  credit  to  a  business 
group in the Centralization Law, see section 1.7.7.6.  

2.13.3. 

Reportable credit  

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As  of  December  31,  2023,  Bezeq's  reportable  credit,  in  accordance  with  legal  position 
104-15  of  the  Securities  Authority  (reportable  credit  incident)  is  Bezeq's  debentures 
series 9, 11, 12, and as of January 11, 2024, also debentures series 13, all as specified Note 
13 to the 2023 statements and in Section 4 of the Board of Directors’ report. 

It should be noted that all of Bezeq's loan agreements (public debentures and private loan 
agreements) include a  cross breach clause in which a right to immediate repayment is 
established  in  the  case  of  a  third  party  lender  made  Bezeq's  debts  to  him  due  for 
immediate payment as a result of a breach event (default) in amounts that exceed the 
amounts stipulated in the various loan agreements. As of the date of the report, Bezeq 
loans do not include financial benchmarks, so the cross breach clause is not relevant to 
financial benchmarks. 

2.13.4. 

Amounts of credit received during the reporting period and thereafter 

On March 26, 2023, Bezeq completed a public offering of debentures (series 13 and 14) 
by way of expanding series traded on the stock exchange, according to a shelf offer report 
dated March 22, 2023, which was published according to a shelf prospectus published on 
April  7,  2020,  as  extended  by  the  Securities  Authority  until  April  7,  2023.  In  this 
framework, NIS 230,040,000 par value debentures (series 13) were issued to the public 
for a total of approximately NIS 182 million, and NIS 278,363,000 par value debentures 
(series 14) for a total of approximately NIS 238 million. For more details on the subject, 
see Bezeq's shelf offer report dated March 22, 2023 and Bezeq's immediate report dated 
March 26,  2023 regarding the results of the offering included in this report  by way of 
reference. 

On  May  9,  2023,  Bezeq  published  a  new  shelf  prospectus  (dated  May  10,  2023)  (“the 
Prospectus"). 

On January 11, 2024, Bezeq completed a public offering of debentures (series 11 and 13) 
by way of expanding series traded on the stock exchange, according to a shelf offer report 
dated January 10, 2024, which was published according to a shelf prospectus published 
on May 9, 2023. In this framework, NIS 567,877,000 par value debentures (series 11) were 
issued  to  the  public  for  a  total  of  NIS  539  million,  and  NIS  432,123,000  par  value 
debentures (series 13) for a total of NIS 353 million. For more details on the subject, see 
Bezeq's shelf offer report dated January 10, 2024 and Bezeq's immediate report dated 
January 11, 2024 regarding the results of the offering included in this report by way of 
reference. For the matter mentioned in this section, see also section 4 of the board of 
directors' report and note 13 of the 2023 reports. 

2.13.5. 

Bezeq's debentures 

For details regarding the debentures issued by the Company and by Bezeq see Note 13 to 
the 2022 statements and Section 4 of the Board of Directors' Report. Also, see Section 
2.13.4. 

2.13.6. 

Credit rating 

Bezeq's debentures are rated by Standard and Poors Maalot Ltd. at a ilAA-/Positive rating, 
and by Midroog Ltd. at a Aa3.il rating with a positive rating horizon. 

For  details  regarding  the  history  of  Bezeq  ratings  in  the  last  two  years,  see  Bezeq's 
immediate reports dated May 10, 2022, May 5, 2023 and September 1, 2024 (Standard 
and Force Maalot Ltd.), as well as from May 10, 2022, May 15, 2023 and September 1, 
2024 (Midrog Ltd.) included in this report by way of reference. 

For this matter see also Section 4 of the Board of Directors' Report.  

2.13.7. 

Bezeq's assessment in relation to debt raising in the coming year (2024) and the sources 
of borrowing 

During 2024, Bezeq is expected to repay a total of NIS 1.35 billion for the principal and 
the interest on its loans, including debentures. Most of Bezeq's borrowing needs for 2024 
have already been realized as detailed in Section 2.13.4. 

Bezeq  raises  funds  from  time  to  time  for  the  purpose  of  managing  its  cash  flow.  The 
financing  options  available  to  Bezeq  are:  Raising  debt  through  loans  from  banking 
corporations and institutional bodies and by issuing securities (private or marketable).  

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2.13.8. 

Liens and collateral 

For  information  regarding  Bezeq's  liens  and  collateral,  see  Note  19  to  the  2023 
statements.  

2.14.  Taxation 

For information on taxation, including losses carried forward for tax purposes in Yes, see Note 7 to 
the 2023 statements. 

On December 10, 2023, Bezeq received a letter from the Tax Authority extending, at Bezeq's request, 
the validity of the taxation decision in the agreement  that  includes the prior  approval of the  Tax 
Authority  for  tax  purposes  for  the  merger  of  Yes  with  and  into  Bezeq  in  accordance  with  the 
provisions of Article 103b of the Income Tax Ordinance ("the Taxation Decision") for one year, i.e., 
until December 31, 2024. It should be noted that the letter included a similar statement to the one 
included in the extension letter from the previous year, according to which, in light of the fact that 
there were no material developments regarding the abolition of the structural separation between 
Bezeq and Yes from the date of the Taxation Decision until the date of this extension, and in light of 
the long time elapsed from the taxation on the subject, the Tax Authority will consider not extending 
the validity of the taxation decision beyond December 31, 2024, as long as there are no significant 
developments in 2024 regarding the abolition of the structural separation between Bezeq and Yes. 
According  to  Bezeq's  position,  which  was  transferred  to  the  Yax  Authority,  it  is  entitled  to  an 
extension of the Tax Authority's approval in accordance with the terms of the Taxation Decision, and 
anyway, even if the validity of the Taxation Decision is not extended, this does not prevent Bezeq 
from requesting from the Tax Authority at any relevant time in the future a new taxation decision 
instead of the said taxation decision. It should also be noted that Bezeq continues to work with the 
various regulatory bodies to abolish the structural separation. 

2.15.  Environmental risks and their ways of management 

2.15.2. 

General 

Some Bezeq facilities, such as broadcasting facilities, wireless communication facilities, or 
high-voltage facilities30 are sources of electromagnetic radiation which are included in the 
definition of "radiation source" in the Non-Ionizing Radiation Law.  

2.15.3. 

Non-Ionizing Radiation Law 

The law regulates the practice of radiation sources, their establishment and operation, as 
well as their supervision. Among other things, the law stipulates that the construction and 
operation of a radiation source is subject to a permit; Provides for punitive provisions, 
and strict liability for a company that has violated the provisions of the law, its employees 
and its officers; Imposes registration and reporting obligations on the permit holder and 
confers supervisory powers mainly to the Commissioner for Non-Ionizing Radiation in the 
Ministry  of  Environmental  Protection  (in  this  section  -  "the  Commissioner"),  including 
regarding  conditions  in  the  permit,  revocation  of  the  permit  and  disposal  of  radiation 
source. 

Bezeq has operating permits from the Commissioner for the communication facilities and 
broadcasting sites operated by it. In addition, Bezeq performed the necessary actions for 
issuing radiation permits for high-voltage facilities located on its assets, and as of the date 
of the report, the Company has radiation permits for 13 high-voltage facilities, all of which 
have a construction and operating permit or a valid type approval.  

It should be noted that the Commissioner requires building permits as a condition for the 
continued  validity  of  operating  permits  for  communication  facilities  (including 
broadcasting facilities) issued by him, as well as the existence of additional conditions, 
inter alia, in relation to "wireless access facilities" that have a "type certificate" issued by 
the Commissioner . See also section2.16.11.  

The law includes a penalty chapter which stipulates, inter alia, that the construction or 
operation  of  a  radiation  source  in  violation  of  the  terms  of  the  permit  and  the 

30The  construction  and  operation  of  these  facilities  requires  an  establishment  permit  as  well  as  an  operating  permit  in 
accordance with the Non-Ionizing Radiation Law. The construction of high-voltage facilities (transformers) at Bezeq sites is 
intended for the supply of energy for the use of Bezeq facilities. 

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construction or operation of a radiation source without a permit after receiving written 
notice from the Commissioner, are a criminal offense.  

2.15.4. 

Permits 

For permits for broadcasting facilities required by the Planning and Construction Law, see 
Section 2.16.11.  

2.15.5. 

Bezeq policy regarding radiation risk management 

Bezeq  implements  a  work  procedure  regarding  the  establishment,  operation  and 
measurement  of  non-ionizing  radiation  sources,  and  an  appropriate  enforcement 
procedure  approved  by  Bezeq's  Board  of  Directors.  Bezeq  has  been  appointed  an 
enforcement  procedure  implementation  officer.  Periodic  reports  on  the  status  of 
radiation sources are forwarded to Bezeq's CEO and the Board of Directors. 

2.16.  Restrictions and supervision of Bezeq operations  

Bezeq is subject to various legal systems that regulate and limit its business activities. The main body 
that supervises Bezeq's activities as a communications company and may give instructions on various 
subjects is the Ministry of Communications. 

2.16.1. 

Supervision of Bezeq rates 

Arrangements under Sections 5 and 15 to 17 of the Communications Act and under the 
NIO license apply to Bezeq’s rates, as detailed later in this section. 

Bezeq rates are subject to regulatory intervention (even if not provided for in regulations), 
and from time to time, Bezeq is exposed to significant changes in its  rate structure and 
rate  level.  Rate  control  creates  or  may  create  difficulties  for  Bezeq  in  providing  an 
appropriate  timely  competitive  response  to  changes  in  the  market  and  competitors' 
offers.  In  addition,  the  restrictions  on  the  granting  of  discounts  in  rates  limit  Bezeq’s 
participation in certain tenders. The transition to maximum prices instead of FIX prices in 
relation  to  Bezeq  services  stipulated  in  the  regulations  (mainly  telephony)  and  the 
exclusion of certain marginal services from the scope of the regulations as of April 1, 2022 
gives Bezeq greater flexibility in relation to these services. 

The following are the main principles of the control arrangements on Bezeq rates:  

2.16.1.1 

the  Communications  Law, 

In  accordance  with 
the  Minister  of 
Communications,  with  the  consent  of  the  Minister  of  Finance,  may 
determine  payments  (including  maximum  or  minimum  payments)  for 
licensee services. Determination of payments can be made, inter alia, based 
on (1) cost according to a calculation method ordered by the Minister plus 
a  reasonable  profit;  Or  (2)  by  reference  points  derived  from  one  of  the 
following:  payment  for  services  provided  by  the  licensee,  payment  for 
comparable services, payments in other countries for such services. Bezeq's 
regulated  service  rates  (telephony  and  other  services)  were  set  in  the 
regulations  as  fixed  rates,  which  were  updated  according  to  the  linkage 
formula  minus  a  reduction  coefficient  as  stipulated  in  the  regulations,  so 
that on average Bezeq's supervised rates were eroded in real terms 

Starting  April  1,  2022,  amendments  to  the  payment  regulations  and  the 
Bezeq license entered into force, the FIX rates were canceled and in their 
place  maximum  rates  were  set,  so  that  the  maximum  payments  for 
telephone line usage fees and outgoing call rates (applicable to a subscriber 
who owns 3 lines or less) were reduced. 

Upon  the  transition  to  a  mechanism  of  maximum  payments,  the  existing 
alternative payment baskets that Bezeq has been marketing in accordance 
with  the  provision  of  Article  15A  of  the  Communications  Law  were 
eliminated31.  Also,  Bezeq  may  market  telephony  service  packages  that 
include a telephone line and call minutes, at rates that will be determined 

31     At the same time, until July 1, 2023, with regard to existing subscribers in these baskets, the maximum payment will be the 
maximum  payment  of  subscribers  who,  on  the  eve  of  the  entry  into  force  of  the  amendment,  paid  for  a  cluster  of  services 
according  to  an  alternative  payment  basket,  according  to  the  conditions  established  in  that  alternative  payment  basket  or 
according to the payment regulations as drafted after the amendment, whgichever is lower. 

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2.16.1.2 

2.16.1.3 

2.16.1.4 

by  it  in  accordance  with  Article  17  of  the  Communications  Law,  provided 
that the payments in these packages are lower than the payments derived 
from the maximum rates that will be determined. 

Rates  stipulated 
in  the  regulations  according  to  Article  5  of  the 
Communications Law - the Minister of Communications and Finance has the 
authority (according to Article 5 of the Communications Law) to determine 
payments for interconnection or for the use of a license holder in the Bezeq 
facilities of another license holder and to issue instructions on the matter 
(including in relation to ancillary arrangements) , among other things, based 
on  the  parameters  listed  in  Section  2.16.1.1.  For  the  the  outline  of  the 
reduction  of  interconnection  rates  as  stipulated  in  the  interconnection 
regulations, see Section 1.7.7.1. 

Determining rates according to  Article 15 of the Communications Law  - a 
service  for  which  no  payment  has  been  set  or  for  which  a  maximum  or 
minimum  payment  has  been  set  according  to  Articles  5  or  15  of  the 
Communications Law, Bezeq may demand a reasonable payment for it. In 
accordance with the Bezeq license, it will offer rates as stated, to anyone 
who  requires  it  throughout  Israel,  and  for  an  advanced  network  in  the 
service  area  specified  in  Appendix  11-1,  without  discrimination,  and  at  a 
uniform rate according to the types of services. 

The  Minister  of  Communications  may  order  Bezeq  to  report  to  him  the 
payment that it intends to demand as stated and any change in payment 
prior to the provision of the service or the implementation of the change. If 
the  Minister  of  Communications  deems  that  Bezeq  intends  to  demand  a 
payment  that  is  unreasonable,  or  a  payment  that  raises  concerns  about 
harming competition, he will be entitled to order Bezeq (for a period not to 
exceed one year) on the amount of payment that it is entitled to demand 
for the service, or to order the separation of payment for service from the 
payment for the services cluster. 

The Minister's examination of whether a payment is unreasonable can be 
done,  among  other  things,  in  accordance  with  the  parameters  stated  in 
Section 2.16.1.1(1), and the Minister may examine the payment based on 
what is stated in Section 2.16.1.1(2). According to the license, Bezeq must 
notify the Ministry of Communications of the rate it sets 14 days in advance. 

On March 27, 2023, a decision was published on a hearing  on behalf of the 
Ministry  of  Communications  regarding  the  determination  of  a  format  for 
examining the reduction of margins by owners of landline communications 
infrastructure.32  According  to  the  decision,  the  margin  reduction  test  will 
take place on a  retail product  based on Bezeq's advanced network in the 
deployment  areas,  and  may  be  extended  by  the  Ministry  to  additional 
companies. Licensed providers who will deploy advanced networks in the 
incentive areas will be subject to the margin reduction format established 
in  the  decision  of  the  Minister  of  Communications  on  the  subject  of 
‘Determining  an  obligation  and  maximum  payment  for  managed  ultra-
broadband  access  service  over  the  fiber  network  of  the  winners  of  the 
incentive fund tenders’. The decision details the method of calculating the 
prices underlying the test and states that the retail margin component will 
be calculated as an addition of 25% to the wholesale costs, or alternatively 
- as a reduction of 20% from the effective retail price to the end customer 
plus  a  reduction  of  component  G  (representing  the  cost  of  international 
transmission). The test will be used as part of a self-examination, and this 
goes beyond establishing a rigid framework that includes reports and pre-
approvals of every marketing proposal. Failure to comply with the margin 

32 According to what was said in the hearing, it replaces two previous hearings (from the years 2014 and 2017) in which no final 
decision was made due to implementation difficulties. "Margin Squeeze" takes place when an infrastructure owner who holds 
market power and provides wholesale services to his competitors, reduces the margin between his retail rate to the consumer 
and his wholesale rate to the competitors, in a way that harms the economic viability of the competitors to purchase wholesale 
inputs from him and market retail services to the consumer based on them. 

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reduction test will lead, among other things, to the exercise of the authority 
of  the  Minister  of  Communications  according  to  Article  17(c)  of  the 
Communications Law and to a reduction of the wholesale payment for the 
BSA service in a way that will bring it within the limits of the proposed test 
for  a  period  of  one  year.  During  this  year  the  Minister  may  consider  a 
permanent update of the reduced rate in the regulations. 

2.16.1.5 

It  should  be  noted  that  Bezeq  also  operated,  prior  to  the  decision  in  the 
hearing, a self-examination for not reducing margins in the BSA service. For 
wholesale rates and new pricing for all wholesale rates see Section 2.16.4. 

2.16.2. 

Bezeq's NIO license 

Bezeq operates, among other things, under the NIO license33. The NIO license contains 
provisions that mainly concern: 

2.16.2.1 

The  scope  of  the  license,  the  services  that  Bezeq  must  provide  and  the 
universal service obligation 

Bezeq must provide its services to everyone on equal terms for each type of 
service, regardless of location or unique cost. The license is not limited in 
time; The Minister may change, revoke, and suspend the license; The license 
and  any  part  thereof  may  not  be  transferred,  encumbered  or  foreclosed. 
Regarding  the  addition  of  wholesale  services  to  the  Bezeq  license,  see 
section1.7.4. Regarding the deployment and universal service obligation in 
connection with advanced infrastructure (fibers), see Section2.7.2. 

2.16.2.2 

Rules of structural separation 

For a description of the structural separation rules applicable to Bezeq, see 
Section1.7.3. 

2.16.2.3 

Rates 

For a description of the main provisions regarding rates, see Section 2.16.1. 

2.16.2.4 

Marketing shared service baskets 

For the provisions in the  NIO license that allow Bezeq to apply to market 
baskets of shared services subject to restrictions, see Section 1.7.3.3. 

2.16.2.5 

Operation of Bezeq’s networks and the level of its services 

Bezeq must maintain and operate the network, and maintain its services at 
all times, including in times of emergency, in a proper and regular manner, 
in  accordance  with  the  technical  requirements  and  the  quality  of  service 
requirements,  and  act  to  improve  its  services.  The  license  includes  an 
appendix regarding the "level of service to the subscriber". Bezeq forwarded 
proposals to the Ministry to amend the appendix while adapting it to the 
customary reality and licenses of other operators, but as of the publication 
of the report, the amendment has not yet been made. For the provisions in 
the license regarding response at the call centers, see Section 1.7.7.3. 

2.16.2.6 

Interconnectivity and use 

Provisions have been made regarding the obligation of interconnectivity to 
another public network and allowing the use of another licensee (including 
wholesale  service);  There  is  also  an  obligation  to  provide  infrastructure 
services  to  the  another  licensee  on  reasonable  and  equal  terms,  and  to 
refrain from preferring a licensee who is an affiliated company.  

2.16.2.7 

Arrangements in the field of security 

Provisions have been made regarding the operation of Bezeq’s network in 
time of emergency, including an obligation to operate in a manner that will 
prevent it from collapsing in an emergency.  

33 A copy of the NIO license is published on the Ministry of Communications' website at - www.moc.gov.il.  

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Bezeq  must  perform  Bezeq  services  and  construction  and  maintenance 
services for infrastructure and end equipment for defense forces in Israel 
and abroad, as stipulated in its agreements with the defense forces. Bezeq 
will also provide special services to the defense forces. Bezeq will work to 
ensure that all purchases and installation of hardware in its Bezeq facilities, 
with the exception of terminal equipment, will be made in full compliance 
with the instructions given to Bezeq under Article 13 of the Communications 
Law.  

Bezeq must appoint a security officer and strictly comply with the security 
provisions in the appendix to the license. For the provisions of the license 
regarding preparation for cyber defense management, see Section 1.7.10. 

2.16.2.8 

Supervision and reporting 

Bezeq  has  extensive 
the  Ministry  of 
reporting  obligations 
Communications.  In  addition,  the  Director  General  of  the  Ministry  of 
Communications (as defined in Bezeq’s license) was granted access rights to 
the facilities and offices used by Bezeq and the seizure of documents. 

to 

2.16.2.9 

Miscellaneous matters 

a.  The NIO license includes restrictions on the acquisition, possession and 
transfer of means of control in accordance with the provisions of the 
Communications Order (see section  2.16.3), as well as restrictions on 
"cross-ownership",  the  main  principle  of  which  is  the  prohibition  on 
cross-holding by entities that have an affiliation with another material 
NIO34  as  stated  in  the  license,  and  restrictions  on  cross-holding  by 
entities with NIO licenses or general licenses in the same  segment of 
activity. 

b.  Bezeq provided the Director General of the Ministry of Communications 
with a bank guarantee in the total amount of NIS 15 million to ensure 
compliance with the terms of the license and to indemnify the State for 
any damage caused to it due to their violation by Bezeq. 

c.  The Director General of the Ministry of Communications is authorized 
to impose a financial sanction for violating the terms of the license (for 
this matter, see also Section 1.7.7.5). 

d.  Bezeq may invest during a calendar year up to 25% of its annual revenue 
in activities not intended for the provision of Bezeq services (when the 
revenue  of  subsidiaries  is  not  considered  Bezeq's  revenue  for  this 
purpose). 

e.  License  to  provide  services  in  the  Judea  and  Samaria  region  -  On 
October 26, 2020, Bezeq received a general license for the provision of 
landline interior Bezeq services in the Judea and Samaria area (before 
that,  the  provision  of  the  service  was  included  in  the  provision  of 
Bezeq's  general  license).  In  accordance  with  what  is  stated  in  the 
preamble to the license, this is a license in the form of a reference to 
Bezeq's  general  license  granted  to  it  by  the  competent  bodies  in  the 
Ministry of Communications, while making the necessary adjustments 
in  the  area,  and  it  is  nothing  but  an  existing  snapshot  in  the  field  of 
infrastructure that is under the responsibility and ownership of Bezeq. 
Accordingly, no material change is expected in Bezeq's conduct in Judea 
and Samaria in relation to the existing situation prior to the granting of 
the license. 

f.  On  May  16,  2022,  Bezeq  received  a  public  appeal  published  by  the 
Ministry of Communications regarding the provision of communication 
services to the business segment, within the framework of which the 
Ministry calls on companies in the communication market that provide 
communication  services  to  the  medium-large  business  segment,  to 

34   NIO with a market share of 25% or more.  

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detail their activities in the field and the barriers agaist expanding this 
activity.  This  is  in  order  to  promote  regulation  that  will  increase 
competition in the field. In accordance with what was said in the voice 
of  the  reader,  the  market  of  medium-large  business  customers  is 
characterized by a significant advantage for size, and significant barriers 
to entry and expansion that limit even players who have been operating 
in it for many years. Also, Bezeq's market shares in the segment and the 
rate of change in them are an indication of a low level of competition in 
the segment, which affects the prices and the level of services received 
by businesses in Israel, and therefore, the Ministry is starting a process 
of examining the state of competition and the barriers in the segment, 
and  is  turning  to  receive  the  references  of  the  players.  On  June  20, 
2022, Bezeq submitted its response to the public appeal, according to 
which  the  field  of  communications  for  large  and  medium-sized 
businesses is a competitive market where there are no barriers to entry 
and expansion and no market failures, and in these circumstances no 
regulatory intervention is required. 

For the wholesale market and wholesale service portfolios see Section 
2.16.4. 

the  amendment  of  Bezeq’s 

Regarding 
the 
determination  of  advanced  network  deployment  obligations  -  see 
Section 2.16.5 

license  regarding 

2.16.3. 

The Communication Order 

Bezeq has been declared a provider of essential  Bezeq services in accordance with the 
Communication Order. By virtue of this declaration, Bezeq is obligated to provide certain 
types of services and may not  stop or reduce them, including basic telephone service, 
infrastructure  service,  transmission  service  and  data  communication  service,  including 
interconnectivity, and other services listed in the addendum to the Order. 

Main additional provisions in the Communication Order: 

2.16.3.1 

2.16.3.2 

2.16.3.3 

2.16.3.4 

2.16.3.5 

Restrictions  on  the  transfer  and  purchase  of  means  of  control  in  Bezeq, 
including  a  restriction  on  the  possession  of  means  of  control  of  a  certain 
type at a rate of 5% or more (7.5% or more regarding an Israeli institutional 
investor) without the prior written approval of the Prime Minister and the 
Minister of Communications (“the Ministers"). 

The transfer or acquisition of control of Bezeq requires the approval of the 
Ministers, having consulted with the Minister of Defense ("Control Permit"). 
Regarding  the  amendment  to  the  Communication  Order  regarding  the 
control permit, see Section 1.1.4. 

Holdings  that  have  not  been  approved  as  aforesaid  will  be  considered 
"excess holdings". The Order stipulated that there would be no validity to 
the  exercise  of  a  right  by  virtue  of  excess  holdings,  and  also  stipulated 
provisions authorizing the Ministers and Bezeq to apply to the court for a 
forced sale of excess holdings. 

Bezeq was required to report to Ministers, upon request, on all information 
on matters related to the provision of an essential service.  

At least 75% of the members of Bezeq's Board of Directors will be citizens 
of  Israel  and  its  residents  with  a  security  classification  and  security 
suitability, as determined by the General Security Service. The Chairman of 
the Board of Directors, the external directors, the CEO of Bezeq and other 
Bezeq  officials  as  specified  in  the  Order  will  be  citizens  of  Israel  and  its 
residents and have a security classification according to the classification of 
the position. 

2.16.3.6 

"Israeliness" requirements for the controlling shareholder in Bezeq: in the 
case of an individual - he is an Israeli entity (as defined in the Order), in the 
case of a corporation - it is incorporated in Israel, its business center in Israel 
and an Israeli entity (as defined in the Order) holds at least 19% of any of 

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the means of control in it, or holds at least 19% of the voting rights at the 
general  assembly  and  the  right  to  appoint  directors  in  the  controlling 
shareholder and it has the right to appoint at least one-fifth of the number 
of directors in Bezeq and Bezeq's subsidiaries, and no less than one director, 
in each them, to be appointed by it, provided that the rate of his holdings in 
Bezeq, both directly and indirectly, will not at any time be less than 3% of 
any type of means of control in Bezeq.  

In  the  amendment  to  the  Communications  Orer  (see  Section  1.1.4)  an 
option was added for the controlling shareholder to replace the Israeliness 
requirement if the Company was given an instruction by the Prime Minister 
according to Article 13 of the Law, at the request of the General Security 
Service,  and  the  General  Security  Service  confirmed  that  it  includes 
alternative requirements to the Israeliness requirement. 

The approval of the Ministers is required for the granting of rights in certain 
Bezeq assets (switches, cable network, transmission network and databases 
and information). In addition, the granting of rights by means of control of 
Bezeq's subsidiaries, including the allotment of shares in excess of 25% by 
the subsidiary, requires the approval of the ministers. 

Certain  Bezeq  operations  require  the  approval  of  the  Minister  of 
Communications, 
including  voluntary  dissolution,  compromise  or 
settlement  between  Bezeq  and  its  creditors,  change  or  reorganization  of 
Bezeq's structure, merger and splitting of Bezeq. 

2.16.3.7 

2.16.3.8 

2.16.4.  Wholesale market  

In recent years, Bezeq has been providing services under the "wholesale market" model, 
in  which  it  has  imposed  obligations  on  the  owners  of  the  lanlinde  interior  access 
Israel  (Bezeq  and  Hot)  to  sell  wholesale  services  to  other 
infrastructure 
communications operators.  

in 

The  regulatory  determinations  in  relation  to  the  wholesale  market  as  well  as  its 
implementation  and  development  during  the  reported  period  have  an  impact  on  a 
significant part of the Group’s activity.  

2.16.4.1 

Service portfolio 

At  the  end  of  2014,  the  Ministry  of  Communications  established  service 
portfolios  for  the  various  services,  which  determine  the  format  of  the 
provision of services by the infrastructure owners. The maximum rates that 
Bezeq  may  charge  for  these  services  were  set  by  the  Minister  of 
Communications  with  the  consent  of  the  Minister  of  Finance  in  the 
regulations for the use of that year. On June 26, 2017,  the rates for Hot’s 
wholesale services were announced. 

2.16.4.2 

BSA service  

Bezeq  began  providing  the  service  on  February  17,  2015.  This  service 
enables  infrastructure-less  service  providers  to  offer  their  customers  a 
unified Internet service which includes both an Internet connection service 
and  Bezeq's  infrastructure  service35.  The  service  is  provided  both  on  the 
Company's traditional network (copper) and on the fiber network. Since the 
launch of the service, hundreds of thousands of customers have moved to 
receive service through such service providers, in this regard, see Sections 
1.5.4.1 and- 2.1.3. 

The service portfolio, to which in February 2022 a "Fiber BSA service" 

35  It should be noted that in the first days of the service, the Ministry conducted a supervisory procedure at Bezeq that led to 
the  imposition  of  sanctions  in  the  amount  of  NIS  8.5  million  paid  by  Bezeq.  After  Bezeq's  Board  of  Directors  rejected  the 
applicant's motion to file a derivative claim in the matter against Bezeq's officers, and ruled that in the circumstances of the 
case, Bezeq does not have a good cause of action against officers and other officials who served during the relevant periods, 
and that conducting legal proceedings will not promote Bezeq's benefit. In February 2022, the applicant submitted a motion 
for approval of a derivative claim against Bezeq's officers (all but one are former executives) in the amount of the financial 
sanction plus interest and linkage differences. 

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chapter was also added, imposes on the owners of the infrastructure, 
including Bezeq, obligations of periodic publication in the automated 
interface (API) and on their website about the deployment of an advanced 
network (this obligation applies to the Company and IBC). In addition, the 
owners of the infrastructure, including in the incentive areas, must publish 
detailed statistical information in an internal interface between the 
operators, which refers to a wide range of parameters. On June 20, 2021, 
the Ministry added to the reporting obligations a detailed periodic 
information requirement regarding access to and connection to optical 
fibers, in accordance with uniform parameters and about the number of 
subscribers to the service over optical fibers divided into statistical areas. 
This obligation applies to providers who deploy fiber. 

BSA service rates over the copper network 

The usage regulations set the maximum rates for the service and they 
were updated between 2017 and 2023 in accordance with the demand 
forecast index according to formulas established by the Minister in his 
notices to the usage regulations. For the years 2017 and 2018, the update 
according to the demand forecast index was applied retroactively and also 
included a graduated offset mechanism. On December 31, 2023, an 
amendment to the usage regulations was published within which the 
aforementioned update mechanism was canceled, and it was determined 
that the rates for 2024 will be updated in accordance with the change in 
the index published in November 2023 compared to the index published in 
November 2022. Bezeq informed the service providers of not increasing 
the rates according to the index, and this also in relation to the rest of the 
wholesale market rates. 

Rates for the BSA service on fiber infrastructure ("Fiber BSA") 

In the usage regulations, the rates for the service were determined as 
maximum rates for an accessibility service and data transmission at an 
aggregate rate of up to 550 Mbps and above 550 Mbps and up to 1,100 
Mbps. The rates are updated once a year, on January 1 starting in 2021, in 
accordance with changes in the consumer price index. According to the 
recommendation of the professional staff at the Ministry, which was the 
basis for the decision regarding the rates, the aforementioned rates will be 
valid for a period of three years and will then be replaced by a non-
temporary rate. Bezeq is entitled to demand a reasonable payment for the 
service of initial installation of internal wiring36 to the subscriber's 
premises. In accordance with the Telecommunications Law, internal wiring 
installed for the provision of Bezeq service on an advanced network will be 
owned by the person whose premises the internal wiring is intended to 
serve only. 

In the usage regulations, in an amendment dated February 15, 2022, it was 
established the duty of a deployer in the incentive area (whose license an 
or administrative order issued to an NIO established the obligation to 
deploy an advanced network according to Article 14d(f) of the Law) to 
provide BSA service via fiber in the incentive areas. The maximum payment 
deployed in the incentive zones may demand from another licensed 
provider for a managed broadband access service at a nationwide 
connection level is identical to that which Bezeq may demand, and does 
not include installation and fault repair in the subscriber's home, for which 
a deployer in the incentive area may charge a reasonable rate to be 
determined, and he will also be required to meet a margin reduction test. 

For the agreement for the provision of the non-residential right of use 
(IRU) service in the BSA fiber service (wholesale market) by the Company 
to Partner and the subsequent reduction of the prices of individual lines in 

36  Internal cable is part of a Bezeq network that is installed on a person's premises and on shared premises and is intended to be 

used by that person's premises only. 

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the BSA fiber service, see Section 2.6.3. 

2.16.4.3 

Wholesale service - use of passive infrastructure 

The "Use of Physical Infrastructure" service portfolio came into force on the 
July 31, 2015 and accordingly allows Bezeq for infrastructure-less suppliers 
to  use  Bezeq's  available  physical  infrastructure  for  the  passage  of 
communication cables, as well as to use available dark fiber from  Bezeq's 
available  optical  cable,  Maximum  rates  for  this  in  the  regulations  of  use. 
Subsequently, the obligation to provide use of Bezeq's passive infrastructure 
(with  the  exception  of  dark  fiber  and  optical  wavelength  service)  was 
extended  in  relation  to  infrastructure  owners  -  IBC  and  Hot.  At  the  same 
time, NIO licensees were required to allow other NIO licensees to use their 
passive  infrastructure37,  and  then  a  service  portfolio  was  established  for 
"mutual use" of passive infrastructure, in which the obligation imposed in 
the  original  service  portfolio  on  an  operator  using 
infrastructure 
infrastructure  to  establish  a  passive  infrastructure  facility  near  Bezeq's 
passive infrastructure facility was abolished.  

The mutual service portfolio does not include provisions for the dark fiber 
rental service and optical wavelength service, which remain in the original 
service portfolio used only by holders of a unique general national interior 
operator license. 

Also,  in  accordance  with  the  decision  of  the  Minister  of  Communications 
dated  March  2023,  it  is  possible  for  all  authorized  providers  to  use  the 
passive 
physical 
infrastructures, not only in the incentive areas, subject to compliance with 
security regulations. 

infrastructures 

reciprocally, 

including 

Bezeq's 

Expanding the possibility to make use of Bezeq's passive infrastructures as 
mentioned  may 
increase  the  extent  of  damage  caused  to  Bezeq 
infrastructures by operators and the difficulty of monitoring what is done to 
them.  On  the  other  hand,  use  of  Bezeq's  passive  infrastructure  by 
authorized providers will involve a payment to Bezeq (even if reduced, as 
described in this section below). 

For  the  determination  of  the  Competition  Authority  in  the  matter  of 
for  the  ruling  on  the  appeal  by  Bezeq,  see 
infrastructure  and 
Section2.16.9.5, and for the motion for approval of a class action and two 
demands  for  the  exercise  of  rights  before  filing  a  derivative  claim  in  this 
matter, see Section 2.18.1. 

Service rates 

The usage rates for Bezeq's passive infrastructure and dark fiber are also set 
in the usage regulations. In accordance with the provision of Article 14 d(9) 
of the Communications Law, the Minister, in the regulations published on 
July 21, 2022, established a reduced rate for using the Company's passive 
infrastructure (including dark fiber) in the incentive areas, and in the area 
beyond  the  incentive  area38,  which  is  about  a  quarter  of  the  rate  in  the 
Company's connection areas in the case of access service for infrastructure 
and over a third for dark fiber service. As indicated in the Minister's decision 
attached  to  the  amendment  of  the  regulations  (alongside  an  economic 
opinion) as part of a new pricing process for all wholesale rates planned for 
2022  (and  for  this  matter  see  Section  2.16.4.2),  among  other  things,  the 
determination  of  the  abovementioend  regulated  rates  will  also  be 
examined. 

37  Except for the passive NIO infrastructure, which is held by the IEC and is required for its activities as a holder of an essential 

service provider license. 

38  An area that is not an incentive area and that is not one of the Company's deployment areas. The reduced payments for the 
services in these areas will come into effect after establishing a regulation regarding the identification of use in these areas. 

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2.16.4.4 

Wholesale telephony service 

This service allows service providers who do not own infrastructure to offer 
their customers telephony service at wholesale rates over the Company's 
network. 

The wholesale telephony service in all configuraitons over the years had no 
actual demand, and there were no customers, except for a few and for tests. 

2.16.4.5 

Wholesale market services pricing procedure 

On September 6, 2022, Bezeq received a letter from the Director General of 
the Ministry of Communications, which includes a notice of the launch of a 
pricing process for wholesale market services - an update and a request for 
information (“the Notice"). The notice was accompanied by a request for 
data  from  Axon  Partners  Group,  which  the  Ministry  chose  to  provide 
consulting  services  for  assistance  in  building  a  cost  model  from  which 
updated rates for the wholesale market will be derived. According to the 
Notice, the work process will progress according to the following steps: (1) 
Gathering  information  from  licensees;  (2)  Building  the  economic  model 
based on a pricing methodology, formulating an up-to-date list of wholesale 
services,  and  deriving  maximum  payments  for  wholesale  services  on  the 
basis of the model that will be published for the hearing (the hearing on the 
cost model is expected, according to the notice, to be published in the first 
quarter of 2023); (3) Decision at the hearing and amendment to the usage 
regulations. Bezeq transmits data and information in accordance with the 
requirement,  and  at  this  stage  it  is  unable  to  evaluate  the  results  of  the 
future  hearing  and  its  consequences.  In  accordance  with  the  hearing 
published on December 21,  2023 regarding the amendment  of the usage 
regulations  (replacing  the  mechanism  for  updating  BSA  prices  on  Bezeq's 
copper network), it was stated that the Ministry of Communications is in the 
process of updating all of the wholesale rates on the landline network. As a 
result of the long time that has passed since the construction of the Frontier 
model  and  the  significant  changes  that  have  taken  place  in  the  market, 
including  the  entry  of  additional  players 
into  the  communications 
infrastructure  market  and  the  large-scale  deployment  of  fiber  optic 
infrastructure  to  the  customer's  home,  the  Company  decided  that  an 
update was needed to the way the maximum payments are determined in 
the wholesale market. The publication of a model for hearing in preparation 
for  amending  the  regulations  was  delayed  for  various  reasons,  and  it  is 
expected to be published for hearing, according to Bezeq’s estimate, at the 
end of the first quarter of 2024 or in the second quarter of 2024. 

2.16.5. 

Advanced network - fiber 

2.16.5.1 

On  December  24,  2020,  an  amendment  to  the  Communications  Law  was 
published  that  regulates  the  deployment  of  an  "advanced  network".  In 
accordance with the amendment to the law, Bezeq may select, from all of 
Israel, the statistical areas in which it wishes to deploy an advanced network 
(not  based  on  its  metallic  network)  and  provide  Internet  access  service 
thereon. 

The Company does not have to deploy the advanced network throughout 
all of Israel, but in all the statistical areas it has chosen, and this until no later 
than March 14, 2027 (which is six years from the deadline set in the Bezeq 
license). 

After  the  obligation  has  been  established  in  the  Bezeq  license  to  provide 
service in its choice areas (the service areas) as stated, the Company may 
deploy an advanced network that is not based on its metallic access network 
and provide Bezeq service over it even not to the general public throughout 
Israel, and landline Bezeq service provider other than the Company (such as 
Hot) may deploy an advanced network (which is not based on his metallic 
access network) and provide Bezeq service over it, even not to the general 
public throughout Israel, and not even at least in a service area. The Minister 
may  set  conditions  for  the  deployment  and  provision  of  the  service  with 

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licenses or a general permit. The Minister may permit, in Bezeq’s licenses or 
in the licenses of another landline Bezeq service provider to provide service 
over their metallic access network that has been upgraded to an advanced 
network, not to the general public throughout  IIsrael and not at least in a 
service  area,  if  he  sees  that  this  contributes  to  competition  and  level  of 
service. 

In the amendment to the law, incentives were established for deployment 
in statistical areas that are not from the deployment areas chosen by the 
Company  ("Incentive  Areas"),  the  main  ones  of  which  are  a  reduced 
payment for the use of the Company's passive infrastructure in the Incentive 
Areas,  the  opening  of  an  incentive  fund,  managed  by  the  Accountant 
General  at  the  Ministry  of  Finance  in  order  to  encourage  deployment,  to 
which mandatory annual payments will be deposited by the liable entities, 
including Bezeq, at a rate of 0.5% of the liable entities' annual revenue. The 
Minister of Communications with the consent of the Minister of Finance and 
the approval of the Economic Committee may change this rate. On July 31, 
2023, the Communications Order (Bezeq and Broadcasting) (Incentive Fund 
Annual  Payment  Rate)  (Provisional  Order),  5783-2023  was  published, 
according to which, following the examination carried out by the Ministry of 
Communications, it was determined within the framework of a provisional 
order that in 2023 the payment rate of the entities liable to the incentive 
fund will be at a rate of 0% instead of 0.5%. Further to the provisional order, 
there  will  be  a  decrease  of  approximately  NIS  40  million  in  the  Group's 
expenses in 2023 compared to 2022. 

The  allocation  of  the  incentive  funds  is  done  through  tenders.  In  the 
conditions of the tenders, the tenders committee may establish threshold 
conditions for participating in the tender, including a condition according to 
which a bidder must have a license. 

The only benchmark for selecting tender winners is the ratio between the 
number of households in the Incentive Areas in the bids of the contestants 
and between the amounts from the incentive fund that will be allocated as 
part of the tenders. 

In  the  license  of  a  winner  of  a  tender  or  by  administrative  order,  an 
obligation is established to deploy an advanced network in a service area 
that includes the Incentive Areas which  it won, including an obligation to 
provide an internet access service over the network to anyone in the area 
within  the  time  periods  specified 
license.  Regarding  the 
determination of such an obligation in the Judea and Samaria region, the 
provisions  of  the  law  in  this  matter  applicable  in  the  Judea  and  Samaria 
region will apply. 

in  the 

Bezeq and a  corporation related to it are prohibited  from participating in 
the  tender  for  the  allocation  of  the  incentive  funds,  or  deploying  an 
advanced  network  and  providing  services  over  it  in  the  Incentive  Areas, 
except after five years have passed from the date of the establishment of 
the deployment obligation in the license of the winner of the tender. 

The  Minister  may  permit  Bezeq,  at  its  request,  to  deploy  an  advanced 
network and provide services on top of it in Incentive Areas for which the 
incentive funds have not yet been allocated, provided that the proportion 
of  households  in  the  areas  to  be  included  in  their  application  does  not 
exceed 10% of the households in the areas included in the statistical areas 
chosen by the Company. 

The above limitations do not detract from the ability of the Company or a 
related corporation to deploy an advanced network in the Timruts area in 
order to provide Bezeq service to a business subscriber, or to provide service 
to a business subscriber on an advanced network that has been deployed. 

The amended law also stipulates that the ownership of the internal wiring 
in an advanced network will belong to the subscriber whose premises are 

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2.16.5.2 

2.16.5.3 

2.16.5.4 

used by the routing only. An authorized supplier may demand a reasonable 
payment for its installation. 

On June 15, 2021, Bezeq's license was amended and, among other things, 
an appendix was added to it that includes the list of statistical areas selected 
by  Bezeq,  which  cover  about  76%  of  Israel’s  population  and,  in  the 
Company's estimation, about 80% of households. Milestones for completing 
the  deployment  of  the  advanced  network  were  also  established  in  the 
license  as  follows:  Completion  of  deployment  to  buildings  where  the 
cumulative  proportion  of  households  is  60%  of  the  total  number  of 
households in the service area (all statistical areas selected by the Company) 
- no later than the end of two years from the determining date (March 14, 
2021)39; 80% - no later than three years from the determining date; 95%  - 
no later than the end of five years from the determining date; Completion 
of layout for all the buildings in the service area no later than the end of six 
years from the determining date. 

On  October  3,  2022,  the  Minister  of  Communications  approved  Bezeq's 
request  to  allow  it  to  deploy  an  advanced  network  and  provide  Bezeq 
service  over  in  statistical  areas  additional  to  the  areas  specified  in  the 
Company's license and to amend the Company's license accordingly. This is 
a deployment in 151 additional areas, including about 60,000 households. 
As detailed in the decision of the Minister of Communications, the rate of 
households in the Company's deployment areas will be 82.5%, which is an 
addition of about 2.3% to this rate, so that the updated rate of households 
in the Company's deployment areas will be about 84.7%. 

The  Tenders  Committee,  established  according  to  Article  14d  of  the 
Communications  Law,  published  two  tenders  for  the  incentive  areas,  on 
October 31, 2021 and on February 1, 2023. According to  the  Ministry (as 
reflected in the explanatory notes to the draft order above), the winners of 
these tenders won a vast majority of the incentive areas, and as of July 2023, 
there is an obligation to deploy and provide Internet access service over an 
advanced  network  on  approximately  99.5%  of  households.  The  Ministry 
stated that it anticipates that some of the winners of the first tender will 
request to return some of the winning bids in their won areas where they 
did  not  deploy.  The  Tenders  Committee  and  the  Ministry are  considering 
incentivizing  the  rapid  return  of  areas  where  the  data  and  information 
indicate that the winners do not intend to deploy an advanced network in 
such a way that a tender could be held for them as early as 2024. On August 
14, 2023, the Minister of Communications approved Bezeq's request of June 
in  accordance  with  the  provisions  of  Article  14e  of  the 
4,  2023, 
Telecommunications Law, to require it to deploy an advanced network and 
provide Internet access service over it in all incentive areas remaining after 
the first and second incentive tenders except in the Kfar Aqab area, which 
is, among other things, in light of the Company's compliance with its license 
conditions.  The  Bezeq 
(Bezeq’s 
deployment obligation in approximately 85% of households). 

license  was  amended  accordingly 

In  providing  Internet  access  services  provided  via  fiber  optics  to  the 
residential  building  (Fiber  To  The  Home  -  FTTH)  to  private  subscribers, 
providers  are  not  allowed  to  offer  subscribers  offers  under  different 
conditions or at a different rate, depending on the proposed infrastructure 
(self or wholesale). The type of infrastructure offered will be a reasonable 
characteristic  that  justifies  distinguishing  one  group  of  subscribers  from 
another  in  relation  to  Internet  access  services  that  are  not  provided  via 
optical fibers to the residential building. The type of infrastructure (own or 
wholesale)  will  not  be  used  as  a  feature  that  allows  different  rates  to  be 
offered when it comes to internet service over fiber. 

2.16.5.5 

Fiber deployment in residential buildings 

39 The date when the Company began to provide a fee-based Internet access service on the advanced network . 

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Regarding the deployment of fibers in new residential buildings, on June 8, 
2021, an amendment to the Panning and Constuction Regulations (Permit 
Application, Conditions and Fees), 5730-1970 was published, regarding the 
In  addition,  the 
obligation  to 
Communications  Law  established  conditions  regarding  the  laying  of  an 
advanced network in a shared residential building, even in the absence of 
the consent of the majority of the apartment owners were also amended. 

in  new  buildings. 

lay  optical  fibers 

2.16.6. 

Powers in respect of real estate 

Pursuant  to the provisions of  Article  4 (f) of the Communications Law, the Minister of 
Communications  granted  Bezeq  real  estate-related  powers  in  accordance  with  the 
provisions of Chapter F of the Law. 

The law distinguishes between state-owned land, the Development Authority, the Jewish 
National Fund, a local authority or a corporation established by law and held by one of 
them, as well as a road ("public land") and other land ("private land"). With regard to 
public  land,  Bezeq,  and  any  person  authorized  thereby,  may  enter  for  the  purpose  of 
performing  works  for  laying  and  maintaining  a  network  and  providing  Bezeq  services, 
provided that the laying of the network was done in accordance with the provisions of 
the Planning and Construction Law. The amendment to the Communications Law and the 
Planning and Construction Law abolished the obligation to obtain approval from the local 
planning and construction committee, so that certain actions are not subject to a building 
permit if they are carried out by a licensee who has been granted powers under Chapter 
F of the Communications Law if they are made according to an approved plan.  

Laying ofnetwork on private land will be done in accordance with the provisions of the 
Planning and Construction Law, and requires the consent of the landowner, the tenant 
for generations or the protected tenant, as the case may be. 

Pursuant  to  the  provisions  of  the  Bezeq  Regulations  (Installation,  Operation  and 
Maintenance), 5745-1985, if Bezeq believes that the provision of a Bezeq service to the 
applicant  requires the installation of a  Bezeq facility, in the applicant's premises (or  in 
common premises), Bezeq may require the applicant as a precondition for providing the 
requested  Bezeq  service  to  assign  a  suitable  place  to  Bezeq  in  the  premises  for  the 
installation  of  the  facility,  for  Bezeq  use  only,  and  it  may  provide  service  through  the 
facility to other applicants as well. 

According  to  the  Planning  and  Construction  Regulations  (Application  for  a  Permit,  its 
Terms and Fees), 5730-1970, an applicant for a permit for the construction of a residential 
building,  it  is  mandatory  to  install  infrastructure  for  telephone,  radio,  television  and 
Internet services so that the customer can choose a provider of his choice. At the same 
time, Bezeq’s license (as well as the Hot Telecom and Yes licenses) was amended so that 
as long as Bezeq uses the internal threading (the part of the access network, installed in 
a person's premises and common premises, and intended to serve that person's premises 
only), it is obligated to provide a maintenance service for the internal threading installed 
by said person, without giving it any property rights in the internal threading. Regarding 
the draft amendment of these regulations for the purpose of imposing an obligation on 
the  laying  of  infrastructure  in  favor  of  fiber,  see  Section    אל  הינפהה  רוקמ  !האיגש
.אצמנ. 

2.16.7. 

Immunities and limitations of liability 

The  Minister  of  Communications  granted  Bezeq  certain  immunities  from  liability  for 
damages, listed in Chapter I of the Communications Law, in accordance with his authority 
to grant immunities to a general licensee. 

In addition, Article 13 of the Communications Law stipulates restrictions on criminal and 
civil  liability  in  fact  made  in  the  framework  of  the  fulfillment  of  a  provision  for  the 
provision of services to the security forces by virtue of the article. 

2.16.8. 

Regulations and rules under the Communications Law 

As of the date of publication of the periodic report, Bezeq is subject to regulations in two 
other  main  areas:  (1)  cessation,  delay  or  limitation  of  Bezeq  operations  and  Bezeq 
services; (2) Installation, operation and maintenance. 

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2.16.9. 

Laws of Economic Competition 

2.16.9.1 

The  Competition  Commissioner  (in  this  section  -  "the  Commissioner") 
declared Bezeq as having a monopoly in these areas:  

2.16.9.2 

2.16.9.3 

a.  Basic  telephone  services,  provision  of  communication  infrastructure 
services,  and  transmission  and  transmission  services  of  public 
broadcasts40. 

b.  Providing fast-access services through subscriber access network41. 

c.  Providing  fast  access  services  to  Internet  providers  through  a  central 

Bezeq public network. 

The  declaration  by  the  Commissioner  of  Bezeq  as  having  a  monopoly 
constitutes prima facie evidence to all that is determined in it, in any legal 
proceeding, including in criminal proceedings.  

internal  enforcement  procedure  with  rules, 
Bezeq  has  adopted  an 
guidelines  and  an  internal  reporting  and  control  system,  the  purpose  of 
which is to ensure that Bezeq and its employees' activities are carried out in 
accordance with the provisions of the Economic Competition Law. 

In  accordance  with  the  conditions  set  forth  in  the  approval  of  the 
Competition Authority dated March 26, 2014 for the merger (as defined in 
the  Economic  Competition  Law)  between  Bezeq  and  Yes,  the  following 
restrictions apply in relation to Bezeq and Yes: 

a.  Bezeq and any person  related to it (in this section  - "Bezeq") will not 
impose  any  restriction  on  the  consumption  of  landline  Internet 
infrastructure  services  resulting  from  the  customer's  cumulative 
browsing  volume,  nor  will  they  cause  a  restriction  or  block  of  the 
customer's ability to use any service or application the Internet. 

b.  Bezeq  will  deduct  from  the  payments  of  an  Internet  provider  for  its 
connection  to  the  Bezeq  network  sums  for  the  provision  of  multi-
channel television services. 

c.  Bezeq  will  sell  and  provide  Internet  infrastructure  services  and 
television  services  on  equal  terms  to  all  Bezeq  customers  (sale  of 
Internet infrastructure services as part of a basket of services will not in 
itself be considered for sale on unequal terms). 

d.  Bezeq and Yes will cancel all exclusivity arrangements regarding non-
original  productions  and  will  not  be  a  party  to  such  exclusivity 
arrangements (except in relation to a third party who has a license to 
broadcast at the time of the decision). In addition, for two years from 
the date of approval of the merger (which have since passed), Bezeq 
will  not  prevent  any  party  (except  those  who  have  a  broadcasting 
license  at  the  time  of  the  decision)  from  acquiring  rights  in  original 
productions (does not apply to new productions). 

For the full text of the decision of the Competition Authority, see Bezeq's 
immediate report dated March 26, 2014. 

On  April  12,  2021,  the  Competition  Authority  published  a  decision  of  the 
Competition Commissioner regarding the amendment of the terms of the 
merger. According to the amendment, the Commissioner decided to allow 
Bezeq's  subsidiaries:  Pelephone,  Bezeq  International  and  Yes  (and  not 
Bezeq), to sell communication packages that include Internet infrastructure, 
Internet  provider  and  TV  services  without  the  obligation  to  sell  the  TV 
services, at a separate price that will be uniform for package buyers and for 
those who are  not package buyers. In addition, the Commissioner decided 
to allow greater flexibility with regard to the purchase of foreign content, so 

40   Announcement dated 30.7.1995. 
41   On November 10, 2004, the Commissioner split his announcement of December 11, 2000 in the field of Internet access 

infrastructure into two separate Announcements (Announcements B and C). 

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2.16.9.4 

2.16.9.5 

that the condition stipulating the cancellation of exclusivity arrangements 
between  Bezeq  and  Yes  regarding  non-original  TV  content,  and  the 
prohibition on being parties to such exclusivity arrangements will not apply 
to foreign  content  purchase, excluding sports content, and thus allow for 
greater flexibility when it comes to purchasing foreign content. 

As part of the approval of the merger of Bezeq and Pelephone dated August 
26,  2004  (as  amended  below),  restrictive  conditions  were  imposed,  the 
main of which is the prohibition of discrimination in favor of Pelephone in 
the supply of a  product in which  Bezeq is a  monopoly, prohibition of the 
conditioning of the supply of certain products by one of the companies with 
the  purchase  of  products  or  services  from  the  other  and  restrictions  on 
certain joint activities. 

the  aforementioned 

On March 7, 2018, Bezeq received a notice from the Competition Authority, 
according  to  which  the  Competition  Commissioner 
is  considering 
determining in accordance with its authority under Article 43 (a) (5) of the 
Economic  Competition  Law  that  Bezeq  abused  its  position  in  violation  of 
Article 29A (a) and Article 29A (b) ( 3) of the Economic Competition Law, and 
to  impose  financial  sanctions  on  Bezeq  and  the  former  CEO  of  Bezeq  for 
alleged  violation  of  the  provisions  of  Article  29  of  the  law  and  of  the 
provisions  of 
the 
announcement, the evidence in its possession indicates that Bezeq allegedly 
used  the  market  power  it  has  as  a  result  of  its  control  of  the  passive 
infrastructure  and  has  placed  barriers  before  new  players  seeking  to  use 
Bezeq's passive infrastructure  that will be used to compete with Bezeq in 
providing communication services to consumers, in a way that could have 
deterred  and  even  prevented  them  from  setting  up  an  self-landline 
communications network or at least delayed them and limited the scope of 
the network. According to the notice, Bezeq's actions raise concerns about 
harm  to  the  final  consumer.  The  violations  alleged  against  Bezeq  are  the 
blocking of access to private areas and placing a demand for fiber cutting. 

sections.  According 

to 

received  a  determination 

Following a hearing held in the matter, in which Bezeq and the former CEO 
of  Bezeq  presented  arguments  and  evidence  that  there  was  no  defect  in 
their moves and that they did not violate the Economic Competition Law, 
on  September  4,  2019,  Bezeq 
("the 
Determination") from the Competition Commissioner regarding the abuse 
of  Bezeq's  position  in  violation  of  the  provisions  of  Article  29A  of  the 
Economic  Competition  Law  and  the  demand  for  payment  under  the 
provisions of Article 50H of the law of NIS 30 million from Bezeq and NIS 0.5 
million from the former Bezeq CEO. On October 24, 2023, the Competition 
Court rejected an appeal filed by Bezeq on the Determination. It should be 
noted  that  the  full  amount  of  the  sanctions  was  paid  by  Bezeq  in  2019. 
Regarding the request for approval of a class action and requirements for 
exhausting  rights  before  submitting  a  derivative  action  further  to  this 
Determination, see Section 2.18.1f. 

2.16.10. 

Telegraph Order 

The Government is dealing with the existing shortage of radio frequencies 
to provide a variety of advanced communication services to the Israeli public 
(among other things, due to the allocation of many frequencies for security 
and  other  public  uses),  by  allocating  them  in  tenders  and  limiting  the 
number of licenses that can be used, as well as by establishing conditions 
and criteria to ensure the efficient use of frequencies.  

The  Telegraph  Order  regulates  the  use  of  the  electromagnetic  spectrum, 
and applies, among other things, to Bezeq's use of radio frequencies, as part 
of its infrastructure. Establishment and operation of a system that uses radio 
frequencies is subject, under the Telegraph Order, to licensing, and the use 
of radio frequencies is subject to the allocation of an appropriate frequency 
in  accordance  with  the  Committee’s  policy.  According  to  the  Telegraph 
Order, license fees and fees are imposed for the Frequencies Committee and 
their allocation. 

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2.16.11. 

Establishment of communication facilities 

The  National  Communications  Outline  Plans,  National  Outline  Plan  36 
(within the Green Line) and National Outline Plan 56 (in the Territories) are 
intended  to  regulate  the  deployment  and  manner  of  construction  of 
communications  facilities  in  such  a  way  as  to  enable  transmission  and 
reception  of  radio,  television  and  wireless  communications,  while 
preventing radiation and minimizing environmental and landscape damage, 
and with a view to simplifying and streamlining the construction processes 
of the facilities. 

Bezeq has established and is setting up transmission facilities and wireless 
communication facilities for the transmission services of its customers, and 
also  uses  wireless  communication  facilities  mainly  for  the  purpose  of 
providing  services  to  areas  that  are  not  connected  to  the  fixed 
communication infrastructure (remote areas or new localities). 

2.16.11.1 

National Outline Plan 36 - Communication facilities within the Green Line 

NOP  36  was  divided  into  two  parts  according  to  the  classification  of  the 
transmission facilities, made in accordance with the technical variables and 
physical  dimensions  of  the  facilities,  which  ultimately  affect  the 
determination of safety ranges for protection against radiation effects and 
the degree of prominence of the facilities in the landscape.  Part  A of the 
NPA,  which  has  been  approved  by  the  Government  and  is  in  force,  deals 
with  guidelines  for  the  construction  of  small  and  micro  broadcasting 
facilities, while Part B, which was not approved by the Government and is 
not in force, deals with guidelines for the construction of large broadcasting 
facilities.  As  a  result,  there  are  currently  no  special  guidelines  regarding 
Bezeq's large transmission facilities, most of which were established by the 
state before Bezeq was established. 

Bezeq  has  issued  building  permits  for  most  of  the  small  transmission 
facilities in accordance with National Outline Plan 36A. From time to time, 
there  is  a  need  to  add  transmission  facilities  that  require  the  issuance  of 
building  permits  in  accordance  with  National  Outline  Plan  36A.  Bezeq 
believes  that  it  is  not  obliged  to  obtain  building  permits  for  miniature 
broadcasting facilities, due to the exemption granted in this matter in the 
Planning and Construction Law and in the Communications Law with respect 
to  "wireless  access  facilities"  (which  include  the  miniature  broadcasting 
facilities). 

2.16.11.2 

National Outline Plan 56 - Communication facilities in the Territories 

National Outline Plan 56 regulates the manner of construction and licensing 
of communications facilities in the Territories. The plan includes transitional 
provisions to facilities established in the permit and to existing facilities. 

The plan includes a requirement to obtain a communications license and to 
obtain the consent of the Commissioner of Government Property in the Civil 
Administration.  

Bezeq has settled the licensing of vast majority of the facilities located in the 
Territories and which are owned by Bezeq (there are a few additional sites 
that  have  not  been  regulated).  In  addition,  Bezeq  also  arranged  with  the 
Communications  Officer  in  the  Civil  Administration  the  licensing  of  the 
facilities  located  in  the  premises  of  the  customer  in  accordance  with  the 
requirement that the Communications Officer sent to Bezeq. 

2.16.11.3 

Radiation permits 

Regarding radiation permits for communication and transmission facilities, 
see Section2.15 2.15. 

Exemption from the permit to add antennas to legally existing transmission 
facilities 

Addition of an antenna to a legally existing transmission facility is exempt 

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from obtaining a permit subject to the existence of cumulative conditions 
and  exceptions  specified  in  the  Planning  and  Construction  Regulations 
(Works and Buildings Exempted from the Permit), 5774-2014. 

2.16.12.  Consumer legislation 

Regarding consumer legislation applicable to Bezeq, see Section 1.7.7.4. 

2.17.  Material agreements 

The following is a concise description of material agreements, not in the ordinary course of Bezeq's 
business, that were signed during the period of the periodic report and / or that were in force during 
the said period:  

2.17.1. 

The trust deeds in respect of debentures (Series 9, 10, 11, 12, 13, 14) issued by Bezeq. 

For  this  matter,  see  details  in  Note  13  to  the  2023  statements  and  in  Section  4  of  the  Board  of 

Directors' Report. 

2.17.2. 

Real estate 

2.17.2.1 

Agreement  on  the  transfer  of  assets  between  Bezeq  and  the  state  dated 
January 31, 1984 

An agreement between the state and Bezeq, according to which Bezeq was 
granted  the  State’s  rights 
in  assets  available  to  the  Ministry  of 
Communications for the provision of Bezeq services, and Bezeq replaced the 
state  with  respect  to  the  rights  in  the  said  assets  and  regarding  the 
obligations and duties relating to those rights on the eve of the agreement. 
In  addition,  according  to  the  said  agreement,  Bezeq  was  transferred  the 
rights, powers, obligations and duties of the State under the agreements, as 
well as the agreements and transactions that were valid in the field of Bezeq 
services on the eve of the beginning of the agreement. 

2.17.2.2 

Settlement agreement dated May 15, 2003 between Bezeq and the State 
and the Israel Land Administration regarding the rights relating to the land. 
See section2.7.4.3. 

2.17.2.3 

Agreement between Bezeq and the Postal Authority (now the Israel Postal 
Company) dated June 30, 2004  

An agreement  between Bezeq and the Postal Authority for the definition 
and regulation of Bezeq and the Postal Authority in their joint assets. The 
agreement specified the common assets and defined the share of each party 
in them. It is stipulated that each of the parties will have exclusive rights in 
part, except in the matter of rights in common property, building rights or 
rights in respect of which it is expressly stated otherwise. The agreement 
stipulates, among other things, a mechanism of the right of refusal if a party 
wishes to make a sale transaction and a right of way in the matter of a lease 
transaction.  With  respect  to  a  number  of  additional  assets  it  has  been 
determined that the sole rights holder in them, in its entirety, will be one 
determined party. 

2.17.3. 

Labor agreements 

2.17.3.1 

Special collective agreement from December 2006 

For this agreement and amendments thereto, see Section 2.9.4. 

2.17.3.2 

Early retirement agreements. 

On  April  24,  2014,  Bezeq  entered  into  an  agreement  with  Menora 
Mivtachim  Insurance  Ltd.  ("Menora")  to  regulate  pension  payments  for 
early retirement of Bezeq employees, as well as the differences in old-age 
and  survivors'  pension  payments,  to  employees  who  retire  from  Bezeq 
under  a  special  collective  agreement  for  retirement  which  was  signed 
between  Bezeq,  the  employees’  representation  and  the  Histadrut  on 
February 12, 2014. The insurance policy was approved by the Supervisor of 

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Insurance and it entered into force on March 31, 2016. Accordingly, as of 
May 1, 2016, Menora is issuing policies to retiring employees, and benefit 
payments and related payments are paid on the basis of these policies. The 
term of the agreement (after being extended three times) is until the end of 
2024. 

2.17.3.3 

IRU agreement between Bezeq and the partner 

For  the agreement  for the provision of the indefeasible right-of-use (IRU) 
service in the BSA fiber service (wholesale market) by Bezeq to Partner, see 
Section 2.6.3. 

2.18. 

Legal Proceedings 

Bezeq's  reporting  policy  is  based  on  qualitative  considerations  and  quantitative  considerations. 
Bezeq decided that the quantitative materiality threshold in relation to events affecting the net profit 
would  be  an  effect  of  about  5%  and  more  on  Bezeq's  average  adjusted  net  profit  (as  defined  in 
Section 1.6) according to Bezeq's consolidated annual statements from the past three years (2021-
2023). Therefore, in the absence of relevant qualitative considerations, this section describes legal 
proceedings to the extent of  NIS 80 million or more42, before tax, as well as legal proceedings in 
which the amount claimed is not specified in the statement of claim, unless it is a claim that does not 
reach the aforementioned quantitative threshold (and all - unless Bezeq assesses additional aspects 
or  consequences  of  the  procedure  beyond  its  financial  scope)43.  With  regard  to  class  actions, 
attention is drawn to the fact that the filing of class actions in Israel does not involve the payment of 
a  fee as a  derivative of the amount  of the claim. Thus, the claim amounts in such claims may be 
significantly higher than the actual exposure volume in respect of those claims. 

2.18.1. 

Procedures are pending 

Date 

Sides 

Court 

a. 

  March 
2015 

Shareholder 
vs. Bezeq 
and former 
Bezeq 
executives 

District 
(Tel Aviv 
- 
Economic
s 
Departm
ent) 

Type of 
procedure 

Motion for 
approval of 
a claim as a 
derivative 
claim 
together 
with a 
derivative 
claim 
statement 

Claim 
amount 
(NIS 
millions) 
502 

Details 

Motion  against  Bezeq,  as  well  as  against  Mr.  Shaul  Elovich,  former 
controlling  shareholder  and  chairman  of  the  board  of  Bezeq  against 
directors of  Bezeq  at  the  relevant  times  who  voted  in favor  of  Bezeq's 
engagement  in  the  transaction  that  is  the  subject  of  the  motion  as 
detailed below (“the Respondents"). 
The motion deals with, according to what is alleged in it, Bezeq's decision, 
through the respondents, to enter into a transaction for the purchase of 
full holdings and shareholder loans of Eurocom DBS (a company under the 
indirect  control  of  Bezeq's  controlling  shareholder)  in  Yes  for  NIS  680 
million  in cash and contingent  consideration of  up  to  an  additional  NIS 
370 million.  
According  to  the  applicant,  the  consideration  was  excessive,  and  the 
Respondents' decisions to enter into the transaction caused Bezeq a great 
deal of damage after they violated their duties of care and reliability to 
Bezeq,  and  were  negligent  in  their  role.  It  was  also  alleged  by  the 
applicant  that Bezeq's controlling shareholder had breached its duty  of 
fairness,  and  that  Bezeq  had  breached  the  duty  of  disclosure  and 
reporting regarding the trustee's commitment to Eurocom DBS's holdings 
in Yes to sell the holdings beginning at the end of March 2015. 
In light of the aforesaid, the petitioner requests that the Court approve 
the filing of a derivative claim on behalf of Bezeq against the Respondents 
for  the  claim  for  damage  caused  to  us  by  Bezeq  as  a  result  of  the 
Respondents'  decisions  regarding  the  transaction  in the  amount  of  NIS 
502 million. 
on July 3, 2017, the Court approved the filing of an amended motion by 
the applicant, which includes additional allegations relating, inter alia, to 
the independence of the entities that advised Bezeq, alleged defects in 

42  

In order to examine the compliance of the claim amounts with the said threshold, the amounts were linked to the consumer 
price index. The amounts specified in this section are the original amounts (excluding linkage differences). With regard to 
the aforesaid threshold, in the case of similar proceedings against several companies in the Group, the amount of the claim 
may be examined cumulatively in respect of all the proceedings together. It is also clarified that if certain proceedings largely 
concern common legal or factual issues, or it is known that such issues are examined or considered together, then for the 
purpose  of  meeting  the  quantitative  materiality  threshold  as  stated  in  these  sections,  the  amount  involved  in  all  those 
proceedings together.  

43  In view of the update of the materiality threshold, as of the date of approval of this periodic report, no legal proceedings are 
described in the periodic report for 2020 that do not reach the current materiality threshold as follows: Section 2.18.1 (12) 
(section number in the Periodic Report for 2020). 

79 

 
 
 
 
 
Claim 
amount 
(NIS 
millions) 

556 in the 
motion 
from 
November 
2015  
and 258 in 
the motion 
from March 
2018 

Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Date 

Sides 

Court 

Type of 
procedure 

Details 

b. 

s
November 
s
2015 
And March 
s 
2018 

Customer 
against 
Bezeq 

Central 
District 
Court 

Two claims 
together 
with 
motions 
for 
approval as 
class 
actions 

it 

in 

filed 

later 

indictments 

investigation  and 

the work of the Audit Committee, the Board of Directors and the general 
assembly, and alleged defects resulting from Eurocom being represented 
by Bezeq directors. 
In light of the Securities Authority's investigation, inter alia, regarding the 
engagement  that  is  the  subject  of  this  lawsuit  and  the  position  of  the 
Securities Authority  that it was improper to delay the proceedings, the 
Court decided to delay the proceedings in this case. On January 17, 2021, 
the  Attorney  General  announced  his  appearance  in  the  proceedings 
(regarding  the  delay  of  the  proceedings  and  not  the  body  of  the 
proceedings). Following the Attorney General's request, the procedure is 
delayed  at  this  stage  until  July  20,  2024,  in  light  of  the  Securities 
Authority's 
(see 
Section.אצמנ אל הינפהה רוקמ !האיגש). 
The  motion  from  November  2015  -  It  is  alleged  that  Bezeq  abused  its 
monopolistic  position,  inter  alia,  by  "preventing  and  blocking  the 
existence  of  competition  in  general  and  the  existence  of  effective 
competition in the communications market in Israel" and acted to delay 
and  thwart  the  wholesale  market  reform,  thereby  harming  the  Israeli 
public and earning unreasonable profits as a result of the abuse of power 
as a monopoly. According to the plaintiffs, the damage caused by Bezeq 
to the communications market in Israel is reflected in Bezeq's excess and 
unreasonable profitability, and they seek to claim damage in the amount 
of NIS 800 million, which they claim  is based on 10% of Bezeq's excess 
operating profit due to abuse of monopolistic power. The plaintiffs set the 
amount of the claim at NIS 556 million, after a reduction of the amount 
claimed  in  another  proceeding  (which  in  the  meantime  ended  in 
departure). 
In December 2017, the Court approved the attachment as evidence in the 
case of an immediate report published by Bezeq on October 22, 2017, in 
which  Bezeq  reported  on  a  final  inspection  report  by  the  Ministry  of 
Communications regarding the implementation of a wholesale telephony 
service  and  an  announcement  of  an  intention  to  impose  a  financial 
sanction. In December 2018, the Ministry of Communications imposed a 
financial sanction in the amount of NIS 11 million on Bezeq.  
On March 3, 2019, Bezeq informed the Court that in light of the expected 
change of case in the case as soon as the request for approval is received, 
it agrees to the Court's proposal to approve the motion to conduct the 
class action without a reasoned decision by the Court and preserving all 
its  claims.  It  should  be  noted  that  in  the  same  announcement,  Bezeq 
informed the Court that on February 25, 2019, it filed an administrative 
petition against  the  decision  of  the  Director  General  of  the  Ministry  of 
Communications  from  December  2018  described  above.  Subsequently, 
on March 5, 2019, the Court approved the motion to conduct the class 
action  lawsuit  and  clarified  that  all  the  parties'  claims  are  reserved  for 
them to discuss the lawsuit itself and that all evidence and investigations 
heard in the motion for approval will form part of the evidence in the class 
action lawsuit. 
In view of conducting a criminal proceeding ("Case 4000") related to this 
proceeding, on November 1, 2021, the Attorney General announced his 
appearance  in  this  proceeding.  In  the  latest  motion  submitted  by  the 
Attorney General, it was requested that the procedure be delayed until 
July 20, 2023. Further to another request by the State regarding the stay 
of  the  procedure,  the  discussion of  the  procedure  has been delayed at 
this stage until March 1, 2024. The applicants submitted a request for the 
continuation of the preliminary proceedings in the case and the request 
is under discussion. 

The motion from March 2018- a motion similar to the November 2015 
motion submitted by the same applicants in relation to the period from 
the date of filing the application from November 2015 to the end of 2017, 
in view of the plaintiffs' claim In addition to the abuse of power by Bezeq, 
there  were  also  "acts  of  corruption  and  unlawful  acts  and  foreign  and 
improper  purposes  of  the  Director  General  of  the  Ministry  of 
Communications".  According  to  the  plaintiffs,  the  damage  caused  by 
Bezeq  to  the  communications  market  in  Israel  is  reflected  in  Bezeq's 
excess and unreasonable profitability. On May 31, 2018, Bezeq submitted 
a  request  to  delay  the  procedure  in  light  of  the  Securities  Authority's 
investigation  and indictments filed subsequently,  the  Court  approved a 
motion  on  behalf  of  the  Attorney  General  to  continue  the  stay  in  the 
proceedings  in  the  case  until  February  15,  2024  and  also  approved  his 
request to submit an update notice until Mach 17, 2024. 

In September 2019, the applicants submitted a request for the filing of a 

80 

 
 
 
 
 
Claim 
amount 
(NIS 
millions) 

About 1,240 
in the first 
application 
and-568 in 
the second 
application 

Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Date 

Sides 

Court 

Type of 
procedure 

Details 

new motion for approval of a class action (a request filed against Bezeq in 
September 2019 following the determination dated Septemebr 4, 2019 of 
the  Competition  Commissioner  regarding  the  abuse  of  Bezeq's  status  - 
see description below subsection (F) to the Court where this proceeding 
is conducted and to the deletion of that motion on the ground that it was 
a  similar  late  motion.  In  addition,  on  October  23,  2019,  Bezeq  was 
submitted a request from the applicants for the motion for approval to 
order the amendment of the motion for approval by adding respondents 
(directors and officers from the relevant period, some of whom still serve 
at Bezeq) and to attach additional evidence to the motion for approval. 
On October 30, 2019, the Court announced that in view of its decision to 
delay the proceedings in the case, it does not consider it appropriate at 
this time to order the  transfer of  the request to amend the motion for 
approval  for  Bezeq's  response,  and  that  upon  termination  of  the 
proceedings  in  the  case,  the  applicants  must  petition  for  appropriate 
instructions. 

The requests deal with the 2015 transaction in which Bezeq acquired from 
Eurocom DBS (a company controlled by Bezeq's controlling shareholders 
at  the  time)  the  balance  of  Yes  shares  held  by  it  (in  this  section:  "the 
Transaction"): 

The first motion was submitted on behalf of everyone who purchased the 
Bezeq shares from February 11, 2015 until June 19, 2017 (except for the 
respondents and / or those on their behalf and / or related to them). The 
motion alleges misleading and / or missing reporting in connection with 
the Transaction, and that following an open investigation by the Securities 
Authority regarding the Transaction, the public became aware of details 
regarding the transaction and its implementation, which led to a decline 
in Bezeq's share price. According to the applicant, the respondents acted 
in violation of the provisions of the Securities Law and in violation of other 
legal  provisions,  causing  Bezeq's  securities  holders  heavy  financial 
damages, amounting to hundreds of millions of NIS, if not more than that. 

to 

The second motion was submitted on behalf of three sub-classes - anyone 
who purchased on the Tel Aviv Stock Exchange from May 21, 2015 to June 
19,  2017  (1)  the  Bezeq  shares,  (2)  the  Company's  shares  and  (3)  the 
Internet  Gold  shares.  According 
the  applicant,  a  serious 
misrepresentation  of  the  investors  who  invested  in  the  shares  of  the 
aforementioned companies was made, which was revealed following the 
opening of an open investigation into the Securities Authority on June 20, 
2017,  by  increasing  the  increase  in  Yes’s  cash  flow  reported  in  Bezeq 
According to the claim, artificially misleading the reasonable investor who 
relied  on  Yes’s  cash  flow  data  to  estimate  its  value,  which  led  to 
overpricing of the above companies. The applicant also claims additional 
damages caused to groups of Company and Internet Gold shareholders. 

Pursuant  to  a  hearing  arrangement  approved  earlier  by  the  Court,  the 
petitioners have agreed in the above petitions on their joint management 
and they are to file a consolidated petition on their behalf.  

Following the request of the Attorney General (who announced in 2017 
his appearance in the proceedings regarding the delay of the proceedings 
and not the body of the proceedings), the proceedings are delayed at this 
stage until July 20, 2024 in light of the Securities Authority investigation 
and indictments filed further thereto (see Section   אל הינפהה רוקמ !האיגש
.אצמנ) 

On May 23, 2023, the applicants in the consolidated procedure, together 
with  the  Company  and  Shaul  and  Or  Elovich  ("Elovich")  submitted  a 
motion for the approval of a compromise settlement in the consolidated 
procedure, where the Company agreed to pay a sum equal to USD 4.35 
million (USD  5.5  million dollars  including  attorney’s fee,  compensation, 
and other expenses) as compensation for exhausting the claims against 
itself  and  against  Elovich  (in  their  capacity  as  officers/controlling 
shareholders of the Company). In the motion, it was emphasized that the 
waiver made does not detract from the claims regarding Elovich regarding 
Bezeq. On January 8, 2024, a hearing was held on the motion, in which 
the Court ordered the parties to the settlement agreement to submit an 
amended motion for approval of the agreement as well as an amended 
agreement, taking into account the issues discussed in that hearing. 
An  amended  and  consolidated  motion  submitted  following  the  Court's 
decision of April 15, 2018 regarding the consolidation of four applications 

81 

c. 

  June 2017 

Two 
motions 
for 
approval of 
class 
actions 

In the 
District 
Court 
(Economi
c 
Departm
ent) in 
Tel Aviv 

Bezeq 
shareholders 
Against 
Bezeq, 
Chairman of 
the Board of 
Bezeq and 
former 
members of 
the Board of 
Bezeq, as 
well as 
members of 
the Eurocom 
Group (the 
first 
application 
also against 
the former 
CEO of 
Bezeq and 
the former 
CEO and 
CFO of DBS) 

d. 

  June - 
August 

Bezeq 
shareholders 

Tel Aviv 
District 

Various 
motions 

 
 
 
 
 
 
  
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Type of 
procedure 

for 
disclosure 
of 
documents 
before 
submitting 
a motion 
for 
approval of 
a 
derivative 
claim in 
accordance 
with Article 
198A of 
the 
Companies 
Law 
Motion for 
approval of 
a 
derivative 
claim 

Date 

Sides 

Court 

2017 and 
June 2018 

against 
Bezeq and 
DBS  

Court 

e. 

  February 
2018 

Tel Aviv 
District 
Court - 
Economic 
Departm
ent 

Bezeq 
shareholders 
against  Bezeq 
as  a 
formal 
respondent, 
as  well  as 
against  Bezeq 
at 
directors 
times 
relevant 
to 
the  motion 
and 
against 
Bezeq's 
controlling 
shareholders 
at  the  times 
relevant 
to 
the  motion, 
Shaul 
Mr. 
and 
Elovich 
Yosef 
Mr. 
Elovich 
(the 
"Respondent
s"). 

f. 

  (1) 
September 
2019  

Customers 
against Bezeq 

Tel Aviv 
District 
Court 

Application 
for 
approval of 
a class 
action 

Details 

Claim 
amount 
(NIS 
millions) 

filed in the same matter. The Court is requested to order Bezeq (and Yes, 
as the case may be) to provide the applicants with certain documents in 
connection with a stakeholder transaction between Yes and Space from 
2013 as amended at the beginning  of 2017 (in this section: "Yes-Space 
Transaction")44. On January 17, 2021, the Attorney General announced 
his appearance in the proceedings (regarding the delay of the proceedings 
and not the body of the proceedings). Following the Attorney General's 
request, the procedure is delayed at this stage until July 20, 2024, in light 
of the Securities Authority's investigation and indictments filed later in it 
(see section.אצמנ אל הינפהה רוקמ !האיגש).  

65 
Minimum 
threshold 
219 
Maximum 
threshold 

400 

The matter of the motion, according to what is claimed in it, is Bezeq's 
conclusion in an assessment agreement with the Tax Authority which was 
signed  on  September  15,  2016  (“the  Assessment  Agreement")  and 
according  to  which  Bezeq  paid  tax  to  the  Tax  Authority  on  financing 
revenue from loans to Yes in the amount of NIS 462 million, while on the 
other hand, it was agreed, among other things, that DBS' losses in respect 
of financing expenses in respect of Bezeq's owner loans to Yes will be fully 
recognized to Bezeq after the merger between Bezeq and Yes.  
According to the applicants, as a result of the signing of the assessment 
agreement, Bezeq paid a total of NIS 660 million. Of this total, NIS 462 
million was paid to the Tax Authority and approximately NIS 198 million 
was  paid  to  Bezeq's  controlling  shareholders  as  a  conditional 
consideration  stipulated  in  the  agreement  for  the  acquisition  of  full 
holdings and shareholder  loans of  Eurocom  DBS,  a company  under  the 
indirect  control  of  the  controlling  owner  of  Bezeq,  in  Yes  ("Yes 
Transaction"). 
According  to  the  petitioners,  Bezeq's  engagement  in  the  assessment 
agreement constituted an exceptional transaction of a public company in 
which Bezeq's controlling shareholders have a personal interest, and was 
carried out illegally because it was contrary to the Company’s benefit and 
because the required legal approvals were not obtained. 
According  to  the  plaintiffs,  the  damage  caused  to  Bezeq  following  the 
conclusion  of  the  Assessment  Agreement  ranges  from  a  minimum 
threshold of NIS 65 million (as long as all Yes losses in respect of financing 
expenses are allowed to be offset by Bezeq). 
According to the plaintiffs, the  respondents who are directors violated, 
inter alia, the duties of care and trust (and with regard to the respondents 
controlling Bezeq, also the duty of fairness), and accordingly the plaintiffs 
motion that the Court approve the filing of a derivative claim on behalf of 
Bezeq and Yes, because it will oblige them to compensate Bezeq for the 
said damages caused to it, according to them, as a result of the breach of 
their obligations to Bezeq. 
On January 17, 2021, the Attorney General announced his appearance in 
the proceedings (regarding the delay of the proceedings and not the body 
of  the  proceedings).  Following  the  Attorney  General's  motion,  the 
procedure  is  delayed  at  this  stage  until  July  20,  2023,  in  light  of  the 
Securities Authority's investigation and indictments filed later there (see 
Section.אצמנ אל הינפהה רוקמ !האיגש). 

Motion submitted following the determination dated September 4, 2019 
of the Competition Commissioner regarding the abuse of Bezeq's status 
("the Determination") (for this matter, see Section 2.16.9.5) in which it 
was  alleged  that  Bezeq's  acts  and  omissions  as  described  in  the 
Determination (blocking the transition of Bezeq competitors from Bezeq's 
infrastructure to the building access section, as well as refusing to thread 
cables in the continuous method and conditioning the deployment in an 
inferior,  expensive  and  problematic 
threading  method)  caused 
substantial damage to consumers. The definition of the group in whose 
name the class action will be conducted is anyone who purchased landline 

44  

It should be noted that on July 23, 2017, a motion was submitted to the District Court (Economic Department) in Tel Aviv 
for approval of a class action in the amount of approx. NIS 37 million against Space, controlling shareholders and officers in 
it as well as against Bezeq CEO and Bezeq Secretary at the relevant times to the claim in connection with the DBS-Space 
Transaction. The proceedings in this motion are also delayed, at this stage, until July 20, 2022. 

82 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Date 

Sides 

Court 

Type of 
procedure 

Details 

Claim 
amount 
(NIS 
millions) 

(2) March 
2020 

Shareholders 
against Bezeq 

Haifa 
District 
Court 

Consolidate
d request 
for 
disclosure 
of 
documents 
prior to 
request for 
approval of 
a derivative 
claim 

g. 

  January 
2021 

Bezeq 
shareholders 
v Bezeq et al.  

Motion for 
approval of 
a class 
action 

Tel Aviv 
District 
Court - 
Economic 
Departm
ent 

communication services  in  Israel,  in  the  period  between  July  2015  and 
March 2018, whether or not he purchased these communication services 
from Bezeq. Damage is claimed due to the loss from the decrease in the 
rate for communications packages, which was prevented from the group 
members due to Bezeq's alleged acts or omissions. Regarding a request 
for the transfer of this motion and its cancellation due to the fact that it 
is a similar late motion that was submitted by the applicants in another 
motion for approval of a class action in March 2018 - see subsection B. On 
June  25,  2020,  the  Court  ruled  that  the  parties  will  petition  for  the 
provision of appropriate instructions in the proceedings upon termination 
of  the  stay  of  proceedings  in  the  same  motion  for  approval  of  a  class 
action  from  March  2018.  The  parties  will  petition  for  appropriate 
instructions. 

Two motions (unified) for the disclosure of documents under Article 198A 
of the Companies Law for the purpose of examining the submission of a 
motion for approval of a derivative claim regarding the exercise of Bezeq's 
rights against officers in connection with the Determination. It is alleged 
that the findings and violations included in the Determination give Bezeq 
cause  of  action  against  Bezeq's  officers  and  that  Bezeq  is  entitled  to 
compensation from the officers for the damages  that were caused and 
that will be caused to it. On June 23, 2020, Bezeq submitted a request to 
delay the proceedings in the motions for disclosure, until the work of the 
Claims Committee established for the purpose and the submission of its 
recommendations to Bezeq's Board of Directors. On July 19, 2020, Bezeq 
submitted its response to the motions. The Attorney General submitted a 
notice  of  his  appearance  in  the  proceedings,  and  at  the  same  time 
submitted  his  position,  according  to  which  a  decision  to  appeal  the 
deterrmination that the petitioners claim constitutes the damage caused 
to Bezeq, may be a derivative proceeding as long as the above decision is 
not final. 
On April 4, 2021, the plaintiffs accepted the Court's proposal to delay the 
proceedings  until  after  the  completion  of  the  work  of  the  Claims 
Committee  established  by  Bezeq  and  a  decision  on  Bezeq's  request  to 
delay the proceedings. Subsequently, on October 13, 2021, Bezeq's Board 
of Directors decided to adopt the Claims Committee's recommendation 
of October 7, 2021, according to which in the circumstances Bezeq does 
not have a good cause of action against officers and other officials who 
served during the relevant periods, and that conducting legal proceedings 
will not promote Bezeq benefit. The Committee came to this conclusion 
after  examining  the  implications,  benefits,  damages,  costs  and  gains 
involved  in  conducting  such  legal  proceedings,  and  came  to  the 
conclusion  that  their  conduct  would  harm  Bezeq.  Bezeq  submitted  a 
notice to the Court. 
On June 4, 2023, the judgment of the Haifa District Court was issued, in 
which  it  partially  granted  the  motions,  and  ordered  the  disclosure  and 
review  of  the  Claims  Committee's  report  appendices  only,  and  not  the 
transcripts of the Committee's hearing minutes. 
A consolidated motion (filed in lieu  of two  similar motions in the same 
matter  that  was  deleted)  against  Bezeq,  the  Company,  and  90  other 
respondents, including past and present officers at Bezeq, the Company 
and Bezeq International, as well as the auditor firm (the "Respondents"). 
The motion deals, as alleged in it, with damages caused to the applicants 
and members of the represented groups (as detailed below) as a result of 
acts and omissions of the respondents who violated the provisions of the 
law, including that Bezeq and the Company included misleading details in 
their reports. In accordance with the provisions of the law, in connection 
with  Bezeq’s  and  the  Company’s  report  dated  November  9,  2020, 
according to which Bezeq International's books contain discrepancies in 
the amounts of hundreds of millions of NIS.45 The definition of the groups 
according to the application is: (a) Everyone who purchased Bezeq shares 
as of March 9, 2003 (date of publication of the annual report for the year 
2002)  until  November  9,  2020,  and  held  them  on  November  9,  2020, 
except for the respondents or those on their behalf and (b) anyone who 
purchased  the  Company’s  shares  on  the  Tel  Aviv  Stock  Exchange  from 
October 25, 2009 until November 9, 2020, and held them on November 
9,  2020,  except  for  the  respondents  or  those  on  their  behalf.  In 

"Over NIS 
2.5 million 
(for the 
purposes of 
substantive 
authority)" 

45 As part of the preparation of the Company and Bezeq International Ltd. for the publication of their statements for the period 
ending on September 30, 2020, it was found by Bezeq International that there are unexplained net asset balances in its 
books (debtors minus creditors). Subsequently, the statements were restated. 

83 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

Date 

Sides 

Court 

Type of 
procedure 

Details 

Claim 
amount 
(NIS 
millions) 

l 

April 2021 

Customer  VS 
Bezeq 

Central 
District 
Court 

Motion  for 
approval  of 
a 
class 
action 

J 

June 2023 

Customers  VS 
the Company 

Tel  Aviv 
District 
Court 

Motion  for 
approval  of 
a 
class 
action 

K 

September 
2023 

Customers  VS 
the Company 

Lod 
(Central) 
District 
Court 

Motion  for 
approval  of 
a 
class 
action 

accordance  with  the  economic  opinion  attached  to  the  motion,  it  was 
alleged  that  following  the  publication  of  the  immediate  report  dated 
November 9, 2020 published by Bezeq and BCOM, the Company’s share 
price decreased by 5.26%-5.40% (it should be noted that the motion also 
claims, in accordance with another opinion attached to it, that compared 
to  Bezeq's  benchmark  indices,  the  damage  to  Bezeq's  shareholders  is 
higher than the decrease in the value of the shares, and is about 7%), and 
the  Company’s  share  price  decreased  in  the  range  of  9.07%-9.36%. 
Accordingly, it was argued that the damage caused to the applicants is in 
the  amount  obtained  from  doubling  the  amount  of  shares  held  by  the 
members of the groups as aforesaid at the rate of the aforesaid decrease 
in  the  shares  of  Bezeq  and  the  Company.  The  case  is  in  mediation 
proceedings. 

It was alleged that Bezeq caused pecuniary and non-pecuniary damages 
to the class members who paid an increased amount for a higher level of 
browsing speed than they could actually use, for upgrading the modem 
so  that  they  could  browse  at  this  rate,  as  well  as  for  harassment, 
inconvenience, mental distress and impaired autonomy. According to the 
motion,  the  class  of  plaintiffs  must  include  anyone  who  used  Bezeq's 
Internet infrastructure in the seven years prior to the date of submission 
of the motion for approval until the date of its approval of the class action, 
and paid for a certain speed level, while the infrastructure in his home is 
capable of providing speed that matches a lower speed level. 

It  is claimed that  Bezeq does not  act  in  accordance  with the  law  when 
giving notice of the end of fixed-term transactions, in that it does not send 
a separate  notice  of  the  expected end  of  the  benefit  period within the 
fixed-term  transaction,  and  only  notifies  the  customer  through  the 
monthly invoice and a text message. These are two motions where the 
Court approved the motion of the applicants to consolidate them into one 
motion that will be heard in the Tel Aviv District Court. Similar requests 
were also submitted against Pelephone (see update to Section 3.16.1) and 
Yes (see update to Section 5.16.1). 
It is claimed that (1) Bezeq made a misleading representation regarding 
the price of the Internet package, since it did not present, in addition to 
the cost of the Internet package, the monthly charge of NIS 19.90 for the 
router. The claim refers to those who were subscribers to a package that 
included the Company's infrastructure and another Internet provider and 
then  purchased  a  new  package,  where  the  Company  provides  the 
provider and infrastructure services (starting in April 2022) and continued 
to  be  charged  for  the  router  they  rented  from  Bezeq,  without  the 
Company making it clear to them that the price displayed does not include 
the router; (2) Bezeq provides customers with an antivirus service for a 
monthly  fee  of  NIS  14.90  by  default  and  without  receiving  express 
in  a  settlement 
in  violation  of  commitments  approved 
consent, 
agreement as part of a previous class action against the Company. 

NIS 

* 
The  amount 
of  the  class 
action 
cannot 
be 
estimated. It 
was  stated 
that 
these 
are 
damages 
amounting 
to 
million, 
which 
within 
jurisdiction 
of the Court. 
The  amount 
of  the  class 
action 
is 
over  NIS  2.5 
million,  but 
it  cannot  be 
accurately 
estimated. 

fall 
the 

be 

The  amount 
of  the  class 
action 
cannot 
accurately 
estimated 
is 
and 
estimated at 
over  NIS  2.5 
million 

1.18.2. 

Legal  proceedings  completed  during  the  period  of  the  report  or  until  the  date  of 
publication of the report 

Date 

Sides 

Court 

Type 
procedure 

of 

Details 

Claim 
amount (NIS 
millions) 

a. 

  January  
2015 

Shareholder 
against  Bezeq 
former 
and 
officers 
in 
Bezeq 

District 
(Tel Aviv - 
Economic 
Departm
ent) 

Motion  for 
approval  of 
class 
a 
action 

A claim for compensation of shareholders for losses which were claimed 
to  have  been  caused  due  to  "Bezeq's  reporting  failures  to  the  stock 
exchange and the concealment of material information from the investing 
public" regarding the "reduction of interconnect fees" and the "reform of 
the wholesale market". 
On August 27, 2018, the decision of the Economic Department of the Tel 
Aviv District Court was issued approving the claim as a class action ("the 
Approval Decision"). 
On  December  1,  2019,  a  ruling  was  issued  at  a  rehearing  held  at  the 

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request of Bezeq and the defendant officers in the Economic Department 
of the Tel Aviv District Court regarding the decision to approve the claim 
as a class action and it was determined as follows: 
1.  Regarding  the  reduction  of  the  interrconnect  fees  -  the  Court 
accepted the motion insofar as it concerns the claims concerning the 
reports  regarding  the  reduction  of  the  interrconnect  fees,  after 
concluding  that  the  plaintiff  did  not  even  prima  facie  prove  the 
existence of damage in connection with the reason for the reduction 
of the mutual connection fees, and therefore therefore it would be 
inappropriate to approve the class action on this ground. 

2.  Regarding  the  wholesale  market  reform  -  the  Court  dismissed  the 
motion  in  relation  to  the  defendants'  claims  regarding  the  reports 
about  the  wholesale  market  reform.  At  the  same  time,  reduce  the 
definition of the group of plaintiffs in relation to this cause. 

On  July  12,  2020,  an  amended  statement  of  claim  was  filed,  including 
corrections in accordance with the ruling in the rehearing, in which the 
total amount of the claim was also corrected to a total of NIS 687 million. 
On  February  8,  2023,  the  Court  issued  a  ruling  approving  a  settlement 
agreement reached between the parties following a mediation process in 
which the plaintiffs were paid, by the officers' insurance company and at 
no cost to the Company and the defendant officers, a total sum of NIS 75 
million  (including  compensation  and  attorney  fees).  In  view  of  the 
provisions  of  the  accounting  standard,  a  provision  was  recorded  in 
Bezeq's  financial  statements  for  the  first  quarter  of  2022  (during 
negotiations for a settlement in the case) in the amount of the settlement 
amount, and on the other hand, in view of the existence of full insurance 
coverage,  an  indemnity  asset  in  the  amount  of  the  provision  was 
recognized in the same report, without impact on Bezeq's results. Upon 
the  issuance  of  the  aforementioned  ruling,  the  registration  of  the 
provision and the aforementioned indemnification asset were canceled 
in the reports for the first quarter of 2023. 
It  is  requested  that  the  Court  order  Bezeq,  Yes,  as  well  as  the  former 
controlling owner of the Company, Mr. Shaul Elovich, and his son, Mr. Or 
Elovich (hereinafter, collectively: "Elovich"), to hand over to the applicant, 
as  a  shareholder  in  Bezeq,  various  documents  for  the  consideration  of 
submitting an application for approval of a derivative claim on behalf of 
the  Company.  According  to  the  applicant,  the  Company  and  Elovich 
violated their fair and fiduciary duties towards Bezeq, in that the sale of 
115 million Bezeq shares on February 2, 2016 by the Company was carried 
out while the Company and Elovich used Bezeq's insider information, and 
at a value significantly higher than the real value of the shares. According 
to the applicant, this sale brought the Company improper profits in the 
amount of approximately NIS 313 million. 
According to the claim in the motion, the insider information which, was 
used as mentioned is, among other things, that the financial statements 
of Yes and Bezeq do not reflect the de facto financial situation of Bezeq, 
but  "free  cash  flow"  that  is  inflated  for  the  purpose  of  increasing  the 
consideration in the context of the transaction in which Bezeq purchased 
the shares of Eurocom Communications in Yes (“the Yes Transaction"). 
On September 19, 2023, a judgment was issued striking out the motion 
on the grounds that it was submitted over five years ago, and no hearing 
was held due to the delay in the proceedings in the case. It was also stated 
in the judgment that the striking out does not constitute a limitation of its 
underlying grounds, and no claim in this regard will be heard regarding 
the period from the date of the judgment until it is filed as a new claim, if 
any. 

b. 

  August 
2021 

Shareholder 
against 
Yes, 
Bezeq, 
Shaul 
Mr. 
Elovich,  and 
Mr. Or Elovich 

The 
District 
Court 
(Economi
c 
Departm
ent) 
Tel Aviv 

in 

to 

Motion 
disclose 
and  review 
documents 
according 
to  Article 
198a  of  the 
Companies 
Law 

2.19.  Targets and business strategy 

2.19.1. 

Forward-looking information 

Bezeq's strategy review below includes forward-looking information within the meaning 
thereof  in  the Securities Law, and involves assessments of future developments in the 
economy in general regarding customer behavior and needs, the pace of adoption of new 
services, technological changes, regulatory policy, competitors' marketing strategy, and 
the effectiveness of strategic marketing. . 

Bezeq's  strategy  and  the  business  objectives  derived  from  it  are  based  on  internal 
research  and  analysis,  secondary  sources  of  information,  especially  research  company 
statements,  publications  regarding  activities  undertaken  by  similar  communications 
operators in Israel and around the world, and consulting work by which Bezeq is assisted.  

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However there is no assurance that the main strategy and activities described below will 
be implemented in practice or in the manner described below. The circumstances that 
may lead to the non-implementation of the strategy or even to its failure are due to the 
general situation in the economy, frequent technological changes, regulatory constraints, 
formulation  of  a  sustainable  business  model  for  new  services  that  Bezeq  intends  to 
provide  and  adopting  a  superior  marketing  strategy  from  competitors.  In  addition, 
changes in the composition of Bezeq's Board of Directors or ownership of Bezeq, which 
will lead to a change in the composition of the Board of Directors, may lead to a change 
in its strategy and business objectives. 

2.19.2. 

The essence of the strategy and intentions for the future  

2.19.2.1 

Vision and purpose 

Bezeq  has  set  itself  the  target  of  being  the  leading  communications 
company in Israel, providing a wide range of communications services and 
solutions, to private and business customers. 

Bezeq  works  to  maintain  its  competitive  position  and  continue  to  be  the 
customer's first choice in telephony, Internet and IT, and for this purpose it 
has set itself a number of targets: 

a.  Preservation of leadership in the aggravating competitive environment 
(service  leadership  and  strengthening  perceived  values  -  product 
innovation,  reliability,  price  perception),  and  within  this  framework, 
leading the optical fiber market; 

b.  Being the leading fiber company in the number of connected retail lines 

in the Israeli communications market; 

c.  Encouraging  the  recruitment  of  new  customers  and  strengthening  a 

sense of loyalty and closeness among existing customers; 

d.  Creating  new  sources  of  revenue  through  the  launch  of  new  and 
innovative  services  and  products  and  entry  into  fields  that  are 
tangential and complementary to the Company's activity, such as the 
field of electricity supply (see Section 1.9); 

e.  Ongoing  adaptation  of 

the  organization 

to 

the  competitive, 

technological and operational excellence environment. 

2.19.2.2 

Means 

To implement the said strategy and objectives, Bezeq operates a wide range 
of advanced communication networks, which operate on a wide range of 
infrastructures nationwide, and enable the provision of the most advanced 
communication  services  in  the  world.  Bezeq  is  working  to  upgrade  and 
develop  the  communications  networks  it  operates,  including  the  fiber 
infrastructure  through  a  wide  fiber  deployment.  The  Company  strives  to 
constantly expand and improve the basket of products and services, and it 
also  offers  and  operates  a  service  network,  including  technical  and 
commercial centers, and a wide range of service and installation technicians. 

2.19.3.  Major projects in planning or execution 

Regarding the deployment of a fiber optic network by Bezeq, see section 2.7.2.  

2.20.  Discussion of risk factors 

There  are  risk  factors  that  arise  from  the  macroeconomic  environment,  from  the  unique 
characteristics of the industry in which Bezeq operates, and risk factors that tare unique to Bezeq, 
which may have significant consequences for Bezeq and affect, among other things, Bezeq's status, 
its results, its credit rating and its ability to repay its debt, all as specified below: 

2.20.1. 

Competition 

Competition in the field of landline interior communications increasing in recent years, 
both in the field of deploying independent networks (see Section 2.6), and in the field of 

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providing services using the wholesale market, through which telecommunication groups 
and other telecommunications operators (those with a special or unified license and even 
licensed providers) compete with Bezeq in the sale of unified Internet service packages 
based on Bezeq infrastructure, at prices set by the regulator (see Section1.7.4 and Section 
2.16.4).  A  large  number  of  customers  receive  wholesale  Internet  services,  which  are 
provided  on  the  Bezeq  network,  when  Bezeq  does  not  have  contact  with  those 
customers.  Increased  competition  in  the  field  of  interior  communications  causes  the 
abandonment of some of Bezeq's customers and leads to lower prices of some of Bezeq's 
services and an increase in the costs of recruiting new customers and retaining existing 
customers. The entities that compete with Bezeq at present, or may compete with it in 
the future, enjoy greater business flexibility than Bezeq, including the ability to cooperate 
with  subsidiaries  and  affiliates  and  market  shared  service  packages  with  them  (see 
Section1.7.3  and  Section  1.7.4).  The  ability  of  competitors  to  market  service  packages 
with  rate  flexibility,  in  the  face  of  Bezeq's  limitations  to  do  so  as  of  this  date,  impairs 
Bezeq's competitive ability. 

2.20.2. 

Governmental supervision and regulation 

Bezeq  is  subject  to  governmental  supervision  and  regulation  relating,  inter  alia,  to 
licensing  activities,  determining  permitted  areas  of  activity,  determining  rates, 
operations, competition, payment of royalties and depositing funds to the incentive fund, 
universal service obligation, the possibility of holding its shares, the relationship between 
Bezeq and its subsidiaries and prohibiting cessation or restriction of  its services (which 
may oblige Bezeq to provide services even in non-economic circumstances) - for details, 
see Section2.16. The aforesaid supervision and regulation sometimes causes government 
intervention,  which  in  Bezeq's  opinion  burdens  its  business  activities.  In  this  context, 
Bezeq is exposed to various sanctions by the Ministry of Communications, including the 
imposition of financial sanctions (for this matter, see Section1.7.7.5).  

In  addition,  the  Minister  of  Communications  may  revoke  Bezeq's  license,  restrict  it  or 
suspend  it  as  appropriate,  in  accordance  with  the  conditions  set  forth  in  the 
Communications Law, and is authorized to change the terms of Bezeq's license, interfere 
with existing rates and marketing proposals and issue instructions. Substantial changes in 
the rules of regulation that apply in the field of communications in general, and to Bezeq 
in particular, may oblige Bezeq to make changes to its strategic plans and impair its ability 
to carry out long-term planning of its business activities. For possible changes following 
the  wholesale  market  reform,  see  section2.16.4.  For  possible  restrictions  under  the 
Centralization  Law  on  the  renewal  of  licenses  and  the  allocation  of  new  licenses,  see 
Section1.7.7.6. 

2.20.3. 

Rates supervision 

Bezeq rates for a key part of its services (including rates for reciprocal linking and use of 
Bezeq  infrastructure  and  its  network)  are  subject  to  government  supervision  and 
intervention. The Minister of Communications has the authority to intervene in existing 
rates and marketing proposals and to give it instructions (see Section2.16.1). On average, 
supervised Bezeq rates are eroding in real terms. Substantial changes in Bezeq's regulated 
rates, if implemented, could have a material adverse effect on its business and its results. 
Regarding  the  supervision  of  the  supervised  Bezeq  rates  and  their  updating,  see 
sections2.16.1 and2.16.4. In addition, the restrictions that apply to Bezeq in marketing 
alternative payment baskets may make it difficult to provide an appropriate competitive 
response  to  changes  in  the  market,  and  they  are  significantly  reflected  in  Bezeq's 
competitors on the basis of its infrastructure in selling unified Internet service packages 
through Bezeq's wholesale service. As part of the application of a wholesale market, the 
Ministry of Communications updates the rates and terms for wholesale services according 
to which Bezeq will sell its services to licensees. The update of the rates leads to lower 
prices in a way that could adversely affect Bezeq's level of revenue and its profitability 
(for the wholesale market, see section 2.16.4). 

2.20.4. 

Streamlining procedures and labor relations 

Implementation of personnel and organization programs (including retirement plans and 
organizational  changes)  involves  coordination  with  employees  and  significant  costs, 
including  early  retirement  compensation  costs.  Processes  of  implementing  such  plans 
may  cause  unrest  in  the  employment  relationship  and  harm  Bezeq's  day-to-day 

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operations - see also Sections2.9.3 and 2.17.3.  

Also,  as  described  in  section1.7.11,  according  to  the  report,  Bezeq,  like  the  other 
companies  in  the  Group,  implements  streamlining  procedures,  which  include,  among 
other  things,  organizational  changes  and  reducing  the  workforce,  while  managing 
significant  infrastructure and other projects.  Streamlining  procedures, by nature, carry 
with  them  the  risks  of  loss  of  knowledge,  turnover  of  employees,  shift  of  managerial 
focus, and so on. 

2.20.5. 

Restrictions regarding the relationship between Bezeq and companies in the Bezeq Group 

Structural separation - Bezeq's NIO license prohibits preferring the main companies in the 
Group  over  their  competitors.  A  separation  is  required  between  the  managements  of 
Bezeq and the said companies, as well as a separation in the business systems, finances 
and marketing, assets and employees, which causes duplication, high overheads and also 
makes it difficult to manage strategy at the Group level. Also, at this stage, Bezeq's ability 
to offer shared service packages of Bezeq and the said companies is limited (see Section 
1.7.3). 

Regarding the possibility that in the future the Group will  be granted a  permit  for the 
provision of non-detachable service packages and the elimination of structural separation 
and for further possible changes following the wholesale market, see Sections 1.7.3 and 
2.16.4. 

2.20.6. 

Legal Proceedings 

Bezeq is a party to legal proceedings, including class actions, which may result in charges 
in substantial amounts, most of which cannot be estimated, and therefore no provision 
was made for most of them in Bezeq's financial statements. In addition, Bezeq's insurance 
policies are limited to defined coverage limits and for certain reasons, and may not cover 
claims for certain types of damages. In recent years, there has been a multiplicity of class 
action lawsuits against large commercial companies. By their very nature, class actions 
can reach large sums. In addition, since Bezeq provides communications infrastructure as 
well as billing and collection services to other licensees, other class action lawsuits against 
the  said  licensees  may  also  involve  Bezeq  as  a  party  in  these  proceedings.  For  a 
description of the legal proceedings, see Section 2.18.  

2.20.7. 

Exposure to exchange rate fluctuations, inflation and interest rates 

Bezeq measures exposure to changes in currency and inflation according to surplus or 
lack of assets versus liabilities, as well as according to cash flow forecasts, according to 
the type of linkage. Bezeq's exposure to changes in inflation is high and Bezeq's exposure 
to changes in the exchange rate against the shekel is low. Bezeq is hedging some of its 
exposure to inflation and foreign exchange. In addition, Bezeq has exposure to changes 
in interest rates in relation to the credit it receives. For this matter, see also Note 30 to 
the 2023 statements and Section 1.6 of the Board of Directors’ report. 

2.20.8. 

Bezeq’s debt and debt repayment capability 

Bezeq is required to maintain a sufficient cash flow in order to meet its obligations and 
its long-term business plans. The lack of sufficient cash flow may have a negative impact 
on Bezeq's business, including the inability to meet its obligations, damage to its ability 
to repay debt, make investments and deal with competitive threats. For more details on 
the financing of Bezeq’s activity, see Section 2.13. 

2.20.9. 

Electromagnetic radiation and licensing of transmission facilities  

The issue of electromagnetic radiation emitted from transmission facilities is regulated 
mainly in the Non-Ionizing Radiation Law (see  Sections 2.15 and 2.16.11). Bezeq works 
for  the  existence  of  construction  and  operation  permits  for  its  various  transmission 
facilities, but the difficulties encountered by Bezeq in this activity, including difficulties 
arising  from  changing  the  policy  of  the  relevant  parties  and  changes  in  legislation  and 
regulations, may adversely affect the infrastructure of the said facilities, the regularity of 
the provision of the services through them, and consequently also the Bezeq revenues 
from  these  services.  Bezeq's  third  party  insurance  policy  does  not  currently  cover 
warranty for electromagnetic radiation. 

2.20.10. 

Frequent technological changes 

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The field of communications is characterized by frequent technological changes and the 
shortening  of  the  economic  life  of  new  technologies  -  see  section2.1.4.  These  trends 
require investing a lot of resources in upgrading Bezeq's existing technologies, lowering 
the barriers to entry for new competitors, increasing depreciation rates and in some cases 
there may be a redundancy of Bezeq-owned technologies and networks. The introduction 
of innovative technology that is not used by Bezeq or that Bezeq has refrained from using 
may harm Bezeq's competitive position. 

2.20.11.  Dependence on macro factors and on levels of business activity in the economy  

The stability of the financial markets and the resilience of the economies of the countries 
of the world have been in recent years subject to high volatility. Bezeq estimates that as 
the local economy slides into a period of recession and deterioration in business activity 
due  to  external  or  internal  events,  including  shocks  in  the  global  economy,  political-
security uncertainty, etc., then its business results may be harmed, among other things, 
as a  result of Bezeq revenues (including investee  revenues)  or  as a  result of increased 
Group financing costs. 

2.20.12. 

Failure in Bezeq’s systems and cyber risks  

Bezeq provides its services through various systems, including, among others, exchanges, 
data transmission and access transmission networks, cables, computer systems, physical 
infrastructure,  server  farms,  and  more  ("the  systems").  The  Systems  are  of  critical 
importance in the operation of Bezeq's business and they play a vital role in its ability to 
successfully  carry  out  its  activities.  Hacking,  disruption,  damage  or  collapse  of  the 
Systems, including as a result of power outages, can adversely affect Bezeq's business. 
Some Bezeq systems have backup, but at the same time, in the event of damage to some 
or all of the above systems, either due to various technical faults (including in the event 
of termination of contact with a supplier who is dependent on system support), or due to 
natural disasters (earthquakes, fire), whether due to damage to physical infrastructure by 
communications  providers  using  them  or  due  to  malicious  damage  (including  through 
cyber  attacks  as  detailed  below),  there  may  be  significant  difficulties,  and  more  than 
significant,  in  providing  Bezeq  services,  including  in  the  event  that  Bezeq  is  unable  to 
return the Systems to capacity quickly. 

Bezeq carries a risk of activity occurring that is intended to harm the use of a computer 
or  computer  material  stored  on  it  ("cyber  attack").  Such  attacks  can  disrupt  business, 
theft of information / money, damage to reputation, and damage to systems, information 
retrieval (including not as a result of a cyber incident), and from there, also to material 
damage to Bezeq’s activity. As a leading communications company that provides diverse 
communications services in various fields, it is a target for cyber attacks and experiences 
cyber attacks, which are handled by it. 

Bezeq is a body guided by the State Authority for Information Security and is committed 
to meeting strict information security standards. The Company is subject to rules in this 
matter even by virtue of its licenses. In this context, Bezeq implements a defense policy 
that includes the most advanced security systems in the world operated in a configuration 
that combines effective security with Bezeq's operational needs and security circuits to 
protect Bezeq's infrastructure and systems designed to prevent and reduce the possibility 
of  Bezeq  data  being  exploited  by  an  external  or  an  internal  party  maliciously  or 
inadvertently, as well as the possibility of an outsider taking over and managing network 
components  or  abusing  information  about  Bezeq's  infrastructure  and  networks  in  any 
way. In this framework, adequate resources are invested, including, among other things, 
technological resources for the purchase of information security solutions and products 
and  resources  for  information  security  standards,  and  various  actions  are  performed, 
including checking alerts and logs in the systems, periodic risk survey, practice according 
to an annual plan, as well as ongoing work in accordance with appropriate procedures. 
Bezeq is certified for three ISO standards (ISO 27001, ISO 27017, ISO 27018) related to 
information  security  (standards  that  define  and  test  the  principles  of  establishing, 
managing  and  maintaining  information  security  in  the  organization),  and  as  part  of 
implementing  the  requirements  of  Bezeq  standards  ensures  the  availability,  integrity, 
reliability and confidentiality of the databases for which it is responsible. 

The  cyber  risk  management  policy  is  approved  by  the  Company's  information  security 
steering  committee  with  the  participation  of  the  Bezeq’s  VP  of  Technologies  and 

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Network. The person responsible for implementing the policy in Bezeq is the director of 
the Information and Cyber Security Department. 

Bezeq monitors the implementation of its defense policy, which includes an examination 
of Bezeq's level of effectiveness and readiness. In this context, Bezeq conducts tests and 
assault drills with different frequency for different scenarios (including through external 
companies that specialize in the field). Also, Bezeq’s Board of Directors is involved in and 
supervises  the  management  of  cyber  risk  in  Bezeq  within  the  framework  of  handling 
Bezeq’s  overall  risk  management  policy  and  receiving  ongoing  updates.  In  Bezeq's 
estimation,  the  risk  management  policy  in  dealing  with  and  reducing  the  cyber  risk  is 
effective. 

Despite  Bezeq's  investments  in  measures  to  reduce  such  risks,  Bezeq  is  unable  to 
guarantee that these measures will succeed in preventing damage and / or disruption 
which may also be significant to systems and related information. 

2.20.13. 

Impairment of subsidiaries 

In accordance with the accounting standards, Bezeq performs valuations for subsidiaries 
for the purpose of examining the periodic impairment of goodwill and of assets in respect 
of which signs of impairment have been identified. Considering the business situation of 
the  subsidiaries  and  the  difference  between  the  book  value  of  Bezeq  and  their 
recoverable amount as a cash-generating unit, a decrease in the value of the subsidiaries' 
activity may lead to impairment loss (write-off) in Bezeq books. Also, a significant change 
in  circumstances  that  leads  to  a  change  in  estimates  can  occur  as  a  result  of  a  high-
intensity discrete event and / or as a result of a sequence of small changes occurring over 
time  that  have  a  significant  cumulative  effect  in  the  long  run  and  /  or  a  change  in 
estimates (even at low rates). Valuations are based on assumptions as of the date of the 
statements that may not materialize or materialize partially and different aspects have 
long-term 
intensities  affecting  the  value  of  the  unit  measured  when 
different 
assumptions may have a relatively large weight compared to short-term assumptions.For 
this  matter,  see  also  Note  11  to  the  2022  statements  and  Section  3.1  of  the  Board  of 
Directors' Report.  

2.20.14.  Pandemic 

Disease outbreaks and epidemic events in general (such as the outbreak of COVID-19 in 
2020) may have consequences for the Company's business activities, depending on the 
extent of the spread and its severity and on the national and global measures that will be 
taken as a result. These consequences may be manifested, among other things, in damage 
to the Company's activities and its customer service system, as well as damage to the 
supply  chain.  Events  of  this  type  are  changing  events  that  are  out  of  the  Company's 
control,  and  their  consequences  are  subject,  among  other  things,  to  the  decisions  of 
countries and authorities in Israel and around the world that may affect the Company 
accordingly. 

2.20.15.  Damage caused by nature, war, disaster 

Damage  to  the  Company's  infrastructure  and  services  as  a  result  of  natural  disasters, 
including earthquakes, as well as as a result of war or disaster, as well as damage to the 
supply chain, may adversely affect the Company's business and results. 

2.20.16.  Damage to electricity supply 

Damage to the supply of electricity to the Company's facilities for various reasons (some 
of which are described in Section 2.20.15) may adversely affect the Company's business 
and damage the Company's ability to provide services. Some of the Company's systems 
have power backup, but at the same time, in the event of a prolonged damage to some 
or all of the systems, significant and even more difficulties may be caused in the provision 
of the Company's services, including in the event that the Company will not be able to 
return the systems to service quickly. 

It should be noted that a significant part of Bezeq's operations (in a consolidated manner) is carried 
out in its subsidiaries. The risk factors of these companies and the assessments of their managements 
in relation to the risk factors are described in Sections 3.19, 4.14 and 5.18, and they are also relevant 
to the Group's activities and results. 

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The following is a rating of the impact of the risk factors described above on Bezeq's operations, in 
Bezeq's Management's assessment. It should be noted that Bezeq’s assessments below regarding 
the degree of influence of the risk factor reflect the degree of influence of the risk factor in assuming 
the  materialization  of  the  risk  factor,  and  the  aforesaid  does  not  express  an  assessment  or  give 
weight to the chances of such materialization. The order in which the risk factors appear above and 
below is not necessarily according to the degree of risk: 

Risk Factors Summary Table – Landline Interior Communications46  

The extent of the impact of the risk factor 
on Bezeq's operations 
Medium 
effect 

High 
effect 

Low effect 

Macro risks 
Exposure to exchange rate fluctuations, inflation and interest 
rates 
Debt and debt repayment capability 
Dependence on macro factors and levels of  business activity 
in the economy 
Pandemic 
Damage caused by nature, war, disaster 
Damage to electricity supply 

Industry risks 

Growing competition 
Governmental supervision and regulation 
Rate supervision 
Electromagnetic radiation / licensing of transmission facilities 
Frequent technological changes 

Special risks for Bezeq 

X 

X 
X 

X 
X 
X 

X 

X47 

X 

X 

X 

X 
X 

Exposure to legal proceedings 
Streamlining processes and labor relations 
Restrictions  regarding  the  relationship  between  Bezeq  and 
companies in the Bezeq Group 
Failure of Company systems and cyber risks 
Impairment of subsidiaries 
The information contained in this section 2.20 and Bezeq's assessments regarding the impact of risk factors 
on Bezeq's activities and business are forward-looking information as defined in the Securities Law. The 
information  and  assessments  are  based  on  data  published  by  the  Ministry  of  Communications,  Bezeq 
assessments  of  the  market  situation  and  the  structure  of  competition  in  it  and  regarding  possible 
developments in this market and in the Israeli economy. The actual results may differ materially from the 
estimates given above if there is a change in one of the factors taken into account in these estimates. 

X 

X 

X 

46  

It is hereby clarified that in the assessments of the Group companies regarding the effect of the risk factors in the summary 
tables (in this section and in Sections 3.19 , 4.14, and 5.18), the probability of the risk factor materialization was not estimated 
fully, but the effect of the risk factor on the relevant company if it materialized. It should be noted that some of the Group 
companies  make  estimates  regarding  the  probability  of  the  occurrence  of  some  of  the  risk  factors  mentioned  in  these 
sections for their specific internal needs. Also, in general, the degree of influence of a risk factor on the Company's operations 
depends in some cases also on the extent and duration of the materialization of the risk, so that it may differ from what is 
indicated. 

47   The extent of the impact of this risk factor on Bezeq's activity was classified as low, assuming that the event would be limited 

in scope and time. Otherwise, the degree of impact may be greater. 

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3. 

Pelephone - Mobile radio telephone (cellular telephony) 

3.1. 

General information about the field of activity 

3.1.1. 

Pelephone's field of activity 

Pelephone  provides  cellular  communication  services  and  the  sale  and  repair  of  end 
equipment. Pelephone services are detailed in the section3.2. Pelephone is a company 
wholly owned by Bezeq.  

3.1.2. 

Legislative and regulatory restrictions unique to the field of activity 

3.1.2.1 

Communications Law and mobile radio telephone license 

Pelephone's activities are subject to regulation and supervision by virtue of 
the  Communications  Law  and  its  regulations,  by  virtue  of  the  Telegraph 
Order,  and  by  virtue  of  mobile  radio  telephone  license  owned  by  it.  The 
mobile  radio  telephone  license  sets  conditions  and  rules  that  apply  to 
Pelephone's operations (for details, see section3.14.2).  

3.1.2.2 

Rate supervision 

Interconnectivity  fees  (rates  for  completing  a  call  and  completing  short 
message messages (SMS) charged by Pelephone from other communication 
operators are fixed in interconnectivity regulations. The rest of the rates are 
under  a  certain  supervisory  regime  as  regulated  under  the  mobile  radio 
telephone  license  and  the  Communications  Law  (see  sections  3.14.1  and 
3.14.2).  

3.1.2.3 

Environmental law and planning and construction law 

Establishment  and  operation  of  wireless  communication  infrastructure, 
including cellular communications, is subject to the provisions of the Non-
Ionizing Radiation Law and the permits required thereunder by the Ministry 
of  Environmental  Protection,  as  well  as  the  provisions  of  planning  and 
construction law (see section 3.13.2). 

3.1.3. 

Changes in the scope of activity in the field 

For  financial  data  on  the  scope  of  Pelephone's  activity,  see  sections    רוקמ  !האיגש
.אצמנ אל הינפהה and 3.3. 

Revenue from services 

The cellular industry is characterized by fierce competition. Competition in the industry 
led to a high transfer of subscriptions between the cellular operators while continuously 
eroding  the  prices  of  the  base  packages  along  with  a  further  increase  in  the  browsing 
volumes included in the packages, which in recent years have caused another significant 
erosion of the average revenue per subscriber (see Section3.6). The growth in the number 
of postpaid subscribers (subscribers who receive service for a monthly payment) in the 
past few years has partially compensated for the erosion of prices. In 2023, the downward 
trend continued (similarly to the years 2021-2022) in the volume of mobilizations between 
companies has decreased. Also, the recovery in revenue from roaming services continued 
in 2023, as it returned to its normal volume after the decline that applied in 2020 due to 
the  effects  of  the  COVID-19  crisis  on  travel  and  stay  abroad  (see  Section  3.19.1.2).  In 
addition, starting from the end of 2020, companies in the market began to offer packages 
with a higher browsing volume that allow subscribers to browse with 5G technology, and 
whose prices are higher than 4G  plans. During the fourth quarter of 2023, there was a 
significant decrease in revenues from roaming services following the "Iron Swords" war. 

Revenue from the sale of end equipment and electronics 

The  end  equipment  market  is  also  characterized  by  fierce  competition  among  cellular 
operators and vis-à-vis many stores that sell end equipment in parallel imports. In 2023, 
fierce competition continued in this field. In order to reduce the damage to revenue, which 
was caused, among other things, due to the changes in the exchange rate, Pelephone is 
increasing  the  range  of  equipment  sold  by  it  and  also  sells  electronic  equipment  and 
appliances other than cellular devices. 

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A signifant part of all end equipment is sold in installments. The decline in end equipment 
sales over the years has led to a decrease in the balance of customers in parallel with a 
decrease in the volume of payments to end equipment suppliers. 

3.1.4. 

Market developments and changes in customer characteristics 

The  cellular  market  is  characterized  by  low  growth  rates  due  to  saturation  in  the 
penetration  rate48.  The  estimated  penetration  rate  as  of  September  30,  2023  is 
approximately 117%. 

3.1.5. 

Technological changes that have a material impact on the field of activity 

The  cellular  communications  market  is  dynamic,  and  is  characterized  by  frequent 
technological  developments  in  all  areas  of  activity  in  it  (communications  network 
technology, end equipment and value-added services). 

Technological developments, as well as the desire to expand the range of services offered 
to the customer and their quality, require cellular operators to upgrade the technology 
of cellular networks from time to time. The cellular networks in Israel currently operate 
mainly in GSM technology, UMTS / and LTE technology, and during 2020 the use of NEW 
RADIO technology in the NONSTAND ALONE architecture (5G) began. Also, Pelephone is 
in the process of upgrading the 5G network core to the STAND ALONE architecture. 

As of the date of the report, Pelephone's LTE network is deployed in most parts of Israel, 
and Pelephone continues to expand its network to improve coverage through the use of 
700  MHz  frequencies  and  to  improve  performance  through  2600  MHz  frequencies,  in 
addition to launching  5G technology using 3500 MHz  frequencies, which  is carried  out 
according to a regular deployment plan. 

In  addition,  Pelephone  operates  additional  network  features  that  include  CARRIER 
AGGREGATION and MASSIVE MIMO in 5G. 

Pelephone  offers  technology-based  services  IMS49:  Voice  over  WiFi  as  an  improved 
response to coverage inside buildings (without the need to use the cellular frequency), as 
well as Voice over LTE which allows making voice calls on a 4G basis (using a data range). 
These two capabilities improve the quality of the voice call and enable the freeing of 3G 
frequency resources (traditionally used for calls) for the purpose of increasing additional 
capacity  used  for  the  data  services  that  are  gaining  momentum  over  the  years.  In 
addition, the Voice over LTE service enables the continuation of a  call with Voice over 
WiFi, that is, a transparent transition of the call (without disconnection) from a Voice over 
WiFi call (performed without using the cellular range), to a Voice over LTE call (performed 
on the cellular network) , and vice versa. 

Pelephone is constantly following and examining the new technologies in the market and 
the need to upgrade the technology of its existing networks, in accordance with the state 
of competition in the market and the economic viability of investing in such technologies. 

Expanding the capacities and speeds of technologies from the LTE (4G) and NEW RADIO 
(5G)  as  well  as  the  development  of  future  cellular  generations  are  conditional  on 
frequency allocation. For details, see Section3.8.2. 

Using Embedded SIM (eSIM) technology - this is a technology that allows a mobile device 
to  be  connected  to  the  network  using  a  non-removable  built-in  SIM  card,  unlike 
traditional SIM cards that can be removed and exchanged between devices. The  eSIM 
technology allows greater flexibility and ease of use in the activation and management of 
several lines on the device, a simpler and faster transition between operators without the 
need for a new physical card, and higher accessibility to roaming packages of different 
operators  ("main  line"  solutions).  In  addition,  the  technology  also  allows  coupling  of 
additional  devices  to  the  cellular  line  (secondary  solution)  such  as  watches  and  smart 

48 Penetration rate - the ratio between the number of subscribers in the market and the total population in Israel (excluding 
foreign and Palestinian employees, although they are included in the number of subscribers). 
49  IMS - IP Multimedia Sub System - A system at the core of the network that is used, among other things, for switching calls 
made over IP networks (for example: Voice over LTE, Voice over Wifi). These two services are provided in combination to provide 
coverage within homes and to reduce traffic over the 3G network. The infrastructure will be used for additional services, such as 
One Number, Rich Call Services and more. 

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bracelets. On February 11, 2024, Pelephone launched the option to connect to its services 
using an eSIM as a main line (at this stage it does not include national prepaid services for 
the subscriber). Shortly after, other cellular operators launched eSIM in their networks as 
well. Regarding Pelephone's acquisition of the company "Roamability", which specializes 
in providing solutions in the global roaming services market, see Section 3.2.1.2. 

3.1.6. 

Critical success factors  

3.1.6.1 

3.1.6.2 

3.1.6.3 

3.1.6.4 

3.1.6.5 

3.1.6.6 

3.1.6.7 

3.1.6.8 

3.1.6.9 

Nationwide  deployment  of  a  high-quality  and  advanced  cellular  network, 
ongoing  maintenance  of  the  network  at  a  high  level  and  significant 
investments  on  an  ongoing  basis  in  the  cellular  infrastructure,  both  for 
quality coverage throughout Israel and to provide customers with advanced 
services  through  advanced  technological  infrastructure  (see  also  section 
3.7.2).  

Growth in the subscriber base. 

Growth in the number of subscribers to 5G routes, with a larger browsing 
volume. 

Ability ot offer a competitive price level. 

Wide and varied distribution channels. 

A  variety  of  service  channels,  including  digital  channels,  that  provide 
efficient and quality support and service to a large variety of customers.  

Adjusting  the  cost  structure  and  implementing  operational  streamlining 
that make it possible to cope with increased competition. 

A brand that represents a quality, reliable and advanced network. 

High quality and skilled personnel. 

3.1.7. 

The main barriers to entry and exit50 

3.1.7.1 

The main barriers to entry into the field of activity are: 

a.  Saturation in the penetration rate in the field (see section 3.1.4).  

b.  The  need  for  a  mobile  radio  telephone  license  for  operators  with 
frequencies  (MVNO  operators  may  operate  on  the  basis  of  a  permit 
only),  the  allocation  of  frequencies  involved  in  high  costs  resulting, 
among  other  things,  from  the  fact  that  these  resources  are  in  short 
supply  (see  section  3.8.2.1)  and  the  subordination  of  the  activity  to 
regulatory supervision (see section 3.14.2). 

c.  The  need  for  significant  financial  means  for  making  heavy  and 
continuous  investments  in  infrastructure,  which  are  affected  by 
frequent technological changes (see also section3.7.2.2). 

d.  The difficulty in setting up radio sites due to regulatory restrictions and 

public opposition. 

3.1.7.2 

The main barriers to exit from the field are: 

a.  Large investments that require a long return on investment.  

b.  The  commitment  to  provide  service  to  customers  derives  from  the 
terms  of  the  radio  telephone  license  license  and  the  agreements  in 
accordance with the terms set forth in the license. 

3.1.8. 

The structure of competition in the field and changes that apply in it  

3.1.8.1 

General 

The  cellular  communications  market  in  Israel  is  characterized  by  fierce 
competition, which is reflected in high subscriber turnover among operators 
in the past few years, rates erosion and profitability erosion. 

50 Some of the above entry and exit barriers apply in a partial and limited manner to virtual operators. 

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As of the date of this report, five operators with a radio telephone license 
license  are  operating  in  the  cellular  communications  market  in  Israel. 
Cellcom,  Partner,  Hot  Mobile  and  XFONE),  and  a  number  of  MVNO 
operators  with  an  radio  telephone  license/permit  in  another  network 
(virtual operators).  

3.1.8.2 

Infrastructure sharing 

Infrastructure sharing enables the consolidation of cellular operator sites in 
a way that significantly reduces the cost of operating and maintaining radio 
sites for each operator. To the best of Pelephone's knowledge, as of the date 
of the report, infrastructure is shared in the market as described below: 

a.  Partner and Hot Mobile operate as part of an infrastructure sharing in 

the radio segment within a shared corporation. 

b.  Cellcom  (who  holds  Golan  Telecom)  and  XFONE  operate  as  part  of 
infrastructure sharing in the radio segment of the 4G network as part 
of  a  joint  corporation  and  the  acquisition  of  other  interior  roaming 
services.  

3.1.8.3 

Virtual operators MVNO 

A number of MVNO licenses have been issued so far for vrtual operators. 
Only a few MVNO license holders are active in the market. 

For more details on the structure of competition in the field, see section 3.6. 

3.1.8.4 

Hearing on private networks 

On July 16, 2023, following a hearing on the subject, the Ministry published 
a policy document outlining the rules for the allocation of a frequency band 
in the 26 GHz range (as well as a narrow band in the 2100 MHz range) for 
use  by parties  other  than  cellular  operators  or  interior  operators,  for  the 
purpose of operating  private networks on a  local basis (area polygon) for 
each  project.  The  implementation  of  the  policy  will  require  regulatory 
adjustments in the relevant legislation and is not expected to significantly 
affect Bezeq or Pelephone business. 

3.2. 

Services and products 

3.2.1. 

Services 

Below is a description of the services that Pelephone provides to the subscriber: 

3.2.1.1 

Package services that include: 

a.  Basic telephone services (VOICE) - basic call services, call completion 
services as well as ancillary services such as - waiting call, "follow me", 
voicemail, voice conference call, caller ID, and more. 

b.  Browsing  and  data  communication  services  -  Internet  browsing 
services using end equipment that is compatible with the use of 3G, 4G 
and 5G technologies. 

c.  SMS delivery and receipt service and multimedia messages MMS -SMS 
receiving and sending service (text messaging  - SMS) and multimedia 
messaging (video / voice / text). 

Value Added Services - Pelephone offers its customers value-added services 
and  related  services,  such  as  data  storage  backup  services  (Pelephone 
Coud), antivirus services, cyber protection services, and more. 

Roaming  services  -  Pelephone  Provides  its  customers  with  roaming 
coverage in about 190 countries around the world. In addition, Pelephone 
also  provides  inbound  roaming  services  to  the  customers  of  foreign 
operators  who  stay  in  Israel.  Regarding  roaming  services,  as  well  as 
regarding the development of the use of eSIM technology in these services 
- as part of Pelephone's activity and its preparation for global trends in the 
roaming  services  market,  which  include,  among  other  things,  a  more 
extensive use of eSIM technology in these services, on October 18, 2023, 

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3.2.1.2 

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3.2.1.4 

Pelephone’s Board of Directors approved the acquisition of full ownership 
in the company "Roamability", which specializes in the supply of solutions 
in  the  global  roaming  services  market,  including  wholesale,  and  including 
providing  a  platform  for  the  management  and  sale  of  these  services. 
Accordingly, Pelephone acquired 100% of the control and ownership rights 
in the company (an American company and an Israeli company) in exchange 
for an amount that is immaterial at the group level. 

Private cellular networks with LTE (Long Term Evolution) or 5G technology 
- Pelephone offers business customers the installation and maintenance of 
a  private  cellular  network  in  the  business  customer's  complex.  A  private 
network  provides  the  business  customer  with  various  benefits,  including: 
business continuity, bandwidth management between the customer's end 
users, low latency, connection to IoT devices, contribution to securing the 
customer's networks and systems, and more. 

3.2.1.5 

Maintenance  and  repair  services  for  end  equipment  -  Pelephone  offers 
repair  service and extended  warranty, for a  monthly fee that entitles the 
customer to repair service and extended warranty for the cellular device, or 
for a one-time payment at the time of repair. 

Pelephone provides some of these services also in the framework of hosting 
agreements,  to  holders  of  an  mobile  radio  telephone  license  in  another 
network that use the Pelephone network in order to provide service to their 
customers. 

3.2.1.6 

Additional services 

a. 

IoT  (Internet  of  Things)  services  -  Pelephone  offers  its  customers 
advanced IoT solutions such as smart building networks with command 
and control systems, and more. 

b.  PTT (Push to Talk) services  -  Pelephone offers its business customers 
some of the most advanced PTT services in the world, which enable fast 
and secure corporate communication at the push of a button. 

3.2.2. 

Products 

Peripheral  devices  -  Pelephone  offers  various  types  of  mobile  phones,  PTT  devices, 
tablets,  laptops,  modems,  smart  watches,  electrical  products  as  well  as  supporting 
accessories such as speakers, headphones and more. 

3.3. 

Segmentation of revenues from products and services 

The following is data regarding Pelephone's revenues from products and services (in NIS millions): 

Products and services 
Revenue from services 
Rate of total revenue 
Revenue from interconnect 
Rate of Pelephon’s total revenue 
Revenue from products (end equipment) 
Rate of Pelephon’s total revenue 
Total revenue 

2023 
1,385 
59% 
371 
15.8% 
592 
25.2% 
2,348 

2022 
1,364 
56.09% 
427 
17.8% 
608 
25.3% 
2,399 

220 1 
1,204 
52.86% 
438 
19.1% 
647 
28.3% 
2,289 

3.4. 

Customers 

The following is data on the distribution of revenue from customers (in NIS millions): 

Products and services 
Revenue from private customers net of interconnect 
Revenue from private customers 
Revenue from business customers (*)net of interconnect 
Revenue from business customers (*) 
Total revenue net of interconnect 
Total revenue 
(*) Revenue from customers in business tracks includes revenue from hosting agreements (agreements that allow 
the provision of mobile telephony service through the Bezeq network of another authorized provider), which were 

2022 
1,193 
1,416 
779 
983 
1,972 
2,399 

2021 
1,131 
1,361 
720 
928 
1,851 
2,289 

2023 
1,180 
1,375 
797 
973 
1,977 
2,348 

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received mainly from Rami Levy. 

At  the  end  of  2023,  the  number  of  Pelephone  subscribers  was  approximately  2.6  million,  including 
approximately 2.2 million postpaid subscribers (subscribers who receive service for a monthly payment), 
and approximately 0.4 million prepaid subscribers (advance payment for consumption of services).  

Pelephone markets packages with an increased volume of use that are also adapted to the needs of 5G, 
and as of the date of publication of the report, Pelephone has about 1.075 million subscribers in such 
packages. 

The following is a breakdown of Pelephone's subscribers with 5G packages: 

Pelephone's 5G package subscriber base (thousands) 

3.5.  Marketing, distribution and service 

Pelephone's  distribution  system  includes  about  210  points  of  sale  where  you  can  join Pelephone 
services. The set of points of sale is diverse and includes stores and stalls operated by Pelephone, 
retail  chains  that  market  Pelephone  products  and  about  20  Service  and  sales  centers  located 
throughout  Israel  that  handle  service,  sales,  device  repair  and  customer  retention.  In  addition, 
Pelephone  operates  an  internal  and  external  network  of  telephone  marketers.  As  a  rule,  the 
compensation to the marketers is paid as commissions from the sales. 

Pelephone's service system for subscribers includes diverse digital channels including the Pelephone 
website hone, self-service app and call centers. 

3.6. 

Competition 

3.6.1. 

General  

In recent years, the Ministry of Communications has taken regulatory moves designed to 
increase competition in the cellular communications market. The large number of cellular 
operators  in  the  market  led  to  a  high  level  of  competition  in  recent  years,  which  is 
reflected in the transition of subscribers between operators and in a reduction in cellular 
package prices, which led to erosion in rates and profitability in both private and business 
customers. 

In order to compensate for the erosion of package prices, Pelephone employs a strategy 
for  growth  in  the  number  of  subscribers  alongside  streamlining  and  costs  structure 
adjustment (see section0). 

The  following  are  data,  to  the  best  of  Pelephone's  assessment,  about  the  number  of 
subscribers of Pelephone and its competitors over the years 2022 and 2023 (thousands 
of subscribers, approximately): 

Partner (3) 

Hot Mobile 
(2) 

MVNO And 
other 
operators (1) 

Total 
subscribers in 
the market 

Pelephone 

Cellcom 
(including 
Golan 
Telecom)  
(3) 

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As of 
December 
31, 2022 

As of 
September 
30,  2023 

Number of 
subscribers  
Market 
Share 
Number of 
subscribers  
Market 
Share 

2,580 

3,452 

2,744 

1,760  

826  

22.7% 

30.4%  

24.2% 

15.5%  

7.3%  

2,618 

3,523 

2,655 

1,837 

860 

22.8% 

30.7% 

23.1% 

16% 

7.5% 

11,362 

11,493  

(1)  Most  of  the  MVNOs  and  the  other  operators  (which  include,  among  others,  XFONE)  are  private 
companies that do not publish  data regarding  the  number of their subscribers, and the said data is 
based on an estimate of data on mobility between companies. 

(2)  Hot Mobile's Q3/2023 data is based on an estimate, according to data published in the reports of Altice, 

the controlling shareholder of Hot, to the best of Pelephone's knowledge. 

(3)  The number of subscribers is correct as of September 30, 2023, based on Cellcom and Partner reports 

to the public. 

3.6.2. 

Infrastructure sharing and granting network use right agreements 

For details regarding the existing infrastructure sharing agreements in the market as of 
the date of the report, see Section 3.1.8.2. As mentioned, infrastructure sharing enables 
the consolidation of cellular operator sites in a way that significantly reduces the cost of 
operating and maintaining radio sites for each operator.  

Pelephone is not a party to the radio network sharing agreement, in accordance with the 
implementation of the Ministry of Communications policy on network sharing dated April 
17,  2014,  so  it  does  not  enjoy  the  savings  resulting  from  the  shared  use  of  the  radio 
network,  but  on  the  other  hand  it  exclusively  controls  its  cellular  network,  the 
maintenance of its technological route and the volume of investments in it. 

3.6.3. 

Positive and negative factors that affect Pelephone's competitive position 

3.6.3.1 

Positive factors: 

a.  A cellular network with a broad and high-quality deployment. 

b. 

Its position as a fast and advanced cellular network, especially against 
the background of the progress of the deployment of the 5G network. 

c.  A  diverse  and  wide  distribution  system  that  operates  through  call 
centers  and  through  a  large  number  of  fromtal  points  of  sale  and  is 
operated by Pelephone, external marketers and through leading retail 
chains. 

d.  A wide range of services and a variety of customer service interfaces, 
including digital channels, which enable the provision of a high level of 
service to customers. 

e.  A solid capital structure and a positive cash flow. 

3.6.3.2 

Adverse factors: 

a.  As a subsidiary of Bezeq, Pelephone is subject to regulatory restrictions 
on  entering  additional  areas  of  activity  and  expanding  the  basket  of 
services to customers who do not apply to its competitors.  

b.  There  are  restrictions  on  joint  activities  with  Bezeq,  including  the 

marketing of joint service packages (see Section 1.7.3). 

c.  The costs of setting up, operating and maintaining cellular networks in 
Pelephone  are  expected  to  be  higher  compared  to  competitors 
operating through the sharing of radio segment infrastructure. 

Regarding negative factors, see also Section 1.7.2. 

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3.7. 

Property, plant and equipment, real estate and facilities 

Pelephone's property, plant and equipment include infrastructure equipment of the network core, 
radio  sites,  electronic  equipment,  computers,  vehicles,  end  equipment,  office  furniture  and 
equipment, and leased improvements.  

3.7.2. 

Infrastructure 

3.7.2.1 

 Pelephone  currently  operates  communication  networks  in  three  main 
technologies, as follows: 

a.  5G - the NEW RADIO technology that uses a very broadband spectrum 
(100  MHz  at  Pelephone)  and  enables  higher  capacity  and  higher 
browsing rates for the user. In the future, the technology will enable IoT 
applications  at  significantly  higher  volumes  than  today  and  at  a  very 
high level of performance. 

b.  4G - LTE technology from the GSM standards family. The advantages of 
the  technology  are  high  capacity  for  data  communication  and  faster 
download and upload rates than those that exist in 3G. All end devices 
that support this technology also support 3G technology and there is a 
smooth transition between the technologies. 

c.  3G  -  technology  in  the  UMTS  method  based  on  GSM  standard.  This 
technology  is  very  common  in  the  world  and  enables  subscriber 
identification and service through a subscriber identification card (SIM) 
 As  part 
that can be transferred from one end device to another. 
of a hearing held by the Ministry regarding the future closure of mobile 
radio-telephone networks operating with old technologies, (2G and 3G 
networks) an outline was established for the closure of these networks, 
which is expected to lead to their closure on December 31, 2025 (or at 
an earlier date at the request of each operator in relation to his network 
and  provided  that  it  meets  the  established  conditions).  The  outline 
includes,  among  other  things,  milestones  of  stopping  the  import  of 
devices that do not support modern technologies, informing the public, 
and stopping the connection of these devices to the network. It should 
be  noted  that  Pelephone's  2G  network  was  closed  by  it  in  the  past. 
Pelephone is prepared in accordance with the above decision to close 
its  3G  network,  according  to  the  timetables  established  in  the 
decision.51 

As of the date of the report, Pelephone's network infrastructure is mainly 
based on two switching farms connected to more than 2,500 sites. 

3.7.2.2 

Network investments 

In recent years, Pelephone has invested in the deployment of a 4G and 5G 
network, including the implementation of innovative technologies such as 
Beam Forming, MASSIVE MIMO, QAM 256 and Carrier Aggregation in the 
access network, and in IMS in the network core (see Section 3.1.5). 

In  this  framework,  starting  in  2020,  Pelephone  is  expanding  the  access 
network (by operating additional frequencies in the 700, 2600 MHz range at 
over a 1,500 sites, as well as in the 3500 MHz range at approximately 900 
sites,  by  installing  and  operating  antennas  and  reception  transmission 
equipment in the areas These frequencies on the various sites. It should be 
noted that among these, in the 700 MHz range, the target for deployment 
is nationwide. 

Pelephone's  activity  outline  for  the  deployment  and  implementation  of 
advanced data communication services in the 5G, is high in investment and 
currently  integrates  with  existing  infrastructures  and  systems,  when  the 

51 On June 6, 2023, an updated decision was made by the Minister stating that a license holder will be allowed to continue providing 
service over the 2G network for the purpose of M2M (machine to machine communication) only until December 31, 2028, subject 
to receiving the Manager's approval. Also, the licensee will be entitled to contact the Manager with another request to extend 
the service period with 2G technology for M2M purposes only, until December 31, 2030. 

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operation of these advanced services will be based on the 5G technology 
which  Pelephone  will  continue  to  deploy  as  mentioned,  and  later  will  be 
based on a new network core dedicated to 5G ( See Section 3.8.2.4). 

In addition, as part of its ongoing investments, throughout the period of the 
license, Pelephone will be required to invest  in the establishment  of new 
broadcasting  sites,  among  other  things,  in  order  to  comply  with  the 
conditions of the mobile radio-telephone license. 

Pelephone's estimates as aforesaid regarding the required investments are 
forward-looking information within its meaning of the Securities Law, based 
on  Pelephone's  forecasts  and  estimates,  inter  alia,  regarding  the  rate  of 
network  expansion  and  upgrade  of  the  network.  Accordingly,  the 
information  may  not  fully  or  partially  materialize  or  may  materialize  in  a 
different format than that which was assessed, insofar as the said forecasts 
and assessments are not fulfilled or will be fulfilled in a different way than 
expected. 

3.7.3. 

Areas used by Pelephone 

Pelephone does not own real estate and it leases from others, including Bezeq, the areas 
it  uses  for  its  activities.  The  following  is  a  description  of  most  of  the  areas  used  by 
Pelephone: 

3.7.3.1 

The  areas  used  by  Pelephone  to  place  communication  sites  and  network 
centers  as  stated  in  the  section  3.7.2  are  spread  throughout  Israel  and 
leased for different  periods (in many cases for 5 years plus the option to 
extend  the  agreement  for  another  5  years).  For  site  licensing,  see 
section.אצמנ אל הינפהה רוקמ !האיגש. 

During the year 2023, an agreement was signed according to which Bezeq will carry out a 
significant renovation in a facility called "Bezeq Ayalon" to which Pelephone's core facility 
in Ramla will be transferred. With the completion of the expected renovation at the end 
of 2024, Pelephone will begin a phased process of vacating the core facility in Ramla that 
will  last  until  the  end  of  2025.  The  agreement  also  regulates  the  lease  relationship 
between Bezeq and Pelephone. 

3.7.3.2 

3.7.3.3 

3.7.3.4 

Pelephone's headquarters are in Petah Tikva. 

For  service  and  sales  activities,  Pelephone  rents  about  40 service  centers 
and sales points spread throughout Israel. 

Pelephone  has  additional  lease  agreements  for  warehouses  (including  a 
central  logistics  center  with  a  central  laboratory  for  repairing  customer 
devices),  offices,  call  centers  and  2  switching  farms  used  by  it  for  its 
operations. 

3.8. 

Intangible assets 

3.8.1. 

Licenses 

For details regarding Pelephone's mobile radio telephone license and operating license in 
Judea and Samaria, see section 3.14.2. 

3.8.2. 

Right to use frequencies 

3.8.2.1 

Shortage IN Radio frequencies 

In Israel, there is a shortage of radio frequencies for public use (among other 
things,  due  to  the  allocation  of  many  frequencies  for  security  uses).  As  a 
result,  the  government  limits  the  number  of  licenses  that  can  be  used  in 
frequencies.  

3.8.2.2 

Pelephone’s frequency inventory 

Pelephone  has  the  right  to  use  frequencies  by  virtue  of  the  mobile  radio 
telephone license and the Telegraph Order in the ranges of 850 MHz52 and 

52 Pelephone has the option of requesting a 5-mega allocation in the 800 MHz range following the 850 MHz frequency evacuation project.  

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2100 MHz for operating the network in UMTS / HSPA technology, and in the 
1800 MHz, 700 MHz and 2600 MHz range for network operation in the LTE 
technology  (see  also  section3.1.5)  and  in  the  range  of  3500  MHz  for  the 
purpose  of  operating  a  network  with  5G  technology.  During  2017, 
Pelephone returned to the National Frequency Database 2 frequency bands 
with a width of 1 Mega each in the range of 850 MHz, and towards the end 
of April 2017, it received a temporary allocation of a band in the range of 
1800 MHz with a width of 5 Mega. This allocation is limited in use and is for 
a fixed period. 

The  Ministry  of  Communications  has  temporarily  reassigned  this  band  to 
Pelephone  until  December  31,  2024,  under  conditions  and  limitations,  in 
order to allow Pelephone to prepare for the expected change in changing 
frequencies in the first Ghz range (see Section 3.8.2.3). 

The  deployment  of  800  MHz  frequencies  that  was  planned  for  2023  was 
postponed  to  2024  and  the  activation  of  these  frequencies  is  expected 
during 2025. 

3.8.2.3 

Switching freqencies in the first Giga range 

In July 2018, the Ministry of Communications informed Pelephone that it 
intends to adjust  cellular frequencies in Israel to European standards and 
the  area  in  which  the  State  of  Israel  is  located,  so  that  Pelephone  and 
another  cellular  operator  will  be  required  to  replace  the  850  MHz 
frequencies with other frequencies in the first GHz. In 2020, the Ministry of 
Communications announced to Pelephone that it intended to implement an 
outline for the replacement of 850 MHz frequencies in the use of Pelephone, 
against  the  background  of  electromagnetic 
interference  caused  to 
neighboring  countries  due  to  non-compliance  of  cellular  frequencies  in 
Israel with European standards and the stadards of the region. According to 
the  outline,  Pelephone  will  receive  frequencies  in  the  range  of  800  MHz 
instead of 850 MHz, when in the first stage and for the purpose of treating 
such interruptions, the amount of 850 MHz frequencies used by Pelephone 
will be reduced to 5 MHz (instead of 10 MHz today) and this as of May 31, 
2020. Pelephone forwarded to the Ministry of Communications, following 
his request, its reference to a number of issues and on March 17.    

On June 1, 2020, Pelephone  returned to the Ministry of  Communications 
frequencies in the range of  850 MHz, with a  width of 5 MHz, so that the 
amount of 850 MHz frequencies owned by Pelephone decreased from 10 
MHz  to  5  MHz.  On  November  26,  2020,  the  Ministry  of  Communications 
allowed Pelephone to reuse full 2X10 MHZs in the 850 range until March 31, 
2021. On December 31, 2021, Pelephone stopped using one of the two 5 
MHz-wide 850 channels and continued using a single 5 MHz channel On June 
27, 2021, a decision was made by the Ministry of Communications regarding 
an  extension  of  the  allocation  of  frequencies  in  850  MHz  and  2100  MHz 
ranges that Pelephone holds, until December 31, 2030 (it is clarified that the 
extension  of  the  850  MHz  frequency  is  subject  to  description  above, 
regarding the exchange of frequencies in the first giga field). 

3.8.2.4 

Tender for advanced broadband services ("the Tender") 

On August 12, 2020 Pelephone won the allocation of frequencies as a result 
of  its  participation  in  the  tender  for  mobile  radio  telephone  services  in 
advanced 5G bandwidths. The following are the main points of the tender: 

The  Tender 
includes  provisions  regarding  the  coverage  and  quality 
requirements  of  the  network  that  will  be  anchored  as  part  of  the 
amendment of the mobile radio telephone licenses of the existing operators 
(see amendment to Pelephone’s license below). 

The Tender including the possibility of receiveing the following incentives: 

a.  Discounts in the frequency fees for the first four years, subject to the 
approval  of  the  Ministry  of  Communications  and  the  Ministry  of 
Finance. 

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b.  Receipt of a conditional grant for the deployment of 5G sites according 
to the conditions specified in the Tender (such as meeting the scope of 
deployment, schedules, deployment period and timing of deployment 
in relation to others and additional conditions set in the Tender). This 
grant was received in 2022. 

For  details,  see  also  Section  3.19.2.1.  For  details  regarding  exposure  to 
interference in the frequency ranges of Pelephone, see section3.19.3.9.  

The following are the conditions under which Pelephone won the allocation 
of such frequencies: 

a.  Winning at 10 Mega in the 700 MHz range (for a period of 15 years); at 
20 Mega in the 2600 MHz range (for a period of 10 years); And at 100 
Mega in the field of 3500 MHz (for a period of 10 years). The license 
period does not change as a result of the Tender and can be renewed 
in  accordance  with  the  license  provisions  (hereinafter:  "Frequency 
Allocation"). It should be noted that the frequencies won by Pelephone 
are used exclusively by Pelephone network, which gives it a competitive 
advantage.  It  should  also  be  noted  that  companies  that  do  not  own 
existing networks did not win the Tender. 

b.  Pelephone winning the frequency allocation involved a total payment 
of  approximately  NIS  88  million,  which  was  made  by  Pelephone  in 
September  2022.  In  this  context,  it  should  be  noted  that  the  Tender 
further  stipulates  that  incentives  may  be  obtained,  as  specified  in 
above, including receiving a conditional grant for the deployment of 5G 
sites according to the conditions specified in the Tender, the amount of 
which, for all the winners, can reach a total amount of NIS 200 million. 
On  October  27,  2021,  a  notice  was  received  from  the  Ministry  of 
Communications that Pelephone is entitled to this grant in the amount 
of NIS 74 million, and the grant was actually received in 2022. As part 
of  the  update  of the  regulations  under  which  the  frequency  fees  are 
paid, a reduction in the amounts of the fees for 2600 and 3500 MHz 
frequencies was determined, as well as a conditional annual discount 
from the total amount of the frequency fees to be paid by Pelephone in 
the  next  four  years  (the  discount  depends  on  the  Company's 
compliance  with  graded  annual  engineering  targets,  which  will  be 
examined by the Ministry of Communications every year). 

On October 1, 2020, Pelephone's license was amended in accordance 
with the winning results (shortly before, Pelephone was allocated the 
frequencies  at  which  it  won  as  stated).  With  the  amendment  of  the 
license, Pelephone began operating the frequencies which it won in the 
Tender at the broadcast sites upgraded by it. 

Said  Frequency  Allocation  enables  supporting  the  increase  in  the 
volume of browsing in the 4G and in the future offer services in the 5G 
at significantly higher browsing rates than those existing today, and will 
allow,  among  other  things,  expanding  a  variety  of  advanced  cellular 
uses, such as smart cities, IoT services, mission critical services with low 
latency,  private  networks  and  more  and  all  in  order  to  provide  a 
competitive solution in the market. It will involve ongoing investments. 

In this regard, see also Note 11 to the 2023 statements. 

On July 17, 2023, Pelephone received a winning notice in the ongoing 
tender  for  5G  mobile  mobile  radio  telephone  services  in  the  26  GHz 
frequency range for the purpose of improving and consolidating the 5G 
capabilities  and  solutions  existing  in  the  cellular  networks  (“the 
Tender"). As part of the Tender, 25 competition bands of 100 MHz each 
(a  total  of  2,500  MHz),  for  competition  between  the  existing  cellular 
operators (existing cellular networks), where each network was entitled 
to win up to 1,200 MH (out of the 2,500). 

Pelephone won a cluster of frequencies in this area as follows: 

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A.  Winning 800 MHz in the 26 GHz section (for a period of 10 years), 
when the license period as a cellular operator does not change as 
a result of the Tender and can be renewed in accordance with the 
license instructions ("frequency allocation"). 

B.  The frequency allocation will be carried out after the extension of 
the license and against the payment of license fees in the amount 
of NIS 4.16 million. Following the war of iron swords, the Ministry 
of Communications postponed the payment date and announced 
that it must be made no later than July 1, 2024. 

The extension of the license  in accordance with the  winning result is 
subject to the approval of the Minister of Communications as stipulated 
in the Tender conditions. 

The aforementioned frequency allocation will allow Pelephone, among 
other  things,  to  expand  the  range  of  advanced  uses  of  the  cellular 
network with 5G technology, with an emphasis on private networks and 
advanced services that require a particularly high browsing speed, such 
as hospital complexes. The cost of integrating this frequency range into 
5G technology will be ongoing, and is not expected to be substantial. 

3.8.3. 

Trademarks 

Pelephone  has  a  number  of  registered  trademarks.  The  main  one  is  the  "Pelephone" 
brand. 

3.8.4. 

Computer software, systems and databases 

Pelephone uses software and computer systems, some based on licenses it has acquired 
and some developed by Pelephone's information systems division. Many of these licenses 
are  limited  in  time  and  are  renewed  from  time  to  time.  The  main  systems  used  by 
Pelephone  are  an  ERP  system  by  Oracle  Applications  and  a  customer  billing  and 
management system by Amdocs. 

Pelephone is also working to upgrade the CRM (customer management) to an advanced 
Salesforce  cloud  platform  together  with  Bezeq  International  and  Yes.  Pelephone  is 
dependent  on  the  Salesforce  system  and  services,  due  to  their  importance  for  the 
purpose of managing relationships with its customers. System failures or the cessation of 
services by this provider are likely to cause operational difficulty until the fault is rectified 
or the system / provider is replaced, which may take a long time 

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3.9. 

Human capital 

3.9.1. 

Organizational structure 

The following is a diagram of Pelephone's organizational structure, as of the date of the 
report: 

Board of 
Directors 

CEO 

HR and 
Administr
ation 
Division 

Finance 
Division 

Private 
Custome
rs 
Division 
*  

Informati
on 
Systems 
Division 

Engineer
ing 
Division 

Busines
s 
Division 

Marketin
g 
Division 

Legal 
advice 
and 
Regulati
on 

Public 
Relation
s 

Internal 
Auditor 

As part  of the implementation of the synergy processes with the  Group's subsidiaries, 
Pelephone's CEO, Mr. Ilan Siegel, also serves as CEO of Yes. In addition, some of the VPs 
who serve on Pelephone also serve as VPs at Yes. 

3.9.2. 

Employee base and number of jobs 

The following is a breakdown of the number of employees in Pelephone according to its 

organizational structure:  

Division 

Management and administration divisions 
Private and business customer divisions 
Engineering  and 
Divisions 
Total 

Information 

Systems 

Number of employees 

31.12.2023 
197 
1,113 
374 

31.12.2022 
194 
1,123 
382 

1,684 

1,704 

The number of employees included in the table above includes employees employed part-
time. The total number of jobs53 at Pelephone as of December 31, 2023, was 1,486. 

3.9.3. 

Terms of employment  

Most  Pelephone  employees  are  employed  under  a  monthly  agreement  or  an  hourly 
agreement, according to the professions and positions in which they are engaged. Most 
of the service and sales staff are part-time shift workers and are employed on an hourly 
basis.  The  other  Pelephone  employees  are  employed  on  a  global  basis.  The  main 
difference between the monthly and hourly agreements and the global agreements lies 
in the salary structure. 

53The calculation of the number of "jobs" in Pelephone is: the total monthly working hours divided by the monthly working hours 

quota. 

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3.9.4. 

Collective agreement 

The labor relations at Pelephone are regulated in a collective agreement signed between 
Pelephone and the new Histadrut - the Cellular, Internet and High-Tech Workers' Union 
("the Histadrut") and the Pelephone Employees’ Committee. The agreement applies to 
all Pelephone employees, with the exception of senior executives and certain employees 
in pre-defined positions who are employed by personal agreements. 

On  November  13,  2019,  a  renewal  of  the  existing  collective  agreement  was  signed 
between the parties, which includes streamlining and synergy procedures, for a period of 
up to June 30, 2022 (“the Agreement"). 

Under the Agreement, Pelephone may, among other things, terminate the employment 
of 210 permanent employees during the term of the Agreement, some of them as part of 
a voluntary retirement. Moreover, the Agreement allowed Pelephone to terminate the 
employment of 190 additional non-permanent employees, in addition to not recruiting 
employees  instead  of  employees  the  employment  oh  whom  will  be  terminated.  The 
Agreement  also  includes  providing  a  one-time  bonus  to  employees  who  will  not  be 
included in the retirement plan. 

On December 6, 2022, Pelephone signed the renewal of the existing collective agreement 
between itself and the General Workers' Histadrut and its employee representative for 
the period from December 6, 2022 to December 31, 2025 ("the Agreement" and "the 
Agreement  Period",  respectively)  under  new  conditions.  According  to  the  Agreement, 
salary increases and bonuses will be given, ancillary conditions will be improved and the 
labor  disputes  announced  by  the  General  Workers'  Histadrut  and  the  employees’ 
representatives will be settled (with the exception of one issue detailed in Section 3.9.5) 
while  maintaining  industrial  peace  during  the  validity  period  of  the  agreement  in  the 
matters  regulated  therein.  The  total  estimated  cost  of  the  Pelephone  agreement, 
including the voluntary retirement of employees whose retirement has been approved, 
is about NIS 71 million. 

Pelephone's  estimates  regarding  the  cost  of  the  Agreement  are  forward-looking 
information,  as  defined  in  the  Securities  Law,  based,  among  other  things,  on  its 
assumptions regarding the manner and scope of the retirement plan implementation and 
additional conditions stipulated in the agreement. These estimates may not materialize, 
or materialize in a different way than expected, depending, among other things, on the 
manner and scope of the actual implementation of the agreement and the retirement 
plan, taking into account Pelephone's needs and its ability to implement its plans and the 
fulfillment of additional conditions stipulated in the Agreement. 

For this matter see also Note 16 to the 2023 statements. 

3.9.5. 

Labor disputes 

On January 31, 2018, Pelephone was notified by the Histadrut ("the Histadrut Notice") of 
the declaration of a labor dispute in accordance with the Labor Disputes Settlement Law, 
5717-1957.  According  to  the  Histadrut  Notice,  the  issues  in  the  dispute  are  the 
employees’ requirements for consultation and negotiations regarding the sale of Bezeq's 
controlling shares to the new owners and the regulation of their rights as a result. 

On December 6, 2022, a collective agreement was signed that includes renewal of the 
agreement  period  from  the  date  of  signing  until  December  31,  2025.  As  part  of  the 
agreement,  all  open  labor  disputes  were  cleared.  It  was  clarified  that  the  economic 
demands  due  to  the  labor  dispute  of  January  31,  2018  have  been  exhausted,  but  the 
demand of the Employees’ Representation to appoint a representative on its behalf on 
the Pelephone Board of Directors has not been exhausted, and it was stipulated in the 
agreement that it will be discussed later (starting in June 2024). 

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3.10.  Suppliers 

3.10.1. 

End equipment suppliers 

Pelephone  purchases  some  of  the  end  equipment  and  accessories  from  different 
providers in Israel, and imports some independently. In addition, Pelephone purchases 
end equipment and accessories by way of purchase consignation with the right to return 
to the end equipment suppliers. Contracts with some suppliers are based on framework 
agreements  that  regulate,  inter  alia,  the  supplier's  technical  support  for  the  end 
equipment provided thereby, the availability of spare parts and repairs and the supplier's 
warranty for the products. In most cases, these agreements do not include an obligation 
on  Pelephone's  part  to  make  purchases,  and  they  are  executed  on  an  ongoing  basis 
through a purchase order according to Pelephone's needs. 

In  the  event  of  a  termination  of  contract  with  a  particular  end  equipment  supplier, 
Pelephone may increase the quantity purchased from other end equipment suppliers, or 
purchase end equipment from a new end equipment supplier. 

Pelephone’s material suppliers are Apple, with whom there is an agreement that requires 
defined  procurement  targets  and  is  valid  until  March  2024  (the  extension  of  the 
agreement between the parties by another year is currently being signed), and Samsung, 
with  which  Pelephone  does  not  have  an  agreement  that  requires  the  purchase  of  a 
minimum annual quantity and the purchases are made on the basis of orders made by 
Pelephone from time to time. 

Pelephone purchases rate from each of the suppliers Apple and Samsung in 2023 was 
approx. 14.5% and approx. 10.5% (respectively) of Pelephone’s total purchases from all 
of Pelephone’s suppliers54. The distribution of peripheral equipment  purchases among 
suppliers is such that it does not create a material dependence on the supplier or model 
of equipment. 

Due to the state of war, there was a  delay in the maritime supply route in relation to 
engineering goods and end equipment. 

3.10.2. 

Infrastructure providers 

The  infrastructure  equipment  for  the  cellular  networks  (5G,  LTE,  UMTS,  as  well  as  the 
equipment for the microwave transmission field) is provided by the company LM Ericsson 
Israel  Ltd.  ("Ericsson").  Pelephone  has  multiyear  agreements  for  supply,  maintenance, 
support, and software upgrades for the entire network, and also for the 5G network core 
with Ericsson, and in its opinion it may depend on it in connection with network support 
and expansion. In addition, the cellular network uses transmission, and Bezeq is a material 
supplier to Pelephone in this field. 

Pelephone  has  a  multi-year  transmission  agreement  with  Bezeq  that  includes  use  and 
maintenance.  

3.11.  Working equity 

Credit policy  

Credit in device sales transactions  - Pelephone gives  most  of its  customers  who purchase mobile 
phones the option to spread the payments up to 36 equal payments. In order to reduce exposure 
that may arise as a result of providing credit to its customers, Pelephone operates in accordance with 
a credit policy that is reviewed from time to time. Pelephone also checks the financial strength of its 
customers (in accordance with the parameters set by it). 

Monthly billing credit for cellular services  - Pelephone customers are charged once a  month with 
billing  cycles,  performed  on  different  dates  throughout  the  month,  for  the  consumption  of  last 
month's cellular services.  

Pelephone receives credit from most of its providers for a period ranging from 30 days to  end of 
month + 92 days. 

The following are data regarding average suppliers' and customers' credit in 2023:  

54  All suppliers - All of Pelephone’s suppliers, including suppliers who are not suppliers of end equipment and electronic devices. 

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Credit volume 
in NIS millions 

Average credit 
days 

Customers for the sale of end equipment (*) 
Customers for services (*) 
Suppliers 
(*) Net of loan-loss 

479 
137 
238 

252 
24 
47 

3.12.  Taxation 

See Note 7 to the 2023 statements.  

3.13. 

Environmental risks and ways of managing them 

3.13.2. 

The  provisions  of  the  law  concerning  the  environment  and  apply  to  the 
activities of Pelephone 

in 
The  broadcast  sites  used  by  Pelephone  are  "radiation  sources" 
accordance  with  the  Non-Ionizing  Radiation  Law.  The  establishment  and 
operation of these sites, with the exception of sites listed in the appendix to 
the law, requires the receipt of a radiation permit. 

The law establishes a two-stage licensing mechanism for obtaining a permit 
to operate a radiation source, according to which the applicant for a permit 
must first obtain a permit to establish the radiation source ("Establishment 
Permit"),  valid  for  a  period  not  exceeding  three  months,  which  can  be 
extended by the Commissioner by up to 9 months, followed by a permit to 
operate  a  source  of  radiation  ("Operating  Permit"),  which  is  valid  for  a 
period  of  five  years  or  as  otherwise  determined  by  the  Minister  of 
Environmental Protection.  

With regard to the Establishment Permit, the law stipulates the granting of 
the permit by performing an assessment of the maximum levels of exposure 
of people and the environment to the radiation expected from the radiation 
source  when  it  is  activated,  including  in  the  event  of  a  malfunction;  And 
taking the necessary measures to limit the levels of exposure of humans and 
the environment to the radiation expected from the radiation source when 
it is activated, including the use of technological means in use ("Limitation 
Means"). 

With regard to the Operating Permit, the law stipulates the granting of the 
permit by the  taking of measures to limit and make measurements of the 
levels  of  exposure  of  humans  and  the  environment  to  the  radiation 
generated  during  the  activation  of  the  radiation  source.  The  law  also 
conditions the granting of an  Operating Permit by presenting a  license in 
accordance  with  the  Communications  Law,  and  in  some  cases,  also  by 
presenting a permit under the Planning and Construction Law. 

The  law  includes  a  penalty  chapter  which  stipulates,  inter  alia,  that  the 
construction or operation of a radiation source in violation of the terms of 
the permit and the construction or operation of a radiation source without 
a  permit  after  receiving  written  notice  from  the  Commissioner,  are  a 
criminal offense.  

In  January  2009,  the  Commissioner  for  Radiation  at  the  Ministry  of 
Environmental  Protection  issued  guidelines  regarding  safety  ranges  and 
maximum  permitted  levels  of  exposure  regarding  radiation  from  radio 
frequencies, including cellular antennas. 

It  should  also  be  noted  that  the  Ministry  of  Environmental  Protection 
operates  a  system  of  continuous  supervision  and  monitoring  of  the 
broadcasting  centers  to  check  their  compliance  with  the  requirements  of 
the law. 

Cellular  services  are  provided  through  a  mobile  phone  that  emits  non-
ionizing radiation (also known as electromagnetic radiation). The Consumer 
Protection  Regulations  (Information  on  Non-Ionizing  Radiation  from  a 

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Mobile  Phone)  5762-2002  stipulate  the  maximum  permissible  level  of 
radiation of a cellphone measured by units SAR (Specific Absorption Rate) 
and  informing  Pelephone's  customers  in  this  context.  To  the  best  of 
Pelephone's knowledge, all the cellular devices it markets meet the required 
SAR standards. See also section3.19.2.5.  

3.13.3. 

Pelephone policy in environmental risk management 

Pelephone  conducts  periodic  radiation  tests  to  ensure  compliance  with 
permitted operating standards and international standards. These tests are 
outsourced  to  companies  licensed  by  the  Ministry  of  Environmental 
Protection.  Pelephone  has  an 
internal  enforcement  procedure  for 
supervising  the  implementation  of  the  provisions  of  the  Non-Ionizing 
Radiation Law, according to  which  a  senior  administrative body has been 
appointed  as  responsible  for  its  implementation.  The  purpose  of  the 
procedure  is  to  implement  the  provisions  of  the  law  and  to  reduce  the 
possibility of violating it. 

3.13.4. 

Transparency to consumers 

Pelephone  is  subject  to  relevant  laws  that  stipulate  advertising  obligations  and 
information  about  the  sources  of  radiation  that  it  operates  and  about  the  radiation 
emanating from the devices it provides. Pelephone publishes information on its website 
regarding  the  level  of  SAR  emitted  from  cell  phones  and  the  Ministry  of  Health's 
recommendations for precautionary measures in the use of cell phones. 

3.14.  Restrictions and supervision of Pelephone’s operations 

3.14.1. 

Legislative restrictions 

3.14.1.1 

 Communications Law  

The provision of cellular services by Pelephone is subject to the provisions 
of  the  Communications  Law  and  its  regulations.  For  details  regarding  the 
mobile  radio  telephone 
license  granted  to  Pelephone  under  the 
Communications Law, see section3.14.2.  

The law authorizes the Director General of the Ministry of Communications 
to impose financial sanctions due to various violations of the provisions of 
the  law  and  of  orders  and  provisions  issued  under  it,  as  well  as  due  to 
violation of conditions in the license.  

3.14.1.2 

Wireless Telegraph Order  

The  Telegraph  Order  regulates  the  use  of  the  electromagnetic  spectrum, 
and applies, among other things, to the use  of radio frequencies made by 
cell phones, as part of its infrastructure. Establishment of a system that uses 
and  operates  radio  frequencies  is  subject,  under  the  Telegraph  Order,  to 
licensing, and the use of radio frequencies is subject to the designation and 
allocation of an appropriate frequency. According to the Telegraph  Order, 
license  fees  and  fees  are  imposed  for  the  designation  of  frequencies  and 
their  allocation.  The  Order  authorizes  the  Ministry  of  Communications  to 
impose financial sanctions due to various violations of its provisions. 

For radio frequencies assigned to cell phones, see section 3.8.2. 

3.14.1.3 

The Non-Ionizing Radiation Law 

With  respect  to  facilities  that  emit  electromagnetic  radiation  see  section 
3.13. 

3.14.1.4 

Consumer legislation and privacy protection and information security laws 

As  part  of  its  activities,  Pelephone  is  subject  to  the  Consumer  Protection 
Law, which regulates a dealer's obligations to consumers, as well as the laws 
of privacy protection and information security (see Section 1.7.7.4).  

3.14.1.5 

Change in interconnectivity fee rates (Call Completion Fee) 

 Interconnectivity  rates  are  set  by  the  regulator.  For  details  see  Section 
1.7.7.1. 

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3.14.2. 

Pelephone's mobile radio telephone license  

3.14.2.1 

General 

Pelephone's mobile radio telephone license as well as the general license to 
provide  cellular  services  in  the  Judea  and  Samaria  area  are  valid  until 
September 9, 202255. 

The  following  are  the  main  instructions  from  Pelephone's  mobile  radio 
telephone license:  

a. 

In  certain  circumstances,  the  Minister  may  change  the  terms  of  the 
license, restrict it or suspend it and, and in some cases even cancel it. 

b.  The license is not transferable and includes restrictions on the purchase 
or transfer (including by way of lien) directly or indirectly of control or 
of 10% or more of any means of control in Pelephone, including the lien 
of such means of control, unless the Minister's prior consent is given.  

c.  Pelephone is obligated to provide an interconnectivity service on equal 
terms  to  any  other  operator  and  must  avoid  any  discrimination  in 
interconnectivity.  

d.  Pelephone  must  refrain  from  preference  of  providing  infrastructure 
services to a licensee who is an affiliated company (as defined in the 
license) over another licensee.  

e.  The 

license  specifies  the  mobile  radio  telephone  services  that 
Pelephone  may  provide  and  states  that  it  is  not  allowed  to  provide 
additional mobile radio telephone services that are not specified in the 
license. 

f.  Pelephone may not sell, rent, or mortgage property from the properties 
used  to  carry  out  the  license  without  the  consent  of  the  Minister  of 
Communications, except for certain exceptions set forth in the license. 

g. 

In times of emergency, the person authorized by law has the authority 
to  give  Pelephone  various  instructions  regarding  the  manner  of  its 
operation and / or the manner of providing the services (see section 
3.19.2.9). 

h.  The license specifies the types of payments that Pelephone may charge 
its subscribers for cellular services, and the reports it must give to the 
Ministry of Communications. The license also stipulates the authority 
of the Minister to intervene in rates, in some cases. 

i. 

j. 

The license requires Pelephone to a minimum standard of service.  

In order to secure Pelephone's obligations and in order to compensate 
and compensate the State of Israel in the event that Pelephone's action 
causes  it  damage,  Pelephone  provided  a  bank  guarantees  to  the 
Ministry of Communications, in the amount of NIS 69 million.  

3.14.2.2 

Ministry of Communications guidelines regarding license changes 

The Ministry periodically updates Bezeq’s license on various issues, as part 
of hearings held by it. 

3.14.3. 

Site construction licensing 

Pelephone's cellular services are provided, among other things, through cellular sites that 
are deployed throughout Israel in accordance with engineering needs. The constant need 
to  upgrade  and  improve  the  quality  of  cellular  services  requires  the  establishment  of 
cellular sites, configuration changes, and changes to existing antenna arrays. 

Pelephone uses transmission sites of two main types and in two tracks: macro sites that 

55 The wording of Pelephone’s mobile radio telephone license is published on the website of the Ministry of Communications at 
www.moc.gov.il. The provisions of the mobile radio telephone license applies on the license in the Judea and Samaria area (with 
certain changes)). 

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require a building permit from the Planning and Construction Committees (see reference 
to National Outline Plan 36A below) and facilities exempt from a building permit under 
the  Communications  Law  and  the  planning  and  Construction  Law  ("Exemption 
Provision"):  Wireless  access  facilities  ("Access  Facilities")  for  which  regulations  were 
published  in  2018  regulating  the  self-licensing  route  based  on  compliance  with  the 
provisions of National Outline Plan 36 and allowing self-licensing for the establishment of 
certain  transmission  facilities.  On  January  1,  2022,  a  series  of  legislative  amendments 
entered into force within the Arrangements Law, which Define the cellular infrastructure 
as a national infrastructure and create a self-licensing route for certain cellular antennas 
and for making adjustments to the various transmission facilities, instead of establishing 
new access facilities, as detailed below. 

Pelephone's ability to maintain and preserve the quality of its cellular services, as well as 
its  coverage,  is  based  in  part  on  its  ability  to  establish  cellular  sites  and  install 
infrastructure  equipment,  including  broadcasting sites.  The  difficulties  encountered  by 
Pelephone  in  obtaining  the  necessary  permits  and  approvals  can  adversely  affect  the 
existing  infrastructure,  the  network's  performance  as  well  as  the  establishment  of 
additional cellular sites required by the network. Difficulties in deployment also exist in 
the Judea and Samaria area, for which a special legal system applies. 

The  inability  to  resolve  these  issues  in  a  timely  manner  may  even  prevent  the 
achievement of service quality targets set forth in the mobile radio telephone license.  

Pelephone, like the other cellular operators in Israel, established some of the cellular sites 
throughout  Israel  on  properties  managed  by  the  Israel  Land  Authority.  This  is,  among 
other  things,  in  accordance  with  the  roof  contract  from  June  2013  that  ended  on 
December  31,  2019.  After  lengthy  negotiations  on  November  23,  2022  a  new  roof 
contract was signed which will be valid until 31.12.2024 with various changes compared 
to the roof agreement. 

a.  Building  permits  for  the  construction  of  a  transmission  facility  for  cellular 

communications by virtue of National Outline Plan 36A: 

Licensing of the construction of cellular transmission sites subject to building permits, 
regulated by National Outline Plan 36A, which came into force in 2002.  

The  licensing  procedure  according  to  NPA  36A  requires,  inter  alia,  the  receipt  of 
approvals as follows: A. Approval of establishment and operation by the Ministry of 
Environmental  Protection,  as  specified  in  section  3.13.2;  B.  Approval  of  the  Civil 
Aviation Administration, in some cases; C. IDF approval. 

In  addition,  according  to  the  law,  a  condition  for  granting  a  permit  for  the 
establishment of a transmission facility for cellular communications is the submission 
of a letter of indemnity to the local committee in respect of claims for compensation 
for impairment. As of the date of this report, Pelephone has deposited approximately 
660 indemnity letters with various local committees. 

Despite NPA 36A in its existing format, Pelephone (and to the best of its knowledge, 
also from its competitors) encounters difficulties in obtaining some of the necessary 
approvals, especially the approvals of the planning and construction authorities.  

b.  Facilities exempt from building permits: 

The  second  route  in  which  Pelephone  has  deployed  broadcast  sites  so  far  is  the 
Access Facilities route. The Access Facilities were subject to the receipt of individual 
radiation permits but are exempt from obtaining a building permit provided that they 
are  established  under  the  conditions  set  forth  in  the  exemption  directive  (Article 
266C (a) of the Planning and Construction Law (installation of a wireless access facility 
for  cellular  method),  5778-2018  and  the  regulations.  However,  in  view  of  the 
amendment to the Planning and Construction Law set forth in the Arrangements Law 
and the new self-licensing route according to it (see below), the route of the Access 
Facilities became redundant. 

As of the date of the report, Pelephone operates about 420 wireless access sites. 

It should be noted that in spot enforcement proceedings, which are taken from time 
to time, additional allegations arise regarding the manner in which the exemption is 
used, including compliance with regulations. To the extent that there are Pelephone 

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facilities  that  do  not  meet  the  conditions  set  forth  in  the  regulations,  there  is 
exposure in respect thereof if the dismantling or adjusting of those facilities becomes 
necessary. 

As part of the Arrangements Law, which entered into force on January 1, 2022, an 
amendment was received to the Planning and Construction Law, which includes the 
removal  of  regulatory  barriers  regarding  the  establishment  of  sites.  The  main 
amendment is the granting of an exemption from licensing procedures for placing 
and using facilities up to 6m on the roof of a building, an exemption for replacing a 
transmission facility, an exemption for adding an antenna to a transmission facility 
established  under  the  Planning  and  Building  Law  and  an  exemption  for  replacing 
masts up to 18m high. The amendment to the Planning and Construction Law also 
includes a new classification of "transmission facilities for communications using the 
Thai method", as defined in Article 202B of the Planning and Construction Law, as 
"national infrastructure", and a new classification of NAP 36A as "a detailed national 
master  plan  for  national  infrastructure".  The  amendment  to  the  Planning  and 
Building Law facilitates the replacement of antennas, the addition of an antenna to 
existing sites, and the strengthening of masts. All, under the technical and practical 
conditions set out in the amendment.  These facilities will continue to meet all the 
conditions of NAP 36 and spatial guidelines of the local committees, with the actual 
meaning of the amendment being the possibility of a "self-licensing" route - that is, 
performing a self-licensing and control procedure in the above cases, and submitting 
documents to the Planning and Construction Committee retrospectively (after the 
completion of the construction of the sites). Simultaneously with this amendment, 
an amendment was also established to the definition of "wireless access facility" in 
Article  27A  of  the  Communications  Law.  As  part  of  the  aforesaid  amendment,  a 
"transmission facility for communication in the cellular method as defined in Article 
266C2  of  the  Planning  and  Building  Law"  was  removed  from  the  definition  of  a 
"wireless access facility". This means that the wireless access facilities that were set 
up with an exemption from a permit continue to exist, but it is no longer possible to 
set up new mobile sites in the "access facilities" route, which is listed above). 

As  part  of  the  report  of  the  inter-ministerial  committee  that  served  as  the 
infrastructure for amendments to the Arrangements Law, it was also recommended 
to update NPA 36A, which came into force about twenty years ago. 

At this stage it is not possible to estimate the future consequences as a result of the 
amendments. 

On  November 14,  2021, Pelephone signed a  framework agreement  to expand the 
local collaboration in the establishment of passive infrastructure on joint mobile sites 
together with Cellcom and PHI Networks (2015) Limited Partnership. In August 2022, 
the Ministry of Communications approved the agreement. This agreement may help 
establish joint mobile sites. 

3.14.4. 

Establishment of sites by parties other than cellular operators 

On  July  17,  2023,  the  Ministry  of  Communications  published  a  decision  (and  an 
amendment  to  the  cellular  operator's  license),  regarding  allowing  entities  that  do  not 
have a cellular license to establish and lease cellular radio centers (communication sites) 
and lease them to cellular operators. The sites will be operated and maintained by the 
cellular  operators  (operation  and  maintenance  will  be  allowed  by  said  parties  as 
subcontractors of the cellular operators). The implementation of the decision requires 
legislative  changes  and  the  establishment  of  regulatory  rules  regarding  the  manner  of 
implementation  and  its  limitations.  In  Pelephone's  estimation  as  of  the  date  of 
publication of the report and before the establishment of regulatory rules on the subject, 
the decision is not expected to have a material impact on Pelephone's business. 

3.14.5. 

In conclusion: A few sites that were established years ago still lack the approvals of the 
Civil Aviation Administration and the IDF, although the applications for approvals have 
already  been  submitted.  Also,  some  planning  and  construction  committees  have 
administrative or other delays in issuing building permits to sites. Therefore, Pelephone 
operates a number of broadcasting sites that have not yet been issued building permits. 

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The establishment of a broadcasting site without obtaining a building permit is a violation 
of the law and in some cases this has led to the issuance of demolition orders or the filing 
of indictments or the filing of civil proceedings against Pelephone and some of its officers.  

As of the date of the report, Pelephone has in most cases been able to avoid demolition 
or  delay  the  execution  of  demolition  orders  within  the  framework  of  arrangements 
reached  with  the  planning  and  construction  authorities,  in  order  to  try  to  settle  the 
missing  license.  These  arrangements  did  not  require  a  confession  of  guilt  and  /  or  a 
conviction  on  the  part  of  Pelephone  officials.  However,  there  is  no  certainty  that  this 
situation  will  continue  in  the  future,  or  that  there  will  be  no  further  cases  in  which 
demolition  orders  will  be  issued  and  indictments  will  be  filed  for  building  permits, 
including against officers. 

Pelephone,  like  the  other  cellular  operators  in  Israel,  may  be  required  to  dismantle 
transmission  sites  for  which  the  necessary  approvals  and  permits  have  not  yet  been 
obtained in accordance with the deadlines set by law. Pelephone uses the license-exempt 
facilities to provide coverage and capacity in crowded areas. If a legal constraint is created 
for the simultaneous dismantling of the sites in a given geographical area, there may be 
a  deterioration  in  the  service  in  that  area,  until  the  establishment  of  alternative 
broadcasting sites. 

3.14.6. 

Economic Competition Law 

In  the  terms  of  the  merger  of  Pelephone  and  the  Company,  various  restrictions  are 
anchored regarding cooperation between the companies (see Section 02.16.9). 

3.15.  Material agreements 

3.15.1. 

For agreements with Ericsson, see section  0. 

3.15.2. 

In July 2016, an agreement was signed between Pelephone and the Accountant General 
of the Ministry of Finance, according to which Pelephone will provide cellular services to 
state employees that was estimated at 100,000 subscribers over three years. Under the 
agreement, Pelephone provides devices to some Accountant General subscribers. 

The State chose to exercise the extension options granted to it in the agreement, and the 
agreement  was  extended  until  May  16,  2024.  On  February  21,  2024,  the  Accountant 
General published a new tender for the supply of cellular communication services and 
end equipment. 

3.15.3. 

Regarding a collective agreement between Pelephone and the Histadrut and Pelephone’s 
Employees’ Committee, see section 3.9.4. 

3.16. 

Legal Proceedings56   

During  the  day-to-day  business,  lawsuits  were  filed  against  Pelephone,  including  motions  for 
approval of class actions.  

3.16.2. 

Pending legal proceedings  

The following is a list of the claims in which the amount claimed is material and claims 
that may have material consequences for Pelephone's operations: 

Date 

Parties 

Instanc
e 

Proceeding 
type 

Details 

a.  7
May 
2012 
. 

Customer 
vs. 
Pelephon
e 

District 
(Tel 
Aviv) 

Class action 
lawsuit 

It is claimed that Pelephone does not inform customers 
who wish to join its services with a device that was not 
purchased  from  Pelephone,  that  as  long  as  the  device 
does not support the 850 MHz frequency, they will enjoy 
partial reception of one frequency and not two. In March 
2014,  the  Court  approved  the  lawsuit  as  a  class  action, 
its 
following  Pelephone's  announcement  regarding 

Amount of the 

claim 

(NIS millions) 

About 124  

56 For reporting policy and materiality thresholds, see section 2.18. 

112

 
 
 
 
 
 
 
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Date 

Parties 

Instanc
e 

Proceeding 
type 

Details 

consent (for reasons of efficiency) to the management of 
the lawsuit as a class action, while maintaining its claims. 
The  procedure  is  split  into  two  stages  (the  stage  of 
clarifying liability and the stage of quantifying damages, 
as  necessary  in  stage  two).    On  January  20,  2019,  a 
decision  was  given  in  the  sale  case  under  Pelephone's 
responsibility for the claim in the lawsuit, on the grounds 
of deception under the Consumer Protection Law and on 
the  grounds  of  lack  of  good  faith  in  negotiations,  in 
relation to the period  up to the  date of the decision to 
approve  the  claim  as  a  class  action  (March  2014). 
Depending on the decision and previous decision in the 
case the next step in the hearing of the case will be on the 
question of the alleged damage. 
It  was  alleged  that  Pelephone,  along  with  three  other 
cellular  companies,  signed  up  subscribers  to  content 
services  without  their  consent  and  illegally,  thereby 
creating  a  "platform"  that  led  the  Accutech  Group  to 
charge  tens  of  thousands  of  people  for  illegal  content 
services. 

It  is  alleged  that  the  defendants  are  illegally  using  the 
location  data  of  their  clients  and  thus  violating  the 
contract  agreements  with  them,  the  operating  licenses 
and  various  laws,  including  the  Privacy  Protection  Law, 
5741-1981. 
It should be noted that in December 2023, another claim 
was filed that includes the same grounds as this claim and 
by  the  same  representatives,  according  to  them  for 
precautionary reasons. 
Two similar motions for the approval of a class action in 
which  it  is  claimed  that  Pelephone  does  not  act  in 
accordance with the law with regard to providing notices 
of  the  termination  of  fixed-period  transactions.  On 
September  11,  2023,  a  consolidated  motion  was 
subsequently filed for approval by the Court. 
In  the  consolidated  motion,  it  was  stated  that  similar 
motions for approval of class actions were also submitted 
against  the  Company  (see  Section  2.18.1)  and  Yes  (see 
update to Section 5.16.1). 
Two similar motions for the approval of a class action in 
which  it  is  claimed  that  Pelephone  does  not  act  in 
accordance with the law with regard to providing notices 
of the termination of transactions for a fixed period. On 
September  11,  2023,  a  consolidated  motion  was 
subsequently submitted for approval by the Court. 
In  the  consolidated  motion,  it  was  stated  that  similar 
motions  for  approval  of  class  actions  were  also 
submitted  against  Bezeq  (see  Section  2.18.1)  and  Yes 
(see update to Section 5.16.1). 
In the motion, it is claimed that within the framework of 
the numbers blocked for dialing by the subscribers of the 
Kosher Floor (as part of the characteristics of the Kosher 
route),  Pelephone  and  the  other  respondents  illegally 
blocked numbers 

113

b. 

 July 2014  Customer 

vs. 
Pelephon
e, three 
other 
cellular 
companie
s and 
additional 
responde
nts 
Customer 
vs. 
Pelephon
e and 
Partner 

c. 

 October 
2017 

d. 

 April 2019  Customer 

vs. 
Pelephon
e, Bezeq 
Internatio
nal and, 6 
other 
companie
s 

District 
(Tel 
Aviv) 

Monetary 
claim and a 
motion to 
recognize it 
as a class 
action 

Central 
Distric
ut 
Court 

Monetary 
claim and a 
motion to be 
recognized 
as a class 
action 

Central 
District 

Monetary 
claim and a 
motion to be 
recognized 
as a class 
action 

e. 

 June 2023 

Customer 
vs. 
Pelephone 

Central 
District 

Consolidated 
motion 
motion 
approve 
class action 

to 
a 

f. 

 December 
2023 

Haifa 
District 
Court 

Monetary 
claim  and  a 
motion to be 
recognized 
as  a 
action 

class 

Amount of the 

claim 

(NIS millions) 

About 100 in 
relation to the 
cellular 
companies and 
about 300 
against all the 
defendants 

About 850  

The amount of 
the claim is not 
stated, but in 
the motion it is 
estimated at 
tens of millions 
of NIS 

Over NIS 2.5 
million. 
Impossible to 
accurately 
estimate. 

Over NIS 3 
million. 
Impossible to 
accurately 
estimate 
until all data 
is received 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

3.16.3. 

Legal proceedings concluded during the reporting period 

Claim filed 

Parties 

Instance 

a. 

 April 2017 

Customer vs. 
Pelephone 

Tel Aviv 
District 
Court 

Proceeding 
type 

A monetary 
claim and a 
motion for 
approval as a 
class action 

b. 

 January 
2023 

Haifa 
District 
Court 

A monetary 
claim with a 
motion for 
approval as a 
class action 

Details 

the 

terms  of 

It  is  claimed  that  the  defendant  unilaterally  and 
without  consent  changed 
the 
agreement  between  itself  and  the  applicant,  and 
others like her, by allowing continued browsing after 
exhausting  the  volume  of  browsing  included  in  the 
package instead of stopping it, despite Pelephone's 
notification on the matter. 
On April 28, 2023, a ruling was issued confirming the 
settlement  arrangement  between  the  parties,  the 
main  of  which  is  the  provision  of  benefits  and 
compensation  with  a  total  value  of  approximately 
NIS 18 million. 
It  is  claimed  that  there  is  no  price  marking  on 
products  sold  by  Pelephone,  contrary  to  the 
provisions of the Consumer Protection Law and the 
provisions  of  the  Consumer  Protection  Regulations 
(Various Rules for Publishing Prices of Properties and 
Services), 5751-1991 

Original claim 
amount (NIS 
millions) 
Approx. 80 

Over NIS 2.5 
million. 
Impossible to 
accurately 
estimate. 

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3.17.  Targets and business strategy 

Pelephone's strategic targets are continued growth in its customer base while promoting a variety 
of packages and solutions to customers and promoting services based on the 5G network, continuing 
to develop innovation and network technologies and providing excellent service and improvement 
in the cost structure. 

3.18.  Expected development in the coming year 

In 2023, a number of factors are expected to affect Pelephone's activity, the main ones being: 

3.18.2. 

Continuing competition and increasing the value to the customer  

Pelephone expects that in 2024, the competition will focus on increasing the value and 
volume of browsing to the customer. 

3.18.3. 

Cellular network innovation and products 

In 2024, Pelephone is expected to continue to promote services and products that will 
enable  increased  revenue  or  an  image  advantage  over  competitors:  eSIM,  private 
networks,  cyber and IoT services and continued focus on large device launches, at the 
same time as the implementation of the deployment plan of the 5G network. 

3.18.4. 

Increasing service consumption by Pelephone subscribers  

Pelephone expects that as a result of an increase in the volume of  browsing offered to 
the customer, and increasing the marketing of service packages based on the 5G network, 
the trend of increasing the consumption of data communication volume on the network 
will continue. 

3.18.5. 

Digital transformation 

In 2024, Pelephone is expected to continue to develop and expand its digital service and 
sales channels. 

3.18.6. 

5G network 

In  2024,  Pelephone  is  expected  to  continue  the  deployment  of  the  5G  network,  the 
construction  of  an  independent  network  core,  and  the  marketing  and  sale  of  services 
based on this technology. 

Pelephone's assessments and expectations regarding developments in the coming year 
presented in this section above are forward-looking information within its meaning in the 
Securities Law. These assessments and expectations are based, among other things, on 
the  state  of  competition  in  the  cellular  field,  the  existing  regulatory  situation  and  the 
manner in which the new regulatory changes are implemented. These assessments may 
not  materialize,  or  materialize  in  a  materially  different  way  than  described  above, 
depending,  inter  alia,  on  the  structure  of  competition  in  the  market,  changes  in  the 
consumption  habits  of  cellular  customers,  technological  developments  and  regulation 
begun in the field. 

3.19.  Discussion of risk factors 

The  following  are  risk  factors  arising  from  the  macroeconomic  environment,  the  unique 
characteristics of the industry in which Pelephone operates, and risk factors unique to Pelephone. 

3.19.1.  Macroeconomic risk factors  

3.19.1.1 

3.19.1.2 

Exposure to changes in exchange rates and inflation - Pelephone is exposed 
to  risks  due  to  changes  in  exchange  rates  as  most  purchases  of  end 
equipment,  accessories,  spare  parts  and  infrastructure  are  made  in  US 
dollars,  while  Pelephone's  revenue  is  in  shekels.  Erosion  of  the  shekel 
against the dollar could hurt Pelephone's profitability if it is not possible to 
adjust  selling  prices  (mainly  of  end  equipment)  in  the  short  term.  Also, 
changes in price indices may affect site rental costs. 

Epidemic and supply chain - outbreaks of diseases and epidemic events in 
general (such as the outbreak of COVID-19 in 2020) may have consequences 
for Pelephone's business activities depending on the extent of the spread 
and  its  severity,  as  well  as  the  national  and  global  measures  that  will  be 
taken  as  a  result.  These  consequences  may  be  reflected,  among  other 

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3.19.1.3 

3.19.1.4 

things,  in  damage  to  Pelephone's  operations  and  its  customer  service 
system,  as  well  as  in damage  to the  supply  chain.  Events of  this type  are 
changing  events  that  are  not  under  Pelephone's  control,  and  their 
consequences  are  subject,  among  other  things,  to  the  decisions  of  states 
and authorities in Israel and around the world that may affect the Company 
accordingly.  

Damage caused by nature, war, disaster  - damage to the switching farms 
and / or servers (including damage to a large number of sites, for example 
from an earthquake) on which Pelephone concentrates its core activity, may 
adversely affect Pelephone's business and its results. 

Damage to electricity supply - Damage to the electricity supply to Pelephone 
facilities for various reasons (some of which are described in Section Error! 
The source of the reference was not found.) may have a negative effect on 
Pelephone's business and damage Pelephone's ability to provide services. 
Some of Pelephone's systems have power backup, but at the same time, in 
the event of prolonged damage to some or all of the systems, there may be 
significant  difficulties  and  beyond  that  in  the  provision  of  Pelephone 
services, including in the event that Pelephone cannot return the systems 
to service quickly. 

3.19.2. 

Industry risk factors  

3.19.2.1 

3.19.2.2 

3.19.2.3 

3.19.2.4 

3.19.2.5 

Infrastructure investments and technological changes - the cellular market 
in  Israel  and  around  the  world  is  characterized  by  significant  capital 
investments  in  the  deployment  of  infrastructure.  Frequent  technological 
changes  in  the  field  of  infrastructure  and  end  equipment,  as  well  as  the 
difficult struggle over various market segments, impose high costs on the 
companies  operating  in  the  market,  which  are  forced  to  update  their 
infrastructure technologies from time to time. 

Competition - the cellular market in Israel is characterized by saturation in 
the penetration rate, fierce competition and a high  number of operators, 
and  is  also  exposed  to  effects  as  a  result  of  technological  and  regulatory 
developments.  The  costs  of  setting  up,  maintaining  and  operating  the 
cellular network in relation to the number of subscribers are expected to be 
higher  in  Pelephone  in  light  of  the  fact  that  it  does  not  operate  in  the 
network sharing model. The end equipment market is also characterized by 
fierce competition between cellular operators and in front of stores that sell 
end equipment in parallel imports. 

Customer credit – a significant portion of the sales of end equipment is done 
by  granting  credit.  The  vast  majority  of  this  credit  that  is  not  covered  by 
collateral is at risk. It should be noted, however, that the credit is spread 
among  a  large  number  of  customers  and  Pelephone  has  efficient  and 
experienced collection mechanisms. 

Regulatory developments - in the field of Pelephone's activities, there is a 
trend  of  legislation  and  standards  in  connection  with  issues  such  as 
increasing  competition,  setting  rates,  the  environment,  product  warranty 
and ways of repair thereof, regulating interconnectivity rates and more. The 
regulatory  intervention  in  the  field  of  activity  may  materially  affect  the 
structure of competition and the operating costs of Pelephone. 

Electromagnetic radiation - Pelephone operates thousands of transmission 
facilities and sells end equipment that emits electromagnetic radiation (see 
section  3.13).  Pelephone  works  to  ensure  that  the  levels  of  radiation 
emitted from the transmission facilities and end equipment sold by it do not 
exceed the permissible radiation levels according to the guidelines of the 
Ministry  of  Environmental  Protection  (determined  in  accordance  with 
international standards). Although Pelephone operates in accordance with 
the  guidelines  of  the  Ministry  of  Environmental  Protection,  if  it  turns  out 
that  there  are  health  risks  or  if  there  are  deviations  from  the  radiation 
facilities at the transmission sites or end equipment, which has a health risk, 
this may have an adverse effect due to reduced use of Pelephone services, 

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3.19.2.6 

3.19.2.7 

3.19.2.8 

difficulty in renting sites, claims for compensation for bodily and property 
damages  to  a  considerable  extent  and  attempts  to  implement  indemnity 
deeds deposited by planning institutions in connection with Article 197 of 
the  Planning  and  Construction  Law.  Pelephone's  third  party  insurance 
policies do not currently cover insurance for electromagnetic radiation. 

Website licensing - construction and operation of cellular antennas, requires 
building permits from the various planning and construction committees, a 
procedure  that  requires,  among  other  things,  obtaining  approvals  from 
government  bodies  and  series  bodies.  For  a  list  of  the  difficulties 
encountered  by  Pelephone  in  setting  up  and  licensing  websites,  see 
Section.אצמנ אל הינפהה רוקמ !האיגש. These difficulties can impair the 
quality of the existing network and even more so the deployment of a new 
network. 

Serious  faults  in  the  information  systems  and  engineering  systems  - 
Pelephone  provides  its  services  through  various  infrastructure  systems, 
including,  among  others,  switches,  data  transmission  and  access 
transmission  networks,  cables,  computer  systems,  physical  infrastructure 
and more (“the systems"). Pelephone businesses have a high dependence 
on these systems. Some Pelephone systems have backup, but at the same 
time, in the event of damage to some or all of the above systems, either due 
to a large-scale technical malfunction, due to a natural disaster (such as an 
earthquake, fire, etc.), or due to damage to physical infrastructure and due 
to malicious damage (such as the introduction of viruses and cyber attacks 
as detailed below), there may be significant difficulties in providing services, 
including  in  the  event  that  Pelephone  is  unable  to  return  the  systems  to 
service quickly. 

Information security, customer data protection and cyber risks - as a leading 
cellular company that provides service to millions of customers, Pelephone 
is  a  target  for  cyber  attacks,  which  aim  to  harm  the  use  of  information 
systems  or  the  information  itself  (“Cyber  Attacks”).  This  type  of  assault 
activity  or  intrusion  event  may  cause  business  disruption,  information  / 
money  theft,  damage  to  databases  and  subscribers'  privacy,  damage  to 
reputation, damage to systems and information leakage which may also be 
caused by an internal party, maliciously or inadvertently 

Pelephone is a body guided by the State Information Security Authority of 
the Prime Minister's Office as well as by the Ministry of Communications, 
and it is committed to complying with strict information security standards. 
In this framework, Pelephone implements a protection policy that includes 
the most advanced security systems in the world, which are installed using 
the method of layers of protection and are operated in a configuration that 
combines  effective  security  with  Pelephone's  operational  needs  and 
security circuits to protect Pelephone's infrastructure and systems, which 
are designed to prevent and reduce the possibility of exploiting Pelephone’s 
data  by  an  external  party  or  maliciously  or  inadvertently  by  an  internal 
entity,  as  well  as  the  possibility  of  an  external  party  taking  over  and 
managing network components or abusing information about Pelephone's 
infrastructure and networks in some way. In this framework, various actions 
are  performed, 
in  the  systems, 
implementing various information security products according to the threat 
outline, periodic risk surveys and practice according to an annual plan. 

including  checking  alerts  and 

logs 

Pelephone complies with the standard of the Prime Minister's Office which 
defines a level of protection against an attack by a hostile country related to 
information  security  (standards  that  define  a  level  of  protection  of  the 
Company's  systems  against  information  security  threats)  and  within  the 
framework of implementing the requirements of the standards, Pelephone 
ensures  the  availability,  integrity,  reliability  and  confidentiality  of  the 
databases under its responsibility. 

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Pelephone  supervises  the  implementation  of  its  protection  policy,  which 
includes testing its level of effectiveness and the Company's readiness. In 
this  framework,  the  company  carries  out  tests  and  attack  exercises  with 
different  frequency  for  different  scenarios  (including  through  external 
companies specializing in the field). Also, Pelephone's Board of Directors is 
involved in and supervises the management of cyber risk at Pelephone, and 
this  is  within  the  framework  of  dealing  with  Pelephone's  overall  risk 
management  policy.  In  the  Company's  estimation,  its  risk  management 
policy in dealing with and reducing the cyber risk is effective. 

The  cyber  risk  management  policy  and 
responsibility of the Information Systems Division, Infrastructure Division. 

implementation 

is  the 

its 

investments 

Despite  Pelephone's 
the 
aforementioned risks, it cannot guarantee that these measures will succeed 
in preventing damage and/or interference that may also be significant in the 
systems and information related to them. 

in  measures 

reduce 

to 

3.19.2.9 

3.19.2.10 

Economic  emergency  -  in  times  of  emergency,  certain  provisions  of  the 
legislation  and  provisions  of  the  mobile  radio  telephone  license  allow 
persons  authorized  under  the  law  to  take  steps  required  to  ensure  state 
security and / or public safety, including: charging Pelephone (as a mobile 
radio  telephone  license  holder)  to  give  service  to  the  security  forces, 
comandeering  of  engineering  equipment  and  facilities  of  Pelephone,  and 
even taking control of Pelephone’s system. 

Lack  of  frequencies  -  for  details  on  the  lack  of  frequencies,  see  section 
3.8.2.1. In many cases, frequency allocation is carried out through tender 
procedures,  in  a  manner  that  may  increase  the  costs  of  purchasing  the 
frequencies  and  place  the  cellular  companies  that  do  not  receive  the 
allocation as part of the tender at risk of competitive inferiority.  

3.19.3. 

Risk factors unique to Pelephone 

3.19.3.1 

3.19.3.2 

3.19.3.3 

3.19.3.4 

Property risks and liabilities - Pelephone is exposed to various property risks 
and  liabilities.  Pelephone  is  assisted  by  an  external  insurance  consultant 
who is an expert in the field. Pelephone has insurance policies that cover 
the risks that are acceptable to them, Pelephone is subject to the limitations 
of  the  terms  of  the  policies,  such  as:  various  property  insurance,  various 
liability insurance, loss of profits, third-party liability insurance and officers' 
insurance.  However,  Pelephone's  insurance  policies  do  not  cover  certain 
types of risks, including certain malfunctions caused by negligence or human 
error, radiation risks, terrorism and more. 

Serious  faults  in  the  cellular  network  -  Pelephone's  cellular  network  is 
spread throughout Israel through the network's core sites, antenna sites and 
other  systems.  Pelephone’s  sytems  are  completely  dependent  on  these 
systems,  which  are  sometimes,  temporarily,  in  a  state  of  partial  survival. 
Malicious  damage  or  malfunction  on  a  large  scale  can  adversely  affect 
Pelephone’s business and its results. 

Epidemic  malfunctions  in  devices  -  various  exposures  resulting  from 
Pelephone's  liability  as  an  importer  due  to  manufacturer  malfunctions  in 
devices that will not be supported by the manufacturers. 

Legal proceedings - Pelephone is a party to legal proceedings, including class 
actions, which may result in a charge of substantial amounts, which cannot 
be  estimated,  and  no  provision  has  been  made  for  some  of  them  in 
Pelephone’s financial statements. These class actions can reach large sums, 
as a substantial portion of the state's residents are consumers of Pelephone, 
and a claim relating to a small damage to a single consumer may become a 
material claim to Pelephone if it is recognized as a class action applicable to 
all or a significant portion of consumers. 

3.19.3.5 

Significant  suppliers  and  customers  -  for  agreements  with  significant 
suppliers and customers, see sections 3.10 and 3.15. Some of Pelephone's 
agreements,  including  with  its  key  customers,  are  timed.  There  is  no 

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3.19.3.6 

3.19.3.7 

3.19.3.8 

3.19.3.9 

certainty that these agreements will be renewed at the end of their term or 
that options granted to customers to extend them will be exercised. 

Labor relations - Pelephone has a collective agreement with the Histadrut 
and  the  Employees’  committee,  which  effects  most  of  its  workers.  The 
collective  agreement  may  reduce  administrative  flexibility  and  impose 
additional  costs  on  Pelephone  (see  section  3.9.4).  In  addition,  the 
implementation  of  personnel-related  plans  may  cause  unrest  in  labor 
relations  and  harm  to  Pelephone's  ongoing  operations.  Regarding  labor 
disputes at Pelephone, see Section 3.9.5. 

Loss of knowledge and information - the changes that are taking place in the 
labor  market  in  Israel  and  around  the  world,  along  with  organizational 
changes, entail a risk of losing key employees, loss of knowledge as a result 
of employee turnover, difficulty in recruiting employees, etc. 

Impairment  of  Pelephone  properties-  in  accordance  with  accounting 
standards, Pelephone conducts a periodic examination of the impairment of 
assets in respect of which indications of impairment have been identified. 
For details on the risk factor relating to the recognition of impairment losses, 
see Section2.20.13.  

Frequency ranges – Pelephone operates fequencies in the 700, 850, 1800, 
2100,  2600  and  3500  MHz  ranges.  The  frequencies  are  exposed  to 
interruptions that may affect the quality of service of the networks operated 
by  Pelephone.  Among  the  other  reasons  that  may  cause  interruptions,  it 
should  be  noted  that  the  850  range  is  also  used  for  terrestrial  television 
broadcasts, so that television stations broadcasting in the Middle East in the 
same range of frequencies cause interference on Pelephon’s UMTS / HSPA 
network on 850 MHz. In addition, the Jordanian networks also use the same 
frequency range of 2100 MHz that Pelephone uses and in light of the limited 
cooperation between the operators in Jordan and Pelephone, this may have 
a negative effect on Pelphone. In addition, Pelephone must avoid interfering 
with  satellite  broadcasts  made  at  several  points  in  Israel  at  3500MHz 
frequencies, which limits the operation of 5G services around these points. 

For details on the implications of switching frequencies in the first giga field, 
see Section 3.8.2.3. 

3.19.3.10  Maintaining  a  sufficient  cash flow  -  Pelephone  must  maintain  a  sufficient 
cash flow in order to meet its long-term business plan. The lack of sufficient 
cash flow may adversely affect Pelephone's business and its ability to make 
large-scale online investments, and may make it difficult for it to cope with 
competitive threats in the field. 

Below  is  a  ranking  of  the  impact  of  the  risk  factors  described  above  on 
Pelephone's activities as estimated by Pelephone's Management. It should 
be  noted  that  Pelephone's  assessments  below  regarding  the  degree  of 
influence of the risk factor reflect the degree of influence of the risk factor 
in assuming the materialization of the risk factor, and the aforesaid does not 
express  an  assessment  or  give  weight  to  such  chances  of materialization. 
The order in which the risk factors appear above and below is not necessarily 
according to the degree of risk. 

Risk factors summary table - cellular telephony  

The extent of the impact of the 
risk factor on Pelephone's 
operations as a whole 
Medium 
effect 

Small 
effect 

High 
effect 

Macro risks 
Exposure to changes in exchange rates  
Epidemic and supply chain 
Damage due to force majeure, war, disaster 
Damage to electricity supply 
Industry risks 

119

X 

X 
X 
X 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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X 

X 

X 

X 

X 

in 

X 
X 

X 
X 

information  systems  and 

Infrastructure investments and technological changes 
Competition 
Customer credit 
Regulatory developments  
Electromagnetic radiation 
Website licensing 
Serious  malfunctions 
engineering systems 
Information  security,  customer  data  protection  and 
cyber risks 
Economic emergency 
Lack of frequencies 
Risk factors of Pelephone 
Property risks and liabilities 
Serious malfunctions in the cellular network 
Epidemic malfunctions in devices 
Legal proceedings 
Substantial suppliers and customers 
Labor relations  
Loss of knowledge and information 
Impairment of Pelephone's assets  
Frequency ranges  
Maintaining sufficient cash flow 
The information contained in section 3.19 and Pelephone's assessments regarding the effect of the 
risk factors on Pelephone's activities and business, are forward-looking information as defined in 
the Securities Law. The information and assessments are based on data published by the Ministry 
of  Communications,  Pelephone's  assessments  of  the  market  situation  and  the  structure  of 
competition  in  it  and  regarding  possible  developments  in  the  Israeli  market  and  economy.  The 
actual results may differ materially from the estimates given above if there is a change in one of 
the factors taken into account in these estimates.  

X 
X 
X 
X 

X 

X 

X 

X 

X 

X 

X 

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4. 

Bezeq International - Internet, international communications and ICT solutions 

4.1. 

General 

4.1.1. 

The structure of the field of activity and changes that apply to it 

Bezeq International operates in several key areas: Internet access services, international 
data  communication,  international  telephony;  Communication  and  computing services 
for businesses that include hosting in server farms, cloud services, cyber protection; and 
supply of equipment, licensing and service contracts for businesses. 

Regarding  regulatory  changes  in  the  Internet  services  market  for  private  customers, 
which are expected to materially affect Bezeq International's activity in this market, see 
Section 4.11.5.3. 

4.1.2. 

Legislative and regulatory restrictions that apply to Bezeq International 

A significant  part of Bezeq International's areas of activity are regulated mainly by the 
Communications Law and regulations thereunder, and the terms of the license granted 
to Bezeq International (see Section 4.11).  

Regarding major developments in the regulation applicable to Bezeq International, see 
section 4.11.5. 

4.1.3. 

Changes in the scope of activity in the field and its profitability 

For data on changes in the scope of Bezeq International's operations and its profitability, 
see Sections1.5.4.3 and-4.3. 

4.1.4. 

Developments in the market and in customer characteristics 

In the field of Internet services, the market is characterized by the transition of customers 
from the retail market services (where the customer purchases the access service and the 
infrastructure  service  from  different  providers)  to  unified  packages  (where  the  access 
service  and  the  infrastructure  service  are  purchased  from  one  provider)  following 
regulatory  changes  (see  Section  4.11.5.3).  In  the  international  data  communication 
market,  there  is  no  change  in  demand  for  data  communication  services  in  Israel  and 
around the world. The increased use of information technologies requires an increase in 
capacity. The positioning of the State of Israel as a communication and technology hub 
leads  to  demand  from  global  companies  for  data  communication  services  to  Israel. 
Following the establishment of diplomatic relations with other countries in the Middle 
East, a further increase in demand for communication services between the Middle East 
and Europe is expected, some of which will go through Israel. 

In the field of cloud, hosting, and computing services for businesses, in 2023, the increase 
in demand for hosting services in server farms and public cloud services continued, as a 
result of the trend of organizations to transfer their computing rooms and infrastructure 
to  server  farms  where  there  are  24/7  maintenance  monitoring  services  and  the  high 
power  supplies  required  for  the  computing  equipment,  as  well  as  as  a  result  of  the 
transition to managed services (as a Service). There are various factors that affect demand 
for cloud services, such as the digital transformation, the entry of cloud companies such 
as  Microsoft,  Google,  Oracle,  AWS  into  the  Israeli  market,  as  well  as  the  transition  of 
government services to the cloud as part of the "Nimbus" project. 

The field of integration solutions is affected by the economic situation in Israel and the 
world, as well as technological changes. In the market, there is a trend of moving from 
the purchase of equipment to software products and cloud-based services (such as SaaS, 
IaaS, PaaS, as well as reliance on public cloud resources such as AWS, Azure, GCP), but it 
is expected that customers will adopt a model that combines the purchase of equipment 
and cloud services ("Hybrid” model). 

4.1.5. 

Main entry and exit barriers 

4.1.5.1 

The  main  entry  barriers  to  the  markets  in  which  Bezeq  International 
operates are making investments, among other things, in infrastructure, in 
establishing service and support systems, etc. (also, some of the activities 
require a license according to the Communications Law. 

4.1.5.2 

The main exit barriers from these markets arise from long-term and binding 

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agreements  with  infrastructure  providers  and  investments  that  require  a 
long time to return. In addition, some require providing service to customers 
during the contract period, which is not short. 

4.1.6. 

Substitutes for Bezeq International products and the changes that apply thereto 

In  the  international  call  market  -  The  main  alternative  product  is  the  use  of  VoIP 
technology, which enables the transfer of international calls over the Internet to other 
users of this technology, as well as to the users of the TDM networks, through the use of 
software  products  (such  as  Teams,  WhatsApp  or  Zoom)  and  in  the  services  of 
telecommunications  providers  abroad.  These  services  have  attractive  rates  of  use 
(including  the  absence  of  usage  fees)  and  together  with  their  availability,  lead  to  a 
continuous  increase  in  the  number  of  users,  and  as  a  result  -  to  harm  to  Bezeq 
International's  revenues.  At  the  same  time,  there  are  currently  more  than  ten 
international operators in Israel licensed by the Ministry of Communications to provide 
international Bezeq services. 

4.1.7. 

The structure of competition in the Internet market and the changes that apply to it  

In the field of Internet access services (ISP), diverse licenses have been provided so far to 
provide access services to many companies. Following regulatory changes, the market is 
moving to the provision of services in a unified format (packages that include access and 
infrastructure services from one provider). This resulted in a significant reduction in the 
number of Internet customers of Bezeq International and the structural change described 
in Section 1.1.4, so that Bezeq International does not currently market Internet services 
to customers in a private service..  

For more details regarding competition in the field of activity, see Section 4.6.1. 

4.1.8. 

Critical success factors 

4.1.8.1 

4.1.8.2 

4.1.8.3 

4.1.8.4 

4.1.8.5 

4.1.8.6 

Recruitment and employment of skilled personnel; 

Streamlining and savings in expenses and personnel; 

Ability to maintain a high level of service and customer satisfaction; 

Technological innovation, identifying needs and trends in the market and 
launching solutions to meet these needs; 

Investments in the infrastructures required for the provision of services; 

Maintaining normal working relationships with leading manufacturers and 
suppliers. 

4.2. 

Products and services 

The following is a list of Bezeq International's main products and services:  

4.2.1. 

Internet and data communication services 

4.2.1.1 

Internet services 

In  the  field  of  Internet  services,  Bezeq  International  provides:  Internet 
access  services  (ISP)  for  private  and  business  customers,  including  the 
provision  of  required  end  equipment  and  support  based  on  DSL, 
transmissions or cables infrastructure, Internet access services are provided 
by Bezeq International in the following configurations: (a) "Retail market" 
services:  Internet  access  service,  without  infrastructure  services;  (B) 
"Wholesale  Market"  services:  an  integrated  package  that  includes  an 
Internet access service together with the Internet infrastructure service of 
the infrastructure companies included in the wholesale market reform; (C) 
"Bundle" or "Reverse Bundle" packages: a combined package that includes 
an  Internet  access  service  together  with  Bezeq's  Internet  infrastructure 
service,  provided  by  Bezeq  International  (in  the  case  of  a  bundle)  or  by 
Bezeq (in the case of a reverse bundle); And (d) packages that include Bezeq 
International's Internet access services, Bezeq's infrastructure services and 
DBS’s STING TV brand - a television services platform based on the Internet 
(along with Internet access services; (e) symmetrical internet lines, intended 
for  the  business  segment;  (f)  Interior  telephony  services  on  broadband 

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(Voice over Boardband). 

Bezeq International provides the above-mentioned Internet services mainly 
through a fully and exclusively owned underwater cable between Israel and 
Italy (JONAH) launched in December 2011, and through underwater cables 
owned  by  other  companies,  from  which  Bezeq  International  acquires 
capacities  (see  details  in  Section  4.9).  Among  the  largest  ISP  providers 
operating  in  Israel,  Bezeq  International  is  the  only  one  that  owns  an 
underwater  cable.  The  ownership  of  the  underwater  cable  frees  Bezeq 
International  from  its  dependence  on  infrastructure  providers,  and  also 
enables it to offer its customers better quality browsing performance. 

It should be noted that due to the fact that Bezeq International is gradually 
decreasing its activity in the private customer market (see Section 4.13), its 
revenue  from  Internet  services  were  damaged,  and  they  are  expected  to 
continue to decrease materially. Also, some of the above services are not 
marketed  to  private  customers  (but  are  provided  to  existing  private 
customers). 

4.2.1.2 

International data communication services 

Providing 
customers, including global deployment, according to customer needs.  

international  data  communication  solutions  for  business 

The services are provided through Bezeq International's underwater cable 
and  underwater  cables  of  other  companies,  in  which  Bezeq  International 
has  long-term  use  rights,  as  well  as  through  business  partnerships  with 
telecommunications  providers  which  provide  its  customers  with  global 
network services.  

In  addition  to  the  abovementioned  services,  Bezeq  International  offers 
holders  of  licenses  to  provide  international  Bezeq  services  and  Internet 
access licenses, international capacity (in the form of rent, or purchase of 
indefeasible use rights), based on Bezeq International's  underwater cable 
and rights-of-use in continental Europe and other international networks.  

4.2.2. 

International telephony services 

In the field of international telephony services, Bezeq International provides international 
direct  dialing  services  (IDD)  for  business  and  private  customers,  free  dialing  service 
abroad  for  business  customers,  routing  and  terminal  services  for  international  calls 
(hubbing)  -  transfer  of  international  calls  between  foreign  communication  providers 
(world- Olam and dialing card service that allows dialing from Israel to abroad and from 
abroad to Israel. In addition, Bezeq International  has partnerships with the companies 
Microsoft  and  Cisco,  within  which  Bezeq  International  provides  NIO  and  international 
operator services to the customers of the aforementioned companies. 

4.2.3. 

Cloud, hosting, and computing services for businesses 

4.2.3.1 

Hosting services 

Bezeq International operates several server farm facilities, where server and 
equipment  hosting  services  (colocation)  are  offered,  as  well  as  ancillary 
services  such  as  backup  and  disaster  recovery  services,  virtual  servers, 
protection services against DDoS attacks, and more. 

4.2.3.2 

Public cloud services 

Bezeq International serves as a distributor of Microsoft, and by virtue of this, 
it  distributes  the  cloud  products  of  this  company,  such  as  Office  365 
products and Azure public cloud services. This activity includes both direct 
sales to end customers (direct) and sales to sub-distributors (indirect). Part 
of the activity is carried out through the subsidiary CloudEdge Ltd. (which 
employs  81  employees  as  of  December  31,  2023),  which  offers 
implementation  solutions  and  professional  services  in  this  field.  Bezeq 
International was recently certified as a partner of the company AWS, and 
by virtue of this certification, it began selling licensing  for this company's 
cloud products, as well as related professional services. 

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4.2.4. 

Cyber protection services 

Bezeq  International  provides  the  business  sector  with  various  services  for  protection 
information  security.  The  services  offered  by  Bezeq 
against  cyber  threats  and 
International  include,  among  others:  a  SIEM-SOC  service  that  monitors  events  and 
indications  of  cyber  attacks  on  the  customer's  systems;  protection  services  against 
distributed denial of service (DDoS) attacks; and protection of end positions. The services 
are provided through cloud-based cyber protection solutions from various manufacturers 
such as Trend Micro and Cisco. 

4.2.5. 

Integration solutions 

Bezeq International serves as a non-exclusive marketer of global manufacturers, and by 
virtue  of  this  it  provides  integration  services  that  include  the  sale,  installation, 
implementation  and  maintenance  of  hardware  and  software 
in  the  field  of 
communication  and  telephony  (such  as  physical  telephone  switchboards  or  cloud 
exchanges, wireless Internet networks, communication networks for server rooms and 
user environments, and systems networking), computing infrastructures (such as servers, 
licensing of various types of software, and more, among others in the areas of system, 
storage,  and  more),  and  information  security  (such  as  firewalls,  endpoint  protection 
solutions,  application  protection  (WAF),  file  laundering,  identification  and  monitoring 
online events and more). In general, Bezeq International provides project management 
services in the field of integration. 

4.3. 

Products and services evenue segmentation 

The following are data regarding Bezeq International's revenues (in NIS million):  

Internet services  

Rate of total Bezeq International revenues 

International telephony services 

Rate of total Bezeq International revenues 

Cloud, hosting, and computing services for 
businesses 

Rate of total Bezeq International revenues 

Integration solutions 

Rate of total Bezeq International revenues 

Total revenue  

2023 

538 

44% 

185 

15% 

224 

19% 

265 

22% 

1,212 

2022 

637 

51% 

183 

15% 

185 

15% 

234 

19% 

1,239 

2021 

683 

55% 

177 

14% 

142 

11% 

235 

19% 

1,237 

4.4. 

Customers 

Bezeq International has no dependence on a single customer, and has no customer whose revenues 
constitute 10% or more of its total revenues. 

Below  are  data  about  the  distributioin  of  revenue  from  private  and  business  customers  (NIS 
millions)57: 

Revenue from private customers 
Revenue from business customers 
Total revenue 

2022 
312 
927 
1,239 

2021 
372 
865 
1,237 

2020 
401 
870 
1,271 

Regarding  Bezeq  International  customers  and  their  characteristics,  the  diverse  consumption 
characteristics for purchasing Internet packages among the public have led to a certain percentage 
of customers purchasing as redundant ISP service from more than one ISP when in practice they use 
the services of only one ISP. On September 10, 2020, the Ministry of Communications wrote a letter 
to the carriers in which it raised concerns that some subscribers to Internet services or other services 
such as email box, do not use them and are not even aware of it. The Ministry recommended in its 

57 The data are after changing the classification of small customers (SOHO) from private customers to business customers carried 
out in 2019. 

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application to act to notify and stop charging subscribers who do not use these services, and also 
requested  periodic  reports  on  the  matter,  over  the  next  6  months.  It  was  also  written  that  the 
Ministry  will  consider  in  the  future  whether  to  set  binding  provisions  in  the  matter,  should  and 
initiated actions will not lead to a significant reduction in this matter. On November 8, 2020, another 
letter was received from the Ministry of Communications, according to which the Ministry expects 
that the next reporting point (set for December 17, 2020), the reported data will reflect the reduction 
of the phenomenon in a significant manner, that a date should be provided at this time on how the 
licensee acts to prevent the recurrence of the phenomenon, and, like its previous letter, that as long 
as  the  phenomenon  is  not  significantly  reduced,  the  Ministry  will  take  various  actions,  including 
establishing binding provisions in this regard. In Bezeq International's assessment, the abolition of 
the  separation  of  infrastructure  provider  will  lead  to  a  significant  reduction  in  the  scope  of  the 
phenomenon. Bezeq International makes proactive inquiries to customers who are found not to be 
using the ISP service, in order to get their approval to disconnect or keep the subscription. 

On motions for approval of class actions in this matter that were filed against Bezeq International, 
see Section 4.12. 

4.5.  Marketing, distribution and service 

Bezeq International operates sales channels for the business market that include a sales center and 
business  customer  managers.  Service  centers  and  technical  support  are  available  to  customers. 
Bezeq International operates service and technical support  centers for the private market. Bezeq 
International maintains an array of field technicians for the purpose of responding to malfunctions 
at customer sites that cannot be solved remotely. 

4.6. 

Competition 

4.6.1. 

ISP Services  

4.6.1.1 

4.6.1.2 

4.6.1.3 

Bezeq International competes in providing ISP services to customers from 
the  business  segment,  and  does  not  conduct  competitive  or  marketing 
activities in connection with the provision of ISP services to the household 
segment. 

The  market  is  saturated  with  competitors,  the  main  ones  being  Cellcom, 
Partner, and Hot Net. 

There are also smaller competitors in the market that mainly address the 
business segment, such as Gilat Telecom and ITC. In the absence of public 
data  on  the  market  shares  of  the  competitors  in  the  business  Internet 
market, it is impossible to assess Bezeq International in this area. 

The competition in 2023 is mainly characterized as competition on prices. 
The ISP service for the business segment is seen as a commodity product, 
i.e. a uniform off-the-shelf product in which the identity of the provider is 
not important, and many customers attach decisive weight to the price. This 
naturally leads to price erosion 

4.6.2. 

International telephony services 

4.6.2.1 

As  of  the  end  of  2023,  about  ten  companies  are  operating  in  the  market 
(among them Bezeq International, Cellcom, Partner, Golan Telecom and Hot 
Mobile).  

Bezeq International estimates that its market share in the field of outgoing 
calls from customers as of December 31, 2023 is approximately 21%58. 

4.6.2.2 

General characteristics of the competition in 2023: 

In 2023, the number of call minutes made through international telephony 
continued to decline, among other things, as a result of an increase in the 
use  of  various  applications  for  making  calls,  as  well  as  due  to  the  service 
packages  offered  by  cellular  companies,  which  include  international  call 
minutes. In many organizations, the increase in the use of services that allow 

58 Based on publications from the Ministry of Communications regarding the number of minutes spent in the fourth quarter of 
2023. 

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calls and meetings to be carried out online continues, reducing the use of 
international telephony services. 

4.6.3. 

International data communication services 

In  the  field  of  international  data  communication  services,  the  various  communication 
providers compete, such as Partner, Cellcom, Hot, as well as underwater cable owners 
such as Tamares Telecom. Bezeq International, which owns the underwater cable, has a 
competitive  advantage  over  telecommunications  providers  that  do  not  own  an 
international infrastructure. In the absence of public data  on the market shares of the 
competitors  in  this  market,  it  is  not  possible  to  estimate  the  market  share  of  Bezeq 
International in this area. 

4.6.4. 

Cloud, hosting, and computing services for businesses 

4.6.4.1 

Hosting services 

The field of hosting services is characterized by many competitors, including 
Bynet, Edgeconnex, Med-1, and more. In 2023, there is demand for hosting 
services in server farms, among other things as a result of the trend in the 
business market to move to managed services (as a service) and services in 
cloud environments, as well  as  the purchase of solutions that will ensure 
recovery from a disaster. In the absence of public data on the market shares 
of  competitors  in  this  market,  Bezeq  International's  market  share  in  this 
area cannot be estimated. 

4.6.4.2 

Public cloud services 

In the field of cloud services, many companies compete in marketing and 
implementing the services of different cloud companies. In recent years, the 
demand  for  public  cloud  services  offered  by  cloud  companies  such  as 
increasing.  Bezeq 
Amazon,  Microsoft,  Google  and  Oracle  has  been 
International acts both as a marketer (sold directly to customers) and as a 
distributor  (sold  through  sub-marketers)  of  licensing  Microsoft's  cloud 
services to customers in Israel, and implementing these service solutions for 
customers.  Following  the  purchase  of  Cloudedge  Ltd.  by  Bezeq 
International,  Bezeq  International  acquired  additional  capabilities  in  this 
field, 
in  providing  professional  services  and 
implementing cloud solutions in large business customers, which gives it a 
competitive advantage in this field. In addition, in 2023 Bezeq International 
began operating as a partner of the AWS company, which allows it to offer 
its customers the cloud products of this company as well. In the absence of 
public  data  on  the  market  shares  of  competitors  in  this  market,  Bezeq 
International's market share in this area cannot be estimated. 

including  knowledge 

4.6.5. 

Cyber protection services 

The  field  of  cyber  protection  is  characterized  by  many  competitors  and  different  and 
varied  solutions.  The  demand  for  cyber  protection  services  is  on  the  rise  due  to  the 
increased risk of cyber threats. In the absence of public data on the market shares of the 
competitors  in  this  market,  it  is  impossible  to  estimate  the  market  share  of  Bezeq 
International in this field. 

4.6.6. 

Integration solutions 

The field of providing hardware and software solutions for businesses is characterized by 
multiple competitors and fierce competition. Bezeq International faces many competitors 
such  as  Bynet,  One-Taldor  Group,  Malam  Group,  Cellcom,  Partner,  Matrix,  and  more. 
Most  manufacturers  are  not  marketed  by  Bezeq  International  exclusively.  The  fierce 
competition in the field leads to price erosion. In the absence of public data on the market 
shares  of  competitors  in  this  market,  Bezeq  International's  market  share  in  this  area 
cannot be estimated. 

4.6.7. 

Unique characteristics 

4.6.7.1 

Positive factors affecting Bezeq International's competitive position: 

B.  A well-known and strong brand. 

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C.  Technological innovation. 

D.  Professional, experienced and skilled personnel. 

D.  Presence in many businesses. 

E.  Ownership of an underwater cable that enables Bezeq International to 
provide  high-quality  international  Internet  and  data  communication 
services. 

F.  Engaging  in  various  fields  that  enable  the  provision  of  a  service 
envelope  to  business  customers,  such  as  communication  services, 
hosting and cloud services, and the supply of equipment and licensing 
in the field of computing and communication. 

4.6.7.2 

Negative factors affecting Bezeq International's competitive position 

International  does  not  own 

The  fact  that  Bezeq 
interior  access 
infrastructures  is  a  competitive  disadvantage  in  the  market  of  internet 
services and data communication for businesses compared to competitors 
that control such infrastructures. 

4.7. 

PP&E, real estate and facilities 

Bezeq  International's  property,  plant  and  equipment  include  switching  and  Internet  equipment, 
underwater cable, central equipment and routers for rent, office equipment, computers, software 
licensing, and leased improvements. 

Bezeq International has SoftSwitch switches from the Dialogic company. These switches are used to 
route  Bezeq  International's  VOICE  movement.  Value-added  services,  including  calling  cards,  are 
based on a smart (IN) system. 

The  CRM  system  (customer  management)  is  based  on  Peoplesoft  software.  The  software  is  not 
supported by the manufacturer, but is maintained by Bezeq International.  In January 2024, Bezeq 
International signed an agreement with Oracle, according to which new CRM and ERP systems will 
be  installed  on  Oracle's  cloud  platform,  for  the  purpose  of  replacing  the  old  systems.  The 
construction of the new systems is expected to be completed in 2025. 

Bezeq International's technological infrastructures that support  the voice, data and the Internet is 
deployed on a number of sites, in Israel and abroad, among others, to ensure, when necessary, high 
survivability for the provision of services. 

Bezeq International has long-term lease agreements for the two main buildings where its offices are 
located.  Regarding  one  of  the  buildings,  the  lease  period  is  until  March  2029,  with  an  option  to 
extend the lease period by five years. The lease period in the other building is until December 2024 
(with an option for extension by another year). 

Bezeq International has a lease agreement for a building with a server farm. The lease period is until 
August 2026, followed by two additional options for extension until 2036. 

Bezeq International has additional lease agreements in connection with warehouses (including the 
logistics center). 

4.8. 

Human capital 

The  following  are  details  about  the  number  of  Bezeq  employees  International  in  years  2022  and 
2023: 

Administrative employees 
Service and sales representatives 
Total 

31.12.2023 

31.12.2022 

597 
105 
702 

676 
273 
949 

The number of employees included in the table includes employees employed part-time. Total jobs59 
Bezeq International as of December 31, 2023 was 679 compared to 927 as of December 31, 2022.  

Organizational structure 

59 Total monthly working hours divided by the monthly working hours quota.  

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The  following  is  a  diagram  of  Bezeq  International's  organizational  structure  as  of  the  date  of  the 
report:  

Board of 
Directors

CEO

Internal 
Audit*

Human 
Respurces

Finance

Solutions 
for 
Businesses

Global 
Businesses

Technologi
es  

Legal 
Advice and 
Regulation

Technical 
Service and 
Delivedy

)*(

The Internal Auditor is a Pelephone employee.

Regarding  streamlining  processes  and 
Pelephone and Yes, see Section 1.8. 

intra-organizational  changes  at  Bezeq  International, 

On  October  3,  2022,  Bezeq  International's  Board  of  Directors  approved  the  implementation  of 
agreements  reached  with  the  new  general  union  and  the  employee  representation  of  Bezeq 
International (as part of conducting negotiations to regulate employee rights) regarding a plan for 
the voluntary retirement of Bezeq International employees during the years 2022-2024 ("Voluntary 
Retirement  Plan").The  estimated  cost  of  the  Voluntary  Retirement  Plan  is  approximately  NIS  70 
million, assuming full implementation of the Voluntary Retirement Plan. The implementation of the 
Voluntary  Retirement  Plan  is  expected  to  allow  Bezeq  International  to  adjust  its  organizational 
structure, the scope of manpower and costs to the changes taking place in the market following the 
regulatory  change  in  the  field  of  Internet  services  (elimination  of  the  separation  between  an 
infrastructure  provider  and  an  ISP  that  allows  Bezeq  to  provide  a  unified  Internet  service)  which 
causes the reduction of ISP activity at Bezeq International , this is in accordance with the alternative 
outline  as  specified  in  Section  1.1.6.  Following  this,  starting  on  November  13,  2022,  Bezeq 
International approves voluntary retirement for Bezeq International employees to the extent of the 
estimated cost of the program (about NIS 70 million). 

On December 6, 2022, Bezeq International signed the renewal of the existing collective agreement 
between itself and the General Workers' Union and its workers' representation for the period from 
December 6, 2022 to December 31, 2025 ("the Agreement" and "Agreement period", respectively). 
According to the Agreement, salary increases and bonuses will be given, ancillary conditions will be 
improved, and the labor disputes announced by the General Workers' Histadrut and the employees’ 
representatives will be settled, while maintaining industrial peace during the validity period of the 
agreements on the issues regulated therein, with the exception of the labor dispute regarding the 
sale of control of the Company, for which the employees’ representation’s requirement remains to 
appoint a director on its behalf, which will be discussed between the parties. The total estimated 
additional cost of the agreement over the period of the Agreement, beyond the estimated voluntary 
retirement  cost  of  approximately  NIS  70  million  (as  mentioned  above),  is  approximately  NIS  28 
million. 

Bezeq International's estimates in relation to the estimate of the cost of the Agreement are forward-
looking information, as defined in the Securities Law, based, among other things, on its assumptions 
regarding the manner and scope of the retirement plan implementation and additional conditions 
stipulated in the Agreement. These estimates may not materialize, or may materialize in a different 
way  than  expected,  depending,  among  other  things,  on  the  manner  and  scope  of  the  actual 
implementation of the agreement and the retirement plan, taking into account the needs of Bezeq 
International and its ability to realize its plans and the fulfillment of additional conditions stipulated 
in the Agreement. 

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For this matter see also Note 16 to the 2023 statements. 

4.9. 

Suppliers 

4.9.1. 

Foreign operators 

Bezeq International has collaborations with about 200 foreign operators, as part of which 
Bezeq  International  forwards  and  receives  international  telephone  calls  from  these 
operators  (including  calls  leaving  Israel,  entering  Israel,  and  calls  between  various 
destinations outside Israel) to about 260 destinations worldwide.  

4.9.2. 

Capacity providers 

Most  of  the  interior  capacity  used  by  it  for  the  purpose  of  providing  its  services  is 
purchased by Bezeq International from Bezeq. 

Most of the international capacity that Bezeq International uses is transmitted through 
the  underwater  cable  it  owns.  As  a  backup,  Bezeq  International  uses  the  capacity 
purchased 
(formerly  Med  Nautilus)  and  Cyprus 
from  Telecom 
Telecommunications Authority (CYTA). 

Italia  Sparkel 

in  an 

indefinite  and  non-specific  attribution, 

As part of its engagement with Telecom Italia Sparkel, Bezeq International acquired the 
indefeasible  right  of  use, 
in  the 
communication capacity transmitted through the underwater cable system operated by 
Telecom  Italia  Sparkel  between  Israel  and  Europe,  and  continued  capacity  over  the 
Company's ground infrastructure to a number of communication nodes in Europe. Some 
of the use periods were extended until July 2030, and some until May 2032. For the said 
use  rights,  Bezeq  International  paid  one-time  payments,  close  to  the  date  of 
commencement of the use of the capacity. 

As part of its engagement with CYTA, Bezeq International has acquired indefeasible right-
of-use, in an undefined part and with a non-specific attribution, in the communication 
capacity transmitted through the underwater cable system operated by CYTA between 
Cyprus and Europe. The period of use was extended until May 2030. 

In addition, Bezeq International acquired indefeasible right-of-use of the non-residential 
parts  in  an  unspecified  part  and  no  specific  attribution  can  be  attributed  to  the 
communication  capacity  transmitted  through  terrestrial  infrastructure  in  Europe  from 
EXA  Infrastructure  (GTT  Communications  Inc.),  for  the  purpose  of  bridging  Bezeq 
International's submarine cable to communications nodes in Europe. The period of use of 
these infrastructures is at least until 2026, with the possibility of extending the period. 

4.9.3. 

Hosting service providers 

Bezeq International acquires hosting services in long-term agreements with a number of 
server  farm  facility  operators,  mainly  for  the  purpose  of  providing  hosting  services  to 
business customers: 

As part of an agreement signed in 2011, Bezeq International purchases Bezeq’s hosting 
services at Bezeq's server farm facility. These services are mostly used to provide hosting 
services  to  business  clients.  The  agreement  is  valid  until  2024  for  certain  parts  of  the 
facility, and for other parts until 2033. 

As part of an agreement signed in 2019 with Edgar Investments and Development Ltd., 
Bezeq  International  acquires  hosting  services  at  this  Bezeq  server  farm  facility.  The 
agreement is valid until 2041, with an option to terminate early in 2034. These services 
are used to provide hosting services to business customers. 

As part of an agreement signed in 2021 with ServerFarm Israel Infrastructure Fund Bnei 
Zion Limited Partnership, Bezeq International purchases hosting services at a server farm 
owned  by this partnership starting from 2023. The agreement  is valid until 2039, with 
options for extension until 2047. These services are used to provide hosting services. For 
business customers. 

4.9.4. 

Microsoft 

Bezeq International has an agreement with Microsoft by virtue of which it is entitled to 
sell  Microsoft's  cloud  products  both  to  end  customers  and  to  indirect  resellers.  The 

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agreement  is  automatically  extended,  and  each  party  may  terminate  it.  Bezeq 
International's  activity  in  the  field  of  the  public  cloud  relies  exclusively  on  Microsoft 
products, therefore the termination of the agreement with Microsoft may significantly 
harm this activity and even lead to its termination. 

4.9.5. 

Main supplier 

Bezeq is a main supplier of Bezeq International and provides it with services as detailed 
in this section above. The rate of purchases of Bezeq International from Bezeq in 2023 
was about 20%. 

4.10.  Taxation 

See Note 7 to the 2023 statements. 

4.11.  Restrictions and supervision of Bezeq International's activities 

4.11.1. 

Restrictions by virtue of laws 

According to the Communications Law, performing Bezeq operations and providing Bezeq 
services,  including  international  Bezeq  services  and  Internet  access  services,  require  a 
license  from  the  Minister  of  Communications.  The  Minister  is  authorized  to  change 
license  terms,  add  to  them  or  derogate  from  them,  while  considering,  among  other 
things,  government  policy  in  the  field  of  Bezeq,  considerations  in  the  public  interest, 
adjusting the licensee to provide services, the license contribution to competition in the 
field of Bezeq and its level of service. 

The law authorizes the Director General of the Ministry of Communications to impose 
financial sanctions due to various violations of the provisions of the law and of orders and 
provisions issued under it, as well as due to violation of conditions in the license. 

4.11.2. 

Licenses 

Bezeq International has a unified general license for the provision of Bezeq services (the 
"Unified License"), which is valid until February 4, 2036. 

The following are the main instructions from the unified license: 

a. 

In certain circumstances, the Minister may change the terms of the license, add to 
them or detract from them, and in some cases even revoke it. 

b.  The license is not transferable and includes restrictions on the purchase or transfer 
(including  by  way  of  lien)  directly  or  indirectly  of  control  of  10%  or  more  of  any 
means of control in Bezeq International, including the lien of such means of control, 
unless prior consent of the Minister.  

c.  Bezeq International must provide an interconnectivity service on equal terms to any 
other operator and must avoid any discrimination in performing interconnectivity.  

d.  Bezeq  International  must  refrain  from  preferring  the  provision  of  infrastructure 
services to a licensee who is an affiliated company (as defined in the license) over 
another licensee.  

e.  Bezeq International may not sell, rent, or mortgage property from the properties 
license  without  the  consent  of  the  Minister  of 

used  to  carry  out  the 
Communications, except for certain exceptions set forth in the license. 

f. 

In times of emergency, a person authorized to do so by law has the authority to give 
Bezeq International various instructions regarding the manner in which it operates 
and / or the manner in which the services are provided. 

g.  The license specifies the types of payments that Bezeq International may charge its 
subscribers for Bezeq services, and the reports it must provide to the Ministry of 
Communications.  The  license  also  stipulates  the  authority  of  the  Minister  to 
intervene in rates, in some cases. 

h.  The license requires Bezeq International to have a minimum level of service. 

In  accordance  with  the  requirement  of  the  Ministry  of  Communications,  Bezeq 
International provided a bank guarantee, in the amount of NIS 2 million, to fulfill 
the conditions of the unified license. 

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4.11.3. 

Real estate authority - On July 9, 2014, the Minister of Communications granted Bezeq 
International  the  powers  related  to  real  estate,  which  are  listed  in  Chapter  F  of  the 
Communications Law, including entering the land for the purpose of laying a network and 
maintaining it (see Section 2.16.6).  

4.11.4. 

Payments for interconnectivity 

In  the  matter  of  interconnectivity  fees  paid  to  the  NIO  and  the  cellular  operator,  see 
Section 1.7.7.1.  

4.11.5.  Major regulatory developments 

4.11.5.1 

4.11.5.2 

4.11.5.3 

For possible changes in the communications market that also affect Bezeq 
International  following  the  Competition  Expansion  Policy  document,  see 
Section .אצמנ אל הינפהה רוקמ !האיגש. 

For decisions made in connection with the "wholesale market" which also 
have implications for the field of activity, see Section 2.16.4.  

Regarding  the  decision  of  the  Ministry  of  Communications  at  the  hearing 
dated  June  20,  2021  on  the  cancellation  of  the  separation  between  the 
broadband infrastructure service and the Internet access service (ISP), see 
Section 1.7.3.3. The changes in the telecommunications market, caused as 
a result of this decision, resulted in a substantial damage to its subscriber 
base, and to the revenues of Bezeq International in the Internet segment. 
The damage is expected to continue and deepen in 2024. 

4.12. 

Legal proceedings60  

During the day-to-day business, lawsuits were filed against Bezeq International, including  motions 
for approval of class actions.  

4.12.1. 

Pending and current legal proceedings  

Date 

Sides 

Court 

District 
(Central) 

Type of 
procedure 

Monetary 
claim 
together with 
a motion to 
recognize it as 
a class action 

Details 

 It is alleged, among other things, that Bezeq International 
sells its customers Internet browsing speeds, even though 
the infrastructure at their place of residence does not allow 
them to reach this speed. In January 2021, the Court upheld 
the claim as a class action. 

Claim 
amount 
(NIS 
millions) 
Unspecifie
d 

District 
(Central) 

Monetary 
claim 
together with 
a motion to 
recognize it as 
a class action 

It  is  alleged  that  Bezeq  International  does  not  inform  its 
customers as required about the possible dangers of using 
the  Internet  and  about  the  possibility  of  joining  a  free 
content filtering service, in violation of the provisions of the 
Communications  Law.  In  addition,  Bezeq  International 
provides  a  website  filtering  service  and  offensive  content 
that the applicants claim is not sufficiently effective. 

Unspecifie
d 

District 
(Central) 

Monetary 
claim 
together with 
a motion to 
recognize it as 
a class action 

It is alleged, among other things, that Bezeq International 
charges its customers payments for services that it does not 
provide to them, ostensibly knowing that the customer has 
replaced  the  Internet  provider  and  disconnected  from 
International.  On  November  5,  2020,  Bezeq 
Bezeq 
International  received  another  motion  for  approval  of  a 
class action in the same matter. 

Unspecifie
d  

60   For reporting policy and materiality thresholds, see Section 2.18.  

131

a. 

 March 
2016 

b. 

 April 2019 

c. 

 October 
2020 

Client 
against 
Bezeq 
Internatio
nal and 
other 
communic
ations 
companie
s 

Client 
against 
Bezeq 
Internatio
nal and 
other 
communic
ations 
companie
s 
Client 
against 
Bezeq 
Internatio
nal 

 
 
 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

e.  November 
2020 

District 
(Central) 

Client 
against 
Bezeq 
Internatio
nal 

Monetary 
claim 
together with 
a motion to 
recognize it as 
a class action 

It is alleged, among other things, that Bezeq International 
charges  fees  for  the  provision  of  'antivirus  service'  and 
'backup  service'  without  actually  being  provided,  when 
according  to  the  claim  it  does  not  disclose  to  customers 
when concluding the contract that they must initiate special 
operations including installation of special software at the 
time of the conclusion of the contract and not at the time 
of the actual provision of the service.  

Unspecifie
d 

4.12.2. 

Legal proceedings completed during the reporting period 

None. 

4.13.  Targets, business strategy and development prospects 

In  light  of  the  cancellation  of  the  separation  between  infrastructure  provider  and  Internet  access 
provider (ISP), Bezeq International intends to cease ISP activity in the private segment in a graded 
manner,  and  focus  on  developing  integration  activities  and  services  for  the  business  segment,  in 
order  to  become  a  growth-focused  ICT  company.  This  is  expected  to  allow  managerial  focus  and 
dedication of resources to integration activity, cloud services, and cyber protection services and cloud 
services,  which  is  growing  due  to  the  trend  of  the  business  segment  moving  to  a  model  of  cloud 
services. Bezeq International will continue to acquire capabilities and knowledge, both through the 
training  of  personnel  and  through  the  acquisition  of  companies  in  complementary  fields.  Bezeq 
International will maintain collaborations with partners in Israel and abroad in order to provide a full 
service envelope to its customers. Bezeq International will offer its services to all business segments, 
including small, medium and large businesses, the public and government segments and more. Bezeq 
International anticipates that the main growth engines will be in the areas of hosting services, cloud 
services and information security services. For further details see Sections 1.1.5 and 1.8. On this side, 
Bezeq International will work towards streamlining and cost savings, with an emphasis on reducing 
manpower,  by  separating  from  labor-intensive  areas  of  activity  and  moving  to  efficient  operating 
methods. These processes depend in part on the cooperation of employee representatives. 

The  above  is  forward-looking  information  as  defined  in  the  Securities  Law,  based  on  Bezeq 
International's  estimates  and  assumptions.  Bezeq  International  cannot  assess  whether  the  above 
objectives may materialize or partially materialize and when. In addition, the targets may be affected 
by changes and developments in the relevant markets, due to regulatory changes that may impair 
Bezeq International's ability to meet existing or changing market requirements, as well as due to all 
other risk factors listed below. 

4.14.  Discussion of risk factors 

The following is a description of the risk factors arising from the macroeconomic environment, the 
unique characteristics of the industry in which Bezeq International operates, and risk factors unique 
to Bezeq International:  

4.14.1. 

Competition  

For  the  effect  of  competition  on  Bezeq  International's  business,  see  Section  4.6  and 
Section 4.13. 

4.14.2. 

Frequent technological changes and investments in infrastructure  

Bezeq  International's  areas  of  activity  are  characterized  by  frequent  technological 
changes. The development of technologies that constitute attractive alternatives to some 
of  Bezeq  International's  products  (such  as  Teams,  WhatsApp  or  Zoom)  may  materially 
impair  Bezeq  International's  operations.  Also,  technological  developments  require 
frequent investments in infrastructure. See Sections 4.1.5.2 and 4.1.6. 

4.14.3. 

Exposure to changes in exchange rates 

Bezeq International is exposed to risks due to changes in exchange rates, especially in the 
field of equipment sales and integration, as well as in international data services, since 
most purchases of equipment and services in these areas are made in US dollars, while 
Bezeq International's revenue is shekels. Erosion of the shekel against the dollar could 
harm Bezeq International's profitability if it is not possible to adjust selling prices in the 
short term.. 

4.14.4. 

Governmental supervision and regulation  

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Regarding the applicability of the provisions of the law and the licensing policy and their 
effect on Bezeq International, see Section 4.11. Certain changes in the regulations applied 
to Bezeq International may have an adverse effect on its results and operations. 

4.14.5. 

Epidemic 

Disease outbreaks and epidemic events in general (such as the outbreak of COVID-19 in 
2020) may have consequences for Bezeq International's business activities depending on 
the scope and severity of the spread as well as the national and global measures that will 
be  taken  as  a  result.  These  consequences  may  be  manifested,  among  other  things,  in 
damage to Bezeq International's operations and its customer service system, as well as in 
damage to the supply chain. Events of this type are changing events that are not under 
the  control  of  Bezeq  International,  and  their  consequences  are  subject,  among  other 
things, to the decisions of countries and authorities in Israel and around the world that 
may affect Bezeq International accordingly. 

4.14.6. 

Serious malfunctions in information systems and engineering systems 

Bezeq  International  provides  its  services  through  various  infrastructure  systems, 
including, among others, switches, data transmission and access transmission networks, 
cables,  computer  systems,  physical  infrastructure  and  more  (“the  Systems").  Bezeq 
International's  business  has  a  high  dependence  on  these  Systems.  Some  Bezeq 
International Systems have backup, but at the same time, in the event of damage to some 
or all of the above Systems, either due to a large-scale technical malfunction, due to a 
natural  disaster  (such  as  an  earthquake,  fire,  etc.),  or  due  to  physical  damage  to 
infrastructure and due to malicious damage (such as the introduction of viruses and cyber 
attacks  as  detailed  below),  significant  difficulties  may  be  caused  in  the  provision  of 
services, including in the event that Bezeq International is unable to quickly return the 
Systems  to  normal.  Regarding  information  systems,  it  should  be  noted  that  the 
information  systems  currently  used  by  Bezeq  International  are  outdated  and  not 
supported by the manufacturer (see Section 4.7),  which poses a  risk  of faults in these 
systems. 

4.14.7. 

Information security, protection of customer data and cyber risks 

Bezeq International is the target of cyber-attacks, the purpose of which is to harm the use 
of  the  information  systems  or  the  information  itself.  This  type  of  assault  activity  or 
intrusion incident can cause business disruption, information / money theft, damage to 
reputation,  damage  to  systems  and  information  leakage.  Another  risk  is  posed  by  the 
leakage of information from within the organization by Bezeq International employees, 
inadvertently or maliciously. 

Bezeq  International's  cyber  protection  management  strategy  is  built  on  three  pillars: 
information  confidentiality,  information  integrity  and  information  availability.  Bezeq 
International  employs  many  measures,  both  technological  and  organizational,  to  deal 
with the aforementioned risks. 

Bezeq International allocates many resources to deal with cyber risks. Bezeq International 
has an information security department that deals with information security and cyber 
risk  management.  Bezeq  International  devotes  significant  budgets  to  the  purchase  of 
systems and technological means to protect information. Detailed procedures have been 
established that refer both to the routine handling of information and to the methods of 
operation  and  the  management  of  information  security  incidents.  Bezeq  International 
employees  undergo  periodic 
information  security  training.  Every  month  Bezeq 
International  employees  are  sent  messages,  instructions  and  updates  aimed  at  raising 
awareness of cyber risks and proper handling of information. 

Bezeq International supervises the implementation of its defense policy, which includes 
testing its level of effectiveness and readiness. In this framework, it performs risk surveys, 
penetration  tests  and  periodic  controls,  both  by  the  internal  audit  and  by  external 
auditors hired by Bezeq International for this purpose. In addition, Bezeq International 
periodically performs tests and attack exercises for various scenarios (including through 
external  companies  specializing  in  the  field).  In  Bezeq  International's  estimation,  the 
information security protection policy is effective. 

Bezeq International is a body guided by the Information Security Authority. Also, Bezeq 
International is obliged to implement information security requirements stipulated in the 

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unified  general  license  granted  to  it  by  the  Ministry  of  Communications.  In  addition, 
Bezeq International is ISO27001 certified, which deals with information security. 

The information security protection policy, protective measures, security incidents and 
lessons learned are discussed by Bezeq International’s Management on a monthly basis, 
and brought to the Bezeq International Board of Directors for review and approval. The 
person  responsible  for  the  implementation  of  the  policy  at  Bezeq  International  is  the 
director of the Information Security Department in the Technology Division. 

Despite  Bezeq  International's  investments  in  measures  to  reduce  such  risks,  it  cannot 
guarantee that these measures will succeed in preventing damage and / or disruption to 
the systems and information related to them. 

4.14.8. 

Damage caused by nature, war, disaster 

Damage to the server farms on which Bezeq International concentrates its core activity, 
or damage to the submarine cable, may adversely affect Bezeq International's business 
and its results. 

4.14.8.1  Damage  to  electricity  supply  -  Damage  to  the  electricity  supply  to  Bezeq  International 
facilities for various reasons (some of which are described in Section Error! The source of 
the  reference  was  not  found.)  may  have  a  negative  effect  on  Bezeq  International’s 
business  and  damage  Pelephone's  ability  to  provide  services.  Some  of  Bezeq 
International’s  systems  have  power  backup,  but  at  the  same  time,  in  the  event  of 
prolonged damage to some or all of the systems, there may be significant difficulties and 
beyond that in the provision of Bezeq International services, including in the event that 
Bezeq International cannot return the systems to service quickly. 

4.14.9. 

Legal Proceedings 

4.14.10.  Bezeq  International  is  a  party  to  legal  proceedings,  including  class  actions,  which  may 
result in charges in substantial amounts, which cannot be estimated, and no provision 
was  made  for  some  of  them  in  Bezeq  International's  financial  statements.  These  class 
actions  can  reach  large  sums,  since  a  substantial  part  of  Israel’s  residents  are  Bezeq 
International’s  customers,  and  a  claim  relating  to  a  small  damage  to  an  individual 
consumer may become a  material claim for Bezeq International if it  is recognized  as a 
class  action  lawsuit  against  all  consumers  or  a  substantial  part  thereof.  In  addition,  in 
certain  contracts,  mainly  in  the  government  and  public  sector  contracts,  Bezeq 
International sometimes enters into contracts for the provision of services subject to a 
partial liability limit, or no liability limit at all. Given the sensitivity of the services provided 
by Bezeq International to these customers, in the event that the customer is harmed in 
such a contract, this may lead to legal proceedings in large amounts. For legal proceedings 
to which Bezeq International is a party, see Section4.12.  

4.14.11. 

Labor relations and streamlining procedures 

Bezeq International has a  collective agreement  with the Histadrut  and the  Employees’ 
Committee  in  respect  of  most  of  its  employees.  The  implementation  of  the  collective 
agreement  may  affect  Bezeq  International's  day-to-day  operations.  In  addition,  the 
implementation of  manpower  plans may cause unrest  in labor relations and harm the 
day-to-day  operations  of  Bezeq  International.  As  described  in  Section1.7.11,  Bezeq 
International implements streamlining plans that involve, among other things, the sharing 
of management resources, organizational changes and the reduction of the workforce, in 
parallel  with  the  management  of  significant 
infrastructure  and  other  projects. 
Streamlining procedures, by their nature, involve the risks of loss of knowledge, turnover 
of employees, shifting of managerial focus, etc. Bezeq International has a number of open 
labor disputes. Regarding labor disputes at Bezeq International, see Section 4.8. 

4.14.12. 

Loss of knowledge and information 

The changes that are taking place in the labor market in Israel and around the world, along 
with organizational changes, entail a risk of losing key employees, loss of knowledge as a 
result of employee turnover, difficulty in recruiting employees, etc. 

4.14.13. 

Impairment of Bezeq International's assets 

Bezeq  International  conducts  a  periodic  impairment  test  of  assets  in  respect  of  which 
identification signs of impairment have been identified in accordance with the accounting 

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standards. For details regarding the risk factor relating to the recording of impairment 
losses, see Section 2.20.12. Changes in regulations in the Internet services market (see 
Section 1.7.2.3) may lead to damage to Bezeq International's results and / or a decrease 
in the value of its assets. Regarding the effect of the treatment of Bezeq International 
customers who do not use ISP services on the value of Bezeq International's assets, see 
Section 4.4. 

4.14.14. 

Impairment of Bezeq International's assets 

Bezeq International conducts, in accordance with the accounting standards, a  periodic 
examination  of  the  impairment  of  assets  in  respect  of  which  indicators  of  impairment 
have  been  identified.  For  details  regarding  the  risk  factor regarding  the  recognition  of 
impairment losses, see Section 2.20.12. Changes in the regulation of the Internet services 
market (see section 1.7.2.4) may lead to damage to Bezeq International's results and / or 
a  decrease  in  the  value  of  its  assets.  Regarding  the  effect  of  the  treatment  of  Bezeq 
International customers who do not use ISP services on the value of Bezeq International's 
assets, see Section 4.4. 

4.14.15.  Cash flow 

Bezeq  International  must  maintain  sufficient  cash  flow  for  it  to  meet  its  long-term 
business plan. Cash flow may be affected in cases of planning gaps, change in the business 
model  and  difficulties  in  collecting  payments  from  customers  or  telecommunications 
operators.  The  lack  of  sufficient  cash  flow  may  adversely  affect  Bezeq  International's 
business, and may make it difficult for it to deal with competitive threats in the field. 

The  following  is  a  rating  of  the  impact  of  the  risk  factors  described  above  on  Bezeq 
International's  operations,  in  accordance  with  the  assessment  of  Bezeq  International's 
Management. It should be noted that Bezeq International's assessments below regarding 
the degree of influence of the risk factor reflect the degree of influence of the risk factor 
in assuming the materialization of the risk factor, and the aforesaid does not express an 
assessment or give weight to such chances of materialization. The order in which the risk 
factors appear above and below is not necessarily according to the degree of risk61: 

Risk factors summary table - international communications, Internet and network 
endpoint services 

The extent of the impact of the risk 
factor on Bezeq International's 
operations 
Medium 
effect 

Low 
effect 

High 
effect 

Macro risks 
Exposure to changes in exchange rates 
Epidemic 

Damage caused by nature, war, disaster 
Damage to electricity supply 
Industry risks 
Growing competition 
Investments in infrastructure and technological changes 
Governmental supervision and regulation 
Serious malfunctions in information systems and 
engineering systems 
Information security, customer data protection and cyber 
risks 
Special risks for Bezeq International 
Legal proceedings 
Labor relations and streamlining procedures 
Loss of knowledge and information 

X 
X 

X 

X 
X 

X 

X 
X 

X 
X62 

X 

X 

61 See Footnote 46.  

62  The extent of the impact of this risk factor on  Bezeq International's activities was classified as medium, assuming that the 
incident would be limited in scope and time. Otherwise, the degree of impact may be large. 

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Impairment of Bezeq International's assets 
Cash flow 

X 
X 

The information contained in this section 4.14 and Bezeq International's assessments regarding the impact 
of risk factors on Bezeq International's activities and business, are forward-looking information as defined in 
the  Securities  Law.  The  information  and  assessments  are  based  on  data  published  by  the  Ministry  of 
Communications, Bezeq International's assessments of the market situation and the structure of competition 
in it and regarding possible developments in the Israeli market and economy. The actual results may differ 
materially from the estimates given above if there is a change in one of the factors taken into account in 
these estimates. 

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5. 

Yes - multi-channel TV 

Yes is a subsidiary wholly owned by Bezeq, which provides a service of multi-channel television broadcasts via 
satellite and on the Internet (OTT), as well as Internet access services. 

5.1. 

General information about the field of activity 

5.1.1. 

The structure of the field of activity and the changes that took place in it 

5.1.1.1 

In the field of subscriber television broadcasts, there are a number of factors 
in a number of main categories: 

a.  Holders of a broadcasting license pursuant to the Communications Law, 
which provide multi-channel television services - (both linear channel 
broadcasting and  on-demand  viewing services63) Yes as well as Hot64 
("the  field  of  satellite  and  cable  broadcasting").  This,  alongside  the 
provision of multi-channel television services via the Internet (see sub-
paragraph  B).  For  details  about  the  regulation  applicable  to  the 
ownership of broadcasting licenses as such, see Section 5.14. 

b. 

Internet  content  providers  (in  format  OTT)  -  in  Israel,  there  are  a 
number of local and international providers of audio-visual content via 
the Internet, which can be viewed using various types of end devices 
(including mobile devices). The main local providers operate in a format 
that includes linear channels and on-demand content). The main ones 
are  Yes  (through  Yes+  and  STING  services,  for  details,  see  Sections 
5.2.2.1,  5.2.2.2    and  5.2.2.1),  Cellcom,  Partner,  Hot,  and  freeTV 
(regarding  the  commencement  of  operations  of  freeTV,  see  Section 
5.5.1). The main international providers operating in Israel are Disney, 
Netflix, Apple, and Amazon, which provide options for watching VOD 
content without linear channels. To the best of Yes’s knowledge, most 
subscribers  of  international  providers  in  Israel  also  subscribe  to  the 
services of some of the local providers. Most of the content providers 
via the Internet market services at a lower scope and price level than 
those used in the field of satellite and cable broadcasting. 

There  are  collaborations  between  some  of  the  local  licensees  and 
suppliers  and  some  of  the  international  suppliers.  Yes  has  several 
collaborations  as  mentioned  which 
include,  among  others, 
collaborations  with  Disney+  and  Netflix,  which  include,  among  other 
things,  distribution  of  their  services  for  a  fee.  For  details  about  the 
contract with Disney+, see the Company's immediate report dated May 
22, 2022 included in this report by way of reference. 

In accordance with the Broadcasting Distribution Law, a broadcasting 
body, whose broadcasts are part of the "open broadcasts" (namely, TV 
channels  distributed  through  the  Idan+  system),  will  give  each 
"registered  content  provider"65  consent  to  broadcast 
linear 
broadcasts  on  the  Internet  free  of  charge,  in  accordance  with  and 
subject to the provisions of the law66. As of the date of this report, Yes 

its 

63 For the question of the regulation of Yes's VOD services, see Section 5.14.2. 

64 Which provides cable television services, which is the owner of a declared monopoly according to the Economic Competition Law 

in the field of multi-channel television broadcasting. 

65 "Registered content provider" is defined in the Broadcasting Distribution Law as a content provider registered in the registry; 
"Content provider" is defined in the Broadcasting Distribution Law as one whose main activity is the transmission of a variety 
of content to the public in Israel, provided that the content is broadcast on its own initiative, through an interface under its 
control, and both that the content can be viewed in real time, simultaneously by the public, and that the content can be viewed 
at a time and place of the viewer’s choice. DBS is a registered content provider. 

66  In February 2023, a provisional order that applied to the commercial channels ended, which applied special arrangements in relation 
to them, including granting a license for their broadcasts on the Internet to any registered content provider that requests it, at the 
best price and conditions given by the relevant commercial channel to another content provider according to a license that was in 
effect at the time the license was granted. All is as detailed in the provisional order. 

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has  agreements  with  the  aforementioned  broadcasters,  which  also 
include on-demand viewing services. 

c.  The DTT array 

A  digital  distribution  system  for  digital  television  (DTT),  known  as 
"Idan+", through which certain channels are distributed to the public, 
67. The system is operated as of the date of the report by 

free of charge
the Second Authority. 

The distribution of the channels is done in exchange for the payment of 
a  distribution  fee,  where  the  Minister  of  Communications  and  the 
Minister  of  Finance  may  determine  that  the  State  will  subsidize  the 
distribution fee that will apply to thematic channel broadcasters and a 
dedicated channel. 

As of the date of this report, the DTT constitutes a replacement product, 
in part, for multi-channel TV broadcasts. 

d.  Parties that offer content without the permission of the rights holders 

(piracy)68 

The multi-channel TV providers, including Yes, offer their services alongside 
other  communication  services  provided  by  them,  including  as  part  of 
baskets that are “non-detachable" (such as a "bundle" package that includes 
Internet  and  television  services).  For  additional  communication  services 
provided  by  communication  groups,  see  Section  1.7.2.  For  the  offer  of 
baskets of communication services by Yes and the restrictions thereon, see 
Section 1.7.3.3. 

5.1.1.2 

In the year of the report, the fierce competition continued to prevail, mainly due to the 
entry  of  freeTV  and  the  activity  of  local  and  international  content  providers  via  the 
Internet,  as  mentioned,  operating  at  a  relatively  low  price  level.  The  activity  via  the 
Internet is carried out without the need to establish a dedicated infrastructure system as 
of the date of this report, even without regulatory supervision. For more details about 
the competition in the field and changes that took place in it in the year of the report, 
including  the  manner  in  which  Yes  operates  -  see  Section  5.5.  For  the  question  of 
arranging broadcasts with new broadcast technologies, see Section 5.14.2. 

For changes in the number of Yes subscribers, see Section 5.5.1. 

5.1.2. 

Restrictions, legislation and special constraints in the field of activity 

Activities of broadcasting license holders are subject to extensive legislation in the field 
of communications, and in particular to the Communications Law, the licensing regime, 
as well as supervision and policy decisions on behalf of the Ministry of Communications. 
The said activity is also under the constant supervision of the council, which sets policy, 
establishes rules and supervises many areas of activity, including broadcast content, local 
production  obligations,  broadcast  ethics,  consumer  protection  and  the  approval  of 
broadcast channels. 

The provision of television services other than via satellite or cable within the meaning of 
the Communications Law is not subject to supervision as stated above. 

In  July  2023,  the  Ministry  of  Communications  published  a  memorandum  of  the 
Communications (Broadcasting) Law, 2023-2023, which includes the text of a bill ("the 

67 As of the date of this report, the television channels of the Broadcasting Corporation (Kan 11, Kan Educational and Channel 
33), the commercial television channels ("Keshet" and "Reshet"), Channel 14, and the Knesset channel (Channel 99) and a number 
of radio stations. The DTT operator must also distribute thematic channels (most of whose broadcasting hours are devoted to 
the subject of the Broadcasting through Digital Broadcasting Stations Law, 5772-2012 (“the Broadcasting Law"), as well as the 
broadcasts of a minor licensee and a designated minor licensee (as defined by the Second Authority Law)  - if requested. The 
Minister of Communications and the Minister of Finance may appoint a private operator for its operation, for whom the Council 
may also grant a general license for broadcasts financed by subscription fees or commercials. 

68 Yes is one of the shareholders of Zira Ltd., which works to prevent copyright infringement in video content on the Internet. 

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Memorandum" and "the Bill", respectively69). According to what is stated in the Bill and 
the explanatory notes to the Bill, the Bill was based on the recommendations of various 
committees over the years (the most recent of which was the Folkman Committee) and 
to update the set of duties and rights applicable to all players operating in the visual and 
audio content market in a number of ways, including the following: 

A.  A new authority will be established in place of the Cable and Satellite Broadcasting 
Council and the Council of the Second Authority for Television and Radio, whose role 
will be to regulate the entire field of viewing and audio content provision in a way 
that  will  be  indifferent  to  the  manner  and  technology  in  which  the  content  is 
distributed, it Will be responsable for the competition in the field of cisual and audio 
content provision, and it will be authorized to issue provisions that prevent actions 
that may harm competition in the field. 

B.  A limited and focused set of duties will be applied to the significant players operating 
in this market, including registration duties (and for this purpose it was proposed to 
establish three different registries - for content providers, Israeli channels, and news 
providers), investment in local productions (see subsection 6 below), distribution of 
content  from  the  Israeli  Broadcasting  Corporation  and  the  Knesset  Channel, 
obligations  in  the  fields  of  sports  and  consumerism,  where  the  extent  of  the 
obligations will change according to the revenue level of the content provider. 

C.  The existing restrictions on the economic models in the content market for visual and 
audio  content  will  be  removed  (while  allowing  some  of  the  provisions  regarding 
cross-costs).  As  far  as  the  holders  of  broadcasting  licenses  (including  Yes)  are 
concerned  -  the  prohibitions  applicable  to  them  regarding  the  broadcasting  of 
advertisements  and  the  production  of  news  content  will  be  lifted.  In  addition,  a 
transitional provision was established according to which TV broadcasting licensees 
as defined in the Second Authority Law, to whom the transfer arrangements set forth 
in  the  Communications  Law  and  the  Broadcasting  Distribution  Law  apply,  will  be 
required  to  allow  the  continued  transfer  of  the  channels  to  registered  licensed 
providers  in  accordance  with  what  is  stated  in  the  said  laws  and  the  mandated 
changes, and this for the period stipulated in the Memorandum. 

D. 

Individual arrangements will be established regarding the provision of news content 
to the public. 

E.  Arrangements  will  be  established  regarding  the  supply  of  sports  content  to  the 
public, so that the supply of significant sports enterprises through a single content 
provider  will  be  avoided,  and  sports  enterprises  of  high  demand  or  of  special 
importance will be accessible to the public. 

Yes submitted its response to the Memorandum. As of the date of this report, to the best 
of Yes's knowledge, no legislative procedures have been promoted in connection with the 
Memorandum. Since this is a legislative memorandum, at this stage it is not known which 
of the provisions of the Memorandum, if any, will be enshrined as binding legislation, and 
what the content and regulations of such legislation will be, and therefore, it is difficult 
at this stage to assess the extent of the impact of the legislation and regulations that will 
be established following the Memorandum on Yes's business (if any). 

5.1.3. 

Changes in the scope of activity in the field and its profitability 

For data on changes in the scope of Yes’s activity and profitability, see Section   !האיגש

.אצמנ אל הינפהה רוקמ. 

5.1.4. 

The critical success factors in the field of activity and the changes that apply to them 

5.1.4.1 

Quality, differentiation and originality in the content of the broadcasts, in 
their variety, branding and packaging. 

69  The  Memorandum  was  published  following  the  report  of  the  recommendations  of  the  committee  for  the  examination  of  the 
overarching regulation in the field of broadcasting, headed by former MK Roi Folkman ("Folkman Committee"), and the decision 
of the Minister of Communications dated September 2021 regarding the adoption in principle of the Committee's recommendations 
subject to changes and adjustments and the hearing published on the subject regarding the Draft Law of Principles of Regulation 
of the Provision of Audio-Visual Content to the Public, 5782-2022 ("the Hearing"). 

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5.1.4.2 

5.1.4.3 

5.1.4.4 

5.1.4.5 

5.1.4.6 

5.1.4.7 

5.1.4.8 

Providing relevant value propositions to various target audiences. 

Providing  advanced  on-demand  services  using  advanced  technologies  (in 
relation to broadcast technologies, in relation to end devices and in relation 
to the user interface). 

Providing TV services via the Internet. 

Offering  a  "basket"  of  communication  services  that  includes  television 
services and other services, such as Internet browsing services (see Section 
5.14.2). 

Collaborations with international content providers and providing access to 
applications operated thereby. 

High level of customer service tailored to the type of service. 

The strength of the brand and its identification with quality, innovation and 
leadership, content and services for subscribers. 

5.1.4.9 

Attractiveness of the price. 

5.1.5. 

The main barriers to entry and exit in relation to the field of activity 

5.1.5.1 

5.1.5.2 

The  main  barriers  to  entry  into  the  field  of  activity  are  (a)  for  cable  and 
satellite  broadcasts  -  the  need  to  obtain  licenses  for  cable  and  satellite 
broadcasts  and  to  comply  with  the  relevant  regulatory  requirements;  (B) 
investments required from operators in the field, including the purchase and 
production  of  content,  as  well  as  for  cable  and  satellite  broadcasts  -  the 
establishment  of  a  dedicated  infrastructure;  (C)  The  limited  scope  of  the 
Israeli market and its characteristics. The scope and level of barriers to entry 
into  Internet  TV  services  are  very  low,  especially  for  the  international 
providers for which Israel is another market for existing activity, and this is 
reflected in an increase in the quantity and variety of services offered in this 
format. 

The  main  exit  barriers  are:  (a)  For  broadcast  license  holders  there  is  a 
regulatory  barrier  -  termination  of  activity  under  the  broadcast  license 
entails  the  Minister  of  Communications'  decision  to  cancel  the  license 
before  the  end  of  the  license  period,  including  conditions  (including  the 
licensee)  to  ensure  broadcast  continuity  and  services  and  to  reduce  the 
harm to subscribers; (B) Long-term engagements with material suppliers. 

5.1.6. 

Substitutes for products in the field of activity and changes that apply to them 

Yes  sees  the  possibility  of  receiving  many  foreign  channels  using  relatively  cheap  end 
equipment as a substitute for its services in relation to certain segments. 

5.1.7. 

The structure of competition in the field of activity and changes that apply to it 

Competition  in  the  field  of  television  is  characterized  by  a  relatively  large  number  of 
players, most of whom operate at relatively low price levels (see section 5.1), and through 
advanced web client interfaces in a way that has led to the intensification of competition 
in the field. An increase in the number of subscribers in the current competitive situation 
can be achieved mainly through the recruitment of subscribers from competitors, which 
requires the investment of considerable resources in retaining existing subscribers and 
recruiting new subscribers. 

Yes  does  not  have  data  on  the  number  of  subscribers  of  the  international  companies 
operating in the field and on the number of viewers of the DTT system, and according to 
Yes, most of them are, in addition, subscribers of the local television providers operating 
in the field. According to Yes, the trend of increasing the total market share of all players 
(out  of  all  households  in  Israel)  is  weakened  due  to  the  fact  that  the  majority  of  the 
remaining households are not potential audiences. 

For more details on the competition in the field see Section 5.5. 

5.2. 

Products and services 

Yes’s services through satellite include lienar channel broadcasts, in a variety of value propositions 
that differ from each other in the scope of the content, the scope of the services included in them, 

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the interface through which they are offered and the price. The offer of OTT services is part of a 
gradual  trend  of  migration  of  Yes’s  services  from  satellite  TV  services  to  OTT  services.  For  the 
migration process see Section5.17.3. 

In  recent  years,  there  has  been  a  trend  of  increasing  demand  for  'discount'  services,  which  are 
characterized  by  a  range  of  services  and  a  lower  price  level  than  those  customary  in  the  field  of 
satellite and cable broadcasting. Accordingly, an increase in the proportion of customers subscribing 
to  STING  TV  services  out  of  all  DBS  customers  results  in  a  decrease  in  the  average  revenue  per 
customer. 

5.2.1. 

Yes’s television services 

5.2.1.1 

Satellite broadcasts 

Satellite Yes broadcasts include linear channel broadcasts, as well as radio, 
music and interactive channels. 

For the purpose of receiving Yes services via satellite, reception plates are 
installed  in  the  buildings,  and  decoders  of  different  types  with  different 
features  are  installed  in  the  subscribers’ houses,  which  allow  a  variety  of 
services to be received depending on the converter's features. 

In accordance with  Yes’s  broadcasting license and the council's decisions, 
the broadcasting of the  Yes via satellite includes a basic package of linear 
channels  that  each  subscriber  is  required  to  purchase  (along  with  other 
basic  packages  that  Yes  may  offer),  as  well  as  other  channels  that  the 
subscriber  can  choose  to  purchase,  either  as  packages  or  as  discrete 
channels. 

DBS  provides  satellite  subscriber  services  to  its  subscribers  ("satellite 
subscribers")  VOD via the Internet (in the OTT  format). The vast  majority of 
satellite subscribers subscribe to a content package that includes VOD and 
the rest may purchase these services, when some of the content included in 
the VOD service is provided in exchange for a separate payment. 

Connecting  satellite  subscribers  to  VOD  services  requires,  among  other 
things,  the  use  of  certain  types  of  decoders.  To  the  question  of  the 
regulation of the field of Yes’s VOD services see Section5.14.2. 

Satellite TV services are offered in a wide package, which includes the vast 
majority of linear channels and VOD services, which is purchased by most 
satellite subscribers, and in packages with a smaller content scope (when 
subscribers can purchase additional channels that are not included in any of 
the packages they purchased). 

5.2.2. 

OTT Services  

Yes offers a number of OTT services: 

5.2.2.1 

Yes+ services 

Yes offers the Yes+ service, which includes linear TV channels, as well as on-
demand services, including VOD content in a number of offered packages, 
the most common of which is similar to that offered in the broad package 
offered  to  the  satellite  subscriber.  The  service  also  includes  advanced 
technological  interface  that  includes  advanced  features  that  are  not 
available  in  the  satellite  interface.  The  service  is  provided  via  compatible 
streamers, TV displays and additional end devices, including mobile devices. 
The service can be used on its own or in parallel with the satellite service. 

5.2.2.2 

STING+ services 

Yes operates the "STING+” service, which includes linear TV channels as well 
as  on-demand  services,  including  VOD  content,  and  is  intended  for 
customers  who  are  not  satellite  subscribers.  The  service  is  offered  in  a 
number of viewing packages that do not include the full range of content 
offered as part of Yes’s other services, and are characterized by relatively 
low  price  levels.  The  service  is  provided  via  compatible  streamers,  TV 
displays and additional end devices including mobile devices. 

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The following is the Yes’s susbscriebr base distributed by satellite subscribers and IP subscribers70 

Subscriber base (thousands) 

Satellite subscribers 

IP subscribers 

5.2.3. 

Internet access services 

Yes  provides  Internet  access  services,  focusing  on  selling  combined  Internet  and 
television packages to customers.71 These services are provided through services received 
by Yes from Gilat Telecom Ltd. 

The following is a breakdown of Yes’s fiber subscriber base: 

Subscriber base (thousands) 

5.3. 

Customers 

The vast majority of Yes’s subscribers are private customers. In general, Yes enters into a subscription 
agreement with its subscribers, which regulates the subscribers' set of rights and obligations in their 
relationship with Yes. With respect to the subscription agreement with the satellite subscribers, the 
approval of the council is required, which was received.72 

70 The number of IP subscribers also includes subscribers who also use the satellite services in parallel (see also Section 1.5.4.4). 

71 The services are provided according to a general permit in accordance with the provisions of a general permit. 

72  According  to  the  broadcasting  license,  the  approval  of  the  Uniform  Contracts  Court  is  also  required  for  the  subscription 
agreement  (approval  previously  granted  and  expired).  Yes  has  applied  to  the  Council  for  amendments  to  the  subscription 
agreement and for the amendment of the license, as part of which  Yes requested, inter alia, to revoke the license provision 

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5.4.  Marketing and distribution 

5.4.1. 

The marketing of Yes’s services is done through advertising in the various media.  Yes’s 
sales  activity  to  existing  and new  customers  is  carried  out  through  the  following  main 
distribution  channels  (some  of  which  are  operated  by  Yes  employees  and  some  by 
external marketers): 

5.4.1.1 

5.4.1.2 

5.4.1.3 

Call centers. 

Digital channels. 

Field sales people, working to recruit new subscribers. 

5.5. 

Competition 

5.5.1. 

Competitors in the field 

The field is characterized as of the date of the report by a number of competing groups 
(see Section 5.1). 

Yes' main competitors are Hot, Cellcom, Partner, freeTV, and Netflix. 

In April 2023, freeTV, a multi-channel broadcasting platform via the Internet, commenced 
its operations, owned by Keshet Broadcasting Ltd., which operates, among other things, 
a commercial TV channel transmitted as part of Yes Broadcasting ("Keshet") and the RGE 
Group Ltd. ("RGE"). For details about the Sports Channel Ltd., which is part of the RGE 
Group, see Section 5.9.2. In the year of the report, the activity of the venture intensified 
the competition in the field. 

To the best of DBS's knowledge, during the year 2023, a cooperation venture between 
Keshet Broadcasting Ltd., which operates, among other things, a commercial TV channel 
transmitted  as  part  of  DBS  Broadcasting  ("Keshet"),  and  RGE  Group  Ltd.  ("RGE")  is 
expected to establish and operate a multi-channel broadcasting platform, while acquiring 
minority  holdings  in  RGE  from  Keshet,  and  this  after  receiving  an  exemption  from  the 
restrictive arrangement of the Competition Authority for the activity of the said venture, 
as  well  as  the  approval  of  the  Second  Authority  to  Keshet,  both  for  a  period  until 
September 2025. According to DBS, the start of the project activity is expected to intensify 
the competition in the field, in particular in view of the identity of the companies of the 
project  (for  details  about  the  Sports  Channel  Ltd.  which  is  part  of  the  RGE  Group  and 
about Keshet, see Section 5.9.2). 

Below  is  data  on  subscription  numbers  and  market  shares73  of  Yes,  to  the  best  of  its 
knowledge, as of December 31, 2022 and 202374: 

2023 

2022 

Subscriptions 
(thousands) 

574 

Market 
Share 
33% 

Subscriptions 
(thousands) 

579 

Market 
Share 
33% 

5.5.2. 

Current competition characteristics 

requiring the approval of the Uniform Contracts Tribunal, in view of an amendment to legislation made in this regard. As of the 
date of this report, the Council's position regarding DBS's requests has not yet been received. 

73 The market shares were calculated from all Yes, Hot, Partner, Cellcom, and freeTV subscribers as detailed below (and not from 
all viewers and subscribers in the field in the absence of actual data about them). The assessment of Yes’s market shares in 2021 
and  2022  is  based  on  the  number  of  Yes,  Cellcom,  and  Partner  subscribers  (according  to  their  reports  on  the  number  of 
subscribers as of the end of the third quarter of 2022), as well as of Hot and freeTV, which do not publish the number of their 
subscribers, so the data in relation to them is according to Yes’s estimate. However, there is no certainty that the data presented 
in relation to Hot and freeTV are accurate, and therefore it is possible, respectively, that the actual market shares are different 
from those estimated. 
74 The number of subscribers is approximate, and the market share is in a circle. Subscriber - one household or a small business 
customer. In the case of a business customer who owns more than a certain number of decoders (such as a hotel, kibbutz or 
gym), the number of subscribers is adjusted. The number of non-small business customers is calculated as the total payment 
received  from  all  non-small  business  customers  divided  by  the  average  revenue  per  small  business  customer,  which  is 
determined once per period. 

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The competition in the field focuses on the variety and content of the broadcasts, the 
price of the services, the quality of the service, and the offer of advanced end equipment 
and  advanced  user  interfaces,  as  well  as  the  offer  of  additional  services,  including 
broadcasts. HD, 4K and on-demand services, including VOD. 

The competition is also characterized by the offer of additional communication services 
alongside the offer of TV content (for the offer of "service baskets" of the Hot, Cellcom 
and Partner groups, see also Section 1.7.1, and for the offer of service baskets by Yes, see 
also Section 1.7.3.3), in access and connection to international content providers and by 
the increase in the number of competitors and their establishment (see Section 5.1). 

5.5.3. 

Positive and negative factors affecting the competitive status of yes 

5.5.3.1 

In the opinion of Yes’s Management, the main competitive advantages of 
the Yes are: 

a.  The quality and variety of content that Yes broadcasts to its subscribers. 

b.  Level, quality and availability of Yes’s customer service system 

c.  Use of advanced technologies to provide advanced services and a good 

user experience. 

d.  Cultivating  and  promoting  the  "Yes"  brand  as  a  preferred,  well-liked 

brand with a high level of loyalty. 

e.  Marketing several call formats, characterized by different price levels, 
different  content  offerings,  different  broadcast  methods,  different 
technological interfaces and different types of customer service format. 

f.  Collaborations with international content providers. 

g.  Selling integrated packages of TV and Internet services 

5.5.3.2 

Yes’s  competitive  activity  in  the  field  of  broadcasting  suffers  from 
disadvantages or factors that adversely affect it, in a number of areas, the 
main ones being: 

a. 

Infrastructure inferiority – Yes’s satellite infrastructure does not allow 
two-way communication, does not allow the provision of VOD services 
and does not allow the transfer of telephony and Internet services, in 
contrast to the use of the Internet which enables the provision of these 
services. In addition, the satellite infrastructure is limited in relation to 
the  Internet  infrastructure  in  the  offer  of  advanced  technological 
interfaces. For details about migration to OTT services and OTT services 
see Sections 5.2.2 and 5.17.1. 

b.  Regulatory restrictions - 

For restrictions regarding the marketing of a shared basket of services, 
see Section 5.14.2. 

For restrictions by virtue of the terms of the Commissioner for a merger 
with Bezeq, see  Section  2.16.9.3. These restrictions also apply to  Yes 
activities in the field of OTT. 

For  competitive  inferiority  resulting  from  the  lack  of  regulatory 
oversight of players who do not have broadcasting licenses, see Section 
5.18.2.2. 

c.  Space  segments  -  the  use  of  space  segments  involves  heavy  fixed 
expenses, depending on the receipt of the services by a third party (see 
section  5.15),  and  involves  a  limitation  with  respect  to  the  ability  to 
expand the supply of broadcasts (see Section 5.6). 

5.5.4. 

Main methods of dealing with competition 

The following are the main methods of Yes to deal with the competition:  

5.5.4.1 

Content - Yes works to purchase, produce and broadcast quality, innovative 
and  diverse  content,  while  creating  differentiation,  emphasizing  branding 
and achieving originality in relation to the content broadcast by it. 

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5.5.4.2 

5.5.4.3 

5.5.4.4 

5.5.4.5 

5.5.4.6 

5.5.4.7 

Pricing policy - offering a variety of services at different price levels. 

Offering OTT services (see Section5.2.2). 

Service - Yes places emphasis on the customer service system. 

Technology - Yes is investing in expanding its technological capabilities, with 
an emphasis on providing innovative and advanced services. 

Branding - Yes cultivates, promotes and differentiates the brand "Yes". 

Collaborations  with  international  content  providers  and  accessibility  of 
content applications. 

5.6. 

Production capacity 

The number of channels that  Yes can transmit to satellite subscribers depends on the number of 
space segments at its disposal, the content compression capabilities and the bandwidth required to 
transmit  each  type  of  channel.  As  of  the  date  of  the  report,  Yes  almost  fully  utilizes  the  space 
segments  it  uses.  The  space  segments  are  provided  to  Yes  by  Space  (see  Section  15.5).  These 
restrictions do not apply in relation to the  OTT and VOD services whose transmission depends on 
web browsing volumes. 

5.7. 

PP&E, real estate and facilities 

The following are the main components of Yes’s PP&E: 

5.7.1. 

Real estate 

DBS leases a number of real estate properties for its operations. Yes’s headquarters, as 
well as its main broadcasting center, are located in leased real estate in Kfar Saba, whose 
lease period ends in 2024 (with options granted to  Yes for the extension of the  lease, 
subject to the terms of the agreement, until 2034). The balance of the lease period of the 
other  properties  that  Yes  leases  ranges  between  about  six  months  to  about  six  years 
(these periods are based on the exercise of options to extend lease periods granted to 
DBS). 

5.7.2. 

Satellite end equipment 

Yes  installs  reception  dishes  and  other  end  infrastructures  in  its  subscription  houses, 
including decoders that enable the reception of the broadcasts, as well as smart cards 
used to decode them. The decoders are rented to subscribers in exchange for fixed fees, 
paid during the period of receipt of the services, or lent to subscribers. 

5.7.3. 

End equipment for OTT services  

Yes+ and Sting TV services can be viewed via a variety of end devices, including streamers 
and  smart  TVs  of  various  models.  Yes  purchases  streamers  and  leases  them  to  its 
subscribers. 

5.7.4. 

Broadcasting equipment and computer and communication systems 

Yes  has  a  main  broadcasting  center  located  in  Kfar  Saba,  as  well  as  a  secondary 
broadcasting  center  located  in  the  Ella  Valley,  through  which  its  broadcasts  are 
transmitted via satellite and OTT. The broadcast centers have reception and transmission 
equipment,  as  well  as  computer  and  communication  systems.  The  secondary 
broadcasting center is partly operated on third-party premises, which provides DBS with 
the  services  of  operating  the  secondary  broadcasting  center  and  maintaining  it  in 
accordance with the framework agreement valid until the end of 202875. 

5.7.5. 

Operating and encryption systems 

Yes  purchases  from  Cinemedia  Group  ("Cinemedia")  development,  implementation, 
encryption, maintenance and warranty services related to the operating systems of the 
satellite  broadcasting  system  and  also  purchases  similar  services  from  Cinemedia  in 
relation to the OTT system, in accordance with the framework agreements between Yes 
and Cinemedia from January 2020. These services are provided in relation to various Yes 

75  This is in accordance with the exercise of the right stipulated in the agreement, a provision according to which  Yes is granted 
the right to extend for five additional years at a time, and its validity. The validity of this provision is under discussion between 
the parties, including in relation to the extension period until 2028. 

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systems, end equipment, and viewing cards and other hardware components required to 
receive  these  services,  and  Yes  has  also  been  granted  relevant  licenses  for  the  use  of 
systems and end equipment. 

The contract period with Cinmedia in relation to the satellite system is until February 2026 
subject to the terms of the agreement, with the possibility of early termination by Yes in 
the event  of the cessation of satellite broadcasts as part of the migration. See  Section 
5.18.1. 

For  the  services  and  products  provided  under  this  agreement,  Yes  pays  monthly 
payments,  where  the  agreement  stipulates  a  minimum  monthly  consideration  for  the 
provision of services to the extent specified, and an additional consideration is possible, 
the  amount  of  which  depends  on  the  types  of  services  provided  to  Yes,  and  on 
development services that Yes may order under the agreement. 

The  engagement  period  in  relation  to  OTT  is  until  December  2024  (after  which  an 
automatic renewal mechanism applies for periods of two years unless one of the parties 
notifies otherwise in accordance with the dates set for this matter in the agreement). Yes 
is granted the right to exit the agreement in relation to the OTT system, subject to prior 
notice and payment of an "exit fee" (at a decreasing rate depending on the duration of 
the agreement period). 

Yes depends on the continuous supply of these services, both in relation to the satellite 
system and in relation to OTT. 

5.7.6. 

Computerized customer management system 

Yes uses software and computer systems to manage the contracts with its subscribers, 
including  its  billing  and  collection  system.  In  this  context,  DBS  contracts  for  licenses, 
development  services and technical support  with NetCracker Technology Solutions Ltd 
and  NetCracker  Technology  EMEA  Limited  (jointly:  "NetCracker"),  and  Yes  also  uses 
Salesforce  software  together  with  Pelephone  and  Bezeq  International,,  according  to 
Pelephone's contract with Salesforce (for details, see Section 3.8.4). 

Yes  is  dependent  on  the  NetCracker  system  and  services  and-Salesforce,  due  to  their 
importance for Yes's management and monitoring of purchase of services and content by 
its subscribers, as well as for the purpose of charging and collecting from its subscribers. 
System failures or discontinuation of services to Yes (Including depending on Pelephone’s 
engagement with Salesforce) are expected to cause operational difficulty until the matter 
is repaired or the system / supplier replaced, which may take a long time. As of the date 
of this report, some of the components of the engagementWith NetCracker is renewed 
annually and some are valid until the end of 2024. The contracting with Salesforce is until 
the end of 2027. 

5.8. 

Intangible assets 

5.8.1. 

Licenses 

DBS has the following main licenses: 

5.8.1.1 

5.8.1.2 

5.8.1.3 

Broadcasting  license  valid  until  February  2026  -  this  license  is  material  to 
Yes’s  satellite  activity  and  constitutes  the  main  regulatory  permit  for  this 
activity (for the terms of this license, see Section 5.1476). 

License  for  satellite  television  broadcasts  in  the  Judea  and  Samaria  area 
valid  until  February  2026,  the  provisions  of  which  are  similar  to  Yes’s 
broadcasting license specified in Section 5.8.1.1.77 

License  to  perform  uplink  operations  (transfer  of  broadcast-focused 
broadcasts to the broadcast satellite and to carry out ancillary set-up and 

76  The expiration date of the aforementioned license was determined further to Yes's request to adjust, as much as possible, 
the expiration date to the estimated date  of completing the transition process (migration) of  Yes from broadcasting via 
satellite to broadcasting via the Internet network. The license gives Yes the right to notify the Ministry of the extension of 
the license in two periods of one year each time, under the conditions stipulated in the license. 

77 In July 2021, an application was made to the Head of the Judea and Samaria Administration for the renewal of this license. 

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operation operations), which are valid until January 2022.78 This license is 
essential  for  Yes’s  activity  and  constitutes  the  regulatory  permit  for  the 
transmission of transmission messages from the transmission center to the 
transmission satellites and from them to the satellite subscribers' homes. 

5.8.2. 

Trademarks 

Yes has registered trademarks79, the main ones of which are intended to protect its trade 
name (Yes) and the key brands it uses (Yes, Yes+, STING+). 

5.9. 

Broadcasting rights 

5.9.1. 

Yes has broadcasting rights in content of two types: 

Content  whose  rights  to  broadcast  are  acquired  from  third  parties,  including  discrete 
content  and  channels.  Yes  works  to  adapt  as  much  as  possible  broadcasting  rights 
acquired by it in a way that will allow broadcasting in the various media and formats in 
which it operates. 

Content that Yes invests in its production (in full or in part), and in addition to the right to 
broadcast the content as part of its broadcasts, Yes usually has rights in the same content, 
at the rates specified in the agreements with the producers. In most cases,  Yes is also 
entitled to grant  rights to the use of rights and to participate in revenues arising from 
additional uses of the content beyond their broadcasting by Yes. 

Broadcasting  and  distribution  of  content  by  Yes,  in  the  various  media,  involves  the 
payment  of  royalties  to  copyright  holders  and  performers  in  musical  works,  sound 
records, scripts and content directing, as well as in respect of sub-broadcasting, including 
under  the  Copyright  Law,  5768-2007  ("Copyright  Law")  and  the  Performers  and 
Broadcasters'  Rights  Law,  5744-1984.  Such  royalties  are  paid  to  a  number  of 
organizations,  which  collect  the  royalties  to  which  they  are  entitled  through 
comprehensive licenses (blanket licenses) for the intellectual property rights holders. The 
payments under these licenses are sometimes based on a fixed payment and sometimes 
on different pricing methods, with some organizations being required to pay additional 
fees for the transfer of content in certain media or in certain formats, in amounts that 
DBS estimates are not expected to be substantial. 

This assessment of Yes is a forward-looking assessment, as defined in the Securities Law, 
based on, among other things, Yes estimates, including in relation to the extent of the use 
of the said content, and the positions of the various organizations, and in the event of 
changes in any of them, this assessment may materialize differently. 

5.9.2. 

Dependence on content provider 

In view of the large number of content providers from whom Yes acquires broadcasting 
rights, Yes does not have a primary content provider and is not dependent on a single 
content provider. However, in the field of Israeli sports broadcasting, as of the date of 
this report, there is a dependence on the acquisition of the broadcasting rights of local 
sports channels from Sports Channel Ltd. and Charlton Ltd., with whom there is a contract 
for  several  years.  This  dependence  stems  from  the  fact  that  they  are  the  exclusive 
providers of Israeli sports broadcasts and in light of the existence of a high demand for 
such  services,  from  among  a  significant  group  of  Yes  customers.  Compensation  under 
these agreements is based on a fixed monthly payment in accordance with the number 
of subscribers to Yes broadcasts (except for exceptions set forth in these agreements). 
Also,  in  view  of  the  high  demand  for  the  contents  of  the  commercial  channels  (see 
Footnote  71)  among  Yes  customers,  it  is  important  to  broadcast  them  as  part  of  its 
broadcasts. 

5.10.  Human capital 

5.10.1. 

Organizational structure 

Yes’s Management consists of divisions, with each division headed by a VP, who serves as 

78 After an extension made in January 2022. 

79 The trademark STING+ has not yet been registered and is in the process of registration. 

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a member of Yes’s Management. 

Board of 
Directors

CEO

Interna
l Audit

Finan
ce 

Conte
nt

Business 
Custome
rs 
Division

Private 
Custom
ers 
Division

Public 
Relati
ons

Marke
ting

IT 

Engin
eering

HR 

Legal 
advice 
and 
regulation

The CEO of Yes also serves as the CEO of Pelephone. In addition, most of the VPs who 
serve at Yes also serve as VPs at Pelephone, so does the Internal Auditor (who also serves 
in Bezeq International). 

5.10.2. 

Yes employee base by divisions:  

Administration 
Customer Division 
Total 

Number of employees 

31.12.2022 
351 
714 
1,065 

31.12.2023 
366 
726 
1,092 

The number of employees included in the table above includes employees employed part-
time. The total number of jobs80 in Yes as of December 31, 2023 was 1,018. 

5.10.3. 

Benefits and nature of employment agreements 

The  terms  of  employment  in  the  Yes  are  regulated,  among  other  things,  in  collective 
agreements and in a collective arrangement, as detailed below, and apply to the majority 
of the employee population (does not apply to some of the management levels and also 
employees  in  special  positions  of  trust).  The  representative  organization  of  Yes’s 
employees is the Histadrut. 

In  addition,  Yes  employees  are  employed  in  accordance  with  personal  employment 
agreements on a monthly or hourly wage basis, with some employees also being entitled 
to  performance-based  compensation.  The  employment  agreements  are  usually  for  an 
indefinite  period  and  each  party  may  terminate  the  contract  with  prior  notice  in 
accordance with the personal agreement  and the law, subject  to the provisions of the 
collective agreement, as applicable. 

In  August  2021,  Yes  engaged  in  a  collective  agreement  with  the  Histadrut  and  the 
Employees’ Committee, which included, among other things, amendments to  previous 
collective agreements and collective arrangement. The new collective agreement is valid 
until December 31, 2024. According to it, among other things, salary increases and grants 
were provided, ancillary conditions were improved, a retirement plan was agreed o, and 
it  was  agreed  that  the  parties  would  maintain  industrial  silence  during  the  period  of 
validity  of  the  agreement  in  all  matters  regulated  therein..  The  collective  agreements 
applicable to Yes employees (as amended above) regulate,  inter alia, the periods after 
which  a  Yes  employee  will  be  considered  a  permanent  employee,  mechanisms  that 
involve  the  Employees’  Committee  in  decision-making  regarding  employment  and  the 
termination of employment of permanent employees, as well as annual wage increases 

80 Calculated as the total monthly working hours divided by the standard monthly working hours. 

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and additional financial benefits to be provided by Yes to employees, during the term of 
the agreement. 

After  ending  on  December  31,  2024,  the  collective  agreement  will  be  automatically 
extended for a period of 12 months each time, if one of the parties does not notify, at 
least 90 days before the end of the validity, of its desire to make changes. 

5.10.4. 

Employee compensation plans 

Yes  usually  provides  its  officers,  as  well  as  managers  and some  of  its  employees,  with 
bonuses on an annual basis based on meeting targets and evaluating performance, for 
components of equity compensation from Bezeq in relation to some of Yes’s executives, 
see Section 2.9.5.  

5.11.  Suppliers 

5.11.1. 

Rate of purchases from main suppliers and the form of engagement with them 

Yes considers as a "main supplier", for the purposes of Section 23 of the First Schedule to 
the  Prospectus  Details  Regulations,  a  supplier  from  whom  Yes’s  annual  volume  of 
purchases exceeded 10% of the total annual volume of purchases of the Group. During 
the year 2023, Yes did not have a main supplier as defined above. 

5.11.2. 

Dependence on suppliers 

Yes believes that it may be dependent on the following suppliers: 

Gilat Telecom, for details on the engagement, see Section 5.2.2. 

Space, for details on the contract, see Section 5.15. 

Cinmedia, for details on the contract, see Section 5.7.5. 

NetCracker and Salesforce, for details on the connection see Section 5.7.6. 

To purchase broadcasting rights from local sports channels, see Section 5.9.2. 

5.12.  Financing 

Most  of the financing of  Yes is carried  out  from its own sources, but  it may need investments or 
credit from the Company according to Yes’s needs. 

In March 2023, Bezeq approved a credit facility or investment in Yes’s equity in a total amount of up 
to NIS 40 million, for a period of 15 months starting on January 1, 2024. This approval is instead of a 
similar approval given in November 2023 (and not in addition to it). 

Yes’s estimate as mentioned above is forward-looking information, as defined in the Securities Law. 
There is no certainty that in the future Yes will require financing from Bezeq or that Bezeq will provide 
financing for Yes’s activities in excess of the above, and on what dates, and this depends, among 
other things, on the situation of  Yes, on developments in its areas of activity and on the state of 
competition in these areas and on Yes’s future financing needs. 

5.13.  Taxation 

 For more details, see Note 7 to the 2023 statements. 

5.14.  Restrictions and supervision of Yes 

5.14.1. 

Regulation of satellite broadcasts 

Yes’s activity as a holder of a regulated satellite broadcasting license in an extensive legal 
system has applied to the field of satellite and cable broadcasting, which includes primary 
in  particular  the  Communications  Law  and  regulations  enacted 
legislation  (and 
thereunder), secondary legislation (including communications rules), as well as, inter alia, 
Council directives. 

In addition, DBS's satellite activity is subject to the provisions of its licenses, primarily the 
broadcasting license. 

The law authorizes the Director General of the Ministry of Communications as well as the 
Chairman  of  the  Council  to  impose  financial  sanctions  for  various  violations  of  the 
provisions of the law and of orders and provisions issued under it, as well as for violation 
of conditions in the broadcasting license. 

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5.14.1.1 

Terms of service for a satellite broadcasting license holder, restrictions on 
cross-ownerships 

Satellite  broadcasting  license  regulations  set  various  restrictions  on  the 
licensee, including, among other things, eligibility conditions in relation to 
the  holdings  of  the  licensee  and  stakeholders,  directly  and  indirectly,  in 
holders  of  cable  broadcasting  licenses,  in  holders  of  franchises  under  the 
Second Authority Law81 and in newspapers with daily circulation, as well as 
"Israeliness" requirements regarding officers in the Yes and "Israeli" holding 
at a minimum rate of 26%, in accordance with the provisions set forth in the 
regulations. 

5.14.1.2 

Rates supervision 

The  broadcasting  license  sets  forth  provisions  regarding  the  types  of 
payments that the licensee may charge its subscribers for services provided 
by virtue of the license, and these are determined in Yes’s Council-approved 
price list. The vast majority of satellite subscribers subscribe to promotions, 
offering  Yes  services,  including  various  composition  of  content  packages, 
ancillary services as well as receiving and installing end equipment, at prices 
lower than the list price. 

Yes has a duty to notify the Chairman of the Council of any change in the 
price list immediately upon its publication and the chairman may in certain 
cases prohibit the change of the price list. The Chairman of the Council may 
also interfere with promotions or discounts offered by Yes, if he finds that 
they  have  the  effect  of  misleading  the  public  or  discriminating  between 
subscribers. 

By virtue of the Communications Law, the license can set maximum prices 
at which a subscription can be charged. As of the date of this report, no such 
prices have been set. 

5.14.1.3 

Obligation to invest in local productions 

In  accordance  with  the  requirements  of  the  broadcasting  license  and  the 
decisions of the Council, in each of the years 2022 and 2023, Yes must invest 
an amount of not less than 8% of its revenues from the subscription fees of 
satellite subscribers82 in local productions, when according to the rules of 
the media and the decisions of the council, Yes must invest different rates 
out  of  these 
local 
productions. 

in  different  categories  of 

investment  amounts 

In January 2024, the Council decided to postpone for 2025 the entry into 
force  of  its  previous  decision,  according  to  which  the  rate  of  investment 
obligation in local productions will exceed and stand at 9%. The Council also 
determined that during 2024 and in accordance with developments, it will 
hold another discussion to examine the current legislative situation and the 
economic situation of licensees, including a hedging formula set out in the 
council's previous decision and give instructions as it sees fit. 

Regarding  the  obligation  to  invest  in  local  productions  -  see  also  Section 
5.16.10. 

5.14.1.4 

Duty to transfer channels 

81 As of the date of the report, the activities of these entities (both in the field of cable broadcasting and under the Second 
Authority Law) are regulated through licenses and not franchises. 
82  Based  on  its  revenues  in  the  past  year  from  satellite  subscribers,  including  Yes’s  revenues  from  end  equipment  and  its 
installation.  According  to  the  position  of  the  Council,  according  to  which  the  actual  investments  are  made,  even  though  Yes 
disagrees with it, these revenues also include revenues from VOD service to satellite subscribers. 

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Yes is obligated to transmit the "mandatory channels" in satellite broadcasts 
and  everything  as  determined  by  the  Minister  and  in  the  broadcasting 
license.83 

In addition, Yes is required to allow channel producers provided by law to 
use  its  infrastructure  to  distribute  broadcasts  to  its  subscribers,  for  a  fee 
("transfer fee") to be determined in the agreement, and in the absence of 
consent - for a fee to be determined by the Minister, after consulting the 
Council.  In  addition,  the  Minister  may  require  the  transmission  of  small-
license  broadcasts  under  the  Second  Authority  Law  (which  did  not  have 
dedicated licenses prior to the amendment to the law), taking into account 
the satellite capacity of Yes. According to the Second Authority Law, holders 
of small and small designated licenses, who had a dedicated license under 
the Communications Law, are exempt from paying transfer fees to Hot to 
Yes, for a transition period, after being extended as part of an amendment 
to the Second Authority Law from February 2023, will end in August 2024. 

5.14.1.5 

Contents of the broadcasts and obligations in relation to the subscriber 

The broadcasting license sets forth provisions relating to the content of DBS 
broadcasts,  including  supervision  by  the  Council  in  relation  to  channels 
broadcast  by  Yes. The Communications Law prohibits broadcast  licensees 
from broadcasting commercials, subject to a number of exceptions. 

In addition, the broadcasting license includes conditions regarding the terms 
of  service  for  subscribers,  including  the  prohibition  of  discrimination 
between them. 

According to an amendment Yes’s broadcasting license, Yes will be entitled, 
as  of  February  28,  2025,  not  to  connect  new  subscribers  to  the  satellite 
services according to the license, and accordingly to refuse requests to enter 
into  the  subscription  agreement,  without  discriminating  between  those 
seeking to become subscribers. 

For  a  preliminary  data  demand  Council  in  connection  with  inactive 
subscribers see Section 1.7.7.7. 

5.14.1.6 

Ownership of broadcast channels 

According to the rules of communication,  Yes, including entities affiliated 
with it (as defined in the rules of communication), may own up to 30% of 
the local channels broadcast as part of Yes broadcasts (compared to a limit 
of  20%  applicable  to  HOT).  Yes  is  also  restricted  according  to  the 
Communications Law, in owning a news broadcast producer. 

5.14.1.7 

General provisions regarding the broadcasting license 

The  Minister  and  the  Council  have  parallel  authority  to  amend  the 
Broadcasting License. The Minister is authorized to revoke or suspend the 
Broadcasting License on the grounds set forth in the Communications Law 
and  the  Broadcasting  License.  The  Communications  and  Broadcasting 
License Law sets limits on the transfer, foreclosure and encumbrance of the 
Broadcasting License and of assets from the license assets. The Broadcasting 
License requires the approval of the Minister in relation to certain changes 
in the maintenance of means of control in the  Yes and imposes reporting 
obligations regarding the holders of the means of control; Infringement of 
competition  is  prohibited  by  way  of  an  agreement,  arrangement  or 
understanding with a third party regarding the provision of broadcasts and 
services  unless  approved  in  advance  and  in  writing  by  the  Council;  The 
obligation to submit reports to the Ministry of Communications, as well as 
conditions  related  to  the  supervision  of  the  licensee's  activities,  were 
established; The obligation to provide bank guarantees to the Ministry of 

83 According to the provisions of the Communications Law, Yes is exempt from payment to the commercial channels included in 
the mandatory channels due to the transmission of their broadcasts  over its satellite broadcasts. For the transmission of the 
commercial channels as part of the OTT services, see Section 5.1.1.1. 

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Communications  to  secure  Yes’s  liabilities  under  the  license  has  been 
determined, in the amount (principal) of NIS 30 million (a total as of the date 
of the report of approximately NIS 40 million). 

5.14.2. 

Regulation of OTT services  

OTT  services  (such  as  those  offered  by  Yes  as  well  as  other  local  providers  and 
international  providers  operating  in  Israel)  are  not  subject  to  the  current  standard  in 
relation to multi-channel satellite television broadcasts or other arrangements under the 
Communications Law. Yes also believes that the VOD services it provides via the Internet 
to satellite subscribers (see  Section5.2.1) are not  subject  to such regulation. However, 
from various decisions of the Council (see also Section 5.2.1), it seems that the Council 
considers itself authorized to arrange the VOD services for Yes satellite subscribers. 

For the processes of examining the regulation of OTT services, see Section 5.1.2. 

To the extent that a regulation of content transfer via the Internet is implemented, it is 
expected  to  impose  restrictions  on  the  provision  of  the  said  services  by  Yes,  but  this 
regulation may reduce the existing gap in the regulation regimes between licensees and 
broadcasters between other entities active in the OTT field. 

The  estimates  concerning  the  results  of  the  regulation  of  OTT  services  in  this  section 
above are forward-looking information, as defined in the Securities Law, based, inter alia, 
on the Regulatory Hearing document and the wording of the legislative initiatives. There 
is no certainty that this issue will be regulated in legislation and regulation in general, and 
in  the  manner  proposed  in  particular.  These  assessments  may  not  materialize,  or 
materialize in a materially different way than would be expected, inter alia, depending on 
the  results  of  the  Regulatory  Hearing  and  the  actual  implementation  of  the  Minister's 
decisions and in legislative amendments, if further regulation is formulated as a  result 
thereof. 

5.14.3. 

Offer of baskets of services 

Yes markets integrated packages of TV and Internet services provided by it. Additionally, 
according to the broadcasting license, Yes may offer a shared basket of services, including 
Bezeq  service  and  Yes  service,  subject  to  obtaining  approval  from  the  Ministry  of 
Communications (in the absence of objection within the period specified in the license 
will  be  considered  as  possible)  and  subject  to  conditions,  the  main  ones  are  the 
“detachability” obligation and the existence of a parallel basket marketed by a licensee 
who  is  not  affiliated  with  Bezeq  (see  Section  1.7.2.3).  A  shared  basket  of  services 
marketed  by  Yes, which  includes Bezeq's Internet  infrastructure service only, does not 
require the approval of the Ministry of Communications and does not have detachability 
obligation. 

Regarding conditions published by the Commissioner in connection with the merger of 
Bezeq and Yes and the amendment under consideration, see Section 2.16.9.3. 

In  the  opinion  of  Yes,  in  view  of  the  development  of  competition  between  the 
communication  groups  and  the  growing  importance  of  providing  comprehensive 
communication services (see Section 1.7.1), in particular in the competition between it 
and HOT, Cellcom and Partner, which are not subject to these restrictions, insofar as the 
restrictions remain in relation to Bezeq's collaborations with it (see Section 1.7.3.3), may 
increase the adverse effect of these restrictions on Yes results.  

5.15.  Material agreements 

The following is a concise description of the main points of the agreements that may be considered 
material agreements that are not in the ordinary course of business of Yes, which were signed or are 
valid during the reporting period: 

Agreement for the lease of space segments84  

84 The assessments in this section regarding the activity and end of the useful lives of the satellites, the amount of segments 
leased and those intended to be made available to Yes for various event controls (such as backup cases), and all implications are 
forward-looking information, as defined in the Securities Law, which is based, among other things, on the information provided 
by Space to Yes, and which in part is not even controlled by Space and depends on its engagements with third parties. Therefore, 

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According to an agreement with Space, since 2013, as amended (including amendment from January 
2023), Yes has leased space segments in satellites from the "Amos" series ("the Space Agreement").  

Comply with the provisions of the Space Agreement, Yes leases space segments on "Amos 3" satellite 
(whose estimated end of useful life is at the beginning of 2026), as well as the "Amos 7" satellite, in 
which Space has the right to lease space segments under an agreement between it and the owner 
of the rights in this satellite, and in which space segments are leased to DBS until February 2025 (or 
until the end of his life, whichever is earlier).85 

Period of the agreement - until the end of the life of the "Amos 3" satellite (subject to the exceptions 
set forth in the agreement), but in any case the agreement will expire no later than February 202686. 

The leased space segments - according to the Space Agreement (and subject to unavailability events), 
until  the  end  of  the  Amos  7  Yes  lease  period,  Yes  will  lease  12  space  segments  from  Space,  in 
accordance with the division between the relevant satellites stipulated in the Agreement according 
to the different periods, and then Yes will lease 10 space segments in Amos 3. The Agreement also 
regulates the provision of backup segments to space segments leased by Space during the term of 
the Agreement, so that in the event of space segments not available on one of the satellites, Space 
will place alternate segments on the other satellite so that the total number of segments is not less 
than 10 segments, subject to the terms and conditions set forth in the Space Agreement.87 

Cost - the average annual cost until the end of the lease in Amos 7 is approximately USD 25 million, 
and  thereafter  approximately  USD  18  million,  subject  to  the  discount  and  reimbursement 
mechanisms set forth in the Space Agreement. 

Early termination of the agreement - according to the Space Agreement, Yes may announce an early 
termination without cause, of a Space Agreement subject to 12 months' prior notice and payment 
of the lease in "Amos 7" plus payment of parts of the lease balance in the space segments in "Amos 
3". 

Yes  has  a  substantial  dependence  on  Space,  as  the  sole  owner  and  sole  supplier  of  the  space 
segments used by Yes, which is also responsible for the operation of the space segments. Regarding 
exposure to risks in the event of a failure in the activity of one of the satellites, the unavailability of 
the space segments used by Yes and the lack of redundancy for the Amos 3 satellite from the end of 
the Amos 7 lease, see Section5.18.3.4. 

5.16. 

Legal Proceedings88 

5.16.1. 

Pending and contingent legal proceedings  

Date 

Sides 

Court 

Type of procedure 

Details 

Amount of 
claim / 
remedies 

a. 

 Decem
ber 
2020 

Tel Aviv 
District 
Court 

b. 

 June 
2017 

Bezeq 
sharehol
ders vs. 
Bezeq, 
Chairma
n of the 

Tel Aviv 
District 
Court 
(Econom
ic 
Departm

Motion for 
approval of class 
actions 

For details regarding an indictment filed in 
December  2020  by  the  State  Attorney's 
Office  (following  an  open 
investigation 
opened in June 2017), inter alia, against the 
former  CEO  of  Yes  and  its  former  CFO  see 
Section.אצמנ אל הינפהה רוקמ !האיגש. 

For details regarding a motion for approval 
of  a  class  action  lawsuit  filed  against, 
among other things, the former CEO of Yes 
and  its  former  CFO,  in  connection  with  a 
2015 transaction in which Bezeq acquired 
the remaining shares of the Yes shares held 

these assessments may not materialize, or materialize in a materially different manner than expected, inter alia, depending on 
the conditions associated with the start of satellite operation, the conditions required for their proper operation and availability, 
the end of the existing satellite’s useful life, and external factors (including third parties and the rights in Amos Satellite 7) that 
affect their activity and the activity of Space as well as the business position of Space. 
85 See Bezeq's immediate report dated February 27, 2023. 
86 In some cases, Yes may announce the continued use of the "Amos 3" satellite even after the end of its life. 
87  In addition, according to the space agreement, it holds spare tubes on the "Amos 7" satellite, and must make every reasonable 
effort  to  locate  alternative  satellite  segments  in  other  satellites  under  the  terms  and  conditions  set  forth  in  the  Agreement, 
including maximum amounts and rates of Space’s participation in additional expenses. 
88 For reporting policy and materiaityl threshold, see Section 2.18.  
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Date 

Sides 

Court 

Type of procedure 

Details 

Amount of 
claim / 
remedies 

Board of 
Bezeq, 
member
s of the 
Board of 
Bezeq, as 
well as 
member
s of the 
Eurocom 
Group 
and vs. 
the 
(former) 
CEO of 
Bezeq 
and CEO 
(former) 
and CFO 
of Yes 

Bezeq 
shareh
olders 
against 
Bezeq 
and Yes 

c. 

 July - 
August 
2017 

ent) 

thereby  from  Eurocom  DBS,  see  Section 
2.18.1c. 

Tel Aviv 
District 
Court 

Motion for 
disclosure of 
documents before 
submitting a motion 
for approval of a 
derivative claim in 
accordance with 
Article 198A of the 
Companies Law  

regarding  a  motion 

For  details 
for 
disclosure of documents before submitting 
a motion for approval of a derivative claim 
in  accordance  with  Article  198A  of  the 
Companies Law against Bezeq and Yes, for 
disclosures  of  certain  documents 
in 
connection  with  a  2013  Yes  and  Space 
stakeholder  transaction  as  amended  in 
2017 (Space Agreement) See Section 2.18.1 
Subsection D. 

d. 

 June 
2023 

Custome
rs vs. Yes 

Motion for approval 
of a class action 

Central 
District 
Court- 
Lod 

e. 

 Augus
t 2023 

Custome
rs vs. Yes 

Motion for approval 
of a class action 

f. 

 Augus
t 2023 

Custome
rs vs. Yes 

Motion for approval 
of a class action 

154

through 

The point of the claim is that Yes does not 
act in accordance with the law with regard 
to  giving  notice  of  the  end  of  fixed-period 
transactions  in  that  it  does  not  send  a 
separate and independent notice of the end 
the  benefit  period,  beyond 
date  of 
informing 
the 
the  customer 
monthly  invoice  and  by  sending  a  text 
message. 
It  should  be  noted  that  similar  motions  on 
the same  subject (failure to provide notice 
as  required  on  the  termination  of  a  fixed-
period  transaction)  were  filed  against  the 
Company 
and 
(see 
Pelephone (see Section 3.16.1). 
The  claim  alleges  that  Yes  violates  the 
including  Article 
law, 
provisions  of  the 
18b(a1)(3) of the Consumer Protection Law, 
the  provisions  of 
license,  and  the 
its 
provisions  of  the  Consumer  Protection 
Regulations 
Telephone 
(Provision  of 
Service), 5772-2012, regarding the required 
waiting time for receiving a response from a 
representative  from  the  beginning  of  the 
call. 
Motion for approval of a class action 

Section  2.18.1) 

Over  NIS 
2.5 million 

Over  NIS 
2.5 million 

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Date 

Sides 

Court 

Type of procedure 

Details 

Amount of 
claim / 
remedies 

Appeal to HCJ 

g. 

 Januar
y 2024 

Organiza
tions of 
creators, 
perform
ers, 
producer
s, 
screenwr
iters, 
and 
editors 
vs. the 
Council, 
the 
Chairma
n of the 
council, 
Yes and 
Hot 

Further  to  the  petition  submitted  in  April 
2023,  which  was  struck  out  in  July  2023, 
while  preserving  the  claims  of  the  parties, 
the petition was refiled, in the framework of 
which  the  Court  was  asked  to  order  the 
Council and the Chairman of the Council to 
respond  and  justify  why  they  would  not 
order Hot and Yes to include their revenue 
from additional services provided by them, 
which  are  not  multi-channel  television 
cable 
services 
communication, 
telephony 
services, Internet access services, and multi-
channel television services over the Internet 
(OTT)  for  the  purpose  of  calculating  their 
local 
annual 
investment  obligations 
productions 
the 
Communications Law. 

satellite  or 

according 

including 

through 

to 

in 

5.16.2. 

Legal proceedings that ended during the reporting period 

Date 
of 
filing 
claim 

a. 

 June 
2018 

Sides 

Court 

Type of procedure 

Details 

Original 
claim 
amount 
(NIS millions) 

Sharehol
ders of 
the 
Compan
y vs. the 
Compan
y, Yes, 
and the 
former 
controlli
ng 
sharehol
ders of 
the 
Compan
y 

Motion for 
disclosure and 
perusal of 
documents in 
accordance with 
Article 198A of the 
Companies Law  

High 
Court of 
Justice 
Tel Aviv 
District 
Court 
(Econom
ic 
Departm
ent) 

submittifilingng  a  motion 

For details regarding the striking out of the 
motion  for  the  disclosure  of  documents 
before 
for 
approval of a derivative claim in accordance 
with  Article  198a  of  the  Companies  Law, 
which  were  filed  by  Bezeq  shareholders 
against  Bezeq,  Yes,  the  former  controlling 
shareholder  of  the  Company,  Mr.  Shaul 
Elovich,  and  his  son,  Mr.  Or  Elovich  ("the 
Elovich "), for the delivery of documents and 
information in connection with the violation 
of the fiduciary, fairness and fiduciary duties 
of  Elovich  in  connection  with  the  sale  of 
Bezeq  shares  on  February  2,  2016  by  the 
Company, see Section 2.18.2. 

5.17.  Targets and strategy 

5.17.1. 

Yes’s  targets  are  to  maintain  market  share,  while  maintaining  DBS's  business  and 
competitive position in the field and Yes’s brand status as a leading communications and 
television brand. 

As of 2019, Yes has been implementing a migration plan from satellite broadcasts to the 
Internet (OTT) in a long-term gradual procedure that is expected to be spread up to early 
2026, in accordance with the decision of the Boards of Directors of Yes and Bezeq. The 
said decisions were made in light of the trends in the television content market, which 
include  lowering  entry  barriers,  entry  of  new  players  and  establishing  OTT  broadcast 
technologies, changing the value chain and changing consumption habits, along with the 
differences between old satellite broadcast technology and OTT broadcast technology, 
changing the value chain and changing consumption habits, along with the differences 
between the old satellite transmission technology and the OTT transmission technology 
on  the  benefits  inherent  in  it  (also  paying  attention  to  the  aspects  of  equipment, 
obligations and content rights). In accordance with the decision, DBS regularly monitors 
market  conditions,  competition  and  the  technological  environment,  and  frequently 
examines the applicability of the outline and the need, if any, to make changes to it, the 

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5.17.2. 

5.17.3. 

pace of implementation or the manner in which it is implemented, taking into account its 
customer needs as well as regulatory amd other obligations of Yes. 

Since this is the implementation of an outline for the transition in a multi-year gradual 
procedure, with ongoing monitoring, there is no certainty, at this stage, regarding the 
actual duration of the process and / or that the move as stated will be completed. As the 
transition is completed, it is expected to lead to savings in  Yes’s expenses and a better 
adaptation to changing market conditions. 

As of the date of approval of the statements, the rate of Yes subscribers using the Services 
Yes+  and  STING+  transmitted  via  the  Internet  (as  stated  in  the  Sections5.2.2.1  and 
.אצמנ אל הינפהה רוקמ !האיגש above) is about 71%89 of all Yes subscribers. For this 
matter see also Section 1.5.4.4 (Note 3). 

In order to achieve the aforementioned targets, along with actions to reduce expenses, 
DBS invests considerable efforts in the areas of marketing and sales and in an appropriate 
marketing  strategy  designed  to  further  recruit  existing  subscribers  and  retain  existing 
subscribers;  Continuous  improvement  in  the  subscriber  service  system;  Upgrading 
customer value propositions, creating differentiation and originality in the content of its 
broadcasts; Offering a variety of products (both low cost and premium), increasing the 
volume of content purchased by each subscriber and expanding the added value services 
of Yes; Marketing of Internet access services, focusing on selling combined Internet and 
TV  packages  to  customers;  Having  collaborations  with  international  content  providers 
and  making  content  apps  accessible,  As  well  as  investment  in  the  development  and 
implementation  of  advanced  technologies,  advanced  customer  interfaces  and  new 
services;  These  efforts  include  the  pursuit  of  Yes  to  implement  the  outline  of  the 
transition to OTT services. 

DBS's  objectives  as  stated  above,  including  with  respect  to  the  transition  outline 
described  above,  are  forward-looking  information,  as  defined  in  the  Securities  Law, 
based, inter alia, on Yes’s Management's assumptions, estimates and forecasts regarding 
the  current  trend 
in  the  broadcasting  market,  regarding  competition,  business 
developments,  consumption  habits,  the  technological  environment,  the  regulatory 
environment and the manner of regulation (both on  Yes and other parties) both in the 
satellite  broadcasting  market  and  in the  Internet  television  broadcasting  market  (OTT) 
and in the Internet access services market, also paying attention to the restrictions that 
apply  and  will  apply  to  Bezeq,  which  affect  Yes.  However,  the  predictions  of  the  Yes 
Management, its preparations, objectives and the above outline may not materialize, or 
materialize  in  a  materially  different  manner,  in  view  of  changes  in  demand  in  the 
aforementioned markets, in view of the intensification of competition in these fields, in 
view  of  the  entry  of  additional  factors  into  them  or  into  alternative  fields,  in  view  of 
change in technologies and in consumption habits, in view of the pace of development of 
the Internet browsing rates, in view of regulatory restrictions imposed or to be imposed 
on DBS, or its collaborations with Bezeq and other parties in the fields, and in view of how 
the fields will be regulated. 

5.18.  Discussion of risk factors 

The following are the threats, weaknesses and other risk factors of Yes (“the Risks") arising from its 
general environment, from the industry and from the unique characteristics of its activities. 

5.18.1.  Macro risks 

5.18.1.1 

Financial  risks  -  Yes  is  exposed  to  various  market  risks  such  as;  Exchange 
rate,  index  and  interest  rate  risks.  The  main  market  risk  is  the  shekel-US 
dollar  exchange  rate,  in  light  of  the  fact  that  some  significant  portion  of 
DBS's  expenses  and  investments  are  made  in  US  dollars  (mainly  content, 
satellite  segments,  purchase  of  end  equipment  and  other 
logistics 
equipment).  Therefore,  sharp  exchange  rate  changes  have  an  effect  on 
DBS's business results. 

5.18.1.2 

Recession  /  economic  slowdown  /  security  situation  -  an  economic 
slowdown  in  the  economy,  an  increase  in  unemployment  rates  and  a 

89 This rate also includes subscribers who also use satellite services. 

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5.18.1.3 

5.18.1.4 

5.18.1.5 

decrease in disposable revenue may lead to a decrease in the number of Yes 
subscribers, a decrease in Yes’s revenues and damage to its business results. 

Also,  an  ongoing  deteriorating  security  situation  in  large  areas  of  Israel, 
which disrupts the daily lives of the residents, could lead to a deterioration 
in the business results of Yes. 

Epidemic - Disease outbreaks and epidemic events in general (such as the 
outbreak of COVID-19 in 2020) may have consequences for Yes’s business 
activities depending on the extent of the spread and its severity as well as 
the  national  and  global  measures  that  will  be  taken  as  a  result.  These 
consequences may be manifested, among other things, in damage to Yes’s 
activities and its customer service system as well as in damage to the supply 
chain. Events of this type are changing events that are not under the control 
of  Yes,  and  their  consequences  are  subject,  among  other  things,  to  the 
decisions of countries and authorities in Israel and around the world that 
may affect Yes accordingly. For this matter see also Section 5.18.1.2 and the 
Company's reference in Sections 2.20.11 and 2.20.14. 

Damage caused by nature, war, disaster - damage to Yes infrastructure and 
services as a result of natural disasters, including earthquakes, as well as as 
a result of war or disaster, may adversely affect its business and results. 

Damage  to  electricity  supply  -  Damage  to  the  electricity  supply  to  Yes’s 
facilities for various reasons (some of which are described in Section Error! 
The source of the reference was not found.) may have a negative effect on 
Yes’s business and damage Yes’s ability to provide services. Some of Yes’s 
systems have power backup, but at the same time, in the event of prolonged 
damage to some or all of the systems, there may be significant difficulties 
and beyond that in the provision of Yes services, including in the event that 
Yes cannot return the systems to service quickly. 

5.18.2. 

Industry risks 

5.18.2.1 

5.18.2.2 

5.18.2.3 

Dependence  on  licenses  –  Yes’s  satellite  TV  broadcasts  are  provided  in 
accordance with the broadcasting license and through additional licenses, 
and therefore depend on the existence of these licenses and their extension 
from time to time. Violation of the provisions of the licenses, as well as the 
provisions  of  the  law  by  virtue  of  which  the  licenses  were  granted,  may 
result, subject to the conditions set forth in the licenses, to revoke, change, 
suspend or not extend the licenses and consequently materially impair Yes’s 
ability to continue operating in the field. 

Regulation - the provision of satellite television broadcasts is subject to the 
obligations  and  limitations  set  forth  in  the  legislation  as  well  as  to  the 
licensing  regime,  supervision  and  approvals  by  various  regulatory  bodies, 
and may therefore be affected and limited in light of policy considerations 
dictated by these bodies and their decisions (see Section 5.14). Regulatory 
changes  may  affect  Yes’s  activity  and  may  materially  impair  its  financial 
results. The OTT services including those of Yes are not monitored, as of the 
date of the report (for the possibility of arranging these services, see Section 
5.14.2). Continued activity of content providers (and the entry of additional 
providers)  via  the  Internet  as  stated  in  the  Section5.1.1  without  the 
application  of  regulatory  rules  to  their  activities  and  /  or  without 
appropriate  amendment  of  the  regulatory  rules  applicable  to  broadcast 
license  holders,  may  materially  impair  the  financial  results  of  Yes.  In 
addition, Yes’s activity, as a company that provides services to the public, is 
subject,  among  other  things,  to  legislation  in  the  field  of  consumer 
protection as well as to the laws of protection of privacy and information 
security (see Section1.7.7.4 1.7.7.4). 

Fierce competition - the field is characterized by fierce competition with a 
variety of different competitors (see Section 5.1.7), which are also expected 
to  increase  in  the  future  in  the  face  of  the  entry  of  additional  local  and 
international  factors,  as  well  as  a  change  in  consumer  preferences,  that 
requires Yes to constantly and continuously invest in recruiting and retaining 

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customers  and  dealing  with  high  transfer  rates  of  subscribers  between 
companies, and may even require a change in Yes’s business model . For the 
characteristics of competition, see Section5.5. 

local  and 

international  factors, 

Yes’s estimate, as stated in this paragraph above in relation to the possibility 
of  the  entry  of 
is  forward-looking 
information. This assessment is based on DBS's assessments of the state of 
the industry and possible changes in it. This assessment may not materialize 
or partially or otherwise materialize in view of the materialization or non-
materialization  of  plans  by  various  factors  to  enter  into  the  industry,  the 
manner  in  which  they  are  actually  implemented  and  the  conditions  of 
competition that will prevail. 

5.18.2.4 

5.18.2.5 

5.18.2.6 

5.18.2.7 

Technological  developments 
technological 
improvements  and  the  development  of  new  technologies  that  will  make 
existing  technology  inferior,  may  require  Yes  to  make  large  financial 
investments in order to maintain its competitive position (see Section5.1.1). 

improvements 

and 

- 

Alternative infrastructure for multi-channel broadcasts - the activity of the 
DTT system, and in particular its expansion, as well as the deepening of the 
intrusion  of  OTT  operators,  may  harm  the  financial  results  of  Yes  (see 
Section5.1.1). 

Unauthorized viewing - the field of broadcasts is exposed to the "pirated" 
connection of viewers to the reception of the broadcasts, without paying a 
subscription  fee,  and  is  also  exposed  to  the  public's  access  to  content  in 
which the broadcaster has rights. 

Exposure to legal proceedings - Yes is a party to legal proceedings, including 
requests  for  approval  of  class  actions,  which  may  result  in  a  charge  of 
material amounts which cannot be assessed, and for which no provision has 
been made in its statements. These class actions can amount to large sums, 
as a substantial portion of Israel’s residents are Yes subscribers, and a claim 
relating  to  a  small  damage  to  a  single  subscriber  may become  a  material 
claim to Yes, if recognized as a class action applicable to all subscribers or to 
a substantial portion thereof. 

5.18.3. 

Special risks to DBS 

5.18.3.1 

5.18.3.2 

5.18.3.3 

Limitations  as  a  result  of  the  ownership  structure  -  Yes  is  limited  in  its 
cooperation  with  Bezeq 
in  relation  to  the  offer  of  a  basket  of 
communications services in a manner that materially affects Yes’s business 
situation and its competitive capabilities (see Section 5.15.3). 

Restrictions  as  a  result  of  the  eligibility  conditions  -  "cross"  holdings  of 
holders, directly or indirectly, in Yes, as well as a decrease in the holding rate 
of Israeli citizens or residents in Yes, may lead to non-compliance with the 
eligibility  conditions  of  its  broadcasting  license  (including  in  light  of  the 
Israeliness requirement (see Section 5.14.1.1). 

Maintaining a sufficient cash flow - Yes must maintain a sufficient cash flow 
for the purpose of meeting its business plan. The lack of sufficient cash flow, 
including through investment or financing from Bezeq, may adversely affect 
DBS's  business,  as  well  as  make  it  more  difficult  for  it  to  deal  with 
competitive threats in view of technological developments and changes in 
consumption habits in the field. 

According  to  Yes’s  estimate,  it  is  expected  to  continue  to  accumulate 
operating losses in the coming years and therefore without Bezeq’s support 
it will not be able to meet its obligations and continue to operate as a going 
concern.  According  to  Yes,  the  sources  of  financing  available  to  it,  which 
include,  inter  alia,  the  working  equity  deficit  and  the  credit  and  Bezeq’s 
investment framework in equity as stated in Section  הינפהה רוקמ !האיגש
.אצמנ אל, will meet the needs of Yes activity for the coming year. 

5.18.3.4 

Yes  satellite  transmissions  are  made  using  space  segments  of  satellites 
located at the same point in space. In the operation of one of the satellites, 

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damage to one of them or unavailability of space segments in any of the 
satellites, including unavailability of a satellite intended to replace a satellite 
that  has  ceased  to  transmit  or  provide  services  to  Yes  or  termination  of 
segment leasing in any of the satellites may significantly disrupt and reduce 
the volume of satellite broadcasts via satellite, unless an alternative is found 
to the segments of space that are not available as aforesaid and also in view 
of  the  lapse  of  time  until  the  implementation  of  such  an  alternative. 
However,  the  duplication  of  satellites  through  which  transmissions  are 
made to subscribers as of the date of this report, also taking into account 
the  partial  backup  mechanisms  set  forth  in  the  Space  Agreements  (the 
quality and scope of which depend on the identity of the backed satellite), 
significantly  reduces  the  risk  of  damage,  failure  or  unavailability,  and 
improve the survivability of the bulk of the broadcast. In the event of the 
availability  of  such  satellite,  it  will  be  possible,  through  space  segments 
available to Yes on the other satellite, to broadcast the channels broadcast 
by  Yes  (all  or  almost  all)  (for  the  Space  Agreement,  including  backup 
mechanisms determined under it, see Section 5.15.1). However, according 
to Yes, the said duplication of satellites is expected to end in the beginning 
of 2025, and from that period onwards, Yes will operate with one satellite - 
see Section 5.15.1. Yes does not have insurance for loss of revenue caused 
by satellite failure. 

Termination of the receipt of the satellite services, for any reason (including 
due  to  the  end  of  the  agreement  period),  while  a  substantial  part  of  Yes 
subscribers are still satellite subscribers may result in substantial damage to 
Yes revenues. 

The progress of the process of switching to or accelerating transmission via 
the Internet may reduce the vulnerabilities mentioned above involving the 
failure, damage, unavailability or termination of satellite services. 

DBS’s  estimates  as  stated  in  this  paragraph  above  is  forward-looking 
information. This assessment is based on the provision of space segments 
implementation  of  space  backup  mechanisms  and  space 
and  the 
assessments in relation to the useful life of satellites, the beginning of the 
activity of new satellites, the end of the activity of existing satellites and the 
exercise of contracts in relation to them, and possible termination of lease 
of segments of space. This assessment may not materialize or be partially or 
otherwise materialized if there is a change in the useful life of the satellites 
and the exercise of their lease option or if space does not provide Yes with 
alternative segments in the  event  of unavailability or failure of the space 
segments or satellites. 

Dependence on the owner of the rights in the space segments  - Yes has a 
substantial  dependence  on  Space,  as  the  sole  rights  holder  and  the  sole 
supplier of the space segments used by Yes, which is also responsible for the 
operation of the space segments. In relation to Amos 7, the supply of the 
segments of space also depends on the third party who owns the satellite 
and the body responsible for its operation, with whom Space has contracted 
(see  Section5.15  and  on  the  realization  of  its  engagement  with  Space  in 
relation to this satellite until the end of the period determined in a manner 
that  will  allow  the  continued  leasing  of  the  segments  of  space  on  this 
satellite. 

Dependence on software suppliers, equipment, content, infrastructure and 
services - Yes has dependence on software vendors and equipment, as well 
as on certain content vendors (see Sections 5.7.2 and 5.7.5) and receipt of 
certain services, including broadcast encryption services (see Section 5.7.5). 
Failure to receive the products and services provided by them may impair 
the  functioning  of  Yes  and  its  results.  In  addition,  inability  to  purchase 
streamers or receiving support services from current provider, is expected 
to  involve  a  period  of  preparation  that  will  be  required  to  make  the 
alternative engagement and change their supply and support system. 

5.18.3.5 

5.18.3.6 

5.18.3.7 

Impairment  of  the  activity  of  the  broadcasting  centers  and  the  logistics 

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5.18.3.8 

5.18.3.9 

limitation 

center - Impairment of the activity of the broadcasting center may cause a 
significant 
in  the  continuation  of  the  broadcasts,  but 
decentralization of broadcasts to two broadcasting centers (in Kfar Saba and 
the Ella Valley) partially reduces the risk of damaging one of them. In the 
event  of  damage  to  one  of  the  broadcasting  centers,  Yes  will  be  able  to 
continue to broadcast from the other broadcasting center; As far as satellite 
broadcasts are concerned, some of its linear channels as well as the VOD 
service,  and  as  far  as  OTT  services  are  concerned  -  some  of  its  linear 
channels,  while  it  can  continue  to  broadcast  only  the  VOD  service  in  the 
event that the activity of the secondary site is stopped. Each broadcasting 
center has the same satellite encryption system, and therefore there is full 
backup  for  the  encryption  system  in  case  of  damage  to  one  of  the 
broadcasting centers. Damage to the Yes logistics center may also disrupt 
its  operations,  and  in  particular  the  installation  and  maintenance  of  end 
equipment. 

The  assessment  of  Yes  as  stated  in  this  paragraph  is  forward-looking 
information.  This  assessment  is  based  on  the  provision  of  the  provider 
services  that  operate  the  secondary  broadcasting  site  in  the  event  of  an 
injury  to  the  broadcasting  center  in  Kfar  Saba.  This  assessment  may  not 
materialize  or  partially  or  otherwise  materialize  if  Yes  is  not  allowed  to 
receive the services of the said provider in full and properly. 

Failure  of  DBS’s  computer  systems  -  significant  failure  of  DBS's  major 
computer  systems  could  significantly  impair  Yes’s  operational  capacity. 
However,  Yes  has  a  remote  backup  site  designed  primarily  for  storing 
information and providing an internal computing service limited to failures 
in such a way that in the event of a failure of the Yes site's computer systems 
in Kfar Saba, it will be possible to reactivate the central systems through the 
backup site. 

Yes’s  assessment  in  relation  to  the  backup  capability  as  stated  in  this 
paragraph  is  forward-looking  information.  This  estimate  is  based  on  the 
functionality  of  the  remote  backup  site.  This  assessment  may  not 
materialize or partially or otherwise materialize if such functionality is not 
possible. 

Cyber  risks  -  Yes  is  exposed  to  the  risk  of  the  occurrence  of  an  activity 
intended to harm the use of a computer or computer material stored on it 
("cyber  attack").  Such  attacks  can  disrupt  business,  cause  theft  of 
information / money, damage databases and subscriber privacy, damage to 
reputation, damage to systems and information leakage, which may also be 
caused  by  an  intentional  or  inadvertent  internal  factor.  As  a  leading 
company in the field of subscriber television broadcasting, Yes is a target for 
cyber  attacks  and  experiences  cyber  attacks,  which  are  handled  by  its 
information security and cyber protection teams. 

DBS has defined a policy for cyber risk management that establishes guiding 
principles  for  cyber  protection,  which  refer,  among  other  things,  to  the 
confidentiality  of  information,  the  reliability  of  information  and  the 
availability of information in connection with the implementation of cyber 
protection  in  the  following  aspects:  organizational  framework,  cloud 
computing,  human  resources  and  security,  physical  and  logical  cyber 
protection  in  processes  ,  in  systems  and  infrastructures.  The  person 
responsible for implementing the policy in  Yes is the information security 
manager. 

Yes  also  implements  standards  for  managing  cyber  risks  and  information 
security,  as  well  as  a  protection  policy  that  includes  layers  of  protection, 
starting  with  managers  and  policies,  and  ending  with  physical  layers  of 
defense  systems  against  cyber  attacks,  which  are  operated 
in  a 
configuration that combines effective security with the operational needs 
of  Yes,  with  the  aim  of  protecting  its  infrastructure  and  systems  and 
reducing the possibility of illegal exploitation of its resources. In addition, 
there are tools for attacking and detecting information security weaknesses 

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that operate automatically and help discover information security loopholes 
and weaknesses. Yes has an annual work plan in connection with reducing 
the exposure resulting  from the cyber risk  while  carrying  out  control and 
monitoring of actual implementation. 

Yes  also  periodically  performs  information  security  surveys,  risk  surveys, 
penetration tests, attack drills, as well as other actions for the purpose of 
examining the effectiveness of the risk management policy in dealing with 
and  reducing  cyber  risk,  as  well  as  control  over  examining  the  way  cyber 
risks  are  managed  through  internal  audits.  In  addition,  Yes  allocated 
resources  to  manage  cyber  risks  through  the  establishment  of  an 
information  security  system  consisting  of  professional  employees  in  the 
field. 

Yes’s Board of Directors is involved in and supervises the management of 
cyber  risk  at  Yes  within  the  framework  of  handling  the  overall  risk 
management policy of Yes. 

Despite Yes’s actions investments in measures to reduce such risks,  Yes is 
unable  to  guarantee  that  these  measures  will  in  practice  succeed  in 
preventing a cyber attack and/or damage and / or disruption to the systems 
and information related to them. 

Technical limitation that prevents the offering of integrated services – Yes’s 
satellite infrastructure suffers from technical limitations compared to Hot 
infrastructure  as  well  as  to  the  Internet  infrastructure.  The  technical 
limitation  prevents  Yes  from  providing  telephony,  Internet  and  various 
interactive  services,  including  VOD,  on  its  satellite  infrastructure,  and 
therefore their supply depends on third parties. 

Defects in the encryption system or its bypass – Yes’s broadcasts via satellite 
and  via  the  Internet,  are  based  on  the  encryption  of  the  broadcasts 
transmitted by it, including the encoding of its satellite broadcasts using the 
"smart cards" installed in the decoders in the satellite subscribers’ houses. 
Defects in its encryption system or hacking or bypassing it may allow free 
viewing of Yes broadcasts, thereby leading to a decrease in revenue, as well 
as a breach of agreements between DBS and its content providers. 

Lack of exclusivity in the field of frequencies - the field of frequencies used 
by DBS to transfer satellite transmission from the transmission satellites to 
the reception dishes installed in the subscribers' homes, and which has been 
allocated under a license by the Ministry of Communications, is defined as 
a frequency range that an Israeli entity that may make authorized use of in 
the field of frequencies. If the holder of the main allotment uses the above-
mentioned frequencies, disruptions in the quality of the Yes broadcasts and 
/ or the availability of the broadcasts to the subscriber may result in damage 
to the financial results of Yes. As of the date of this report, to the best of 
Yes’s knowledge, no holder of the main allotment used the said frequencies 
in  a  manner  that  caused  actual  and  /  or  persistent  interruptions  in  Yes’s 
broadcasts. 

Interference  for  transmissions  -  since  Yes  transmissions  via  satellite  are 
transmitted  wirelessly  from  the  transmission  centers  to  the  transmission 
satellites and from there to the reception dishes in the subscribers' houses, 
transmission  of  wireless  signals,  in  the  same  frequency  range,  whether 
originating in Israel and abroad, and extreme weather conditions of heavy 
rain, hail or snow may cause disruptions in the quality and / or availability 
of  the  broadcasts  via  the  satellite  provided  by  Yes  to  the  subscriber  and 
material  damage  to  its  financial  results.  In  relation  to  broadcasts  via  the 
Internet, there may be disruptions in the quality and / or availability of the 
broadcasts  as  a  result  of  disruptions  or  unavailability  of  the  Internet 
infrastructure. 

5.18.3.10 

5.18.3.11 

5.18.3.12 

5.18.3.13 

5.18.3.14 

Labor relations - Yes is a party to a collective agreement with the Histadrut 
and  the  Employees’  Committee,  which  may  reduce  its  administrative 
flexibility (see Section 5.10.3). In addition, In addition, disruptions in labor 

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5.18.3.15 

5.18.3.16 

relations at Yes, and possibly also at other Bezeq subsidiaries, could cause 
damage to Yes’s day-to-day operations. 

Loss of knowledge and information  - The changes that are taking place in 
the labor market in Israel and around the world, along with organizational 
changes, entail risks for the loss of key employees, loss of knowledge as a 
result of employee turnover and difficulty in recruiting employees, etc. 

Delay  in  improving  internet  browsing  speeds  -  as  Yes’s  outline  for  the 
transition  to  OTT  broadcasting  (see  Section0)  is  also  based  on  an 
improvement in Internet  browsing speeds, nationwide, failure to improve 
browsing  speeds  through  the  deployment  of  fiber  optics  or  through  the 
implementation of another technological solution, by the Company or other 
communications operators, can delay the implementation of the layout or 
impair its implementation. 

DBS  assessments  as  to  the  browsing  speeds  required  to  enable  OTT 
broadcasts as designed in an outline in a way that enables the operation of 
several  converters  in  a  customer's  home  is  forward-looking  information. 
These  estimates  are  based  on  the  expected  development  in  browsing 
speeds,  taking  into  account,  among  other  things,  the  expected  needs  of 
customers' homes and the expected mix of broadcasts. These assessments 
may not materialize or materialize differently if there is a delay in improving 
Internet browsing rates or a change in customer needs or Yes. 

Below is a presentation of the risk factors according to their influence in the 
opinion of the Yes’s Management. It should be noted that the following DBS 
assessments regarding the extent of the risk factor's impact on Yes reflect 
the extent of the risk factors’ impact in assuming the materialization of the 
risk factor, and the aforesaid does not express any assessment or give any 
weight  to  such  prospects.  In  addition,  the  order  in  which  the  risk  factors 
appear above and below is not necessarily according to the risk inherent in 
each risk factor or the probability of its occurrence.90: 

Risk Factors Summary Table - Multi-Channel TV  

Macro risk 
Financial risks 
Recession / economic slowdown / security situation 
Pandemic 
Damage caused by nature, war, disaster 
Damage to electricity supply 
Industry risk 
Dependence on licenses 
Changes in regulation 
Fierce competition 
Technological developments and changes 
Alternative infrastructures  
Unauthorized viewing  
Exposure to legal proceedings 
Unique risk 
Limitations as a result of the ownership structure 
Restrictions due to eligibility conditions 
The need to maintain a sufficient cash flow 
Satellite failure and damage 
Dependence on the supplier of space segments 
Dependence  on  software,  content,  equipment  and 

The degree of influence 
Small 
Medium 
High 

X 

X91 

X 

X 
X 

X 
X 
X 

X 
X 
X 
X 
X 

X 
X 
X 
X 

X 

90 See Footnote 51. 
91 The extent of the effect of this risk factor on Yes’s activity was classified as moderate, assuming that the event would be limited 
in scope and time. Otherwise, the degree of impact may be large. 
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The degree of influence 
Small 
Medium 
High 

infrastructure vendors 
Impairment of the activity of the broadcast centers  
Failure of computer systems 
Cyber failures 
Technical limitation that prevents the offer of integrated 
services 
Encryption system failure 
Lack of exclusivity in frequencies 
Interference with transmissions 
Work relations 
Loss og knowledge and information 
Delay in improving internet browsing rates  

X 
X 
X 

X 

X 

X 

X 

X 

X 

X 

The information contained in this section 5.18 and Yes’s assessments regarding the impact of risk 
factors  on  Yes’s  activities  and  business,  are  forward-looking  information  as  defined  in  the 
Securities Law. The information and assessments are based on data published by the regulatory 
bodies, on Yes’s assessments of the market situation and its competitive structure, on possible 
developments  in  the  Israeli  market  and  economy,  and  on  the  factors  specified  in  this  section 
above. The actual results may differ materially from the estimates given above if there is a change 
in one of the factors taken into account in these estimates. 

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6. 

The Company 

6.1. 

Financing 

6.1.2. 

The Company's debentures 

For details about the debentures issued by the Company, see Note 13 to the consolidated 
statements and Section 4 to the Board of Directors' report.  

6.1.3. 

Credit rating  

On June 19, 2023, Midroog Ltd. established an A3.il rating with a stable horizon for the 
Company's debentures (series C) and (series F) that were in circulation as of that date, as 
well as a stable horizon for additional debentures (series F) to be issued by the Company 
in the amount of up to NIS 550 million by way of series expansion. 

6.2. 

Legal proceedings 

6.2.1. 

6.2.2. 

In June 2017, two motions for approval of a class action lawsuit, in the total amount of 
NIS  1.8  billion,  were  filed  against  the  Company,  Bezeq,  officers  in  the  Group  and 
companies from the then controlling group in Bezeq regarding the purchase of Yes shares 
by Bezeq from Eurocom. On May 23, 2023, the Company signed a settlement agreement 
(“the Settlement Agreement") in connection with the 2 motions mentioned above, and 
according to it, without  admitting any of the claimed fraud, including the existence of 
misleading  details  in  the  reports  or  statements  of  Bezeq  and/or  the  Company,  the 
responsibility  of  any  of  the  respondents  to  the  alleged  misleading  details,  the  alleged 
damages or the entitlement of the members of the classes to the claimed remedies, the 
Company  agreed  to  pay  as  follows:  (a)  to  the  members  of  Class  A  defined  in  the 
settlement agreement as "everyone who purchased Bezeq shares in the period between 
February 11, 2015 and June 19, 2017, with the exception of the respondents or anyone 
on their behalf" - a total amount in shekels equal to 1,500,000 US dollars; (b) to members 
of Class B defined in the settlement agreement as "everyone who purchased shares of 
the Company on the Tel Aviv Stock Exchange Ltd. starting on May 21, 2015 at 13:00 until 
June 19, 2017 (inclusive)" - a total amount in shekels equal to 2,850,000 US dollars. 

In  addition,  as  part  of  the  Settlement  Agreement,  the  parties  recommended  that  the 
Company pay compensation to the applicants, their attorney fees, and additional costs in 
connection with the execution of the Settlement Agreement. The total amount that the 
Company 
including  the 
compensation amounts for the classes as detailed above, amounts to a total in NIS equal 
to USD 5,500,000. The aforementioned settlement amount does not include the offset of 
the insurance company's participation by virtue of officers' insurance. 

is  expected  to  pay  under  the  Settlement  Agreement, 

On  August  23,  2023,  the  Attorney  General  submitted  his  reference  to  the  Settlement 
Agreement  according  to  which  there  is  no  objection  from  his  side  to  the  Settlement 
Agreement,  along  with  several  comments  on  the  merits  of  the  matter.  On  August  31, 
2023, Bezeq and some of the respondents submitted a motion to the Court to schedule a 
hearing on the Settlement Agreement. Following a number of interim motions that were 
submitted,  on  January  8,  2024,  a  discussion  regarding  the  Settlement  Agreement  was 
held, in which a number of comments on the substance of the matter were received from 
the Attorney General, and in accordance with the Court's decision, the parties must make 
a  number  of  Changes  to  the  Settlement  Agreement  and  its  submission,  including  the 
addition of an opinion, without the  Settlement Agreement being changed by the Court 
until March 17, 2024. 

In  November  2020,  a  claim  was  filed  with  the  Tel  Aviv  District  Court  (Economic 
Department) accompanied by a motion for approval as a class action by a private person 
who claims to be a shareholder of Bezeq ("the Applicant") against the Company, Bezeq 
and  members  of  Bezeq’s  Board  of  Directors  ("the  Respondents").  The  matter  of  the 
motion  is  the  approval  of  a  class  action  for  compensation  of  the  Applicant  and  the 
members of the represented group for damages caused to them, according to the motion, 
"due to Bezeq's failure to report and disclose to the Tel Aviv Stock Exchange (hereinafter: 
"TASE") and the concealment of material information from investors, in connection with 
a public report on "the Ministry of Communications' moves to eradicate the phenomenon 
of dual subscribers in the field of ISP Internet services, on the extensive and substantial 
scope  of  the  phenomenon  of  dual  subscribers  in  the  Bezeq  International  subsidiary 

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6.2.3. 

(hereinafter: "Bezeq International") and their material negative impact on the business 
of  the  subsidiary  and  Bezeq".  The  definition  of  the  group  according  to  the  motion  is 
anyone who purchased the Bezeq shares from August 17, 2020 until October 30, 2020 
and  held  the  above  shares  or  some  of  them  on  October  30,  2020,  except  for  the 
respondents  and  /  or  those  on  their  behalf  and  /  or  entities  related  to  them.  In  the 
application, the damage caused to the group members as a result of the incidents that 
are the subject of the lawsuit amounts to approximately NIS 55 million to NIS 65 million, 
based on an expert opinion attached to the motion. 

On November 30, 2022, the applicant's summaries were submitted, and in accordance 
with  the  Court's  decision,  on  March  29,  2023,  the  respondents'  summaries  were 
submitted, and on April 24, 2023, response summaries were submitted on behalf of the 
applicant. 

In  November  2020,  a  lawsuit  was  filed  in  the  Tel  Aviv  District  Court  (Economic 
Department)  with  motion  for  approval  as  a  class  action  by  a  private  individual  ("the 
Applicant")  who  claims  is  a  shareholder  of  the  Company  who  claims  to  hold  the 
Company's  shares  and  Bezeq  shares,  against  the  Company,  Bezeq  and  72  other 
respondents,  which  include  past  and  present  officers  in  the  two  companies  ("the 
Respondents").  The  matter  of  the  application  is  the  approval  of  a  class  action  for 
compensation of the Applicant and the members of the represented groups for damages 
caused  to  them,  as alleged  in  the  motion,  as  a  result  of  the  Respondents'  actions  and 
omissions when they refrained from disclosing to the investing public seemingly material 
information  that  they  had  to  disclose  in  accordance  with  the  provisions  of  the  law,  in 
connection with the two companies' report dated November 9, 2020 according to which 
Bezeq International books have unexplained net  asset  balances (deductible) of tens of 
millions of NIS, whin a significant portion of them otiginate, apparently, in past periods of 
more than 15 years. The definition of the groups according to the motion is: (a) Anyone 
who purchased Bezeq shares from November 8, 2005 to November 9, 2020, except the 
Respondents or those  on their behalf and (b) Everyone who purchased the Company's 
shares  on  the  Tel  Aviv  Stock  Exchange  from  November  8,  2007  to  November  9,  2020, 
except the Respondents or those on their behalf. The amount of the class action specified 
in the statement of claim is "over NIS 2.5 million (for matters of substantive authority)" 
when in accordance with the economic opinion that was attached to the motion, "the 
estimate for the drop in the price of the security" in respect of the information included 
in the immediate report dated November 9, 2020 is 5.26%-5.40% in relation to Bezeq and 
9.07% - 9.36% in relation to the Company. 

In  July  2022,  the  applicant,  Bezeq  and  the  Company  submitted  a  notice  regarding  a 
motion  for  a  mediation  procedure  and  a  motion  for  the  approval  of  a  negotiated 
settlement, in which they announced that in the conversation that took place between 
them, they agreed on holding a mediation process ("the Negotiated Settlement"). The 
Court  approved  the  aforesaid  settlement,  and  accordingly,  the  parties  began  holding 
mediation proceedings, and according to the Court’s decision, they must act to exhaust 
the procedure within 3 months and submit an update on the matter by April 2, 2024. 

__________________________________ 
B Communications Ltd. 

March 12, 2023 
Date 

Names and roles of the signatories: 
Darren Glatt, Chairman of the Board of Directors 
Tomer Raved, CEO 

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7.  Appendix A - Glossary 

A.  Abbreviated names for pieces of legislation that appear in the report  

Consumer Protection 
Law 

Economic 
Competition Law 

-  Consumer Protection Law, 5741-1981 

-  Economic Competition Law, 5748-1988 

Companies Law 

-  Companies Act, 5769-1999 

Non-Ionizing 
Radiation Law 

-  The Non-Ionizing Radiation Law, 5776-2006 

Centralization Law 

-  Law for the Promotion of Competition and the Reduction of Centralization,  5774-

2013 

Second Authority Law 

-  Second Television and Radio Authority Law, 5755-1990 

Planning and 
Construction Law 

-  Planning and Construction Law, 5725-1965 

Communications Law 

-  The Communications (Bezeq and Broadcasting) Law, 5742-1982 

Securities Law 

-  Securities Law, 5728-1968 

Rules of 
communication 

Rules of Communication (Holder of a Broadcasting License), 5747-1987 

- 

Telegraph Order 

- Wireless Telegraph Order [New Version], 5732-1972 

General Permit 
Regulations 

Usage regulations 

Communications  Regulations  (Bezeq  and  Broadcasting)  (General  Permit  for  the 
Provision of Bezeq Services), 5782-2022 

Communications  (Bezeq  and  Broadcasting)  Regulations  (Use  of  an  NIO’s  Public 
Network), 5775-2014 

The Communications 
Order 

- 

Communications  Order  (Bezeq  and  Broadcasting)  (determination  of  an  essential 
service  provided  by  Bezeq,  The  Israel  Telecommunications  Company  Ltd.),  5777-
1997 

Prospectus Details 
Regulations 

-  Securities Regulations (Prospectus Details, Draft Prospectus Structure and Form), 

5729-1969 

Reciprocal linking 

-  Communications  Regulations  (Bezeq  and  Broadcasting)  (Payments  for  Reciprocal 

regulations 

Satellite Broadcasting 
License Regulations 

Linking), 5764-2000 

-  Communications Regulations (Bezeq and Broadcasting) (Procedures and Conditions 

for Licensing Satellite Broadcasting), 5758-1998 

B.  Technological terms and other key terms appearing in the report92 

Statistical area 

Internet Gold  

Bezeq Online  

Bezeq International 

Golan telecom 

- 

- 

- 

- 

- 

A  continuous  area  unit  created  from  a  geographic-statistical  division,  as 
ordered by the Minister of Communications according to Aarticle 14f of the 
Communications Law; The division into statistical areas is based on the CBS. 

Internet Gold Gold Lines  

Bezeq online Ltd. 

Bezeq International Ltd 

Golan Telecom Ltd. 

92 It should be noted that the definitions of the terms are provided for the convenience of the reader, and are not necessarily 
identical to the definitions in the Communications Law or its regulations.  

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2023 statements 

- 

Interconnectivity fee  

- 

Yes 

Hot  

Hot Telecom 

Hot Mobile 

The Histadrut 

Council 

The Second Authority 

Walla 

Space 

Eurocom DBS 

Eurocom 

Communications 

Switching  

Mbps 

NIO 

Roaming 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

Network endpoint 

- 

The  Company's  consolidated  financial  statements  for  the  year  ended 
December 31, 2023  

The interconnectivity fee (also called the call completion fee) is a payment 
that  one  operator  pays  to  another  operator  for  a  reciprocal  link  (see 
definition below)  

Yes Television and Communications Services Ltd. 

Hot Communications Systems Ltd., and corporations under its control that 
operate in the field of broadcasting (multi-channel television) 

Hot Telecom Limited Partnership 

Hot  Mobile  Ltd.  (formerly  MIRS  Communications  Ltd.)  and  corporations 
under its control 
The New General Workers' Union  

Cable and Satellite Broadcasting Council 

The Second Television and Radio Authority  

Walla! Communications Ltd. and corporations under its control 

Space Communications Ltd. 

Eurocom DBS Ltd. 

Eurocom Communications Ltd. 

In  the  context  of  a  communications  network  -  a  telephony  system  that 
supports the connection of devices for transferring calls between different 
end units  

Megabits per second; Measurement unit for data transfer speed 

National interior operator; A body that provides landline interior telephony 
services under a general or unique NIO license 

Roaming  services  allow  a  customer  of  one  communication  network  to 
receive  services  from  another  communication  network  other  than  his 
"home network" (the network with the license he subscribes to), based on 
roaming agreements between the home network and the host network 

Network  endpoint  -  an  interface  to  which  one  is  connected,  on  the  one 
hand a public Bezeq network and on the other hand end equipment or a 
private  network.  Network  endpoint  services  include  the  supply  and 
maintenance of equipment and services in the customer's premises 

Authorized provider 

Bezeq license holder or registered in the registry maintained according to 
Article 4A1 of the Communications Law 

Cellcom 

Pelephone 

Partner 

Interconnectivity 

Mobile radio 

- 

- 

- 

- 

- 

Cellcom Israel Ltd. and corporations under its control 

Pelephone Communications Ltd. 

Partner Communications Ltd. and corporations under its control 

Interconnectivity  enables  the  transmission  of  instant  messages  between 
subscribers  of  different  licensees,  or  the  provision  of  services  by  one 
licensee to the subscribers of another licensee; Interconnectivity is possible 
through a connection between a public Bezeq network of one licensee (for 
example - Bezeq) and a public network of another licensee (for example - a 
cellular operator); See also " Interconnectivity Fee" Definition 

Mobile radio telephone phone; Cellular telephony 

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telephone 

NIO license 

Mobile Radio license 

Broadcasting license 

ILA 

Rami Levy 

Advanced network 

- 

- 

- 

- 

- 

Unique  general  or  general  license  for  the  provision  of  landline  interior 
Bezeq services 

General license for the provision of mobile radio telephone services - in the 
cellular method 

License for satellite television broadcasts 

Israel Lands Authority 

Rami Levy Cellular Communications Ltd. 

A network based on optical fibers that reach a network endpoint in an end 
user's apartment, or an equivalent network in terms of the level of service 
that can be provided over it according to standards ordered by the Minister 
and published on the website of the Ministry of Communications; For this 
purpose,  "apartment"  -  a  room  or  cabin,  or  a  set  of  rooms  or  cabins 
intended to be used as a complete and separate unit for living, business, or 
any other need, including a detached apartment 

Traditional network 

Non-advanced Bezeq network 

Bezeq services 

- 

A service that is one of the following, provided to the general public or a 
part of it through the Bezeq network: 

Internet access 
service 

Data transfer 
services 

Telephone service 

On-demand viewing 
services 

Reporting period 

Bitstream Access 
(BSA) 

xDSL 

DTT 

GSM 

HD 

- 

- 

- 

- 

- 

- 

- 

(1) Telephony service; 

(2) Internet access service; 

(3) Data transfer service; 

(4) Another service listed in the First Schedule 

A service that can be provided to subscribers for consideration, in money 
or  money  equivalents,  that  allows  them  to  link  to  the  endpoints  of  the 
Internet network that are accessible to the general public 

Network  services  for  data  transfer  from  point  to  point,  data  transfer 
between  computers  and  various  communication  networks  and  remote 
business access services 

A service that allows the transfer or reception of a Bezeq message based 
on a number according to the numbering plan 

Services  that  allow  viewing  content  when  it  is  not  broadcast,  including 
VOD,  Catch Up (viewing content  that has been broadcast, until a certain 
period  of  time  has  passed since  the  time  of  its  original  broadcast),  Start 
Over  (the  possibility  to  go  back  and  watch  content  from  the  beginning), 
recording and saving content in the cloud 

Twelve months ended December 31, 2023 

Managed broadband access that allows provider services to connect to the 
infrastructure owner network and offer broadband services to subscribers 

Digital Subscriber Line - technology that uses the copper wires of telephone 
lines to transmit data  at high rates by using frequencies higher than the 
audible frequency and therefore allows simultaneous use of call and data 
transmission 

Digital Terrestrial Television- Wireless digital broadcasting of TV channels 
via terrestrial relay stations 

Global  System  for  Mobile  Communications  -  International  Standard  for 
Cellular Communication Networks ("2G") 

High Definition TV - High definition (broadcast) TV broadcasts 

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HSPA 

IBC 

ICT 

IP 

IPVPN  

ISP 

LTE 

MVNO 

NGN 

UMTS 

VoB 

VOD 

VoIP 

Wi-Fi 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

High Speed Packet Access - Cellular technology that is a continuation of the 
UMTS standard that enables data transfer at high speeds ("3.5G") 

ABC Israel Broadband Company (2013) Ltd.  

Business integration service (Information and communications technology) 

Internet Protocol. The use of this protocol enables convergence between 
voice (data) and contractual (video) services over the same network 

A virtual private network (Virtual Private Network) based  on an Internet 
Protocol (IP) which is established on the public network, and through which 
it is possible to: (a) allow end users to connect to the corporate network 
and  perform  remote  access;  And  -  (b)  make  a  connection  between  the 
branches of the organization (intranet) 

Internet Service Provider - has a special license to provide Internet access 
services  (Internet  Service  Provider).  The  Internet  access  provider  is  the 
body  that  allows  the  end  user  to  connect  to  the  IP  /  TCP  protocol  that 
connects it to the global Internet network 

Long  Term  Evolution  -  Fast  WIFI  mobile  standard  devices  such  as  cell 
phones 

Mobile Virtual Network Operator - a virtual cellular operator, which uses 
the existing communication infrastructure of the cellular operators without 
the need for its own infrastructure 

Next Generation Network - Bezeq's communications network based on IP 
architecture 

Universal Mobile Telecommunications System - an international standard 
for  cellular  communications  that  is  a  development  of  the  GSM  standard 
("3G")  

Voice  Over  Broadband  -  Telephony  services  and  related  services  in  IP 
technology using landline broadband access services 

Video on Demand - TV services on demand by the subscriber 

Voice over Internet Protocol - technology that enables the transmission of 
voice messages (telephony service delivery) via IP protocol 

Wireless Fidelity - Wireless access to the Internet in the local area 

169

 
 
 
 
 
 
Chapter A (Description of the Corporation's Business) for the 2023 Periodic Report 

8. 

Appendix  B  -  Financial  Indices  and Operational Performance  Indices  (Key  Performance 
Indicators) 

General  

The indices below, which are specified in the chapters of Bezeq’s periodic report, are financial indices that 
are not defined or detailed in generally accepted accounting principles included in the financial statements. 
The definition of the indices and / or how they are calculated may change from time to time, they do  not 
constitute a substitute for indices based on accepted accounting rules and they may not even be calculated 
in the same way as parallel indices in other companies. 

Details will be provided below in relation to the aforesaid indices, including in accordance with the update of 
the  decision  of  the  Securities  Authority  99-6  regarding  the  use  of  financial  indices  that  are  not  based  on 
generally accepted accounting rules. 

Financial indices 

EBITDA 

(Earnings Before Interest, Taxes, Depreciation and Amortization) EBITDA is defined as profit before financing 
expenses (revenue), taxes, depreciation and amortization. The EBITDA index is an accepted index in the field 
of the Company's activity which neutralizes aspects due to differences in the capital structure, various aspects 
of taxation and the manner and period of the reduction of  property, plant  and  equipment and intangible 
assets.  The  Company's  EBITDA  is  calculated  as  operating  profit  before  depreciation,  amortization  and 
impairment (ongoing losses from impairment of property, plant and equipment and intangible assets). As of 
January  1,  2019,  and  for  the  purpose  of  adequately  presenting  economic  activity,  the  Company  presents 
ongoing losses from impairment of property, plant and equipment and intangible assets in the DB and Walla 
under depreciation and amortization, as well as ongoing losses from impairment of broadcasting rights under 
operating expenses and general expenses (in the statement of income). 

Free flow (Free Cash Flow - FCF) 

The Company's free cash flow is calculated as cash arising from current activities less cash for the purchase / 
sale of property, plant and equipment and intangible assets (net) and as of 2018, with the application of a 
IFRS16 standard, payments for leases are also deducted. The free cash flow index is an accepted index in the 
field of the company's activity in general and it represents the cash that the Company is able to produce after 
the investment needed to maintain or expand its asset base. 

Operational performance indices (Key Performance Indicators) 

ARPU (Average Revenue Per User) 

The ARPU reflects the average monthly revenue per line / subscriber / parent house and is calculated as the 
monthly average distribution of the total relevant  revenue for the period in the average number of active 
lines / subscribers / households in that period, as applicable. It will be clarified that the Group has four main 
areas of activity that correspond to the corporate division between the Group companies and the definition 
of a different active subscription between the areas of activity. 

Churn rate 

The churn rate reflects the Company's ability to retain its customer base and is calculated as the distribution 
of the number of lines / subscribers / households that disconnected from the Company's services during the 
period in the average number of active lines / subscribers / households in that period, as applicable. It will be 
clarified that the Group has four main areas of activity that correspond to the corporate division between the 
Group companies and the definition of a different active subscription between the areas of activity. 

170

 
 
 
 
 
Chapter B 
Report of the Board of Directors  
On the State of Affairs of the Corporation 

For the Year Ended December 31, 2023

 
 
 
 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year 
ended December 31, 2023 

The Board of Directors of B Communications Ltd. (“the Company") is honored to submit the Board of Directors' 
report  on  the  State  of  the  Company  and  consolidated  for  all  Group  Companies  (the  Company  and  the 
Subsidiaries will be collectively referred to hereinafter as: "the Group"), for a period of a year ended December 
31, 2023 (“the Report Date") in accordance with the Securities Regulations (Periodic and Immediate Reports), 
5730-1970 ("the Reporting Regulations").  

For  the  investigation  by  the  Securities  Authority  and  the  Israel  Police,  see  Note  1.3  to  the  Company’s 
statements. 

The auditors drew attention to this in their opinion on the statements. 

The Group reports on four main operating segments in its statements, as follows: 

1.  Landline interior communication 
2.  Cellular communication 
3. 

Internet and international communications services and ICT solutions (hereinafter: "Bezeq International 
Services") 
4.  Multichannel TV 

On  April  23,  2023,  the  name  of  DBS  Satellite  Services  (1998)  Ltd.  was  changed  to  Yes  Television  and 
Communication Services Ltd. (hereinafter: "Yes"). 

The following are the Group's consolidated results: 

2023 

2022 

Increase/decrease 

NIS millions 

NIS millions 

NIS millions 

% 

 Net profit 

EBITDA* 

Adjusted EBITDA* 

1,054 

3,616 

3,806 

Adjusted net profit* 

1,212 

891 

3,493 

3,724 

1,087 

163 

123 

82 

125 

18.3 

3.5 

2.2 

11.5 

* Financial indices that are not based on generally accepted accounting principles, see below. 

The net profit was affected, among other things, by a decrease in other operating expenses and the cancellation 
of the expenses on the fiber deployment incentive fund in the Group, an increase in the net profit of Yes, as 
well as a decrease in financing expenses in the landline national interior communications segment, offsetting 
an increase in salary expenses. 

For more information, see Chapter 1.2 below. 

1 

 
 
 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year 
ended December 31, 2023 

* Financial indices that are not based on generally accepted accounting principles 
As of the Report Date, the Group's Management is assisted by financial performance indices that are 
not based on the generally accepted accounting rules for examining and presenting the Group's financial 
performance.  These  indices  do  not  constitute  a  substitute  for  the  information  contained  in  Bezeq’s 
statements. 

The following is a breakdown of the indices: 

Index 

Details of the method of calculation and the purposes of the index 

EBITDA 
(Earnings Before 
Interest, Taxes, 
Depreciation and 
Amortization) 

Adjusted EBITDA 

Adjusted 
profit 

net 

Defined  as  profit  before  financing  income  (expenses),  financing,  taxes, 
depreciation, and amortization. 
The EBITDA index is an accepted index in the Group’s field of activity which 
neutralizes aspects due to differences in the capital structure, various aspects 
of taxation and the manner and period of the amortization of property, plant 
and  equipment  and  intangible  assets.  The  Group's  EBITDA  is  calculated  as 
operating profit before depreciation, amortization, and impairment (including 
ongoing  losses  from  impairment  of  property,  plant  and  equipment  and 
intangible assets as described in Notes 3.7, 10.5, and 10.6 to the Statements). 
Calculated as an EBITDA index net of the other operating expenses / income 
item, net, and one-off losses / profits from impairment / increase in value and 
expenses in respect of the equity compensation plan. 
The index allows comparisons of operational performance between different 
periods while neutralizing the effects of exceptional expenses / income of a 
one-off nature. 
It should be noted that the adjusted EBITDA index should not be compared to 
indices with a similar name reported by other companies due to a possible 
difference in the way the index is calculated. 
Defined as net profit neutralizing other operating expenses/income, net after 
tax  and  one-off  losses/gains  from  depreciation/appreciation  after  tax,  and 
expenses  for  the  equity  compensation  plan.  The  index  allows  performance 
comparisons  between  different  periods  while  neutralizing  the  effects  of 
unusual expenses/income of a one-off nature. 

The following is a breakdown of the calculation of the indices: 

Operating profit 

Depreciation, amortization, and impairment 

EBITDA 

Other operating expenses, net 

Equity compensation plan expenses 

Adjusted EBITDA 

Net profit 

Other operating expenses, net after tax 

Equity compensation plan expenses 

Adjusted EBITDA 

2023 

2022 

NIS millions 

1,625 

1,868 

3,493 

220 

11 

3,724 

2023 

2022 

NIS millions 

891 

185 

11 

1,087 

2 

1,749 

1,867 

3,616 

180 

10 

3,806 

1,054 

148 

10 

1,212 

 
 
 
 
 
 
 
Report of the Board of Directors on the state of affairs of the corporation for the Year ended December 31, 2023 

1. 

Explanations by the Board of Directors on the state of the corporation's business, the results of its operations, shareholders' equity, cash flows and other matters 

1.1 

Financial position - Assets 

December 
31, 2023 

December 
31, 2022 

Increase (decrease) 

NIS millions 

% 

NIS millions 

% 

1,892 

1,727 

165 

9.6 

2,089 

2,189 

 )100( 

 )4.6( 

Explanation 

For more information, see Chapter 1.4 below. 
The decrease was mainly due to the cancellation of an insurance indemnity balance for a provision for a 
claim in the landline national interior communications segment. 

82 

85 

 )3( 

124 

1,746 

6,542 

286 

3,251 

29 

 )3.5( 

7.1 

4.4 

0.9 

The increase was due to the Bezeq International services segment, mainly from the cost of additional 
contracts  that  came  into  force  as  well  as  from  an  increase  in  the  consumer  price  index,  offsetting  a 
decrease mainly in the cellular communication segment due to current depreciation expenses. 
The increase was due to the Bezeq International services segment, mainly from the cost of additional 
contracts  that  came  into  force  as  well  as  from  an  increase  in  the  consumer  price  index,  offsetting  a 
decrease mainly in the cellular communication segment due to current depreciation expenses. 
The increase was mainly due to the landline national interior communications segment, among other 
things due to the progress of the fiber network deployment project. 

Cash and 
current 
investments 
Current and 
non-current 
trade 
receivables 
Inventory 

1,870 

6,828 

Right-of-use 
assets 
Property, 
plant and 
equipment 
Intangible 
assets 
Deferred 
expenses 
and non-
current 
investments 
Total assets  16,353 

3,280 

312 

315 

 )3( 

 )1.0( 

15,855 

498 

3.1 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the state of affairs of the corporation for the Year ended December 31, 2023 

1.1. 

Financial position – Liabilities and equity 

Debt to financial institutions and 
bondholders 

December 
31, 2023 
NIS millions 

December 
31, 2022 
% 

Increase (decrease) 

NIS millions 

% 

8,903 

9,178 

(275) 

(3.0) 

Liabilities in respect of leases 
Trade payables 

Employee benefits 

2,041 

1,908 

133 

7.0 

1,758 

1,598 

160 

10.0 

583 

600 

(17) 

(2.8) 

Provisions 

Deferred tax liabilities 
Other liabilities 

Total liabilities 
Non-controlling interests 
Total equity deficit attributed to the 
Company's shareholders 
Total equity 

140 

322 

160 

205 

319 

151 

13,907 
2,257 

13,959 
1,842 

189 

54 

(65) 

3 

9 

(52) 
415 

135 

(31.7) 

0.9 

6.0 

(0.4) 
22.5 

249.3 

2,446 

1,896 

550 

29.0 

Total liabilities and equity 

16,353 

15,855 

498 

3.1 

Explanation 

The  decrease  in  debt  resulted  from  the  repayment  of  debentures  and  loans, 
offsetting the expansion of series 13 and 14 debentures and the receipt of loans in 
the landline national interior communications segment. For more information, see 
Note 13 to the Statements. 
The increase was due to the Bezeq International services segment, mainly from the 
cost of additional contracts that came into effect as well as from an increase in the 
consumer price index, offsetting a decrease mainly in the cellular communication 
sector due to payments during the year. 
The increase was mainly due to the landline national interior communications. For 
more information, see Note 14 to the Statements. 
The decrease was due to payments for the retirement of employees, offsetting the 
increase in provisions for the termination of employee-employer relations through 
early retirement and voluntary retirement in the Group, and due to the recording 
of a one-off provision for the amount of the special bonus that will be paid to Bezeq 
employees as part of the amendment of the collective agreement, see Note 16 to 
the Statements. 
The decrease was mainly due to the cancellation of the provision for a claim offset 
interior 
insurance 
by 
communications. 

landline  national 

indemnification 

field  of 

in  the 

Shareholders’ equity constitutes approximately 14.9% of the total balance sheet, 
compared  to  approximately  11.9%  of  the  total  balance  sheet  on  December  31, 
2022. The increase was due to 2023profits, offsetting the distribution of dividends 
per share and the buyback of shares in the Company. 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the state of affairs of the corporation for the Year ended December 31, 2023 

1.2. 

Enterprise results 

1.2.1. 

Key results 

2023 

2022 

Increase (decrease) 

NIS millions 

NIS millions 

% 

Explanation 

Revenues 

9,103 

8,986 

117 

1.3 

Operating and general 
expenses 

3,381 

3,396 

(15) 

(0.4) 

Salary 

1,926 

1,877 

49 

2.6 

Depreciation, amortization 
and impairment 

1,867 

1,868 

(1) 

(0.1) 

Other operating expenses, 
net 

180 

220 

(40) 

Operating Profit 

1,749 

1,625 

124 

Financing expenses, net 

Taxes on revenue 

Profit in the year  

349 

346 

1,054 

398 

(49) 

336 

891 

10 

163 

(18.2
) 

7.6 

(12.3
) 

3.0 

18.3 

The increase was due to growth in the landline national interior communications and multi-channel 
television segments, offsetting a decrease in revenues from the cellular communications segment and the 
Bezeq International services segment. 

It should be noted that the expenses were affected, among other things, by a decrease in expenses for the 
fiber deployment incentive fund due to a temporary order, in which it was determined that in 2023 the rate 
of payment of the entities liable to the incentive fund will be 0% instead of 0.5%, for further details see 
Chapter 1.2.2 below. 

The increase was mainly due to the landline national interior communications segment, offsetting a 
decrease mainly in the international Bezeq services segment. For more information, see Note 23 to the 
Statements. 

The decrease was due to a decrease in expenses for the termination of employee-employer relations 
through early retirement and voluntary retirement and collective agreements in the Group, as well as a 
decrease in expenses for provision for claims, offsetting the recording of a one-off provision in the amount 
of NIS 75 million for the special grant that will be paid to employees of the landline national interior 
communications segment as part of the amendment of the collective agreement, see Note 24 to the 
Statements. 

The decrease was mainly due to the landline national interior communications segment. For more 
information, see Note 25 to the Statements. 

5 

 
 
 
 
 
 
Report of the Board of Directors on the state of affairs of the corporation for the Year ended 
December 31, 2023 

1.2.2. 

Operating segments 

a.  The  following  are  data  regarding  revenues  and  operating profit  in  accordance  with  the 

Group's operating segments: 

2023

2022

 NIS

millions

 of %

segment

revenue

 NIS

millions

 of %

segment

revenue

Revenues by operating segments 

Interior landline communication 

Cellular communication 

Bezeq International services 

Multi-channel TV 

Others and adjustments 

Total 

4,412

2,348

1,212

1,309

(178)

9,103

48.5

25.8

13.3

14.4

(2.0)

100.0

4,306

2,399

1,239

1,277

(235)

8,986

47.9

26.7

13.8

14.2

(2.6)

100.0

2023 

2022 

NIS millions 

% of segment 
revenue 

NIS millions 

% of segment 
revenue 

Profit (loss) by operating segments 

Interior landline communication 

Cellular communication 

Bezeq International services 

Multi-channel TV (proforma) * 

Others and adjustments 

Consolidated operating profit / percentage of Group 
revenues 

1,451 

196 

39 

(4) 

67 

1,749 

32.9 

8.3 

3.2 

(0.3) 

- 

19.2 

1,460 

193 

(30) 

(48) 

50 

1,625 

33.9 

8.0 

(2.4) 

(3.8) 

- 

18.1 

* The results of the multi-channel television segment are presented net of the overall impact of impairment recognized 
starting from 2018, is in accordance with the way the Group's chief operating decision maker evaluates the segment's 
performance and makes decisions regarding the allocation of resources to the segment. In addition, see Note 31.4 to the 
Consolidated Financial Statements for a summary of selected data from the Yes’ statements.

6 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the state of affairs of the corporation for the Year ended December 31, 2023 

1.2.2. 

Activity segments (Cont.) 

b. Interior landline communications segment 

2023 

2022 

Increase 
(decrease) 

NIS millions 

% 

Explanation 

Internet - infrastructure  1,947  1,789 

158  8.8 

The increase was mainly due to an increase in the average revenue per retail subscription, which was mainly due to an increase in the number of subscribers 
connected to the fiber network, complementary end equipment, and the provision of Internet access services (ISP) starting in April 2022. In addition, there was an 
increase in the scope of wholesale market activity in the field of fiber and in the use of Bezeq infrastructures. 

Landline telephony 

650 

780 

(130)  (16.7) 

The decrease was due to a decrease in the average revenue per telephone line due to the reduction of telephony rates by the Ministry of Communications starting 
in April 2022 and a further reduction starting in July 2023, a decrease in interconnection rates starting from June 15, 2023, and a decrease in the volume of traffic. 
There was also a decrease in the number of lines. 

Transmission, data 
communication and 
other 

Cloud and digital 
services 

1,466  1,406 

60 

4.3 

The increase was due to data transmission and communication services for businesses and an increase in paid jobs. The increase was largely offset by a decrease in 
transmission revenues to Internet Service Providers (ISPs) due to the switch of subscribers to Bezeq due to the Unified Internet reform. 

349 

331 

18 

5.4 

The increase was due, among other things, to virtual switchboard services and cloud services. 

Total revenues 

4,412  4,306 

106  2.5 

Operating and general 
expenses 

769 

759 

10 

1.3 

The increase was mainly due to an increase in the expenses on subcontractors and materials, mainly for the deployment of the fiber network and paid works, 
offsetting a decrease in expenses on the  fiber deployment incentive fund due to a temporary order, in which it was determined that in 2023 the payment rate of 
the entities liable to the incentive fund will be at a rate of 0% instead of 0.5% as well as a decrease in interconnection payments to communication operators, 
mainly due to a reduction in rates as of June 15, 2023. 

Salary 

1,028  970 

58 

6.0 

The increase was due to salary updates (including the minimum wage), hiring employees, as well as a one-off grant for permanent employees following the wage 
agreement in the public segment, mainly offsetting employee retirement. 

Depreciation and 
amortization 

Other operating 
expenses, net 

1,019  1,005 

14 

1.4 

145 

112 

33 

29.5 

The increase was due to the recording of a one-off provision in the amount of NIS 75 million for the amount of the special grant that will be paid to Bezeq 
employees as part of the amendment to the collective agreement, as well as a decrease in capital gains from the sale of real estate. The increase was partially offset 
by a decrease in provision expenses for claims and provision expenses for early retirement. 

Operating profit 

1,451  1,460 

(9) 

(0.6) 

Financing expenses, net  256 

332 

(76) 

(22.9) 

The decrease in net financing expenses was mainly due to an increase in financing income from investments, a decrease in linkage differences for debentures 
mainly due to a lower index increase, as well as due to early repayment costs of debentures which were recognized in the corresponding year. This is done by 
offsetting financing expenses on employee benefits against financing income that was recognized in 2022, see Note 25 to the Statements. 

Taxes on revenue 

294 

279 

Segment profit 

901 

849 

15 

52 

5.4 

6.1 

7 

 
 
 
 
 
 
 
 
Report of the Board of Directors on the state of affairs of the corporation for the Year ended December 31, 2023 

1.2.2. 

Activity segments (Cont.) 

c. Cellular communications segment 

2023 

2022 

Increase (decrease) 

NIS millions 

% 

Explanation 

Revenue from services 
net of interconnect * 

1,385 

1,364 

21 

1.5 

The increase was mainly due to continued growth in the number of subscribers, including subscribers to 5G 
plans.  This  increase  was  partially  offset  by  a  decrease  in  revenues  from  a  project  with  the  Ministry  of 
Education recorded in 2022, as well as a decrease in revenues from hosting services. 

Interconnect revenues * 

371 

427 

(56) 

(13.1) 

The decrease was mainly due to the reduction of interconnect rates in June 2023. 

Sale of end equipment to 
customers 

592 

608 

(16) 

(2.6) 

The decrease was mainly due to a decrease in the number of devices sold. 

Total revenues 

2,348 

2,399 

(51) 

(2.1) 

Operating and general 
expenses 

1,278 

1,327 

(49) 

(3.7) 

Salary 

323 

314 

9 

2.9 

The decrease was mainly due to a decrease in expenses attributed to interconnect revenues (parallel to the 
decrease in revenues) as well as a decrease in expenses for the fiber deployment incentive fund. 
The  decrease  was  partially  offset  by  an  increase  in  loan-loss  expenses  as  well  as  an  increase  in  network 
expenses, among other things due to an increase in the index and electricity rates. 

The increase was mainly due to the effects of the collective agreement that was signed in December 2022, 
offsetting an increase in salary for investment as well as a decrease in the number of employees. 

Depreciation and 
amortization 

Other operating 
expenses, net 

549 

532 

17 

3.2 

The increase was mainly due to the updating of the estimate of the cost of right-of-use assets carried out in 
2022 for past periods. This increase was partly offset by assets whose depreciation period ended. 

2 

33 

(31) 

(93.9) 

The  decrease  was  due  to  the  effects  of  the  collective  agreement  regarding  a  bonus  for  employees  and 
expenses for employee retirement in 2022. 

Operating profit 

196 

193 

3 

1.6 

Financing income, net 

13 

26 

(13) 

(50.0) 

Taxes on revenue  

Segment profit 

50 

159 

54 

165 

(4) 

(6) 

(7.4) 

(3.6) 

The decrease was mainly due to a decrease in interest revenue from loans given to the parent company and 
repaid. This decrease was partially offset by a decrease in exchange rate differential expenses in light of the 
increase in the exchange rate as well as an increase in interest revenue from deposits. 

* Revenue from interconnectivity (hereinafter: "interconnect") - as part of the reform to change the interconnect RAETS regime (hereafter: "the Reform"), which began gradually from June 2023 
to June 2025, interconnect revenues from mobile radio telephone operators and NIO operators to whom the reform applies are presented separately.\ 

8 

 
 
 
 
 
 
 
 
Report of the Board of Directors on the state of affairs of the corporation for the Year ended December 31, 2023 

1.2.2. 

Activity segments (Cont.) 

d. Bezeq International services 

2023 

2022 

Increase 
(decrease) 

Explanation 

NIS millions 

% 

Revenues 

1,212 

1,239 

(27) 

(2.2) 

Operating, general and 
impairment expenses 

800 

827 

(27) 

(3.3) 

The decrease was largely due to a decrease in revenue from internet services (ISP), mainly due to a decrease in the 
number of subscribers following the unified internet reform that began in April 2022. This decrease was largely offset 
by an increase in Bezeq's business activity as a whole, mainly from the consolidation of the subsidiary CloudEdge in 
the second quarter of last year and an increase in this activity, an increase in revenues from equipment, licensing and 
service contracts, data services, and server farm activity. 

The decrease was mainly due to a decrease in expenses for the use of Internet infrastructure in view of a decrease in 
activity in this field, as well as a decrease in marketing and general expenses. This decrease was partially offset mainly 
by an increase in expenses due to the consolidation of the subsidiary CloudEdge in the second quarter of last year 
and an increase in this activity, an increase in expenses for the sale of equipment, licensing and service contracts and 
data services. 

Salary 

216 

237 

(21) 

(8.9) 

The decrease was mainly due to a continuous decrease in the number of Bezeq International employees, which was 
partially offset by an increase in the salary of the subsidiary CloudEdge. 

Depreciation, 
amortization, and 
impairment 

137 

134 

3 

2.2 

The increase was due to an increase in current depreciation for PP&E and impairments of right-of-use assets, which 
was offset by a decrease in asset depreciation. 

Other operating expenses  20 

71 

(51) 

(71.8) 

The  decrease  was  mainly  due  to  the  registration  of  the  provision  for  voluntary  retirement  last  year,  offsetting 
expenses for updating the provision for voluntary retirement, and updating the provision for claims. 

Operating profit (loss) 

Financing expenses, net 

Income taxes  

Segment profit (loss) 

39 

10 

- 

29 

(30) 

69 

- 

1 

1 

(32) 

9 

(1) 

61 

900.0 

The increase was mainly due to an increase in financing expenses for leasing building. 

(100) 

- 

9 

 
 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the state of affairs of the corporation for the Year ended December 31, 2023 

1.2.2. 

Activity segments (Cont.) 

e. Multi-channel TV (proforma) * 

2023 

2022 

Increase (decrease) 

NIS millions 

% 

Revenues 

1,309 

1,277 

32 

2.5 

886 

855 

31 

3.6 

Explanation 

The increase was mainly due to an increase in revenues from combined television and fiber 
packages as well as revenues from new content packages, mainly from collaborations with 
international content providers, offsetting the change in the mix of subscribers from premium to 
discount as well as a decrease in revenues from the sale of content to external entities. 

The increase was mainly due to an increase in costs for fiber activity as well as an increase in costs 
for collaborations with international content providers, as well as from an increase in satellite 
segment expenses mainly as a result of a change in the dollar exchange rate. On the other hand, 
there was a decrease in expenses for the fiber deployment incentive fund and a decrease in 
marketing and general expenses. 

Operating and 
general expenses 

Salary 

Depreciation and 
amortization 

Other operating 
expenses 

Operating loss 

Financing 
expenses, net 

Taxes on revenue 

Segment profit 
(loss) 

186 

244 

(3) 

(4) 

(9) 

1 

4 

193 

274 

3 

(48) 

(6) 

1 

(43) 

(7) 

(3.6) 

The decrease was mainly due to the updating of salary discounts. 

(30) 

(10.9) 

The decrease was mainly due to assets that were fully depreciated and a change in the estimated 
life expectancy of assets. 

(6) 

44 

(3) 

- 

47 

The change was mainly due to a loss due to the effect of asset impairments in 2022 as well as an 
update of the provision for employee retirement. 

- 

91.7 

(50.0) 

The increase was mainly due to an increase in interest revenue from deposits. 

- 

- 

* The results of the multi-channel television segment are presented net of the overall impact of impairment recognized starting from 2018, see “proforma” income below. This is in 

accordance with the way the Group's chief operating decision maker evaluates the segment's performance and makes decisions regarding the allocation of resources to the segment. For 
more information, see Notes 10.5 and 28 to the Statements. In addition, see Note 31.4 to the Statements for a summary of selected data from Yes’ statements.

10 

 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended December 31, 2023 

1.2.2. 

Activity segments (Cont.) 

e. Multi-channel TV (Cont.) - Comparison between accounting income and proforma income 

2023 

2022 

Accounting profit 

Pro forma profit 

Accounting profit 

Pro forma profit 

NIS millions 

Revenues 

1,309 

1,309 

1,277 

1,277 

Operating and general expenses 

861 

Salary 

Depreciation and amortization 

Other operating expenses (income), 
net 

Operating profit (loss) 

Financing income, net 

Taxes on revenue 

Profit (loss) for the year 

193 

166 

(5) 

94 

(9) 

1 

102 

886 

186 

244 

(3) 

(4) 

(9) 

1 

4 

867 

200 

199 

3 

8 

(6) 

1 

13 

855 

193 

274 

3 

(48) 

(6) 

1 

(43) 

11 

 
 
  
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended December 31, 2023 

1.3. 

Main data from the Group's consolidated quarterly income statements (NIS millions) 

Q1/2023 

Q2/2023 

Q3/2023 

Q4/2023 

2023 

Explanation 

Revenues 

2,308 

2,299 

2,265 

2,231 

9,103 

Operating expenses 

1,842 

1,815 

1,843 

1,854 

7,354 

Operating profit 

Financing expenses, net 

Profit after financing 
expenses, net 

Taxes on revenue 

Profit for the period 

466 

88 

378 

92 

286 

484 

98 

386 

100 

286 

422 

77 

345 

74 

271 

377 

86 

291 

80 

211 

1,749 

349 

1,400 

346 

1,054 

The decrease in revenues in the fourth quarter includes a decrease in revenues from 
roaming services in the cellular communication segment in light of the effect of the 
war. For more information see Chapter 1.8 below. 
It should be noted that the expenses of the third quarter include the recording of a 
one-off provision in the amount of NIS 75 million for the special grant that will be 
paid to Bezeq employees as part of the amendment of the collective agreement 
(see Note 16.1.1 to the Statements) as well as a decrease in expenses on the fiber 
deployment incentive fund due to a temporary order, in which It was determined 
that in 2023 the rate of payment of the entities liable to the incentive fund will be 
at a rate of 0% instead of 0.5%. 
The fourth quarter includes expenses for termination of employee-employer 
relations in early retirement and voluntary retirement, see Note 16.5 to the 
Statements. 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended December 31, 2023 

1.4. 

Cash flow 

2023 

2022 

Change 

Explanation 

NIS millions 
% of total revenue 

NIS 
millions 

Net cash flow derived 
from operating 
activities 

Net cash flow used for 
Investing operations 

Net cash flow used for 
financing operations 

Net decrease in cash 
and cash equivalents 

Effect of changes in 
foreign currency 
exchange rate 

3,442 

3,491 

(49) 

(1.4) 

(1,835) 

(1,420) 

(415) 

(29.2) 

(1,715) 

(2,315) 

600 

25.9 

(108) 

(244) 

136 

55.7 

(2) 

- 

)2( 

 - 

The decrease in the net cash flow from current activity was mainly due to the advance of the crediting dates 
with the credit card companies in 2022 and a shift in collection from customers from the fourth quarter of 
2021 to the first quarter of 2022 due to the labor strikes in the cellular communications segment and in the 
Bezeq International services segment in 2021. The decrease was largely offset by the increase in net profit as 
well  as  an  increase  in  the  cash  flow  from  current  activity  in  the  landline  national  interior  communication 
segment is mainly due to changes in working capital in employee benefits. 

The increase in the net cash flow used for investment activity was mainly due to a net increase in investment 
in deposits in banks and other financial investments in the landline national interior communication segment 
and in the Company. 

The decrease in the net cash flow used for financing activity was mainly due to a decrease in the repayment of 
debentures as well as the expansion of debentures (series 13 and 14) in 2023, offsetting a decrease in receiving 
loans, an increase in the dividend paid and an increase in principal and interest payments for leases. 

13 

 
 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended December 31, 2023 

Average volume in the reported year  

Long-term liabilities (including current liabilities) to financial institutions and bondholders: approx. NIS 9,497 million. 
Supplier credit: approx. NIS 962 million. 
Short-term customer credit: approx. NIS 502 million. 
Long-term customer credit: approx. NIS 295 million. 

Working equity 

The Group's consolidated working equity deficit as of December 31, 2023 amounted to approximately NIS 91 million, compared with a working equity deficit of approximately NIS 1 
million as of December 31, 2022. 

The Company's working equity (according to the "Solo” Statements) as of December 31, 2023 amounted to approximately NIS 99 million, compared with working equity of approximately 
NIS 68 million as of December 31, 2022. 

Bezeq (according to the "Solo" Statements) as of December 31, 2023, has a working equity deficit in the amount of approx. NIS 162 million, compared with a working equity deficit of 
NIS 62 million as of December 31, 2022. 

The increase in the deficit in the consolidated working equity was mainly due to an increase in the current maturities of the financial debt and trade payables of Bezeq Group.

14 

 
 
  
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

1.5. 

Disclosure regarding the Company's projected cash flow 

The Company's Board of Directors reviewed the Company's consolidated financial statements and separate 
(Solo) financial statements as of  December 31, 2023, including sources for repayment of the Company's 
liabilities,  including  the  Company's  debentures  (Series  C).  In  addition,  the  Company's  Board  of  Directors 
examined the warning signs set forth in Regulation 10(b)(14)(a) of the Securities Regulations (Periodic and 
Immediate Reports), 5730-1970 and stated that despite the existence of a continuous negative  cash flow 
from  current  operations  in  the  Company's  separate  (solo)  financial  statements  and  a  deficit  in  working 
equity in the Company's consolidated statements, in the assessment of the Company's Board of Directors, 
after  receiving  explanations  for  its  opinion  from  the  Company's  Management,  there  is  no  reasonable 
concern  that the Company and the Group will not meet their existing and expected obligations when they 
are due to be met. The Company and the Group have the ability to meet the existing and expected cash 
needs  in  the  foreseeable  future,  even  in  the  scenario  of  an  unexpected  deterioration  in  their  business, 
through  the  cash  balances  in  their  possession,  through  the  creation  of  cash  from  operations,  through 
sources  of  (net)  liquidity  from  subsidiaries,  and  through  the  borrowing  and  refinancing  of  significant 
amounts of debt from banking and non-banking sources. 

The above information includes forward-looking information based on the Company's estimates regarding 
liquidity. The actual data may differ substantially from the above estimate in case of a change in one of the 
factors considered in these estimates. 

1.6. 

Buyback of the Company's shares 

During the year 2023, the Company repurchased 1,593,213 of its shares for approximately NIS 123 million. 

1.7. 

Update on the effects of inflation and the increase in interest rates on the results of the Group's 
activities 

As stated in Note 30.5.1 to the Statements, changes in the inflation rate affect the Group's profitability 
and future cash flows, mainly due to Bezeq’s index-linked liabilities. Bezeq implements a policy to reduce 
and partially hedge the exposure to the price index and the dollar-shekel exchange rate through the 
execution of forward transactions. See details regarding hedging transactions in Note 30.6 to the 
Statements. 

In 2023, the increase in the consumer price index was reflected in the recording of financing expenses in 
respect of the Group's financial debt amounting to approximately NIS 88 million (approximately NIS 79 
million after hedging), a decrease of approximately NIS 65 million (approximately NIS 41 million after 
hedging) compared to the corresponding year. It should be noted that the effect of the increase in the 
consumer price index on the results of the Group's activities was not material. Also, it should be noted 
that the net effect of the increase in interest rates in the economy in the said year on the results of the 
Group's activities was immaterial. 

In accordance with the scope of Bezeq’s index-linked debt as of December 31, 2023, every 1% increase in 
the Consumer Price Index is expected to result in an increase in its financing expenses to the extent of 
approximately NIS 25 million, this is before considering the effect of hedging transactions. In addition, 
depending on the scope of the Bezeq’s existing variable interest rate debt, a change of 1% in the Bank of 
Israel interest rate is expected to cause an increase in Bezeq's financing expenses to the extent of 
approximately NIS 7 million per year, and accordingly, is not expected to have a material effect on Bezeq’s 
operating results. 

The Company's debentures are in shekels and are therefore not affected by changes in the inflation rate 
or an increase in interest rate. 

15 

 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

1.8. 

State of War - "Iron Swords" 

As of October 7, 2023, the State of Israel is in a state of war in the Gaza Strip, as well as in a state of 
limited hostilities in the northern border area. The state of war creates various effects on the Bezeq Group 
companies, which are reflected on the one hand in an increase in demand for some services, in Internet 
traffic and in the use of landline telephony, and on the other hand in a decrease in roaming activity, a 
decrease in the sale of cellular devices, and the removal/freezing of business lines in areas that are 
affected by the war. Also, with the outbreak of the war, due to the recruitment of employees to reserve 
service and a decrease in contractor activity, there was a slowdown in deployment and installation activity 
in the Bezeq network. Also, a number of regulatory moves were made as part of the State of Israel's 
handling of the state of war, including a law to postpone payment dates for those entitled and to ease 
phone call charges, including calls related to distance learning. It should be noted that some of the Group 
companies took their own initiative to ease the charges towards localities in the Gaza Envelope and on the 
northern border. 

The Bezeq Group companies, which provide, among other things, essential communication services to 
private, business, and institutional customers, including the state institutions, the security forces, and the 
health system, are prepared accordingly and respond to the various needs, including fault solving, 
increasing vigilance and preparedness in cyber systems, and assisting the community in various ways. 
Also, the Group companies regularly examine and follow closely the developments related to the war. 

At this stage, the effects of the war and its consequences as described above do not have a material 
impact on the activities of the Company and Bezeq Group and their business results. Also, the liquidity and 
financial situation of the Company and Bezeq Group allows them to function well during the war. The 
scope and duration of the war and its consequences on the state of the Israeli economy, as well as on 
Bezeq Group companies, are unobservable and difficult to predict, and they depend, among other things, 
on the manner and scope of the development of the war and the possibility of the economy slipping into 
recession as a result. In this context, attention is also drawn to the relevant risk factors detailed in Chapter 
A (Description of the Corporation's Business) of the periodic report for the year 2023 (Sections 2.20.11, 
2.20.15, 3.19.2.9, 4.14.8, 5.18.1.2, 5.18.1.4). 

Some of the information contained in this section is forward-looking information, as defined in the 
Securities Law, based on estimates, assumptions, and expectations of the Company and Bezeq Group 
which may not materialize, or materialize in a materially different way than anticipated, depending, 
among other things, on the manner and scope of the development of the war and the state of the 
economy as a whole. 

2. 

Corporate governance aspects 

2.1. 

Involvement of the Group members in the community and donations 

The Company supports Bezeq's corporate responsibility policy and will continue to promote this policy in 
all Group companies. The Company's donation policy focuses on health, education, and community issues. 
In the year of the report, the Company donated to the Ichilov Hospital, the Reut Rehabilitation Hospital 
and other non-profit organizations in amounts that are not material to the Company. 

In 2023, the Bezeq Group donated a total of about NIS 11.4 million, which includes a financial donation of 
about NIS 4.2 million, donation of services and communication infrastructure to associations, evacuees, 
and disadvantaged populations in the amount of about NIS 5.1 million, and a salary donation for the 
volunteering of employees, the employment of at-risk youth, and the volunteering of the children of 
employees in the community in the amount of approximately NIS 2.2 million. 

16 

 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

According to the community contribution policy approved by Bezeq's Board of Directors, Bezeq 
contributes to the community out of its deep commitment to the issue of social responsibility, through 
financial donations, donations of services and communication infrastructure, and support the employees’ 
and their children’s volunteering in the community. 

Bezeq focuses the main contribution on reducing the digital gap in Israel by donating communication 
services to non-profit organizations and disadvantaged populations, supporting programs that promote 
digital equality through training, providing skills and assistance, and harnessing additional partners. At the 
same time, Bezeq works to create a social impact while providing a framework for initiative, meaningful 
action, and volunteering in the community. 

In addition, as part of the "Iron Swords" War that began in the fourth quarter, the Group mobilized to help 
the affected populations through a variety of initiatives, projects, donations, and volunteer work. 

2.2. 

Disclosure regarding auditor's salary 

The following are the fee expenses for the auditors of the main consolidated companies in the Group for 
audit and audit-related services (NIS thousands): 

Company 

Auditor 

B Communications 
Ltd. 

Somekh 
Chaikin 

Somekh 
Chaikin 

Somekh 
Chaikin 

Somekh 
Chaikin 

Somekh 
Chaikin 

Bezeq – the Israeli 
Telecommunications 
Corp. Ltd. 

Pelephone 
Communications 
Ltd. 

Bezeq International 
Ltd. 

Yes TV and 
Communications 
Services Ltd. (Yes) 

Total 

Details 
Audit and audit-
related, including audit-
related tax services 
Other services1 
Audit and audit-
related, including audit-
related tax services 
Other services1 
Audit and audit-
related, including audit-
related tax services 
Other services1 
Audit and audit-
related, including audit-
related tax services 
Other services1 
Audit and audit-
related, including audit-
related tax services 
Other services1 

2023 

2022 

432 
66 

1,607 
403 

674 
659 

357 
112 

643 
283 
5,236 

400 
151 

1,530 
485 

603 
434 

379 
403 

612 
283 
5,280 

The accountants’ fees were discussed by the Boards of Directors’ committees for examining the 
statements and approved by the Boards of Directors of the Company and of each of the Group companies. 
The fees are determined with reference to the volume of hours and the derived hourly rate. 

1     "Other services" provided to main companies in the Group in 2023 and 2022 included, among other things, consulting services on 

tax and accounting issues that are not related to auditing and special approvals. 

17 

 
 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

2.3. 

Directors with accounting and financial expertise and independent directors 

As of the date of the report, all seven directors serving in the Company have accounting and financial 
expertise; For details about the directors with accounting and financial expertise serving in the Company 
as of the date of the report, see Regulation 26 in the report of additional details on the Company (part D 
of this periodic report) and also in Sections 2 and 9 of the corporate governance questionnaire. 

2.4. 

Additional corporate governance issues 

The Company established a gatekeepers’ forum, with the participation of the Internal Auditor, the 
auditors, and the external legal advisors, led by the Company's CFO. This forum convenes as needed, in 
order to discuss general control and enforcement issues in the Company. 

18 

 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

2.5. 

Disclosure regarding the internal auditor in a reporting corporation 

Details 

concentration 

Name of 
internal auditor 

Ilan Chaikin 

Date of entry 
into office 

Compliance 
with the 
provisions of 
the law 

Employment 
format 

Method of 
appointment 

Organizational 
supervisor of 
the Internal 
Auditor 

Work plan 

2008 

The internal auditor complies with the conditions set forth in Article 3(a) and 8 of the Internal 
Audit Law and the provisions of Article 146(b) of the Companies Law. 

Hourly fee, according to the number of hours determined at the beginning of each year by the 
Audit Committee. 

The method of appointment and summary of the reasons for approving the appointment: 
The appointment was approved by the Board of Directors in 2008, following the recommendation 
of the Audit Committee. 
Duties, powers and roles assigned to the auditor: 
The authority and responsibility of the Company's Internal Auditor are fixed in the Company's 
internal audit procedure approved by the Audit Committee. According to the procedure, the 
Auditor's duties and powers are: 
Checking the correctness of the Company's operations and the actions of its officers, checking the 
reliability and integrity of the financial and operational information, examining the management of 
funds and liabilities and examining the Company's computerized information systems and the 
Company's information security system. The Internal Auditor is also responsible for examining 
employee complaints in accordance with the arrangements established by an audit committee in 
accordance with Article 117(6) of the Companies Law, 5759-1999. 
His powers are to receive any information, explanation and document necessary to fulfill his duties, 
right  of  access  to  any  regular  or  computerized  database  of  the  Company,  any  database  and  any 
automatic or non-automatic data processing work plan of the  Company and its  units and receive 
permission to enter any property of the Company. The Internal Auditor is also entitled to be invited 
to all meetings of Management, the Board of Directors and its committees. 

The organizational supervisor of the internal auditor is the CEO of the Company. 

The work plan in 2023 was derived from the Company's multi-year work plan established for the 
years 2021-2024. 
The considerations in determining the internal audit work plan 
The guiding principle in building the internal audit work plan is the inherent risk in the  Company's 
processes and activities. In order to assess these risks, the internal audit referred to the risk survey 
conducted by it, as well as to other sources that influenced the risk assessment in these processes, 
such as conversations with Management, findings of previous audits and other relevant activities. 
The main considerations in building the work plan are: 
Reasonable coverage of most areas of the Company's activity in accordance with the exposure to 
material risks, considering existing controls in the Company's areas of activity and the findings of 
previous audits. 
Parties involved in determining the work plan 

19 

 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

The Internal Auditor, Management and the Audit Committee of the Board of Directors. 
The party that receives the work plan and approves it 
The  Audit  Committee  of  the  Board  of  Directors,  after  the  issue  has  been  discussed  with  the 
Company's CEO. 
The Auditor's discretion to deviate from the work plan 
The CEO of the Company or the Chairman of the Audit Committee may propose issues in matters 
where the need arises to conduct an urgent inspection as well as recommend reducing or stopping 
an inspection on a  subject  approved in the work plan. The Internal Auditor has the discretion to 
deviate from the work plan. 
Examination of material transactions 
The Internal Auditor is present at the Board of Directors' discussions where material transactions 
are approved and reviews the relevant material sent as part of these discussions. 

2.5. 

Disclosure regarding internal auditor in a reporting corporation (Cont.) 

Details concentration 

Reference of the audit 
to material equity-
held investee 
corporations 

Performing the audit 

Access to information 

Internal Auditor’s 
report 

Board of Directors’ 
evaluation of the 
Internal Auditor's 
activity 

Compensation 

The work plan of the Company’s Internal Auditor does not include an audit of material equity-
held investee corporations. 
The internal auditor conducts meetings with the internal auditor and other control factors of 
materially held corporations for the purpose of receiving periodic updates. 

In accordance with the Internal Auditor’s notice, the audit work is conducted in accordance 
with the internal audit standards accepted in Israel and around the world and in accordance 
with professional guidelines in the field of internal audit, including international internal audit 
standards as well as in accordance with the Internal Audit Law and the Companies Law. 
The Internal Auditor was presented with documents and information as stated in Article 9 of 
the Internal Audit Law and was given constant and unmediated access to the corporation's 
information systems, including financial data. 
The Internal Auditor submits written audit reports regularly during the reporting year to the 
chairman of the Board of Directors, the CEO, the Chairman of the Audit Committee and the 
members of the committee.  The reports are submitted before the date of the committee 
hearing (usually about three days before this date). 
The Company's Audit Committee convened to discuss internal audit reports on the 
implementation of the audit procedure by the Internal Auditor for the second half of 2022 
on March 14, 2023. In addition, an audit report on the implementation of the audit 
procedure by the Internal Auditor for the first half of 2023 was presented on November 9, 
2023 and an internal audit report on investment management was presented on January 8, 
2024. 

The Board of Directors believes that the scope of the audit, the nature and continuity of the 
Internal Auditor's activity, as well as the work plan, are reasonable under the circumstances 
of the case and are capable of achieving the goals of the audit. 

The Internal Auditor’s compensation is determined each year according to the scope of the 
audit hours, according to an hourly fee. In 2022, the number of hours invested in the audit 
by the Internal Auditor was approximately 200 hours, noting that the said number of hours 
is sufficient for the Internal Auditor to complete the audit work properly. 

In 2023, the Internal Auditor was paid compensation in the amount of NIS 56K including VAT. 
In the opinion of the Board of Directors, the scope of the Internal Auditor’s compensation 
had no effect on his professional judgment. 

20 

 
 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended December 31, 2023 

3. 

Disclosure in connection with the Corporation's financial reporting 

3.1. 

Disclosure regarding valuations 

The following are details of highly material valuations and a substantial and a material valuation in accordance with Regulation 8B(i) of the Securities Regulations 
(Periodic and Immediate Reports), 5730-1970. 

A highly material valuation of Bezeq Fixed Lines as of December 31, 2023 is not attached to the report since it was the Company's opinion that under any reasonably 
possible change in the key assumptions used to determine the recoverable value of the cash-generating unit, no highly material impairment would have been 
recognized. 

Pelephone 

Bezeq 

Highly material valuation is 
attached to the Statements as of 
December 31, 2023 

Highly material valuation is attached 
to the Statements as of December 31, 
2023 

Yes Television and Communication 
Services Ltd. ("Yes") 

A very substantial valuation as of 
December 31, 2023 

Attached to Bezeq's financial 
statements for December 31, 2023. 

See Sections 3.1.1 and 3.1.3 below 

Bezeq International 

Material valuation as of December 
31, 2022 - 

See Section 3.1.1 below 

Identification of subject of 
valuation 

Pelephone’s value in use for the 
purpose of examining the 
impairment of assets in 
accordance with International 
Accounting Standard 36. 

Bezeq’s value in use for the purpose 
of testing goodwill impairment 
attributed thereto in the Company's 
statements in accordance with 
International Accounting Standard 36. 

Examination of impairment of the 
assets of Yes as of December 31, 2023 

Examination of impairment of the 
assets of Bezeq International Ltd.  as 
of December 31, 2023 

Timing of the valuation 

December 31, 2023; 

December 31, 2023; 

December 31, 2023; 

December 31, 2022; 

The valuation was signed on 
March 4, 2024. 

The valuation was signed on March 4, 
2024. 

The valuation was signed on   March 4, 
2024. 

The valuation was signed on March 4, 
2024. 

Value of the subject of the 
valuation close to the 
date of the valuation, if 
the accepted accounting 
rules, including 
depreciation and 

NIS 1,400 million book value of the 
net operating assets of 
Pelephone* plus the balance of 
excess costs created when Bezeq 
shares were purchased by the 
Company. 

NIS 10,760 million book value of the 
net operating assets of Bezeq plus the 
balance of excess costs created when 
Bezeq shares were purchased by the 
Company. 

Book value before impairment as of 
December 31, 2023 is in the amount of 
approx. NIS 16 million. 

Book value before impairment as of 
December 31, 2023 is approximately 
NIS 7 million. 

21 

 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended December 31, 2023 

Pelephone 

Bezeq 

Highly material valuation is 
attached to the Statements as of 
December 31, 2023 

Highly material valuation is attached 
to the Statements as of December 31, 
2023 

Yes Television and Communication 
Services Ltd. ("Yes") 

A very substantial valuation as of 
December 31, 2023 

Attached to Bezeq's financial 
statements for December 31, 2023. 

See Sections 3.1.1 and 3.1.3 below 

Bezeq International 

Material valuation as of December 
31, 2022 - 

See Section 3.1.1 below 

amortization, did not 
require a change in its 
value in accordance with 
the valuation 

Value of the subject of the 
valuation determined 
according to the valuation 

Approx. NIS 2,343 million. 

Approx. NIS 16,577 million. 

The Company concluded that 
there is no impairment that 
requires a reduction in the unit’s 
book value amount recorded in 
the Company's books. 

The Company concluded that there is 
no impairment that requires a 
reduction in the amount of goodwill 
recorded in the Company's books. 

Yes’s enterprise value, according to the 
cash flow discounting method, is 
higher than the fair value of Yes assets 
and liabilities, net, and therefore 
determined as the basis for 
determining Yes's recoverable amount. 
The value in use of Yes's assets, using 
the revenue discount method (value in 
use), has a negative value of 
approximately NIS 24 million. Note that 
the fair value minus sales costs of Yes's 
assets for that date amounted to a 
negative value of approximately NIS 60 
million. Therefore, and in accordance 
with the provisions of IAS36, the 
recoverable amount of Yes’s assets was 
determined as the value in use or the 
fair value minus selling costs, 
whichever is higher, i.e., a negative 
value of NIS 24 million. 

Yes's total enterprise value is negative 
in the amount of approximately NIS 
194 million. In light of the negative 
enterprise value, the net value of the 
assets and liabilities of Yes was 
determined as the fair value or zero, 
whichever is higher. Accordingly, 
Bezeq International’s recoverable 
amount was determined, obtained 
according to fair value minus sales 
costs of the balance sheet items 
according to IAS 36 requirements, in a 
negative amount of about NIS 23 
million. 

Based on the valuation, in 2023, the 
Group recognized an impairment loss 
of approximately NIS 87 million. 

22 

 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended December 31, 2023 

Pelephone 

Bezeq 

Highly material valuation is 
attached to the Statements as of 
December 31, 2023 

Highly material valuation is attached 
to the Statements as of December 31, 
2023 

Yes Television and Communication 
Services Ltd. ("Yes") 

A very substantial valuation as of 
December 31, 2023 

Attached to Bezeq's financial 
statements for December 31, 2023. 

See Sections 3.1.1 and 3.1.3 below 

Bezeq International 

Material valuation as of December 
31, 2022 - 

See Section 3.1.1 below 

Based on the valuation, in 2023, the 
Group recognized an impairment loss 
of approximately NIS 204 million. 

Identification and 
characterization of the 
valuator 

The valuation was performed by Prof. Hadas Gelander, Partner, Director of Valuations and Economic Models in the Economic Department of Ernest Young 
(Israel) Ltd. 

Prof. Gelander holds a bachelor's degree in accounting from the College of Management, Rishon LeZion; A master's degree in business administration 
from the Hebrew University of Jerusalem; And a doctorate cum laude from Ben-Gurion University, Be’er-Sheva, and is also a certified public accountant 
in Israel. 

As part of her role, Prof. Gelander accompanies projects with leading companies in Israel and around the world, in various fields of activity and industries 
such as technology, finance, pharmaceuticals, energy, infrastructure, real estate and industry. In addition, as part of her role accompanying and advising 
companies in the areas of valuations for business (valuations and fair opinions) and accounting (allocation of acquisition costs, valuation of intangible 
assets, valuation of options for employees, etc.) needs, she provided economic opinions as a court-appointed expert witness. 

Valuation model 

The valuator has no dependence on the Company or Bezeq. Bezeq undertook to indemnify the valuator for damages in excess of three times her fee 
unless she acted maliciously or through gross negligence. 
The  discounted  cash  flow  (DCF) 
method. 

The  discounted  cash  flow  (DCF) 
method. 

The  discounted  cash  flow  (DCF) 
method. 

In the first stage – value in use was 
calculated  using  the  discounted 
cash flow (DCF) method. 

In the second stage - the fair value 
of  Bezeq  International’s  net  assets 
and liabilities, minus sales costs, as 
of  December  31,  2023,  was 
determined. 

23 

 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended December 31, 2023 

Pelephone 

Bezeq 

Highly material valuation is 
attached to the Statements as of 
December 31, 2023 

Highly material valuation is attached 
to the Statements as of December 31, 
2023 

Yes Television and Communication 
Services Ltd. ("Yes") 

A very substantial valuation as of 
December 31, 2023 

Attached to Bezeq's financial 
statements for December 31, 2023. 

See Sections 3.1.1 and 3.1.3 below 

Bezeq International 

Material valuation as of December 
31, 2022 - 

See Section 3.1.1 below 

Assumptions under which 
the valuator made the 
valuation 

Discount rate - 10% (after tax). 
Permanent growth rate - 1.5% 

Discount rate - 8% (after tax). 
Permanent growth rate - 1% 

Discount rate - 11% (after tax). 
Permanent growth rate - 1% 

Discount rate – 11.5% (after tax). 
Permanent growth rate - 3% 

Percentage of the scrap value of the 
total value which is estimated to be 
73.7%. 

Percentage of the scrap value of the 
total value which is estimated to be 
74.8%. 

The percentage of the scrap value of 
the total value determined in the 
valuation is irrelevant. 

The percentage of the scrap value 
of the total value determined in the 
valuation is irrelevant. 

In addition, assumptions were 
made regarding the fair value minus 
cost of sale of Bezeq International’s 
assets. 

* Pelephone's net operating assets do not include customer debt balances for the sale of end equipment in installments presented at current value.

24 

 
 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

3.1. 

Disclosure regarding valuations (Cont.) 

3.1.1 

3.1.2 

Despite the negative operating value of Yes, Bezeq supports YES by approving credit facilities or 
investing in Yes’ capital (see Note 412.2.2 to the Statements). Bezeq's aforementioned support 
in  Yes  stems,  among  other  things,  from  the  current  and  expected  contribution  of  the  multi-
channel TV activity to the overall activity of Bezeq Group. 

In the consolidated financial statements of the Company as of December 31, 2023, the value of 
the  activity  segment  "Bezeq"  the  Israel  Telecommunications  Corp.  Ltd.,  the  activity  segment 
Pelephone Communications Ltd., the activity segment Yes TV and Communications Services Ltd. 
(Yes) and the Bezeq International Ltd. activity segment amounted to over 25% of its total assets. 
Accordingly, the valuator is considered a highly material valuator according to Legal Staff Position 
105-30 of the Securities Authority ("Staff Position"). For details about the valuator as required 
by the Staff Position, see the valuation attached to Bezeq's Statements. 

3.1.3 

Information  according  to  Regulation  10(b)(8)  of  the  Securities  Regulations  (Periodic  and 
Immediate Reports), 5730-1970 

A.  Regarding  Yes’  valuation  as  of  December  31,  2022,  which  was  attached  to  Bezeq's  2022 
statements,  the  Group  examined  the  actual  data  in  2023  regarding  free  cash  flows 
compared  to  the  2023  forecast  that  was  included  in  the  aforementioned  valuation  and 
found  that  the  free  cash  flows  of  Yes,  according  to  its  2023  statements,  are  significantly 
higher than the forecast in the aforementioned valuation. The gap was mainly due to timing 
differences  in  working  equity.  For  more  information,  see  Appendix  G  in  the  attached 
valuation of Yes as of December 31, 2023. 

B.  Regarding  the  valuation  of  Bezeq  International  as  of  December  31,  2022,  which  was 
attached to the 2022 statements, the Company examined the actual data in 2023 regarding 
the free cash flows of Bezeq International compared to the 2023 forecast that was included 
in the aforementioned valuation and found that the free cash flows of Bezeq International, 
according  to  its  2023  statements,  are  higher  than  the  forecast  in  the  aforementioned 
valuation. The gap resulted mainly from higher revenues due to a lower than forecast ISP 
customer churn rate and a decrease in revenue-dependent operating expenses. 

3.1.4 

For more information, see Note 10 to the Statements. 

3.2. 

Due to the materiality of the lawsuits filed against the Group, which cannot be estimated or for which the 
exposure  cannot  yet  be  calculated,  the  auditor  CPAs  drew  attention  to  this  in  their  opinion  on  the 
Statements. 

3.3. 

Material events after the reporting period 

On January 25, 2024, Bezeq's Board of Directors approved Bezeq's entry into the field of electricity supply 
and Bezeq's engagement with PowerGen Ltd., a company wholly owned by Generation Capital Ltd., which 
coordinates  the  fund’s  energy  activities,  in  a  non-binding  memorandum  of  understanding  regarding 
strategic cooperation and the establishment of a joint venture in the field of electricity supply ("the MOU"). 
The  signing  of  the  aforementioned  MOU  is  in  accordance  with  Bezeq's  strategy,  which  includes  finding 
opportunities for expansion in areas that are tangential and complementary to Bezeq Group's activities, and 
entry into areas of activity with high growth from Bezeq’s core areas while diversifying the portfolio and 
reducing dependence on regulatory risks. 

Regarding additional material events after the date of the Statements - see Notes 32 to the Statements. 

25 

 
 
 
 
 
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

4. 

Details related to a series of liability certificates 

4.1. 

The following are data about the Company's debentures in circulation, as of December 31, 2022: 

Series F debentures 

A 

B 

Issue date (without extensions) 

July 6, 2021 

Total nominal value at the date of 
issuance (par value) 

NIS  393,973,000  

C  The nominal value (par value) as of the 

NIS 2,009,766,642 

date of the report 

D  The amount of interest accrued as of 

NIS 6,230,277   

the date of the report 

E  Fair value as included in the Statements  NIS 1,946,327,424   

F  Stock market value 

G 

Interest type 

NIS 1,930,782,813 

Fixed at 3.65% 

H  Principal payment dates 

On November 30, 2026 

I 

Interest payment dates 

On May 31 and November 30 of each year, starting on November 30, 
2021 until November 30, 2026. 

J 

Linkage 

K  Total liability in relation to total 

Company liabilities 

Non-linked 

Material 

L  Trustee details 

Trust company - Reznik Paz Nevo Trusts Ltd. 
Name of person in charge at the trust company - CPA Michal Avtalion 
E-mail michal@rpn.co.il, Tel.: 03-6389200, fax: 03-6389222 
Address - 14 Yad Harutzim St., Tel Aviv. 

M  Rating 

A3.il rating by Midroog 

N 

Compliance with the terms of the trust 
deeds 

O  Liens 

P 

Q 

Financial clauses/restrictions applicable 
to the Company for the purpose of 
securing the value of the guaranty and 
the rights of the holders to act to 
exercise the lien granted in their favor 
Restriction that applies to the Company 
in connection with the creation of 
additional liens on its assets or in 
connection with its authority to issue 
additional debentures 

The Company issued to the trustees of the debentures of series F 
certificates regarding its compliance with the terms of the debentures 
for the year 2023. 
First degree unlimited amount lien pari passu on 728,373,713 ordinary 
Bezeq shares of NIS 1 each held directly by the Company and on the 
rights attached to these shares. 

The Company has committed that during two consecutive quarters the 
LTV will not exceed (1) a rate of 80% until November 30, 2023 and (2) 
75% starting from December 2023 until the final repayment date of the 
debentures. 

For  details  about  the  restrictions  that  apply  to  the  Company  in 
connection with the expansion of the series, see Section 3.2.2 of the 
debentures (series F) of the Company. 

26 

 
 
     
 
 
 
 
Report of the Board of Directors on the State of Affairs of the Corporation for the Year ended 
December 31, 2023 

4.2. 

4.3. 

4.4. 

4.5. 

On June 19, 2023, Midroog established an A3.il rating with a stable horizon for the Company's Series C and 
Series F debentures that were in circulation as of that date. In addition, Midroog established an A3.il rating 
with a stable horizon for additional debentures to be issued by the Company from series F in the amount of 
up to NIS 550 million by way of series expansion (see immediate report Ref. 2023-01-057163). 

On June 22, 2023, the Company issued to institutional bodies and the public approximately NIS 538 million 
in Series F debentures for approximately NIS 500 million. 

On  July  20,  2023,  the  Company  made  a  full  and  final  early  repayment  of  NIS  497  million  on  Series  C 
debentures plus accrued interest until their maturity date. 

On  January  11,  2024,  Bezeq  completed  a  public  offering  of  debentures  (series  11  and  13),  by  way  of 
expanding the series traded on the stock exchange, according to a shelf offer report dated January 10, 2024, 
which  was  published  according  to  a  shelf  prospectus  published  on  May  9,  2023.  In  this  framework,  NIS 
567,877,000 par value debentures (series 11) were issued to the public for a total of NIS 539 million and NIS 
432,123,000 par value debentures (series 13) for a total of NIS 353 million. 

Financial clauses of the Company's debentures 

In accordance with the Company's commitment in debenture series F to comply with the LTV clause, the LTV ratio 
as of December 31, 2023 was 50.8%. 

The Company's net debt balance as of December 31, 2023 is approximately NIS 1,884 million and consists of a debt 
balance principal and accrued interest as of the balance sheet date in respect of its debentures in the amount of NIS 
2,016 million, net of cash balances and investments in the amount of NIS 132 million. 

5. 

Miscellaneous 

For information regarding the balance of liabilities of the reporting corporation in its financial statements as 
of December 31, 2023, see the form to be reported by the Company on the MAGNA system on March 13, 
2024. 

Darren Glatt 
Chairman of the Board of Directors 

Tomer Raved 
CEO 

Date of signing: March 12, 2024. 

27 

 
 
 
 
 
 
 
 
 
 
 
 
Chapter C 

Consolidated Financial Statements 
for Year Ended December 31, 2023 

 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
Page 

4 

8 
10 
10 
11 
12 
14 

Consolidated Statements as of December 31, 2023 

Table of contents 

Auditors' reports 

Statements 

Consolidated Statements of Financial Position 

Consolidated Statements of Income 
Consolidated Statements of Comprehensive Income 

Consolidated Statements of Changes in Equity 

Consolidated Cash Flows Statements 

Notes to the Consolidated Statements 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

General 

Basis of preparation of the statements 

Material accounting policy 

Cash and cash equivalents 

Investments 

Trade receivables 

Income taxes 

Leases 

PP&E 

Intangible assets 

Deferred expenses and non-current investments 

Investees 

Debentures, loans and credit 

Trade payables 

Provisions 

Employee benefits 

Contingent liabilities 

Contracts 

Collateral, liens and guaranties 

Equity 

Revenues 

General and operating expenses 

Salaries 

Other operating expenses (income), net 

Financing expenses, net 

Share-based compensation 

Profit per share 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated Statements as of December 31, 2023 

28 

29 

30 

31 

32 

Segmental reporting 

Transactions with interested parties and related parties 

Financial instruments 

Summary of selected data from the statements of Bezeq the Israel Telecommunications Corp. 
Ltd., Pelephone Communications Ltd., Bezeq International Ltd. and Yes TV and Communications 
Services Ltd. (Yes) 

Material events during and after the reporting period 

 
 
 
 
 
 
Somekh Chaikin 
KPMG Millennium Tower 
17 HaArbaa Street P.O.B. 609 
Tel Aviv 6100601 
03 684 8000 

Auditors' report to the shareholders of B Communications Ltd. 

We  reviewed  the  attached  consolidated  statements  of  the  financial  position  of  B  Communications  Ltd. 
(hereinafter – “the Company") as of December 31, 2023 and 2022 and the consolidated statements of income, 
comprehensive income, changes in equity and cash flows for each of the three years in the period ended on 
December  31,  2023.  These  statements  are  the  responsibility  of  the  Company's  Board  of  Directors  and 
Management. Our responsibility is to express an opinion on these statements based on our audit. 

We conducted our audit in accordance with auditing standards accepted in Israel, including standards set forth 
in the Accountants Regulations (Accountant’s Mode of Operation), 5733-1973. According to these standards, we 
are required to plan and perform the audit in order to obtain a reasonable degree of assurance that the separate 
financial  information  is  not  materially  misrepresented.  An  audit  includes  a  sample  examination  of  evidence 
supporting the amounts and details included in the statements. An audit also includes an examination of the 
accounting rules applied in preparing the statements and of the significant estimates made by the Company's 
Board  of  Directors  and  Management,  as  well  as  an  assessment  of  the  adequacy  of  the  presentation  of  the 
statements. We believe that our audit provides an adequate basis for our opinion. 

In  our  opinion,  the  above  consolidated  financial  statements  adequately  reflect,  in  all  material  respects,  the 
financial position of the Company and its consolidated companies as of December 31, 2023 and 2022, as well as 
the results of their operations, their changes in equity and their cash flows for each of the three years in the 
period ending on December 31, 2023, in accordance with International Financial Reporting Standards (IFRS) and 
the provisions of the Securities Regulations (Annual Financial Statements), 5770-2010. 

Without  limiting  our  above  opinion,  we  draw  attention  to  what  is  stated  in  Note  1.3  in  the  consolidated 
statements,  regarding  the  investigation  by  the  Securities  Authority  and  the  Israel  Police  of  a  suspicion  of 
committing offenses under the Securities Law and the Penal Code concerning, inter alia, transactions related to 
the former controlling shareholder in various offenses, among other things, for offenses of bribery and causing 
misleading detail in immediate reporting, and regarding the filing of an indictment against the former controlling 
shareholder  of  the  Company  and  former  senior  officers  of  Bezeq  Group,  which  attributes  to  the  defendants 
fraudulent  receipt  and  reporting  offenses  under  the  Securities  Law.  Also,  following  the  opening  of  the 
aforementioned investigation, a number of civil legal proceedings were opened against the Company, former 
officers of the Company as well as companies from the group that previously controlled the Company, including 
motions for the approval of class actions. As stated in the above note, at this stage the Company is unable to 
assess the effects of the investigations, their findings and results on the Company as well as on the statements 
and estimates used in the preparation of these reports, if any. 

In addition, without limiting our above opinion, we draw attention to what is stated in Note 17 to the Company’s 
consolidated statements regarding claims filed against Group companies, which cannot be estimated or for which 
the exposure cannot yet be calculated. 

Key audit matters  

Key  matters  in  the  audit  listed  below  are  the  matters  that  were  communicated,  or  were  required  to  be 
communicated, to the Company's Board of Directors and which, according to our professional judgment, were 
most significant in the audit of the consolidated statements for the current period. These matters include, among 
others, any matter which: (1) Relates, or may relate, to material sections or disclosures in the statements, and 
(2) Our judgment regarding it was particularly challenging, subjective or complex. These matters are answered 
as part of our audit and formation of our opinion on the consolidated statements as a whole. The communication 
of these matters below does not change our opinion on the consolidated statements as a whole, and we do not 
use it to give a separate opinion on these matters or on the sections or disclosures to which they refer. 
4 

 
 
 
 
 
 
 
 
 
 
 
Somekh Chaikin 
KPMG Millennium Tower 
17 HaArbaa Street P.O.B. 609 
Tel Aviv 6100601 
03 684 8000 

Measuring the impairment of cash-generating units of Yes Ltd. and Bezeq International Ltd. 

Why was the matter determined as a key audit matter 
As described in Notes 3.7, 10.2, 10.5 and 10.6 to the consolidated statements, as of December 31, 2023, the 
recoverable amount of the cash generating units Yes Ltd. and Bezeq International Ltd. (hereinafter: the "Units") 
is negative in the amount of NIS (24) and (23) million, respectively, and the total loss from the  impairment of 
these units for the year that ended on December 31, 2023 amounts to NIS 291 million.  

In accordance with International Accounting Standard 36 ("IAS36"), the recoverable amount is the higher of the 
value  in  use  of  a  cash-generating  unit,  which  is  measured  by  the  Company's  future  cash  flow  forecast 
measurement  method  (DCF),  and  the  fair  value  minus  selling  costs.  Allocation  of  the  impairment  of  the 
Company's assets is carried out in accordance with the fair value minus sales costs of each of the unit's assets. 
The impairment audit of the units required us to exercise discretion, when examining the reasonableness of the 
assumptions  and  estimates  used  by  Management  and  external  experts  on  its  behalf,  for  the  purpose  of 
measuring the recoverable amount and allocating the impairment. Accordingly, we identified the measurement 
of the impairment of the units as a key matter in the audit. 

Audit procedures carried out in response to the key matter in the audit 

The main procedures we carried out in connection with this key matter as part of our audit included, among 
others:  checking  the  completeness  and  accuracy  of  the  databases  used  to  calculate  the  fair  value  minus  the 
exercise costs of the Company's assets, checking the reasonableness of the significant assumptions and estimates 
used in building the forecasted cash flows by comparing them to historical results, multi-year plans and updated 
market data. We also checked the adequacy of the information presented in Notes 3.7, 10.2, 10.5 and 10.6 to 
the consolidated statements, made inquiries of the relevant parties in the Company involved in the process and 
checked the planning, implementation and operational effectiveness of certain internal controls related to the 
assessment of the recoverable amount of the units. 

For the purpose of carrying out the procedures, we used experts with skill and knowledge in fair value valuations 
in  order  to  assist  in  assessing  the  adequacy  of  the  evaluation  method,  assessing  the  reasonableness  of  the 
discount rate and the growth rate, as well as in performing arithmetic tests for calculating the use value of the 
units and fair value minus sales costs of the units' assets. 

We also audited, in accordance with Audit Standard (Israel) 911 of the Institute of Certified Public Accountants 
in Israel "Audit of Components of Internal Control over Financial Reporting", components of internal control over 
the financial reporting of the Company as of December 31, 2023, and our report dated March 12, 2024 included 
an unreserved opinion on the effective existence of those components. 

Somekh Chaikin 
Certified Public Accountants 

March 12, 2024 

Somekh Chaikin, Israeli partnership and a member of the KPMG network of independent firms 
incorporated under the Swiss entity KPMG International Cooperative ("KPMG International") 

 
 
 
 
 
 
 
 
 
 
 
  
Somekh Chaikin 
KPMG Millennium Tower 
17 HaArbaa Street P.O.B. 609 
Tel Aviv 6100601 
03 684 8000 

The  auditors'  report  to  the  shareholders  of  B  Communications  Ltd.  regarding  an  audit  of  components  of 
internal control over financial reporting in accordance with Article 9b (c) of the Securities Regulations (Periodic 
and Immediate Reporting), 5730-1970 

We audited components of internal control over financial reporting of B Communications Ltd. and subsidiaries 
(hereafter collectively - "the Company") as of December 31, 2023. These control components were determined 
as  explained  in  the  next  paragraph.  The  Company's  Board  of  Directors  and  Management  are  responsible  for 
maintaining effective internal control over financial reporting and evaluating the effectiveness of components of 
internal  control  over  financial  reporting  attached  to  the  periodic  report  as  of  the  aforementioned  date.  Our 
responsibility is to express an opinion on components of internal control over the Company's financial reporting 
based on our audit. 

Components of internal control over financial reporting that were audited were determined in accordance with 
Audit  Standard  (Israel)  911  of  the  Institute  of  Certified  Public  Accountants  in  Israel  "Audit  of  Components  of 
Internal Control Over Financial Reporting" (hereinafter - "Audit Standard (Israel) 911"). These components are: 
(1)  Controls  at  the  organization  level,  including  controls  on  the  process  of  preparing  and  closing  financial 

reporting; 

(2)  Controls over cash process and debt management; 

We conducted our audit in accordance with Auditing Standard (Israel) 911. According to this standard, we are 
required to plan and perform the audit with the aim of identifying the audited control elements and obtaining a 
reasonable degree of assurance as to whether these control elements have been effectively implemented in all 
material  respects.  Our  audit  included  gaining  an  understanding  of  internal  control  over  financial  reporting, 
identifying  the  audited  control  components,  assessing  the  risk  of  a  material  weakness in  the  audited  control 
components, as well as examining and evaluating the effectiveness of the planning and operation of those control 
components  based  on  the  assessed  risk.  Our  audit,  regarding  those  control  elements,  also  included  the 
performance  of  such  other  procedures  as  we  deemed  necessary  according  to  the  circumstances.  Our  audit 
referred only to the audited control components, as opposed to internal control over all the essential processes 
in connection with the financial reporting, and therefore our opinion refers to the audited control components 
only. Also, our audit did not refer to mutual effects between the audited and non-audited control components 
and therefore, our opinion does not take into account such possible effects. We believe that our audit provides 
an adequate basis for our opinion in the context described above. 

Due  to  inherent  limitations,  internal  control  over  financial  reporting  in  general,  as  well  as  its  components  in 
particular, may not prevent or detect a misstatement. Also, drawing conclusions about the future based on any 
current assessment of effectiveness is exposed to the risk that controls will become inappropriate due to changes 
in circumstances or that the extent to which the policies or procedures exist will change for the worse. 

In our opinion, the Company effectively maintained, in all material respects, the audited control components as 
of December 31, 2023. 

As described in the report regarding the  effectiveness of the internal control over the financial reporting and 
disclosure, as of December 31, 2023, of B Communications Ltd. (hereinafter – “the Corporation"), regarding the 
investigations  of  the  Securities  Authority  and  the  Israel  Police,  as  specified  in  Section  1.1.7  of  the  chapter 
describing  the  corporation's  business  in  this  report,  to  the  Corporation  does  not  have  complete  information 
regarding these investigations, their design, the materials and evidence available to the law authorities in the 
matter. Accordingly, the Corporation is unable to assess the effects, findings and results of the investigations on 
the Company, as well as on the statements and the estimates used in their preparation, if any. 

 
 
 
 
 
 
 
 
 
 
Somekh Chaikin 
KPMG Millennium Tower 
17 HaArbaa Street P.O.B. 609 
Tel Aviv 6100601 
03 684 8000 

We also audited, in accordance with generally accepted auditing standards in Israel, the consolidated financial 
statements of the company for December 31, 2023 and 2022 and for each of the three years in the period ending 
on  December  31,  2023  and  our  report,  dated  March  12,  2024,  included  an  unlimited  opinion  on  those 
statements, based on our audit and the reports of the other auditors, as well as references to what is stated in 
Note 1.3 regarding the investigation of the Securities Authority and the Israel Police into suspicions of committing 
offenses under the Securities Law and the Penal Code concerning, among other things, transactions related to 
the  former  controlling  shareholder  and  the  notice  of  the  Tel  Aviv  District  Attorney's  Office  (Taxation  and 
Economy) regarding the consideration of prosecuting the Company and holding a hearing for suspicions of the 
offense of bribery and the offense of reporting with the aim of misleading a reasonable investor, as well as what 
is  stated  in  this  note  regarding  the  filing  of  an  indictment  against  the  former  controlling  shareholder  of  the 
Company,  for  various  offenses,  among  others  the  offenses  of  bribery  and  causing  a  misleading  detail  in  an 
immediate report, and regarding the filing of an indictment against the former controlling shareholder of the 
Company and former senior officers of Bezeq Group, which attributes to the defendants fraudulent receipt and 
reporting offenses under the Securities Law. Also, following the opening of the aforementioned investigation, a 
number of civil legal proceedings were opened against the Company, former officers of the Company as well as 
companies from the group that previously controlled the Company, including motions for the approval of class 
actions.  As  stated  in  the  above  note,  at  this  stage  the  Company  is  unable  to  assess  the  effects  of  the 
investigations, their findings and results on the Company as well as on the statements and estimates used in the 
preparation of these statements, if any, and drawing attention to what is stated in Note 17 regarding claims filed 
against the Group and for which it is not possible to estimate or calculate the exposure at this stage. 

Somekh Chaikin 
Certified Public Accountants 

March 12, 2024 

Somekh Chaikin, Israeli partnership and a member of the KPMG network of independent firms 
incorporated  u n d e r   t h e   Swiss entity K P M G   I n t e r n a t i o n a l   C o o p e r a t i v e   ( " K P M G   I n t e r n a t i o n a l " )  

 
 
 
 
 
  
 
 
Consolidated Statements as of December 31, 2023 

Consolidated statements of financial position as of  December 31 

Assets 

Note 

NIS millions 

NIS millions 

2023 

2022 

Cash and cash equivalents  

Investments 

Trade receivables 

Other receivables 

Inventory  

Total current assets 

Trade and other receivables 

Right-of-use assets 

Property plant & equipment 

Intangible assets 

Deferred expenses and non-current investments 

4,3.3 

5,3.3 

3.3 ,6

3.3 ,6

644 

1,248 

1,477 

166 

82 

3,617 

3.3 ,6

446 

3.6 ,8

3.4 ,9

1,870 

6,828 

3.5 ,10

3,280 

11 

312 

 754  

 973  

1,440  

 289  

 85  

3,541  

 460  

1,746  

6,542  

3,251  

 315  

Total non-current assets  

12,736 

12,314  

Total assets 

16,353 

15,855  

8 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
Consolidated Statements as of December 31, 2023 

Consolidated statements of financial position as of December 31 (Cont.) 

Liabilities and equity 

Note 

NIS millions 

NIS millions 

2023 

2022 

Debentures, loans and credit 

Current maturities of lease liabilities 

Trade payables  

Employee benefits 

Provisions  

 Total current liabilities 

Loans and debentures 

Lease liabilities 

Employee benefits 

Derivatives and other liabilities 

Deferred tax liabilities 

Provisions 

Total non-current liabilities 

Total liabilities 

Equity attributed to: 

Shareholders of the Company 

Non-controlling interests 

Total equity  

3.3 ,13

3.6 ,8

14 

3.8 ,16

3.9 ,15

3.3 ,13

3.6 ,8

3.8 ,16

 ,7

3.12

3.9 ,15

20 

12.8 

1,074 

433 

1,758 

332 

111 

3,708 

7,829 

1,608 

251 

160 

322 

29 

 921  

 456  

1,598  

 399  

 168  

3,542  

8,257  

1,452  

 201  

 151  

 319  

 37  

10,199 

10,417  

13,907 

13,959  

189 

2,257 

2,446 

 54  

1,842  

1,896  

Total liabilities and equity 

16,353 

15,855  

Darren Glatt 
Chairman of the Board of Directors 

Tomer Raved 
CEO 

Itzik Tadmor 
CFO 

Date of approval of the financial statements: March 12, 2024 

The notes attached to the consolidated statements form an integral part thereof. 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated Statements as of December 31, 2023 

Consolidated income statements for the year ended December 31 

2023 

2022 

2021 

Note 

NIS millions 

NIS millions 

NIS millions 

 ,21

3.10

9,103 

8,986  

8,821  

Revenues 

Operating expenses 

General and operating expenses 

Salaries 

22 

23 

Depreciation, amortization and impairment  

8,9,10,11 

Other operating expenses (income), net 

24 

Total operating expenses 

Operating profit 

Financing expenses (income)  

 ,25

3.11

Financing expenses 

Financing income 

Financing expenses, net 

Profit before income taxes 

Income taxes expenses 

Net profit for the year 

Net profit attributable to shareholders of the 
Company 
Net  profit  attributable  to  non-controlling 
interests 

Net profit for the year 

Profit per share (NIS) 

Basic 

Diluted  

 ,7

3.12

27 

3,3  
81

1,926 

1,867 

180 

7,35  
4

1,74  
9

851  

 )
(169

934  

1,400 

346 

1,054 

187 

867 

1,054 

1.75 

1.74 

3,396  

1,877  

1,868  

 220  

7,361  

1,625  

 530  

)

(132

 398  

1,227  

 336  

 891  

 158  

 733  

 891  

1.42  

1.41  

3,265  

1,888  

1,889  

(77)

6,965  

1,856  

 533  

(55)

 478  

1,378  

 382  

 996  

 129  

 867  

 996  

1.11  

1.11  

Consolidated statements of comprehensive income for the year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

Net profit for the year 

Reassessment of defined benefit plan, net of tax – will not be 
transferred to income 

Additional other comprehensive income (loss) from hedging, 
net of tax – will be transferred to income 

Total comprehensive income for the period 

Attributable to: 

Shareholders of the company 

Non-controlling interests 

Total comprehensive income for the period 

1,054 

18 

(6 )

1,066 

190 

876 

1,066 

 891  

 56  

(6)

 941  

 171  

 770  

 941  

 996  

(1)

 37  

1,032  

 139  

 893  

1,032  

The notes attached to the consolidated statements form an integral part thereof. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
Consolidated Statements as of December 31, 2023 

Consolidated statements of changes in equity for the year ended December 31 

Share 
capital 

Shares 
premium  

Treasury 
shares 

Other 
funds 

NIS 
millions 

NIS 
millions 

NIS 
millions 

NIS 
millions 

Deficit 
balance 

NIS 
millions 

Total 

NIS 
millions 

Non-
controlling 
interests 

NIS millions 

 Balance as of January 1, 2021 

12 

1,495 

 )*( 

Profit for the year 2021 

Other  comprehensive  income  for  the 
year, net of tax 

Total comprehensive income for the year 
2021 

Transactions imputed directly to equity 

Share-based compensation (See Note 26) 

Buyback of shares (see Note 20) 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 - 

 Balance as of December 31, 2021 

12 

1,495 

Profit for the year 2022 

Other  comprehensive  income  (loss)  for 
the year, net of tax 

Total  comprehensive  income  (loss)  for 
the year 2022 

Transactions imputed directly to equity 

Share-based compensation (See Note 26) 

Business consolidation 

Dividend  distributed  to  non-controlling 
interests (see Note 12.7) 

Transaction 
interests (See Note 12.6) 

with 

non-controlling 

Buyback of shares (see Note 20) 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

 Balance as of December 31, 2022 

12 

1,495 

Profit for the year 2023 

Other  comprehensive  income  (loss)  for 
the year, net of tax 

Total comprehensive  profit (loss) for the 
year 2023 

Transactions imputed directly to equity 

Share-based compensation (See Note 26) 

Dividend  distributed  to  non-controlling 
interests (see Note 12.7) 

Transaction 
interests (See Note 12.6) 

with 

non-controlling 

Buyback of shares (see Note 20) 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

- 

 - 

 - 

 - 

 - 

(16)

(16)

- 

- 

- 

- 

- 

- 

- 

)

121

(

 )
137

(

- 

- 

- 

- 

- 

- 

(23 )

(39)

 - 

10 

10 

 - 

 - 

(29)

- 

(2)

(2)

1 

- 

- 

- 

- 

- 

(2 )

(2 )

- 

- 

- 

- 

Total 

NIS 
millions 

427 

996 

36 

 )
1,575

(

107)

(

129 

 - 

129 

10 

534 

867 

26 

129 

139 

893 

1,032 

 - 

 - 

 )

1,446

(

 - 

(16)

16 

27 

 - 

27 

(16)

1,454 

1,470 

158 

158 

733 

891 

15 

13 

37 

50 

173 

171 

770 

941 

- 

- 

- 

1 

- 

- 

(13)

- 

(13)

)

(121

(30 )

 )
1,286
(

54 

187 

187 

11 

1 

12 

1 

)

(392

)

(392

(2)

- 

1,842 

867 

(15)

)

(121

1,896 

1,054 

5 

3 

9 

12 

192 

190 

876 

1,066 

- 

- 

(32 )

- 

- 

- 

(32 )

(23 )

189 

10 

10 

 )
(466

 )
(466

(5 )

- 

(37 )

(23 )

2,257 

2,446 

 Balance as of December 31, 2023 

12 

1,495 

 )
160

(

(32 )

 )
1,126
(

(*) Represents an amount lower than NIS 1 million. 

The notes attached to the consolidated statements form an integral part thereof. 

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consolidated Statements as of December 31, 2023 

Consolidated statements of cash flows for the year ended December 31 

Cash flows from current activities 

Profit for the year 

Adjustments: 

Depreciation, amortization and impairment 

Capital gains, net 

Financing expenses, net 
Share-based compensation 
Income taxes expenses 

Change in trade and other receivables 

Change in inventory 

Change in trade and other payables 

Change in provisions 

Change in employee benefits 

Change in other liabilities 

Income taxes paid, net 
 Net cash derived from operating activities 

Cash flows for investing activities 

Purchase of PP&E 

Investment in intangible assets and deferred expenses 

Investment transactions, net 

Payment in respect of frequencies 

Government grant in respect of frequencies 

Proceeds from the sale of PP&E  

Purchase of a subsidiary minus cash purchased 

Interest received from bank deposits 

Miscellaneous 

Net cash used for investing activities 
Cash flows for financing activities 

Issuance of debentures and receipt of loans 

Repayment of debentures and loans 

Purchase of non-controlling interests 

Lease principal and interest payments 

Buyback of Company shares 

Interest paid 
Dividend distributed to non-controlling interests 

Early repayment fees 

Payment for completed hedging transactions 

Miscellaneous 

Net cash used for financing activities 

Net increase (decrease) in cash and cash equivalents 

Effect of changes in foreign currency exchange rate 

Cash and cash equivalents as of January 1 

Cash and cash equivalents at the end of the year 

Note 

2023 
NIS millions 

2022 
NIS millions 

2021 
NIS millions 

1,054 

 891  

 996  

8,9,10,11  1,867 
24 

(2 )

25 

26 
7 
6 

14 

15 

16 

9 

10,11 

13 

13 

12 

8 

20 

13 
12 

13 

364 
10 
346 
(10 )

(15 )

59 

18 

(3 )

23 

 )
(269
3,442 

 )
1,333
(

 )
(375

 )
(245

- 

- 

39 

(14 )

72 

21 

 )
1,835
(

1,015 

 )
1,409
(

(37 )

 )
(484

(23 )

 )
(312

 )
(466

- 

4 

(3 )
 )
1,715
(

 )
(108

(2 )

754 

644 

1,868  

1,889  

(8)

 445  
 12  
 336  
 342  

(21)

(54)

 24  

(91)

 18  

)
(271
3,491  

 )

1,353

(

)

(346

 223  

(88)

 74  

 40  

(9)

23 

 16  

)

(175

 498  
 27  
 382  
)
(229

(19)

(41)

(47)

(65)

(5)

)
(385
2,826  

 )

1,328

(

)

(363

)

(164

- 

- 

 278  

- 

8 

(9)

 )

1,420

(

 )

1,578

(

 400  

 )

1,416

(

(15)

)

(420

)

(121

)

(307

)

(392

(26)

(18)

- 
 )
2,315

(

)

(244

- 

 998  

 754  

1,730  

 )

2,072

(

- 

)

(387

(16)

)

(333

- 

(34)

(30) 

)2( 
 )
1,144

(

 104  

- 

 894  

 998  

The notes attached to the consolidated statements form an integral part thereof.

 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Consolidated Statements as of December 31, 2023 

1.  General 

1.1. 

The reporting entity 

B  Communications  Ltd.  (hereinafter  -  “the  Company")  is  a  company  incorporated  in 
Israel and its registered office is at 144 Menachem Begin Rd., Tel Aviv. The Company is a 
public company traded on the Tel Aviv Stock Exchange. The consolidated statements of 
the Company as of December 31, 2023 include those of the Company and its subsidiaries 
(hereinafter - "the Group"). 

On  April  14,  2010,  the  Company  acquired  30.44%  of  the  shares  of  Bezeq,  the  largest 
telecommunications group in Israel, and became the controlling shareholder of Bezeq. 
Bezeq's shares are listed for trading on the Tel Aviv Stock Exchange. 

As of December 31, 2023, the Company owned approximately 27.08% of Bezeq’s issued 
shareholder capital. As of the date of publication of the statements, the Company owns 
approximately 27.19% of the issued shareholder capital of Bezeq (see note 12.6). 

1.2. 

Control of the Company 

On December 2, 2019, Searchlight Capital Partners, through its subsidiary, Searchlight II 
BZQ (hereinafter - "Searchlight"), and the Forer family which controls TNR Investments 
Ltd.  (hereinafter  -  "the  Forer  Family"),  completed  the  purchase  of  the  control  of  the 
Company, so that Searchlight owned 60.18% and the Forer Family owned 11.39% of the 
Company's ordinary and issued shares. 

As  of  December  31,  2023,  Searchlight  and  the  Forer  Family  own  66.24%  and  12.54%, 
respectively,  of  the  Company's  net  ordinary  and  issued shares.  The  proportion  of  the 
holdings  of  Searchlight  and  the  Forer  Family  increased  following  a  buyback  of  the 
Company's shares carried out during the years 2021 and 2023 (see Note 20). 

1.3. 

Investigations by the Israel Securities Authority and the Israel Police 

1.3.1. 

During the years 2017 and 2018, the Israel Securities Authority and the Israel 
Police conducted investigations into suspicions of committing offenses under 
the Securities Law and the Penal Law, 5733-1977 ("Penal Law"), concerning 
transactions related to the former controlling shareholder of Bezeq and the 
Company and former Chairman of the Bezeq Board of  Directors, Mr. Shaul 
Elovich  ("Elovich")  regarding  the  purchase  of  shares 
in  Yes  TV  and 
Communications  Services  Ltd.  ("Yes")  and  the  provision  of  satellite 
communication  services 
the  Ministry  of 
Communications  with  Bezeq  (the  "DBS  Case")  as  well  as  suspicions  of  the 
exercise  of  powers  by  the  Prime  Minister,  Mr.  Binyamin  Netanyahu,  to 
promote  issues  concerning  the  business  and  economic  interests  of  Elovich 
and  Bezeq  Group.  ("Case  4000").  Following  the  investigations,  indictments 
were filed and notices were received as follows: 

the  conduct  of 

to  Yes, 

1.3.1.1. 

On January 28, 2020, an indictment was filed with the Jerusalem 
District  Court  against  Elovich  for  various  offenses,  among 
others, the offenses of bribery and causing a misleading detail 
in  an  immediate  report  in  connection  with  suspicions  of  the 
exercise  of  powers  by  the  Prime  Minister,  Mr.  Binyamin 
Netanyahu,  to  promote  issues  concerning  the  business  and 
economic interests of Elovich and Bezeq Group. 

13 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

1.3. 

Investigations by the Israel Securities Authority and the Israel Police (Cont.) 

1.3.1.2. 

Further to a notice from the Tel Aviv District Attorney's Office 
(Taxation and Economics) dated December 23, 2020 regarding  

the  consideration  to  prosecute  Bezeq  and  a  summons  to  a 
hearing in Case 4000, according to which: 

In respect of the suspected bribery offenses (an offense under 
Article 291 of the Penal Law, 5733-1973 along with Article 23 of 
the  Penal  Law),  and  the  offense  of  reporting  with  the  aim  of 
misleading  a  reasonable  investor  (an  offense  under  Article 
53(a)(4) of the Securities Law, along with Article 23 of the Penal 
Law, on February 1, 2024, an agreement  was signed between 
the State of Israel (through the Tel Aviv District Attorney's Office 
(Taxation  and  Economy))  and  Bezeq 
for  a  conditional 
termination of proceedings under the conditions in accordance 
with  Point  B  of  Chapter  91  of  the  Securities  Law  ("the 
Settlement"). 

In accordance with the Settlement, the State of Israel will not 
file an indictment in Bezeq's case in connection with any of the 
suspicions  investigated  in  the  investigation  file,  and  this  is 
subject to the suspect fulfilling its obligations according to the 
settlement as follows: (1) payment of an amount in the amount 
of NIS 800 thousand; (2) refraining from all A statement that is 
knowingly inconsistent with or contradicts the Settlement and 
the  facts  that  Bezeq  admitted  as  part  of  the  Settlement 
(“Walla”). 

As  part  of  the  Settlement,  the  State  of  Israel  also  informed 
Bezeq  that  it  had  decided  to  close  the  investigation  file 
regarding the company Walla! Communications Ltd. (a company 
that  was  fully  owned  by  Bezeq  at  the  times  relevant  to  the 
suspicions  and  received  a  similar  notice  regarding  the 
consideration of filing an indictment against it for suspicions of 
the offense of bribery). 

As part of the Settlement, Bezeq admitted the facts detailed in 
the settlement and these are: 

A. 

In the relevant period, between the years 2012 and 2016, Shaul 
Elovich ("Elovich") was the controlling shareholder of the Bezeq 
Group.  Walla,  which  during  the  relevant  period  was  a  wholly 
owned  subsidiary  of  Bezeq,  operated  the  "Walla  NEWS!" 
website. 

B.  Elovich  and  other  Bezeq  representatives  worked  with  the 
Director  General  of  the  Ministry  of  Communications  Shlomo 
issue  of  cancelling  the  structural 
Filber  to  promote  the 
separation in the Bezeq Group. 

C.  On  December  22,  2016,  Shlomo  Filber  ("Filber")  sent  Bezeq  a 
letter titled "Cancellation of the structural separation obligation 
in the Bezeq Group", which was drafted by him in coordination 
with Bezeq representatives, with the knowledge of Elovich and 
the CEO of Bezeq at that time, Stella Handler ("Handler"). The 

 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

letter included a misleading detail, according to which the fact 
regarding  the  obligation  to  hold  a  hearing  prior  to  the 
cancellation of the corporate separation in Bezeq was omitted, 
and a misleading representation was made, according to which 
both  the  cancellation  of  the  corporate  separation  and  the 
cancellation  of  the  structural  separation  are  in  an  advanced 
stage and have a higher feasibility than in actuality. 

D.  On December 23, 2016, Bezeq reported in an immediate report 
to  the  public  about  the  transmission  of  the  letter  and  its 
contents. This report included the misleading detail contained 
in the Ministry of Communications letter.  Elovich and Handler 
knew  that  the  letter  from  the  Ministry  of  Communications 
contained the misleading detail and that it would be reported 
to  the  public.  The  next  day,  the  Ministry  of  Communications 
published a clarification according to which the cancellation of 
the corporate separation will be done after a hearing procedure 
and subsequently Bezeq published a report clarifying this part 
of the previous report. 

It  should  be  noted  that,  as  appears  from  the  settlement,  the 
suspicions against Bezeq stem from the actions and/or omissions of 
Elovich and Handler, who were involved in the execution of the acts 
described in the settlement and who no longer serve at Bezeq. 

1.3.1.3. 

On  December  23,  2021,  to  the  best  of  Bezeq's  knowledge,  a 
notice  was  published  by  the  Attorney  General's  Office, 
according  to  which,  among  other  things,  the  Taxation  and 
Economic Attorney's Office filed with the economic department 
of the Tel Aviv District  Court, on the same day,  an indictment 
against  Elovich,  as  well  as  against  former  senior  officials  of 
Bezeq  Group  and  Yes,  Or  Elovich,  Amikam  Shurer,  Linor 
Yochelman,  Ron  Ayalon,  and  Mickey  Neiman  in  the  Yes  Case. 
According to the notice: 

A.  The  indictment  attributes  to  the  defendants  the  offenses  of 
obtaining by fraud under aggravated circumstances, fraud and 
breach  of  trust  in  a  corporation,  and  reporting  offenses 
according to the Securities Law, and refers to two cases: fraud 
in relation to the payment of consideration for the purchase of 
YES shares by Bezeq, and fraud in relation to the conduct of the 
independent committees that were established in Bezeq for the 
purpose of examining Bezeq transactions in which Elovich was 
personally interested. 

B.  The  Taxation  and  Economic  Attorney's  Office  entered  into  an 
arrangement  for  a  conditional  termination  of  proceedings 
under the terms of the Securities Law with Stella Handler, in the 
framework of which Stella Handler admitted the facts according 
to which she was involved in the inclusion of a misleading detail 
in Bezeq’s reports. In accordance with what is specified in the 
settlement, the Yes case was closed in the case of Stella Handler. 

 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

1.3. 

Investigations by the Israel Securities Authority and the Israel Police (Cont.) 

1.3.1.4. 

1.3.1.5. 

1.3.1.6. 

C.  The investigation files of other suspects investigated in the cases 
mentioned  above  were  closed,  including  against  the  Bezeq’s 
former  VP  of  Regulation,  as  well  as  against  Or  Elovich  and 
Amikam Shurer (in relation to both of them - except in regards 
to the Yes case as indicated at the beginning of this section). 

On July 20, 2022, the decision of the Economic Department of 
the Tel Aviv-Yafo District Court was published on the request of 
some  of  the  defendants  to  drop  charges  in  the  case  ("the 
Decision").  In  accordance  with  the  Decision,  the  second  and 
third charges in the indictment (fraud in relation to the conduct 
of the independent committees in the "Bezeq-Yes" transaction 
and the "Yes-Space" transaction) were dropped against all the 
defendants  in  the  following  charges:  the  former  controlling 
shareholder  of  Bezeq,  Mr.  Shaul  Elovich,  former  officers  in 
Bezeq  -  Mr.  Or  Elovich,  Mr.  Amikam  Shurer  and  Mrs.  Linor 
Yochelman,  as  well  as  against  the  companies  accused  of  the 
same  charges  -  companies  from  the  "Eurocom"  group.  It  was 
also determined in the Decision, among other things, that it is 
not  possible  to  accept  the  claim  put  forward  by  Mr.  Shaul 
Elovich, that the indictment does not reveal guilt in connection 
with the first charge (fraudulent obtainment of advances at the 
expense of the second contingent consideration in the "Bezeq-
Yes" transaction). It was also emphasized in the Decision, that it 
does  not  in  any  way  affect  the  civil  aspect,  and  the  pending 
proceedings in this context. 

On July 13, 2023, the judgment of the Supreme Court was given 
in  the  appeal  filed  by  the  State  against  the  aforementioned 
decision, according to which the State's appeal regarding all the 
respondents  (with  the  exception  of  Eurocom  Holdings  (1979) 
Ltd.)  was  accepted  and  the  case  was  returned  to  the  District 
Court for further evidentiary investigation 

As  far  as  YES  is  concerned,  which  on  November  20,  2017 
received a "suspect notification letter" according to which the 
investigation case in which it was questioned as a suspect was 
forwarded to the Attorney General's Office for consideration  - 
in accordance with the notice of the Attorney General's Office 
received at Yes, after the Securities Authority case, in which it 
was  questioned  as  a  suspect,  was  examined  by  the  Attorney 
General's Office, it was decided on January 11, 2021 to dismiss 
the case against it, without filing an indictment. 

1.3.2. 

It  should  be  noted  that  following  the  launching  of  the  aforementioned 
investigations, a number of civil legal proceedings were opened against Bezeq 
and Yes, Bezeq officers during the relevant period, as well as companies from 
the Group that formerly controlled Bezeq, including motions for approval of 
class  actions  and  motions  for  discovery  of  documents  before  submitting  a 
motion  for  approval  of  a  derivative  claim.  For  details  regarding  these 
procedures, see Note 17. 

1.3.3. 

Bezeq does not yet have complete information regarding the investigations, 
their  content,  the  materials  and  evidence  in  the  possession  of  the  law 
authorities in the matter (although in January 2021 Bezeq received the core 

 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

of the investigation material in connection with Case 4000 and this as part of 
the hearing on this matter as detailed in section 1.3.1.2 above). Accordingly, 
Bezeq is still unable to assess the effects of the investigations, their findings, 
and their results on Bezeq, as well as on the statements and the estimates 
used in the preparation of these reports, if any. 

Definitions 

In these statements: 

The Company 
The Group 
Bezeq 
Consolidated 
companies 
Included 
companies 
Investees 
Related party 

Interested party 

B Communications Ltd 
the Company and its consolidated companies 
"Bezeq" The Israel Telecommunications Corp. Ltd 
Companies  whose  reports  are  fully  consolidated,  directly  or 
indirectly, with the Company's reports as specified in Note 12. 
Companies, the Group's investment in which is included, directly 
or indirectly, in the statements based on the balance sheet value. 
Consolidated companies or included companies. 
As  defined  in  International  Accounting  Standard  24  regarding 
related parties. 
As defined in Paragraph (1) of the definition of "interested party" 
in a corporation in Article 1 of the Securities Law, 5748-1968. 

2. 

Basis of preparation of the statements 

2.1. 

Declaration of compliance with international financial reporting standards 

The consolidated financial statements were prepared by the group in accordance with 
international financial reporting standards (hereinafter: "IFRS") and in accordance with 
the securities regulations (annual financial statements), 2010. 

The  consolidated  financial  statements  were  approved  by  the  Company’s  Board  of 
Directors on March 12, 2024. 

2.2. 

Activity currency and presentation currency 

The  consolidated  financial  statements  are  presented  in  new  shekels,  which  are  the 
group's  operating currency, and are rounded to the nearest  million. The shekel is the 
currency that represents the main economic environment in which the group operates. 

2.3. 

Basis of measurement 

The  consolidated  statements  were  prepared  on  the  historical  cost  basis  with  the 
exception of the following items: 
* Derivative financial instruments and investments in securities measured at fair value 
through income 
* Inventory measured as the lower of cost or net exercise value 
* Deferred tax assets and liabilities 
* Provisions 
* Assets and liabilities in respect of employee benefits 

For more information regarding the measurement method of these assets and liabilities, 
see Note 3 regarding the material accounting policy. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

2.4. 

Operating cycle period 

The operating cycle of the Group does not exceed one year. Therefore, current assets 
and current liabilities include items that are intended and expected to be realized within 
a year from the date of the financial statements. 

2.5. 

Format for analyzing expenses recognized in the profit and loss statement 

Costs and expenses in the income statement are presented and analyzed according to a 
classification  method  based  on  the  nature  of  the  expenses.  The  aforementioned 
classification is suitable for understanding the business of the  Group, which deals in a 
wide variety of services provided through a shared infrastructure. All costs and expenses 
are used to provide the services. 

2.6. 

Use of estimates and discretion 

international 
When  preparing  the  consolidated  statements 
accounting  standards  (IFRS),  Management  is  required  to  exercise  discretion  and  be 
assisted  by  estimates,  estimates  and  assumptions  that  affect  the  implementation  of 
accounting  policies  and  the  reported  amounts  of  assets  and  liabilities,  revenue,  and 
expenses. Actual results may differ from estimates. 

in  accordance  with 

The estimates and assumptions are reviewed on an ongoing basis. Changes in accounting 
estimates are recognized in the period in which the estimates were updated and in any 
future period affected. 

The following is information regarding significant estimates and judgments, for which a 
change in estimates and assumptions has the potential to have a material impact on the 
statements of the next fiscal year: 

Key assumptions 
Assuming  the  expected  cash  flows 
from the cash generating units 

Possible implications 
Recognition of an impairment 
loss  or  cancellation  of  an 
impairment loss 

Reference 
Note 10 

the 

Subject 
Measuring 
recoverable 
amounts  of  cash 
generating units 
Provisions 
contingent 
liabilities, 
including levies 

and 

Assessing the chances of claims against 
the  Group  companies  and  measuring 
the  potential  liabilities  related  to  the 
claims 

Bezeq estimates of the payment to the 
authorities for levies on real estate in 
the "Sakia" complex 

Employee benefits  Actuarial assumptions such as discount 
rate,  future  wage  increase  rate  and 
departure rate 

Deferred taxes 

Effective  control 
over Bezeq 

Assumption regarding the expectation 
of  exercising  the  tax  benefit  in  the 
future, including an assumption that it 
is more likely than not that transferred 
losses  accumulated 
in  Yes  for  tax 
purposes will not be used 
The  possibility  of  appointing  most  of 
the members of the Board of Directors 
of Bezeq, as a result of the Company's 
permit  to  control  Bezeq,  the  control 

a 

Cancellation  or  creation  of  a 
claim, 
provision 
for 
recognition 
of 
and 
income/expenses 
recognition  of  profit  or  loss 
for said change, respectively 

Change in share capital gains 
gain  from  the  sale  of  real 
estate in the "Sakia" complex 
Increase  or  decrease 
in 
liabilities 
employee 
for 
benefits  and  commitment  to 
early retirement 
Recognition of a deferred tax 
asset  and  impact  on  income 
taxes expenses 

Notes 15,17 

Note 6.6 

Note 16 

Note 7 

Consolidation  of  Bezeq's 
statements  or  treatment  of 
investment in Bezeq using the 
equity method 

Notes  12.4, 
12.6 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

Subject 

Key assumptions 
over the composition and distribution 
of the other shareholders in Bezeq and 
the  restrictions  applicable  to  these 
shareholders 
the 
Communications Law 

under 

2.7. 

Fair value determination 

Possible implications 

Reference 

In order to prepare the statements, the Group is required to determine the fair value of 
certain assets and liabilities. Additional information regarding the assumptions used in 
determining the fair values is provided in Note 30.7 on fair value. 

3.  Material accounting policy 

The accounting policy rules detailed below have been consistently applied to all periods presented 
in these consolidated reports by the Group entities. 

In this note, where the Group chose accounting alternatives, which were allowed by accounting 
standards  and/or  accounting  policies  on  a  subject  where  there  is  no  explicit  instruction  in 
accounting standards, the said disclosure is presented in  bold. There  is no reason to attribute 
excessive importance to the aforementioned emphasis compared to the rest of the accounting 
policies that have not been emphasized. 

3.1. 

Consolidation of the statements 

3.1.1. 

Subsidiaries 

Subsidiaries  are  entities  controlled  by  the  Company.  The  statements  of 
subsidiaries are included in the consolidated statements from the day control 
is obtained until the day control is lost. 

Control exists when the group is exposed, or has rights, to variable returns 
from its involvement  in the acquiree and has the ability to influence these 
returns  through  its  power  of  influence  in  the  acquiree.  When  examining 
control, actual rights held by the group and by others are taken into account. 

3.1.2. 

Non-controlling interests 

Non-controlling  interests  are  the  equity  in  a  subsidiary  that  cannot  be 
attributed,  directly  or  indirectly,  to  the  parent  company  and  include 
additional elements such as: a share-based compensation that will be settled 
in equity instruments of subsidiaries. 

3.1.3. 

Allocation  of  profit  or  loss  and  other  comprehensive  income  among  the 
shareholders 

Profit  or  loss  and  any  other  component  of  comprehensive  income  is 
attributed to the Company's owners and non-controlling interests. The total 
profit or loss and other comprehensive income is attributed to the owners of 
the Company and the non-controlling interests even if as a result the balance 
of the non-controlling rights will be negative. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

3.1.4. 

Transactions with non-controlling interests while retaining control 

Transactions  with  non-controlling  interests  while  retaining  control  are 
treated  as  equity  transactions.  Any  difference  between  the  consideration 
paid or received and the change in non-controlling interests is credited to the 
Company's owner's share of equity directly to surplus. The amount by which 
the  non-controlling  interests  are  adjusted  is  calculated  as  follows:  by  the 
increase in the holding rate, according to the relative portion purchased from 
the balance of the non-controlling interests in the consolidated statements 
on the eve of the transaction. Also, when there are changes in the holding 
rate  in  a  subsidiary,  while  retaining  control,  the  Company  reallocates  the 
cumulative amounts recognized in other comprehensive income between the 
owners of the Company and the non-controlling interests. 

3.2. 

Foreign currency transactions 

From time to time, the Group enters into transactions with suppliers abroad, mainly in 
dollar and euro currencies. Foreign currency transactions are translated into the Group's 
functional  currency  according  to  the  exchange  rate  in  effect  on  the  dates  of  the 
transactions.  Financial  assets  and  liabilities  denominated  in  a  foreign  currency  at  the 
reporting date are translated into the activity currency according to the exchange rate in 
effect at that time. 

3.3. 

Financial Instruments 

3.3.1. 

Non-derivative financial assets 

Non-derivative  financial  assets  mainly  include  investments  in  deposits, 
marketable securities, customers and other receivables, and cash and cash 
equivalents. 

At the time of initial recognition, financial assets are classified into one of the 
following  measurement  categories:  amortized  cost;  or  fair  value  through 
income. 

The  Group's  debt  instruments  held  as  part  of  a  business  model  aimed  at 
collecting  contractual  cash  flows  in  accordance  with  IFRS  9  mainly  include 
short-term and long-term customers (see Note 6). 

The contractual cash flows for these financial assets include only principal and 
interest  payments  which  reflect  a  return  for  the  time  value  of  money  and 
credit risk. Accordingly, these financial assets are measured at amortized cost. 

Financial assets are deducted when the Group's contractual rights to the cash 
flows arising from the financial asset expire, or when the Group transfers the 
rights to receive the cash flows arising from the financial asset in a transaction 
in which all the risks and benefits from ownership of the financial asset are 
effectively transferred. 

The  Group  initially  recognizes  financial  assets  at  the  time  when  the  Group 
becomes a party to the contractual provisions of the instrument, meaning the 
time when the Group committed to buy or sell the asset. 

All  financial  assets  in  the  Group  that  are  not  classified  for  amortized  cost 
measurement are measured at fair value through income. 

The Group classifies financial assets as follows: 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

Cash and cash equivalents 

Cash  includes  immediately  usable  cash  balances  and  deposits  on  demand. 
The cash value includes short-term investments (where the duration between 
the original deposit date and the redemption date is up to 3 months), with a 
high level of liquidity, which can be easily converted into known amounts of 
cash and which are exposed to an insignificant risk of changes in value. 

Financial  assets  at  fair  value  through  profit  and  loss  are  measured  in 
subsequent periods at fair value. Net gains and losses, including interest or 
dividends revenue, are recognized in income. 

3.3.2. 

Derivative financial instruments including hedge accounting 

The  Group  holds  derivative  financial  instruments  for  cash  flow  hedging 
purposes in respect of risks of future changes in the consumer price index in 
connection with the debentures issued by the Group. 

At the time of creating the hedging relationship, the Group documents its risk 
management objective and strategy for performing the hedging. The group 
also documents the economic relationship between the hedged item and the 
hedging instrument, including whether the changes in the cash flows of the 
hedged item and the hedging instrument are expected to offset each other. 

Derivatives are initially recognized at fair value. Attributable transaction costs 
are charged to income as incurred. After initial recognition, the derivatives 
are measured at fair value, with the effective part of the changes in the fair 
value  of  the  derivative  being  credited  to  a  hedge  fund  as  part  of  other 
comprehensive income . The effective part of the changes in the fair value of 
a derivative, which is credited to other comprehensive income, is limited to 
the  cumulative  change  in  the  fair  value  of  the  hedged  item  (according  to 
current value) from the date the hedge was created. 

In  addition,  the  Group  owns  derivative  financial  instruments  for  cash  flow 
hedging purposes for foreign currency risks. Hedge accounting is not applied 
in respect of these instruments. In cases as mentioned, the Group performs 
economic hedging, and derivative instruments as mentioned are recognized 
at fair value; The changes in the fair value are immediately credited to the 
income statement, as financing income or expenses. 

3.3.3. 

Non-derivative financial instruments 

Non-derivative financial liabilities include: debentures issued by the Group, 
loans and credit from banking corporations and other credit providers (see 
Note 13), suppliers and other beneficiaries (see Note 14). 

After initial recognition, financial liabilities are measured at amortized cost in 
accordance with the effective interest method. 

Financial liabilities are deducted when the Group's liability, as specified in the 
agreement, expires or when it is discharged or cancelled. 

The  value  of  index-linked  financial  liabilities,  which  are  not  measured 
according to fair value, is estimated in each period according to the actual 
increase/decrease rate of the index. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

3.3. 

PP&E 

The Group chose to measure PP&E items at cost minus accumulated depreciation and 
impairment losses. 

Cost includes costs directly attributable to the purchase of the property. The cost of self-
constructed  assets  includes  the  cost  of  materials,  direct  labor,  contactor  costs,  and 
discounted financing costs, any additional cost that can be directly attributed to bringing 
the  asset  to  the  location  and  condition  necessary  for  it  to  be  able  to  operate  in  the 
manner intended by Management, as well as an estimate of the costs of dismantling and 
removing the items and restoring the site where the item is located in cases where the 
Group is obligated to clear and restore the site. 

Most  spare  parts,  auxiliary  equipment,  and  backup  equipment  are  classified  as  fixed 
assets when they meet the definition of PP&E, since their useful duration is over a year 
in accordance with IAS 16. 

When significant PP&E parts have different durations, they are treated as separate items 
(significant components) of the PP&E. 

Profit or loss from the sale of PP&E is included in the other income or other expenses, 
as the case may be, in the income statement. 

Depreciation is imputed to the income statement according to the straight-line method 
over the estimated useful life of each part of the PP&E items. 

Improvements in leased buildings are generally  amortized  over the lease term (which 
includes the period of the extension options held by the Group which in its assessment 
are  reasonably  certain  to  be  exercised)  or  the  useful  duration  of  the  leasehold 
improvements, whichever is shorter. 

international  network  equipment  (switching, 

Asset 
Landline  and 
transmission and power) 
Landline network 
Multi-channel TV equipment and infrastructure 
Subscriber equipment and installations 
Vehicles 
Office and general equipment 
Electronic  equipment,  computers  and  internal  communication 
systems 
Cellular network 
Passive radio equipment at cellular network sites 
Structures 
Underwater cable 

Years 
-220 

10-40 
1-7 
3-8 
6-7 
5-14 
3-7 

4-10 
Until December 31, 2042 
25 
10-25 

The estimates regarding the depreciation method, the useful life and the residual value 
are re-examined at least every reporting year and adjusted when necessary. 

3.4. 

Intangible assets and goodwill 

3.4.1. 

The Group's intangible assets mainly include software and computer licenses 
and rights to use cellular communication frequencies (see Note 10). 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

Frequency rights refer to the frequencies assigned to Pelephone for cellular 
activity,  following  its  winning  in  dedicated  tenders  held  by  the  Ministry  of 
Communications.  Depreciation  for  the  property 
imputed  to  the 
depreciation and amortization item in the income statement according to the 
"straight line" method and is reduced over the frequency allocation period, 
which  begins  at  the  time  of  their  use.  3G  frequencies  (UMTS/HSEA)  are 
amortized until the end of 2030, 4G frequencies (LTE) and 5g frequencies will 
be amortized until September 2032. 

is 

Amortization  of  intangible  assets  is  credited  to  the  income  statement 
according to the straight-line method, over the estimated useful duration of 
the intangible assets from the date the assets are available for use. 

The estimated useful duration for the current period is: 

Property type 

Amortization period 

Frequency usage rights 

3G frequencies - until December 2030 
4G and 5G frequencies - until August 2032 

Computer software and licenses 
to use the software 

1-7  years,  depending  on  the  license  period  or  over  the 
estimated duration of use of the software 

The estimates regarding the depreciation and useful duration method are re-
examined at least every reporting year and adjusted when necessary. 

3.4.2. 

Goodwill 

Goodwill created as a result of the acquisition of subsidiaries is included in 
the intangible assets section. After initial recognition, goodwill is measured at 
cost minus accumulated impairment losses that is not currently amortized. 
Goodwill is examined for impairment at least once a year. See also Note 10. 

3.6. 

Leases 

The  Group's lease agreements, the Group mainly leases cellular communication sites, 
buildings, and vehicles. 

For lease contracts that include non-lease components, such as services or maintenance 
related to a lease component, the Group has chosen to treat the contract as a single 
lease component, without separating the components. 

Since the interest rate inherent in the lease cannot be easily determined, the  Group's 
additional interest rate is used. 

After initial recognition, the asset is treated according to the cost model, and is amortized 
over the lease term or the asset's useful duration (whichever is earlier). 

3.6.1. 

Lease period 

The  lease  period  is  defined  as  a  period  during  which  the  lease  cannot  be 
canceled, and includes the periods for which there is an option to extend or 
cancel  the  lease  if  it  is  reasonably  certain  that  the  group  will  exercise  the 
options to extend the lease and not exercise the option to cancel the lease. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

3.6.2. 

Variable lease payments 

Most  of  the  Group’s  leasing  agreements  include  lease  payments  that  are 
linked to the Consumer Price Index. These payments are initially measured by 
using  the  existing  index  at  the  start  of  the  lease,  and  are  included  in  the 
measurement of the lease liability. When there is a change in the cash flow 
of future lease payments resulting from the change in the index, the balance 
of the obligation is updated against the right-of-use asset. 

3.6.3. 

Depreciation of a right-of-use asset 

After the start date of the lease, the right-of-use asset is measured using the 
cost method, minus accumulated depreciation and minus accumulated losses 
from impairments and is adjusted for remeasurements of the liability for the 
lease.  Depreciation  is  calculated  on  a  straight-line  basis  over  the  useful 
duration or the contractual lease period, whichever is earlier, as follows: 

Property type 

Weighted average of the period of the agreements as 

of December 31, 2023 (years) 

Cellular communication sites 

Structures 

Vehicles 

6.3 

16.3 

1.8 

3.7. 

Impairment of non-financial assets 

The Company performs an impairment test for its cash generating units once a year (see 
Note 10), or if there are indicators of impairment. 

Recoverable amount measurement 

The recoverable amount of an asset or of a cash generating unit is the value in use or the 
fair  value  less  selling  costs,  whichever  is  higher.  In  determining  the  value  in  use,  the 
Group discounts the predicted future cash flows according to the discount rate which 
reflects the market's assessments regarding the time value of money and the specific 
risks related to the asset or cash generating unit (for which the future cash flows were 
not adjusted). 

Allocation of goodwill to cash generating units 

For the purpose of examining the impairment of goodwill, cash-generating units to which 
goodwill has been allocated are grouped so that the level at which  the impairment  is 
examined reflects the lowest level at which the goodwill is subject to monitoring for the 
purpose of internal reporting, but in any case is not greater than the activity segment. 
Goodwill  acquired  as  part  of  business  combinations  is  allocated  for  the  purpose  of 
examining impairment to cash-generating units that are expected to yield benefits from 
the synergy of the combination. 

Recognition of an impairment loss 

An  impairment  loss  of  a  cash-generating  unit  is  recognized  when  the  cash-generating 
unit's book value, including goodwill, as far as relevant, exceeds its recoverable amount 
and is imputed to income. An impairment loss recognized for a cash-generating unit is 
allocated first to amortize the book value of goodwill attributed to the unit, and then to 
amortize the book value of the other assets in the cash-generating unit. For the purpose 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

of allocating the loss from impairment, the value of the assets is not reduced below their 
fair value minus realization costs, their value in use (if determinable), or zero, whichever 
is higher. 

Loss  from  impairment  of  assets  that  is  created  as  a  result  of  a  one-time  update  of 
forecasts for the coming years is classified in the income statement under the section 
"Impairment loss". On the other hand, loss from impairment of assets resulting from 
the  ongoing  adjustment  of  non-current  assets  of  the  group  companies  to  their  fair 
value minus exercise costs (created in light of the prospect of continued negative cash 
flow  and  negative  operating  value  of  those  companies)  is  classified  in  the  income 
statement under the same sections in which the current expenses were classified for 
these assets. The aforementioned classification is more in line with the presentation 
method  based  on  the  essence  of  the  expense  and  is  also  more  suitable  for 
understanding the Group's business. 

3.7. 

Impairment of non-financial assets (Cont.) 

Accordingly,  in  the  income  statement,  the  continuous  decrease  in  the  value  of 
broadcasting  rights  is  shown  as  part  of  "General  and  operating  expenses"  while  the 
continuous decrease in the value of items of PP&E, intangible assets and capacity usage 
rights is presented as part of the "Depreciation, amortization and impairment" expenses. 

3.8. 

Employee benefits 

3.8.1. 

Post-employment benefits 

The Group has several post-employment benefit plans. The plans are usually 
funded  by  deposits  to  insurance  companies  and  are  classified  as  defined 
deposit plans as well as defined benefit plans. 

Defined deposit plans 

A defined deposit plan is a post-employment plan whereby the Group pays 
fixed  payments  to  a  separate  entity  without  having  any  legal  or  implied 
obligation to pay additional payments. 

The Group's obligations to deposit in a defined deposit plan are imputed as 
an expense to income in the periods during which the employees provided 
the services. 

Defined benefit plans 

The  Group's  net  liability,  which  refers  to  a  defined  benefit  plan  for  post-
employment benefits, is calculated for each plan separately by estimating the 
future amount of the benefit that the employee will receive in exchange for 
his  services  in  the  current  period  and  in  previous  periods.  This  benefit  is 
presented according to current value minus the fair value of the plan's assets. 
The calculations are made every year by a qualified actuary. The discount rate 
is determined according to the yield at the time of reporting on high-quality 
corporate debentures, whose currency is the same as the currency in which 
the benefit is paid or linked thereto, and whose vesting date is similar to the 
terms of the Group's liability. 

The net interest costs for a defined benefit plan are calculated by multiplying 
the net liability by the discount rate used to measure the liability for a defined 
benefit, as determined at the beginning of the annual reporting period. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

The Group chose to present the interest costs that were credited to profit 
and loss, as part of the Financing expenses section. 

losses  and 

Remeasurement of the net defined benefit liability includes actuarial profits 
interest). 
return  on  plan  assets 
and 
Remeasurements  are  imputed  immediately,  through  other  comprehensive 
income, directly to surplus. 

(excluding 

the 

When there is an improvement or reduction in the benefits that the  Group 
provides to employees, part of the increased or reduced benefits that refers 
to the past services of the employees is immediately recognized as  income 
when the amendment or reduction of the plan occurs. 

3.8.1. 

Other long-term employee benefits 

The Group's liability for long-term employee benefits (such as an obligation 
for accrued vacation and sick days), which do not refer to post-employment 
benefit plans, is for the amount of the future benefit due to employees for 
services granted in the current period and in previous periods. The amount of 
these  benefits  is  presented  at  its  current  value.  The  discount  rate  is 
determined  according  to  the  yield  at  the  time  of  reporting  on  high-quality 
linked  corporate  debentures  whose  currency  is  the  shekel,  and  whose 
repayment date is similar to the terms of the Group's commitment. Actuarial 
changes are  imputed to the  income statement  in the period in which  they 
were created. The actuarial changes resulting from a change in the discount 
rate are imputed to the Financing expenses/income section, while the other 
differences are imputed to Salaries expenses. 

3.8.2. 

Early retirement and severance benefits 

Severance benefits are recognized as an expense when the Group has made 
a  clear  commitment,  with  no  actual  possibility  of  cancellation,  to  dismiss 
employees  before  they  reach  the  accepted  retirement  date  according  to  a 
detailed formal plan. Benefits given to employees in voluntary retirement are 
imputed  as  an  expense  when  the  Group  offered  the  employees  a  plan 
encouraging voluntary retirement and the employees accepted the offer, or 
when Bezeq can no longer go back on its offer. 

The  expenses  for  early  retirement  and  dismissal  that  were  imputed  to 
income are presented in the Other operating expenses (income) Section. The 
actuarial changes resulting from a change in the discount rate of long-term 
benefits  for  early  retirement  and  dismissal  are  credited  to  the  financing 
expenses section, while the other actuarial changes are imputed to Other 
operating expenses (income). 

3.9. 

Provisions 

A provision is recognized when the Group has a current, legal or implied obligation, as a 
result of an event that occurred in the past, which can be reliably measured, and when 
it is expected that an inflow of economic benefits will be required to settle the obligation. 

3.9.1. 

Lawsuits 

The  handling  of  pending  lawsuits  is  in  accordance  with  IAS37  and  its 
accompanying  provisions.  According  to  the  provisions,  the  claims  are 
classified  according  to  groups  with  similar  characteristics,  according  to  the 
areas of probability of the realization of the risk exposures as detailed below: 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

A.  Expected - probability above 50%. 
B.  Possible - probability more than unlikely and less than or equal to 50%. 
C.  Unlikely - probability less than or equal to 5%. 

With respect to claims for which the Group has a legal obligation as a result 
of  an  event  that  occurred  in  the  past  and  whose  realization  is  likely  to  be 
expected, provisions are included in the statements which, in the opinion of 
the  Group  Management  that  is  based,  among  other  things,  on  its  legal 
advisors  handling  those  claims,  are  adequate  under  the  circumstances  of 
each  case  and  this  despite  the  fact  that  the  said  claims  are  denied  by  the 
Group  companies.  In  addition,  there  are  a  limited  number  of  legal 
proceedings,  most  of  which  were  received  recently,  the  chances  of  which 
cannot be assessed at this stage, and for that reason no provision was made 
for them. 

In  Note  17,  details  were  given  regarding  the  amount  of  the  additional 
exposure due to pending claims which are likely to be realized. 

The Group recognizes an indemnity asset only if it is practically certain that 
the indemnity would be received if the Company eliminates the liability. The 
amount  recognized  for  the  indemnity  does  not  exceed  the  amount  of  the 
provision. 

3.10.  Revenues 

Revenues  in  the  Group  are  divided  according  to  the  activity  segments  (Note  21)  as 
follows: 
• 

Landline national interior communication - mainly internet services, telephony, 
transmission and data communication, and others. 

•  Cellular communication- cellular services and sale of end equipment. 
•  Multi-channel television 
• 

Internet services (ISP, international communication, and ICT services) 

3.10.1. 

The Group recognizes revenue when the customer obtains control over the 
promised goods or service. Revenue is measured according to the amount of 
consideration  to  which  the  Group  expects  to  be  entitled  in  return  for  the 
transfer of goods or services promised to the customer, apart from amounts 
collected for the benefit of third parties. 

When there is a significant financing component in the contract,  the Bezeq 
recognizes  the  consideration  amount  using  the  discount  rate  that  will  be 
reflected  in  a  separate  financing  transaction  between  itself  and  the 
customer at the time of engagement. The financing component is recognized 
as interest revenue or expenses during the period calculated according to the 
effective interest method. 

In cases where the gap between the date of receipt of payment and the date 
of delivery of the goods or service to the customer is a year or less, the Group 
applies the practical relief stipulated in the standard and does not separate 
a significant financing component. 

Measuring progress of performance obligation fulfilment 

In  most  types  of  revenue,  the  Group  recognizes  revenue  over  time  by 
measuring progress toward fulfillment in full of the performance obligation 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

in a manner that reflects the Group's performance in transferring control of 
the promised goods or services to the customer. 

3.10.2. 

Contract costs 

There  are  agreements  in  the  group  that  include  supplemental  costs  of 
obtaining  a  contract  with  a  customer,  such  as  sales  commissions  paid  to 
resellers  and  salespeople  employed  by  the  Group  for  sales  and  upgrades. 
These costs are recognized as an asset when it is expected that the Group will 
recover these costs. 

3.10.  Revenues (Cont.) 

Costs  discounted  as  an  asset  are  amortized  to  the  income  statement  on  a 
systematic basis according to the expected duration of the subscribers and 
according  to  their  expected  average  churn  rate  according  to  the  type  of 
subscriber and the service received thereby (mainly in the range between 1 
and 4 years). 

In each reporting period, the Group examines whether the book value of the 
asset recognized as mentioned above exceeds the remaining amount of the 
consideration that the Group expects to receive in exchange for the goods or 
services  to  which  the  asset  refers,  minus  the  costs  directly  related  to  the 
provision  of  such  goods  or  services  that  were  not  recognized  as  expenses, 
and, if necessary, recognizes a loss from impairment in income. 

3.11. 

Financing income and expenses 

Financing income mainly includes interest revenue accrued using the effective interest 
method for the sale of terminal equipment in installments, interest revenue from capital 
and changes in the fair value of financial assets presented at fair value through profit and 
loss. 

Financing expenses mainly include interest expenses and linkage on loans received and 
bonds issued, expenses for early repayment of the debt as well as financing expenses for 
employee benefits. 

In cash flow statements, interest received is presented under cash flows from investing 
activities. The Group chose to present the interest and linkage differences paid for loans 
and debentures as part of cash flows used for financing activities. 

3.12. 

Income taxes expenses 

Income taxes expenses include current and deferred taxes. Income taxes expenses are 
imputed to the income statement or to other comprehensive income if they arise from 
items that are recognized in other comprehensive income. 

Current taxes 

The current tax is the amount of tax expected to be paid on the taxable revenue for the 
year, when it is calculated according to the applicable tax rates according to the laws 
enacted or enacted de-facto at the time of the report. Current taxes also include changes 
in tax payments referring to previous years. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

Offsetting current tax assets and liabilities 

The Group offsets current tax assets and liabilities if there is an enforceable legal right to 
offset  current  tax  assets  and  liabilities,  and  there  is  an  intention  to  settle  current  tax 
assets and liabilities on a net basis, or if the current tax assets and liabilities are settled 
at the same time. 

3.12. 

Income taxes expenses (Cont.) 

Uncertain tax positions 

The provision for uncertain tax positions, including additional tax and interest expenses, 
is  recognized  when  it  is  more  likely  than  not  that  the  group  will  require  its  financial 
resources to settle the obligation. 

Deferred taxes 

The  recognition  of  deferred  taxes  refers  to  temporary  differences  between  the  book 
value  of  assets  and  liabilities  for  financial  reporting  purposes  and  their  value  for  tax 
purposes.  The  Group  does  not  recognize  deferred  taxes  for  the  following  temporary 
differences: 

Initial recognition of goodwill  

1. 
2.  Differences arising from investment in subsidiaries and affiliated companies, if it is 
not expected that they will be reversed in the foreseeable future and if the Group 
controls the date of reversal of the difference. 

Deferred  taxes  are  measured  according  to  the  tax  rates  expected  to  apply  to  the 
temporary differences at the time they will materialize, based on the laws that have been 
enacted or whose legislation has been completed de-facto as of the reporting date. 

A deferred tax asset is recognized in the books for transferred losses, tax benefits and 
deductible temporary differences, when it is expected that in the future there will be 
taxable revenue against which they can be utilized. The deferred tax assets are reviewed 
at  each  reporting  date,  and  if  it  is  not  expected  that  the  related  tax  benefits  will 
materialize, they are amortized (see also Note 7). 

Deferred tax assets that have not been recognized are revalued at each reporting date 
and recognized if the expectation has changed so that it is expected that in the future 
there will be taxable revenue against which it will be possible to utilize them. 

Offsetting deferred tax assets and liabilities 

The Group offsets deferred tax assets and liabilities if there is an enforceable legal right 
to offset current tax assets and liabilities, and they are attributed to the same taxable 
revenue taxed by the same tax authority in the same taxable company, which intends to 
settle  current  tax  assets  and liabilities  on  a  net  basis,  or  if  the  current  tax  assets  and 
liabilities are settled at the same time. 

Presentation of tax expenses as part of a cash flow statement 

Cash flows arising from income taxes are classified in the cash flow statement as cash 
flows from operating activities, unless they can be specifically identified with investing 
activities and financing activities. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

3.13.  Dividend 

A liability relating to a dividend proposed or announced after the date of the statements 
is recognized only in the period in which the announcement was made (approval of the 
general assembly). In cash flow statements, a dividend paid is presented as a financing 
activity. 

3.14.  New standards adopted during the reporting period: 

Amendment to the IAS 1 standard - Presentation of Financial Statements: "Disclosure of 
Accounting Policies" 

In accordance with the amendment, companies are required to disclose their  material 
accounting policy after the requirement to present their material accounting policies has 
passed.  According  to  the  amendment,  information  about  the  accounting  policy  is 
material if, when taken into  account  together with other  information provided in the 
financial statements, it can reasonably be expected that it will influence decisions that 
the users of the statements make based on those statements. 

The amendment to IAS 1 also clarifies that information about the accounting policy may 
be  material  if,  without  it,  the  users  of  the  statements  would  be  prevented  from 
In  addition,  the 
understanding  other  material 
amendment  clarifies  that  there  is  no  need  to  disclose  information  about  accounting 
policies that are immaterial. 

in  the  statements. 

information 

4. 

Cash and cash equivalents 

Cash and cash equivalents balance as of December 31, 2023 mainly includes deposits in banks for 
a period of up to 90 days as well as balances in current accounts. 

5. 

Investments 

December 
2023 

31, 

December 
2022 

31, 

NIS millions 
484 
759 
5 
- 

1,248 

NIS millions 
789*
159  
 15  
 10*

973  

Shekel deposits in banks (1) 
Investment in securities at fair value through income 
Derivatives 
Foreign currency deposits in banks (2) 

* Reclassified 

(1) Deposits in shekels in banks, due until December 2024. 
(2) Deposits in US dollars in banks, due until March 2024. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

6. 

Trade and other receivables 

6.1. 

Composition of trade and other receivables: 

Customers* 

Open debts and checks regarding it 

Credit cards 

Revenue receivable 

Long-term customer current maturities 

Relate parties and interested parties 

Other receivables and current tax assets* 

Current tax assets 

Other receivables 

Expenses in advance 

Long-term customers and other receivables* 

Customers – open debts 
Long-term  receivables  and  authorities  (mainly  for  real  estate 
sales)** 

December 
2023 

31, 

December 
2022 

31, 

NIS millions 

NIS millions 

474  

178 

225 

329 

1 

673  

191  

242  

333  

 1  

1,47  
7

1,440  

16 

83 

67 

166 

275 

171 

446 
2,089 

 28  

224  

 37  

289  

305  

155  

460  
2,189  

* Customer balances are presented net of the provision for predicted credit losses. 
** See Note 6.6. 

6.2. 

The discount interest rates for long-term customers are in accordance with the credit 
risk estimate of the customers. The interest rates used by the Group for discount in 2023 
are 5.51%-6.29% (in 2022: 2.36%-4.93%). 

6.3. 

Expected exercise dates of long-term customers and receivables: 

Expected repayment dates 

2025 

2026 

2027 onwards 

December 31, 2023 

NIS millions 

206 

69 

171 

446 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

6.4. 

Aging of customer debts as of the reporting date: 

December 31, 2023 

December 31, 2022 

Gross  customer 
balance 

Provision 
for 
predicted  credit 
losses 

Gross  customer 
balance 

Provision 
for 
predicted  credit 
losses 

NIS millions 

NIS millions 

NIS millions 

NIS millions 

Not in arrears 

Arrears up to 1 year 

Arrears 1-2 years 

Arears over 2 years 

1,560 

188 

35 

39 
1,822 

(4 )

 )24( 

 )18( 

 )24( 

 )70( 

1,621 

141 

15 

32 

1,809 

(7)

(24)

(7)

(26)

(64)

6.5. 

The transactions in the provision for predicted credit losses during the year is as follows: 

Balance as of January 1 

Loss recognized from impairment 

Loan-loss 

Balance as of December 31 

2023 

2022 

NIS millions 

NIS millions 

64 

25 

(19 )

70 

 68 

 29 

(33) 

 64 

6.6. 

The balance of long-term receivables and authorities include a balance of receivables in 
the amount of NIS 106 million for the permit fees and the improvement levy that Bezeq 
paid to the Israel Land Authority and the Or Yehuda Local Authority for the sale of the 
Sakia  complex  in  2019.  In  addition,  Bezeq  provided  index-linked  guarantees  in  the 
amount  of approximately  NIS 131 million in accordance with the requirements  of the 
Israel Lands Authority and the Or Yehuda local authority to pay the balance of the permit 
fees and the improvement levy. On October 17, 2023, a judgment was issued rejecting 
the administrative appeal filed by Bezeq against the decision of the Appeals Committee. 
The Appeals Committee transferred the procedure to a decisive appraiser to determine 
the amount of the improvement levy, and ILA is liable to indemnify Bezeq in full for the 
amount of the levy. Accordingly, Bezeq recorded in the financial statements a liability of 
NIS 45 million for the additional estimated payment for the improvement levy, and at 
the same time, Bezeq recognized an indemnifying property in the same amount. 

In its 2019 statements, Bezeq recognized share capital gains from the sale of the Sakia 
complex in the amount of NIS 403 million before tax. The recognition of the share capital 
gains is based on Bezeq's estimates of the final amount to be paid to the authorities. It 
should  be  noted  that  to  the  extent  that  Bezeq's  Management  estimates  do  not 
materialize, the final  share capital gains  before tax will range from approximately NIS 
250 million to approximately NIS 450 million. 

A legal proceeding is underway between the parties from 2021. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

7. 

Income taxes 

7.1. 

Corporate tax rate 

The current taxes for the reporting periods and deferred tax balances as of December 
31, 2023 are calculated in accordance with the tax rate relevant to the Group, which is 
23%. 

7.2. 

Final tax assessments 

7.2.1. 

The Company has final tax assessments up to and including 2018. 

7.2.2.  Bezeq has final tax assessments up to and including 2018. 

On September 15, 2016, at the same time as the signing of an assessment agreement 
that ended the dispute between Bezeq and the assessor regarding financing income in 
respect of the owner's loans to Yes, the Tax Authority gave permission for tax purposes 
to perform a merger of Yes with and into Bezeq, in accordance with the provisions of 
Article 103b to the Income Tax Ordinance. According to the approval, Yes losses at the 
time of the merger were offset against the profits of Bezeq (the absorbing Company), an 
amount will not be allowed to be offset if it exceeds approximately 12.5% (spread over 
8 years) of the total losses of the transferring company and the absorbing company or 
50% of the absorbing company's taxable revenue in that tax year before offsetting the 
loss from previous years, whichever is lower. 

The approval is given in accordance with the applicable tax laws at the time it is given. 
Without deducting from the amount of losses stipulated in the assessment agreement, 
if  there  is  a  change  in  the  applicable  tax  laws,  the  Tax  Authority  will  re-examine  the 
taxation  decision  according  to  the  tax  laws  that  will  apply  at  the  time  of  the  merger. 
However,  it  was  clarified  that  the  approval  is  valid  until  December  31,  2019.  The  Tax 
Authority  will  extend  the  validity  of  the  approval  by  an  additional  year,  every  year, 
subject to a declaration by Bezeq and Yes that there has been no material change in their 
business and in the conditions of the taxation decision, and subject to the interpretation 
given to the tax laws, provided that said interpretation has been published in writing. A 
change in the tax laws that does not require a change in the approval will not cause a 
change in it. The validity of the taxation decision has been extended several times since 
then. 

On December 10, 2023, Bezeq received a letter from the Tax Authority extending, at the 
request  of  Bezeq,  the  validity  of  the  taxation  decision  for  one  more  year,  i.e.  until 
December  31,  2023.  It  should  be  noted  that  the  Tax  Authority's  letter  included  a 
statement similar to the one included in its letter from the previous year according to 
the  fact  that  in  light  of  the  fact  that  there  have  been  no  substantial  developments 
regarding the cancellation of the structural separation between Bezeq and Yes from the 
date of the taxation decision to the date of this extension, and in light of the long time 
that has passed since the date of the taxation decision, and after examining all Bezeq’s 
claims on the subject, the Tax Authority will consider not extending the validity of the 
taxation  decision  beyond  December  31,  2024,  as  long  as  there  are  no  material 
developments in 2024 in regards to the cancellation of the structural separation between 
Bezeq and Yes. 

Bezeq's position submitted to the Tax Authority is that it is entitled to an extension of 
the Tax Authority's approval in accordance with the terms of the taxation decision, and 
in any case, even if the validity of the taxation decision is not extended, this does not 
prevent Bezeq from requesting from the Tax Authority at any relevant time in the future 
a new taxation decision in lieu of the aforementioned taxation decision. It should also be 

 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

noted that Bezeq continues to work with the various regulatory bodies to eliminate the 
structural separation. 

The  balance  of  Yes  losses  for  tax  purposes,  as  of  December  31,  2023,  amounts  to 
approximately NIS 5.2 billion. See Note 7.6 below regarding deferred taxes that were not 
recognized for transferrable losses. 

7.2.3. 
7.2.4. 

Pelephone has final tax assessments up to and including the year 2018. 
Bezeq  International  has  final tax  assessments  up  to  and  including  the  year 
2019. 

7.2.5. 

Yes has final tax assessments up to and including the year 2016. 

7.2.6. 

Bezeq Online has final tax assessments up to and including the year 2018. 

7.3. 

Income taxes expenses 

Current tax expenses 

Expenses for the current year 

Adjustments for previous years 

Total current tax expenses 
Deferred tax expenses 

Creating and reversing other temporary differences 
Creation of deferred taxes for losses for tax purposes from 
the sale of a subsidiary 

Total deferred tax expenses 

Income taxes expenses 

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

337 

1 

338 

8 

- 

8 

346 

 293  

- 

 293  

 43  

- 

 43  

 336  

 289  

 14  

 303  

 42  

 37 

 79  

 382  

7.4. 

Adjustment between the theoretical tax on the profit before income taxes and 
the tax expenses 

Profit before income taxes 

Statutory tax rate 

Income taxes according to the statutory tax rate 
Expenses  that  are  not  recognized  for  tax  and  other 
purposes, as well as losses for which deferred taxes  were 
not incurred, net 
Income taxes expenses 

Year ended December 31 

2022 

2022 

2022 

NIS millions 

NIS millions 

NIS millions 

1,400 

23% 

322 

24 
346 

1,227  

23%  

 282  

 54  
 336  

1,378  

23% 

 317  

 65  
 382  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

7.5. 

Recognized deferred tax assets and liabilities and the changes therein 

tax 
for 

Deferred 
assets 
employee 
benefit plans   
NIS millions 

Deferred 
tax 
liabilities for PP&E 
and 
intangible 
assets 
NIS millions 

deferred 

Other 
taxes 
NIS millions 

Total 
NIS millions 

251 

)

(547

24 

)

(272

(23)

(6)

222 

10 

5 

237 

11 

- 

 )
(536

(6 )

- 

 )
(542

(31)

2 

(5 )

(12 )

- 

(17 )

(43)

(4)

 )
(319

(8 )

5 

 )
(322

to 

imputed 

Balance  as  of  January  1, 
2022 
Changes 
income: 
Creation  and  reversal  of 
temporary differences 
Changes  imputed  to  other 
comprehensive income 
Balance as of December 31, 
2022 
Changes 
income: 
Creation  and  reversal  of 
temporary differences 
Changes  imputed  to  other 
comprehensive income 
Balance as of December 31, 
2023 

imputed 

to 

7.6. 

Unrecognized deferred tax assets and liabilities 

Bezeq received approval from the Tax Authority to utilize losses carried forward for tax 
purposes when merging with Yes. The approval is conditioned, among other things, on 
receiving  approval  from  the  Ministry  of  Communications  to  cancel  the  structural 
separation between the two companies. The validity of the approval requires that it be 
extended by the Tax Authority for an additional year every year until the actual merger, 
as described in Note 7.2.1 above. 

As of the date of the statements, no deferred taxes were recognized in respect of the 
losses of Yes transferred for tax purposes in the amount of approximately NIS 5.2 billion, 
and no deferred taxes were recognized in respect of a loss from the impairment of assets 
in  Yes  and  Bezeq  International  (see  Note  10),  since  their  exercise  is  not  expected 
according to the Group's estimate as of the date of the statements. 

In addition, in the calculation of the deferred taxes, the taxes that would apply in the 
event of the exercise of the investment in subsidiaries were not recognized, since the 
Group  intends  and  has  the  ability  to  hold  these  investments.  Also,  no  deferred  taxes 
were  recognized  for  the  distribution  of  profits  in  these  subsidiaries  since  the  inter-
company dividends are not subject to tax. Also, the Company does not create deferred 
taxes for its transferred losses. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

8. 

Leases 

As part of the lease agreements, the Group mainly leases cellular communication sites, buildings 
(including offices, warehouses, communication rooms and sales points), and vehicles. 

8.1. 

Right-of-use assets 

Cost 
Balance as of January 1, 2022 
Additions* 
Subtractions 
canceled agreements 

for 

terminated  or 

Balance as of December 31, 2022 
Additions* 
Subtractions 
canceled agreements 

for 

terminated  or 

Balance as of December 31, 2023 
Amortizations and impairment losses 
Balance as of January 1, 2022 
Amortization for the year 
Subtractions 
canceled agreements 

terminated  or 

for 

for 

Changes in agreements and others 
Impairment loss 
Balance as of December 31, 2022 
Amortization for the year 
Subtractions 
canceled agreements 
Changes in agreements and others 
Impairment loss 
Balance as of December 31, 2023 
Book value 
As of January 1, 2022 

terminated  or 

As of December 31, 2022 

As of December 31, 2023 

Communicat
ion sites 

Structures  

Vehicles 

Total 

NIS millions 

NIS millions 

NIS millions 

NIS millions 

1,262 
111 

(85)
1,288 
131 

(91 )
1,328 

510 
156 

(73)
(8)
- 
585 
177 

(81 )
(8 )
- 
673 

752 

703 

655 

1,194 
90 

(17)
1,267 
299 

(16 )
1,550 

298 
111 

(15)
(1)
- 
393 
118 

(8 )
(9 )
- 
494 

896 

874 

1,056 

331 
107 

(46)
392 
105 

(107
 )
390 

151 
129 

(44)
(11)
(2)
223 
134 

(104
 )
(23 )
1 
231 

180 

169 

159 

2,787 
308 

(148
)
2,947 
535 

(214
 )
3,268 

959 
396 

)
(132
(20)
(2)
1,201 
429 

(193
 )
(40 )
1 
1,398 

1,828 

1,746 

1,870 

* Additions for new agreements, linkage differences, and changes to existing agreements. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

8.2. 

Lease liabilities 

Communication 
sites 

Structures  

Vehicles 

Total 

NIS millions 

NIS millions 

NIS millions 

NIS millions 

Balance as of January 1, 2022 

Additions* 
Subtractions   

834 

118 
)16( 

Financing expenses for lease obligations  17 
Lease payments 

)169( 

Balance as of December 31, 2022 
Additions* 

784 
138 

Subtractions   
Financing expenses for lease obligations  21 

 )10( 

Lease payments 
Balance as of December 31, 2023 

 )206( 
727 

Book value as of December 31, 2022 

Current maturities of lease liabilities 
Long-term lease liabilities 

Balance as of December 31, 2022 

Book value as of December 31, 2023 
Current maturities of lease liabilities 

225 
559 

784 

209 

935 

93 
)2( 

24 
)124( 

926 
307 

 )8( 
36 

 )134( 
1,127 

110 
816 

926 

115 

Long-term lease liabilities 
518 
Total balance as of December 31, 2023  727 
* Additions for new agreements and changes to existing agreements. 

1,012 
1,127 

208 

115 
- 

2 
)127( 

198 
130 

 )3( 
6 

 )144( 
187 

121 
77 

198 

109 

78 
187 

1,977 

326 
)18( 

43 
)420( 

1,908 
575 

 )21( 
63 

 )484( 
2,041 

456 
1,452 

1,908 

433 

1,608 
2,041 

8.3. 

Analysis of due dates for the Group's lease obligations (including principal and 
interest to be paid) 

Expected repayment dates 

Up to 1 year 

1-5 years 

Over 5 years 

Total 

December 31, 2023 

NIS millions 

487 

960 

1,083 

2,530 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

8.4. 

Options for ending or extending a lease 

In most of its leases, the Group assumed that it was reasonably certain that the extension 
option  contained  in  the  agreements  would  be  used,  and  therefore  there  were  no 
material obligations for leases that were not presented in the statements. Most lease 
agreements  include  an  option  to  cancel  the  agreement  with  advance  notice  and/or 
payment  of  a  fine  as  stipulated  in  the  agreements.  The  Group  assumed  that  it  was 
reasonably certain that the cancellation options would not be exercised. 

8.5. 

Information regarding material lease agreements that have not yet been included in 
the measurement of the lease assets and liabilities 

IIF  Bnei  Zion  Limited  Partnership 

On  October  7,  2021,  a  hosting  services  agreement  was  signed  between  Bezeq 
International  and  ServerFarm 
(hereinafter: 
"ServerFarm"),  according  to  which  ServerFarm  will  provide  Bezeq  International  with 
hosting services in a server farm facility established by it. The server farm is expected to 
be used to provide hosting services to business customers. The delivery date is divided 
into two phases, the first phase was delivered in Q2/2023, and the second phase was 
expected to be delivered in  March 2024.  The term of the agreement  is 15 years, and 
there are options for extension until 2047. 

Following  the  hosting  services  agreement  with  Serverfarm  that  Bezeq  International 
signed  in  October  2021,  Bezeq  International  received  during  the  second  quarter  as 
mentioned its share of the Bnei Zion server farm property. Bezeq International handles 
the hosting services agreement  as a  lease agreement  for  which  Bezeq recorded in its 
financial statements an asset and a liability in the amount of NIS 197 million. 

After the balance sheet date, in January 2024, Bezeq International signed an amendment 
to the hosting services agreement according to which, as of January 2024, the scope of 
the lease will be reduced by half of the area and the scope of the electricity supply to 
which  Bezeq  International  committed  in  the  original  agreement.  The  effect  of  the 
amendment to the hosting agreement, which was treated as a leasing amendment, is 
the amortization of an asset and liability for a lease in the amount of NIS 97 and 104 
million,  respectively,  and  the  recording  of  a  profit  from  a  lease  amendment  in  the 
amount of NIS 7 million. 

 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

9. 

PP&E 

Landline 

and 

international 

network 

equipment 

(switching, 

Cables 

landline 

and 

and 

international 

network 

Equipment 

and 

infrastruct

ure 

for 

multi-

Office 

equipment, 

Land 

and 

transmission, 

communication 

Cellular 

channel 

Subscriber 

computers 

structures 
NIS millions 

power) 

infrastructure 

network 

television 

equipment 

and vehicles 

Total 

1,282 
43 
)11( 

1,314 
49 
 )3( 

2,939 
229 
)429( 

2,739 
212 
 )160( 

12,342 
433 
)22( 

12,753 
422 
 )22( 

3,409 
145 
)2( 

3,552 
186 
 )3( 

1,407 
126 
)200( 

1,333 
121 
 )113( 

1,864 
327 
)380( 

1,811 
318 
 )334( 

1,360 

2,791 

13,153 

3,735 

1,341 

1,795 

818 
79 
)316( 

581 
92 
 )79( 

594 

24,061 
1,382 
 )1,360( 

24,083 
1,400 
 )714( 

24,769 

1,023 

1,664 

9,297 

2,770 

1,311 

1,055 

629 

17,749 

222 
)429( 

200 
)22( 

162 
)1( 

50 
)192( 

307 
)373( 

60 
)320( 

1,027 
 )1,340( 

5 

(5)

- 

60 

19 

1,059 

1,462 

9,470 

2,931 

1,229 

1,008 

32 
 )2( 

16 

221 
 )160( 

187 
 )22( 

159 
 )7( 

37 
 )
(110

328 
 )320( 

6 

 )2( 

- 

49 

1 

1,105 

1,529 

9,633 

3,083 

1,205 

1,017 

259 

1,275 

3,045 

639 

96 

809 

13 

382 

55 
 )77( 

9 

369 

189 

105 

17,541 

1,019 
 )698( 

79 

17,941 

6,312 

for 

and 

Cost 
Balance as of January 1, 
2022 
Additions 
Subtractions 
Balance as of December 
31, 2022 
Additions 
Subtractions 
Balance as of December 
31, 2023 
Depreciation 
impairment losses 
Balance as of January 1, 
2022 
Amortization 
year 
Subtractions 
Impairment 
(cancellation 
impairment) 
Balance as of December 
31, 2022 
Amortization 
year 
Subtractions 
Impairment 
(cancellation 
impairment) 
Balance as of December 
31, 2023 
Book value 
As of January 1, 2022 

the 

the 

for 

of 

of 

26 
)3( 

13 

As  of  December  31, 
2022 

As  of  December  31, 
2023 

255 

1,277 

3,283 

621 

104 

803 

199 

6,542 

255 

1,262 

3,520 

652 

136 

778 

225 

6,828 

9.1. 

9.2. 

The residual value of the Group's copper cables is determined based on a valuation at 
the end of each quarter. The value of the remainder amounts to approximately NIS 246 
million as of December 31, 2023, and approximately NIS 234 million as of December 31, 
2022. 

The  Group  companies  examined  the  duration  of  the  PP&E  within  the  framework  of 
depreciation  committees  in  order  to  determine  the  estimated  duration  of  their 
equipment. Following the findings of the depreciation committees, immaterial changes 
were made to the estimated duration of certain assets. The aforementioned change had 
no material effect on the Group's depreciation expenses. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

9.3.  Most of the real estate assets used by Bezeq are under a discounted lease from the Israel 
Lands Authority starting in 1993 for a period of 49 years, with an option to extend for 
another 49 years. The lease rights are amortized over the lease term. 

9.4. 

9.5. 

9.6. 

9.7. 

9.8. 

On September 14, 2020, Bezeq's  Board of  Directors approved the launch of a  plan to 
deploy the fiber network. Following the decision of the Board of Directors, Bezeq began 
deploying fiber to buildings, including the deployment of vertical equipment in buildings, 
and on March 14, 2021 announced the launch of services to its customers over the fiber 
network. It should be noted that the connection of customers will be done gradually. On 
May 25, 2021, Bezeq's Board of Directors approved Bezeq's fiber deployment plan and 
its  submission  to  the  Ministry  of  Communications 
in  accordance  with  the 
Communications Law. As part of the plan, Bezeq was expected to deploy and operate an 
ultra-fast  fiber  network  that  will  cover  approximately  76%  of  the  Israel’s  population 
(according  to  Bezeq,  approximately  80%  of  households).  On  May  31,  2021,  Bezeq 
submitted to the Ministry of Communications the list of statistical areas in which it chose 
to deploy as stated, and on June 15, 2021, Bezeq received an amendment to the Bezeq 
license regarding the determination of advanced network deployment obligations ("the 
amendment  to  the  license").  On  October  3,  2022,  the  Minister  of  Communications 
approved Bezeq's request to allow it to deploy an advanced network and provide Bezeq 
service over it in statistical areas additional to the areas specified in the Bezeq license, 
and to amend the Bezeq license accordingly. This is a deployment in 151 additional areas, 
which include about 60,000 households. As detailed in the decision of the Minister of 
Communications, the rate of households in Bezeq's deployment areas is 82.5%, and this 
is an addition of approximately 2.3% to this rate, so that the updated rate of households 
in Bezeq's deployment areas will be approximately 84.7%. The amendment to the license 
includes, among other things, the milestones for completing the network deployment 
within six years from the determined date (March 14, 2021). For this matter, see also 
Note 18.7 regarding the Group companies’ obligation to pay to the incentive fund. 

On August  14, 2023, the  Minister of Communications approved Bezeq's request  from 
June 4, 2023, in accordance with the provisions of Article 14e of the Communications 
Law,  to  impose  on  it  an  obligation  to  deploy  an  advanced  network  and  provide  an 
internet access service over it, in all incentive areas remaining after the first and second 
incentive tenders except in the Kfar Aqab area, and this Among other things, in light of 
Bezeq’s  compliance  with  its  license  conditions.  The  Bezeq  license  was  amended 
accordingly (Bezeq’s obligation to deploy in approximately 85% of households). 

In accordance with the Communications (Bezeq and Broadcasting) Decree (establishing 
an  essential  service  provided  by  "Bezeq"  the  Israel  Communications  Company  Ltd.), 
1997-1997, the approval of the Prime Minister and the Minister of Communications is 
required for the transfer of rights in certain assets of Bezeq (among others, switches, 
cable network, transmission network and databases and information). 

Regarding liens in connection with loans and credit, see Note 13. Regarding additional 
liens, see Note 19. 

For contracts for the purchase of PP&E, see Note 18. 

In 2023, the Bezeq Group wrote off PP&E that were fully depreciated and are not used 
by Bezeq Group in the amount of approximately NIS 675 million. 

 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

10. 

Intangible assets 

Cost 
Balance  as  of  January  1, 
2022 
Purchases  or  additions 
from self-development 
Subtractions 
Balance as of December 31, 
2022 
Purchases  or  additions 
from self-development 
Subtractions 
Balance as of December 31, 
2023 
Amortizations 
impairment losses 
Balance  as  of  January  1, 
2022 
Amortization for the year 
Subtractions 
Impairment 
Balance as of December 31, 
2022 
Amortization for the year 
Subtractions 
Impairment (see below) 
Balance as of December 31, 
2023 
Carrying amount 

and 

Computer 
software and 
licenses 
NIS millions 

Goodwill 
NIS millions 

Right  to  use 
cellular 
communicati
on 
frequencies 
NIS millions 

brand 

Customer 
and 
relations 
NIS millions 

Others 
NIS millions 

Total 
NIS millions 

3,069 

2,779 

566 

7,479 

9 
- 

229 
)
(152

- 
- 

- 
)
(790

3,078 

2,856 

566 

6,689 

- 
- 

242 
(62 )

4 
- 

- 
- 

81 

7 
- 

88 

28*
- 

13,974 

245 
)
(942

13,277 

274 
(62 )

3,078 

3,036 

570 

6,689 

116 

13,489 

1,510 
- 
- 
- 

1,510 
- 
- 
- 

2,421 
137 
(152
)
87 

2,493 
147 
(62 )
77 

1,510 

2,655 

353 
21 
- 
- 

374 
21 
- 
- 

395 

213 

192 

175 

6,358 
- 
(790
)
- 

5,568 
- 
- 
- 

5,568 

1,121 

1,121 

1,121 

81 
- 
- 
- 

81 
- 
- 
- 

81 

- 

7 

35 

10,723 
158 
(942
)
87 

10,026 
168 
(62 )
77 

10,209 

3,251 

3,251 

3,280 

As of January 1, 2022 

1,559 

As of December 31, 2022 

1,568 

As of December 31, 2023 

1,568 

358 

363 

381 

* See Note 12.4.1. 

10.1.  Right to use cellular communication frequencies 

In 2020, Pelephone won a cluster of frequencies as part of the tender for mobile radio 
telephone  services with advanced bandwidths, at a total cost  of NIS 88.2 million. The 
payment  was  made  in  September  2022.  In  September  2020,  upon  receiving  the 
frequencies, Pelephone began to operate the frequencies. In addition, according to the 
tender rules, Pelephone won a 5G network deployment grant in the amount of NIS 74 
million. The aforementioned grant was received in November 2022. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

10.2.  Examination of impairment of cash generating units 

For the purpose of testing for impairment, the goodwill was  attributed to the Group's 
activity segments as follows: 

Landline interior communication (Bezeq) (see Note 10.4) 
Other (see Note 12.4.1 and Note 12.3.3) 

December 
2023 

31, 

December 
2022 

31, 

NIS millions 
1,559 
9 

1,568 

NIS millions 
1,559  
 9  

1,568  

10.3.  Examination  of 

impairment  of  the  cellular  communications  segment 

(Pelephone) 

Due to the existence of an asset with an indefinite duration (brand), which is attributed 
to  the  cellular  communication  cash-generating  unit,  the  Company  examined  the 
recoverable amount of the cellular communication cash-generating unit as of December 
31, 2023. 

The value in use of the cellular communication cash-generating unit as of December 31, 
2023 was calculated using the method of discounting future cash flows (DCF), based on 
the forecast of cash flows from the activity for a period of five years from the end of the 
current period, and with the addition of scrap value (representative year). The cash flow 
forecast is based, among other things, on Pelephone's performance in recent years and 
estimates regarding the expected trends in the cellular market in the coming years (level 
of competition, level of prices, regulation and technological developments). 

A central assumption underlying the forecast  is that the prevailing competition in the 
market will continue with high intensity in the short term, and that a stabilization and a 
certain  increase  in  the  price  level  will  occur  in  the  medium-long  term.  The  revenue 
forecast  is  based  on  assumptions  regarding  the  status  of  Pelephone  subscribers,  the 
average revenue per subscriber and the volume of end equipment sales. The operating 
expenses  and  the  level  of  investments  have  been  adjusted  to  the  projected  scope  of 
Pelephone's activities. 

The nominal discount rate used in the valuation is 11.25% after tax (14% before tax). In 
2022 the discount rate was 10% after tax (12.4% before tax). Also, a permanent growth 
rate of 1.5% was assumed (in 2022 - 1.5%). 

The valuation is sensitive to changes in the permanent growth rate and the discount rate. 
Also, the valuation is sensitive to the net flow in the representative year in general, and 
to the assessment of the ARPU (average revenue per subscriber) level and the status of 
the subscribers at the end of the forecast range (and in the terminal year) in particular 
(a change of NIS 1 in ARPU throughout the forecast years results in a change in enterprise 
value in the amount of about NIS 268 million, a change of 100k subscribers throughout 
the years of the forecast (and in the terminal year) results in a change in the enterprise 
value in the amount of about NIS 469 million). 

The  valuation  was  conducted  by  an  external  valuator.  Based  on  the  valuation  as 
explained  above,  Pelephone's  enterprise  value  amounted  to  approximately  NIS  2,343 
million, compared to the value in the Company's books of NIS 1,400 million. Therefore, 
the Company was not required to carry out an amortization in respect of the impairment 
of the cellular communication cash-generating unit. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

10.4.  Examination of impairment of landline interior communication goodwill 

(Bezeq) 

The  balance  of  goodwill  attributed  to  the  landline  interior  communication  cash-
generating unit in the Company’s books is  NIS 1,559 million. Therefore, the  Company 
examined  the  recoverable  amount  of  the  landline  interior  communication  cash-
generating unit as of December 31, 2023. 

The value in use of the landline interior communication cash-generating unit is calculated 
using  the  discounting  future  cash  flows  (DCF)  method,  based  on  the  forecast  of  cash 
flows from the activity for a period of five years from the end of the current period, and 
with the addition of scrap value (representative year). 

The cash flow forecast is based, among other things, on Bezeq’s performance in recent 
years  and  assessments  regarding  the  expected  trends  in  the  landline  market  in  the 
coming years (level of competition, retail and wholesale price levels, regulatory aspects 
and technological developments). 

The main assumptions underlying the forecast are: a decrease in revenue from telephony 
(a result of a decrease in the number of lines, erosion in the consumption of call minutes 
per line, as well as the effect of the decision of the Ministry of Communications regarding 
the  determination of maximum rates for  Bezeq’s  retail telephony services), growth in 
revenue  from Internet  (supported by the growth of the  market,  the  establishment  of 
Internet  services  through  the  fiber  network,  and  the  elimination  of  the  separation 
between  broadband  infrastructure  service  and  Internet  access  service),  erosion  in 
revenue  from data  communication and transmission (due to an expected  decrease  in 
transmission revenue from ISP companies and despite an expected consistent growth in 
revenue from data communication services), and moderate growth in cloud and digital 
revenue. The operating, sales, marketing and investment expenses were adjusted to the 
scope of the sector's activity and included assumptions regarding the status of Bezeq’s 
employees and the wage and retirement expenses derived from them and assumptions 
regarding the rate of deployment of the fiber infrastructure. 

The nominal discount rate used in the valuation is  9% after tax (before tax  11.4%). In 
2022 the discount rate was 8% after tax (before tax 10.5%). Also, a permanent growth 
rate of 1% was assumed (in 2022 - 1%). 

The valuation was conducted by an external valuer. Based on the valuation as explained 
above,  Bezeq's  enterprise  value  amounted  to  approximately  NIS  16,467  million, 
compared  to  the  value  in  the  Company's  books  in  the  amount  of  NIS  10,760  million. 
therefore the Company was not required to make a reduction for the decrease in value 
of a cash-generating unit of the landline interior communications segment. 

10.5. 

Impairment of the multi-channel TV segment (Yes) 

At the end of 2023, Yes updated its forecasts for the following years, paying attention to 
the  trends  and  changes  in  its  operation  environment.  The  value  in  use  of  the  multi-
channel  TV  cash-generating  unit  as  of  December  31,  2023  was  calculated  using  the 
method of discounting future cash flows (DCF), based on the Yes cash flow forecast up 
to  and  including  the  year  2028,  and  with  the  addition  of  scrap  value  (representative 
year). The nominal discount rate used in the valuation is 11% after tax (12.5% before tax) 
(in  2022  -  10%  before  and  after  tax).  Likewise,  a  permanent  growth  rate  of  1%  was 
assumed (in 2022 - 1%). 

 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

The cash flow forecast was based, among other things, on Yes’s performance in recent 
years and assessments regarding the expected trends in the television market for  the 
coming  years,  including  the  development  of  technology,  consumer  preferences, 
competitors and the level of competition, the level of prices and regulatory obligations. 

A central assumption underlying the forecast is that the satellite product will be replaced 
by  an  IP  product  (television  broadcasts  via  the  Internet)  over  time  due  to  the 
technological gap between satellite and IP and the customer experience and the lower 
operating  and  maintenance  costs  of  IP.  As  a  result,  the  multi-year  forecast  reflects  a 
planned  outline  of  a  gradual  migration  process  (from  satellite  transmission  to 
distribution  of  broadcasts  based  on  the  Internet  network)  accordingly.  In  addition,  a 
gradual replacement of the satellite converters with IP converters was also assumed. As 
stated  above,  the  forecast  period  reflects  the  period  of  transition  from  satellite 
transmission to the distribution of broadcasts based on the Internet until  fully leaving 
the satellite. 

Also, the forecast includes a deepening of Yes’s activity in the sale of combined television 
and internet packages. These circumstances, along with an expectation of a high level of 
competition  throughout  the  entire  forecast  period  and  a  relatively  rigid  expense 
structure, led to an expectation of operating losses and negative cash flows in some of 
the forecast years. It should be noted that the actual implementation of the outline is 
and  will  be  carried  out  while  constantly  examining  the  conditions  of  the  market,  the 
competition, and the technological environment and making the necessary adjustments 
as a result. 

As of December  31, 2023, the Yes’s  enterprise value under the cash flow discounting 
approach is higher than the fair value of Yes’s assets and liabilities, net, and is therefore 
determined as the basis for determining Yes's recoverable amount. 

It should be noted that the assessment of the value in use is sensitive to the net cash 
flow in the representative year in general, and to the assessment of the ARPU (average 
revenue per subscriber) level and the subscriber base at the end of the forecast range in 
particular.  (A  change  of  NIS  1  in  ARPU  throughout  the  years  of  the  forecast  (and  the 
terminal year) results in a change in enterprise value in the amount of approximately NIS 
60 million, and a change of 5K subscribers throughout the years of the forecast (and in 
the  terminal  year)  results  in  a  change  in  the  enterprise  value  in  the  amount  of 
approximately NIS 80 million). 

 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

10.5. 

Impairment of the multi-channel TV segment (Yes) (Cont.) 

The following are details regarding the value of Yes’s activities and the fair value of the 
assets  and  liabilities,  net  as  determined  by  an  external  valuator,  and  recognized 
impairment losses: 

enterprise 
Yes 
(according 
value 
to 
DCF 
the 
method) 

Fair  value  of  Yes 
assets 
and 
liabilities, net 

Book value of Yes 
and 
assets 
liabilities, 
net 
before 
recognition 
impairment 

of 

Impairment 
loss 

NIS millions 

NIS millions 

NIS millions 

NIS millions 

 )24( 

 )60( 

16 

 )40( 

)

(131

(51)

)14( 

(37)

)

(129

(85)

)27( 

(58)

)

(159

)

(145

)76( 

)103( 

)88( 

(69)

 )
(204

)275( 

for 

As  of  December  31, 
the 
2023  and 
period 
three 
of 
months that ended on 
that date 

for 

As  of  September  30, 
2023  and 
the 
three 
of 
period 
months that ended on 
that date (unaudited) 

As  of  June  30,  2023 
and  for  the  period  of 
three  months 
that 
ended  on  that  date 
(unaudited) 

As  of  March  31,  2023 
and  for  the  period  of 
three  months 
that 
ended  on  that  date 
(unaudited) 

Total 
recognized in 2023 

impairment 

As  of  December  31, 
2022  and  for  the  year 
that  ended  on  that 
date 

As  of  December  31,  2023,  Yes’s  enterprise  value  under  the  cash  flow  discounting 
approach is higher than the fair value of Yes’s assets and liabilities, net, and is therefore 
determined as the basis for determining Yes’s recoverable amount. 

It should be noted that the valuation of Yes’s value in use is sensitive to the net cash flow 
in the representative year in general, and to the assessment of the ARPU level (average 
revenue per subscriber) and the status of subscribers at the end of the forecast range in 
particular.  (A  change  of  NIS  1  in  ARPU  throughout  the  years  of  the  forecast  (and  the 
terminal year) results in a change in the enterprise value in the amount of approximately 
NIS 60 million, and a change of 5K subscribers throughout the years of the forecast (and 
in  the  terminal  year)  results  in  a  change  in  the  enterprise  value  in  the  amount  of 
approximately NIS 75 million). 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

10.5 Impairment of the multi-channel TV segment (Yes) (Cont.) 

Below is a breakdown of the allocation of impairment loss to Yes’s assets: 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

Broadcast rights - minus used rights * 

103 

PP&E ** 

Intangible assets ** 

Other receivables (advance expenses) * 

Rights-of-use of leased properties ** 

62 

37 

(1 )

3 

Total impairment recognized in the year 

204 

 149  

 76  

 45  

 3  

 2  

 275  

 146  

 91  

 48  

 4  

(1)

 288  

* The expense was presented as part of General and operating expenses 
**  The  expense  was  presented  as  part  of  depreciation,  amortization,  and  impairment 
expenses. 

The following is information regarding the manner in which the Group determined the 
fair value (at level 3) of the assets in which the impairment occurred as detailed above: 

Broadcast rights - the fair value of the broadcast rights is calculated taking into account 
legal restrictions on their sale and based on the stage of their production, probability of 
sale, and expected rate of return on investment. 

PP&E - the fair value of the PP&E items that can be sold to a market participant (mainly 
converters) was based on the estimate of the amount for which they can be sold on the 
day of the valuation and after deducting the costs that will be required to carry out the 
sale. 

10.5. 

Impairment of the multi-channel TV segment (Yes) 

Intangible assets - No substantial fair value was assigned to YES’s intangible assets, since 
most of the software and licenses of  Yes were uniquely adapted to  Yes and therefore 
have no substantial value in a transaction between a willing buyer and a willing seller. 

Rights of use in leased assets - the fair value of right-of-use assets is affected by the ability 
to lease the asset subject to the lease to a third party, the lease fees for the asset in the 
market and the exit fines in the lease contract. 

Other receivables (advance expenses) - no substantial fair value was attributed to the 
advance  expenses  of  Yes  for  the  maintenance  of  its  systems,  since  most  of  the 
maintenance  agreements  were  uniquely  adapted  to  Yes  and  therefore  have  no 
substantial value in a transaction between a willing buyer and a willing seller. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

10.6. 

Impairment of the Internet and international communication services and ICT 
solutions segment (Bezeq International) 

At the end of 2023, Bezeq International updated its forecasts for the following years, 
paying attention to the trends and changes in its operating environment. The value-in-
use for Bezeq Group of the Bezeq international services cash-generating unit, calculated 
as of December 31, 2023 using the method of discounting future cash flows (DCF), based 
on the forecast of cash flows from operations for a period of five years from the end of 
2023, and with the addition of scrap value (representative year). The nominal discount 
rate  used  in  the  valuation  is  11.5%  (after  and  before  tax)  (10.3%  in  2022).  Also,  a 
permanent growth rate of 3% was assumed (3% in 2022). 

The  cash  flow  forecast  was  based,  among  other  things,  on  Bezeq  International's 
performance  in  recent  years  and  assessments  regarding  the  expected  trends  in  the 
markets in which it operates in the coming years (the level of competition, the level of 
prices, regulation and technological developments). 

The revenue forecast is based on assumptions according to which Bezeq International's 
Internet  subscriber  base,  as  well  as  its  revenue  from  these  subscribers,  will  be 
significantly  affected  as  a  result  of  the  impact  of  the  Ministry  of  Communications' 
decision on the cancellation of the separation between broadband infrastructure service 
and Internet access service (ISP), as detailed in Note 12.3 below, including assumptions 
regarding  subscribers  who  do  not  use  ISP  services,  assumptions  regarding  Bezeq 
international  activity  in  the  international  communication  market  and  assessments 
regarding its development in the field of communication services for businesses which 
includes  public  cloud  activity,  and  assumptions  regarding  the  field  of  international 
communication activity. 

Operating, sales, marketing and investment expenses were adjusted to the scope of the 
segment’s  activity,  including assumptions  regarding  the  extent  of  the  decrease  in  the 
number of Bezeq International employees and the salaries expenses derived from them, 
as  well  as  assumptions  regarding  the  development  of  traffic  costs  in  the  Internet 
segment  (retail  and  wholesale  rates  and  the  development  of  the  field  of  Internet 
television broadcasting in general, and the expected migration of Yes from TV broadcasts 
via satellite to TV broadcasts via the Internet in particular). 

These  assumptions,  and  especially  the  expected  significant  changes 
in  Bezeq 
International's Internet activity, were expressed in the expectation of operating losses 
and  negative  cash  flows  in  the  coming  years.  The  nominal  cost  of  capital  used  in  the 
valuation is 10.3% (after tax) (in 2021 - 8.5%). Also, a permanent growth rate of 3% was 
assumed (in 2021 - 1%). 

The valuation is sensitive to the net flow in the representative year in general, and to the 
intensity of changes in the field of internet activity in particular (subscribers, ARPU, and 
traffic costs). 

The  valuation  was  conducted  by  an  external  valuator.  Based  on  the  valuation  as 
explained  above,  Bezeq  International's  enterprise  value  as  of  December  31,  2023 
amounted to a negative amount of approximately NIS 194 million (as of December 31, 
2022  a  total  negative  enterprise  value  of  NIS  166  million).  In  light  of  the  negative 
enterprise value, the value of Bezeq International's non-current assets as of December 
31, 2023 was determined to be the fair values minus exercise costs or zero, whichever is 
higher. The fair value of Bezeq International's assets minus exercise costs as of December 
31,  2023  is  negative  in  the  amount  of  approximately  NIS  23  million.  Accordingly,  the 
Group recognized  in 2023 an impairment  loss in the amount  of approximately NIS 87 
million. 

 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

10.6. 

Impairment of the Internet, international communication, network endpoint, 
and ICT solutions services segment (Bezeq International) (Cont.) 

The following are details regarding Bezeq International's enterprise value and the fair 
value  of  the  assets  and  liabilities,  net  as  determined  by  an  external  valuator,  and 
recognized impairment losses: 

Bezeq 
International 
enterprise  value 
(according  to  the 
DCF method) 

value 

Fair 
Bezeq 
International 
assets 
liabilities, net 

of 

and 

Book  value  of 
Bezeq 
International 
assets 
liabilities, 
before 
recognition 
impairment 

and 
net 

of 

Impairment 
loss 

As  of  December  31, 
for  the 
2023  and 
period 
three 
of 
months  that  ended 
on that date 

for 

As  of  September  30, 
the 
2023  and 
period 
three 
of 
months  that  ended 
on 
date 
that 
(unaudited) 

As  of  June  30,  2023 
and  for  the  period  of 
three  months 
that 
ended  on  that  date 
(unaudited) 

As of March 31, 2023 
and  for  the  period  of 
three  months 
that 
ended  on  that  date 
(unaudited) 

Total 
recognized in 2023 

impairment 

As  of  December  31, 
2022 and for the year 
that  ended  on  that 
date 

NIS millions 

NIS millions 

NIS millions 

NIS millions 

 )194( 

 )23( 

7 

 )30( 

)162( 

)4( 

11 

)15( 

)162( 

)27( 

)6( 

)21( 

)162( 

)5( 

16 

)166( 

)22( 

)21( 

 )87( 

)104( 

The following is a breakdown of the allocation of the total loss from the impairment in 
Bezeq International's assets: 

PP&E and intangible assets ** 
Short- and long-term advance expenses * 
Rights-of-use of leased vehicle assets ** 
Long-term advance expenses for capacities ** 
Total impairment recognized in the year 

2023 

NIS millions 
57 
17 
1 
12 
87 

2022 

NIS millions 
71 
21 
- 
12 
104 

2021 

NIS millions 
75 
28 
2 
17 
122 

* The expense was presented as part of General and operating expenses. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

** The expense was presented as part of depreciation, amortization and impairment expenses. 

The following is information regarding the manner in which the group  determined the 
fair value (at level 3) of the assets minus realization costs: 

PP&E - the fair  value of the  PP&E items that can be sold to a  market participant  was 
based on the cost approach in which the cost of replacing with new equipment is taken 
into account, minus the costs of physical wear and tear and technological obsolescence, 
minus the costs that will be required to carry out the sale. 

Intangible assets - no substantial fair value was attributed to intangible assets, since most 
of  Bezeq  International's  software  and  licenses  were  uniquely  adapted  to  Bezeq 
International, and therefore have no substantial value in a transaction between a willing 
buyer and a willing seller. 

International capacity - in light  of the nature of the signed agreements, which  do not 
allow these rights to be assigned except to Bezeq International or a sister company of 
Bezeq International, which are not considered a market participant (third party) for the 
purpose of calculating fair value according to international accounting standard IFRS 13, 
these rights have no fair value. 

Short-term and long-term advance expenses - no substantial fair value was attributed to 
the upfront expenses for the maintenance of Bezeq International's systems, since most 
of  the  maintenance  agreements  were  uniquely  adapted  to  Bezeq  International,  and 
therefore have no substantial value in a transaction between a willing buyer and a willing 
seller. 

Rights-of-use  of  leased  assets  -  the  fair  value  of  right-of-use  assets  is  affected  by  the 
ability to lease the asset subject to the lease to a third party, the lease fees for the asset 
in the market and the exit fines in the lease contract. 

Notes to Consolidated Statements as of December 31, 2023 

10. Deferred expenses and non-current investments

December  31, 
2023 

December  31, 
2022 

NIS millions 

NIS millions 

Subscriber acquisition asset, net (see Note 11.1 below) 

166 

Investment in long-term bank deposits 

Deferred expenses (see Note 11.2 below) 
Bank deposit used to provide loans to Bezeq employees (see Note 
11.3 below) 

Derivative instruments 

Broadcasting rights 

8 

15 

32 

31 

60 

312 

156 

27 

13 

33 

29 

57 

315 

11.1.  The following is a breakdown of subscriber acquisition assets: 

Cost 
Balance as of January 1, 2022 

Additions  
Subtractions  

Balance as of December 31, 2022 
Additions  

Subtractions  
Balance as of December 31, 2023 

Depreciation and impairment losses 
Balance as of January 1, 2022 

Depreciation 
Subtractions  

Balance as of December 31, 2022
Depreciation 

Subtractions  
Balance as of December 31, 2023 

Book value 

As of January 1, 2022 

As of December 31, 2022 

As of December 31, 2023 

Subscriber 
acquisition assets 
NIS millions 

479 

127 
)234( 

372 
132 

 )153( 
351 

328 

122 
)234( 

216 
122 

 )153( 
185 

151 

156 

166 

11.2. 

The balance of deferred expenses is presented minus an impairment loss. See Note 10.6 
regarding the impairment of assets in Bezeq International. 

11.3.  Bank deposit for providing loans to Bezeq employees without a repayment date. 

Notes to Consolidated Statements as of December 31, 2023 

12. 

Investees 

12.1.  Consolidated companies 

12.1.1. 

The place of incorporation of the companies directly held by the Company is 
Israel. The  following is a  breakdown of the companies consolidated by the 
company and the company's rights in the  share capital of the consolidated 
companies as of December 31, 2023: 

Bezeq the Israel Telecommunications Corp. Ltd. 

Companies consolidated by Bezeq: 

Pelephone Communications Ltd 

Yes TV and Communications Services Ltd. (Yes) (see Note 12.2 below) 

Bezeq International Ltd. (see Note 12.3 below) 

Bezeq Online Ltd. 

12.1.2. 

As of October 11, 2022, all Bezeq shares held by the Company are directly 
held  by  the  Company,  after  on  that  day  all  Bezeq  shares  held  by  B 
Communications  (SP2)  Ltd.  (a  company  fully  owned  and  controlled  by  B 
Communications) were transferred to the direct holding of the company (SP1) 
Ltd. which is fully owned and controlled by the Company). After the transfer 
of Bezeq shares to the Company, the companies B Communications (SP2) Ltd. 
and B Communications (SP1) Ltd. were closed. 

12.1.3. 

Structural change in Bezeq's subsidiaries 

Following on from previous decisions regarding a plan for a structural change 
in  the  framework  of  which  the  private  activity  of  Bezeq  International  was 
supposed  to  merge  with  and  into  Yes,  and  the  ICT  activity  of  Bezeq 
International to spin off into a new company wholly owned by Bezeq ("the 
merger/spin-off plan"), the Bezeq Board of Directors and the boards of Bezeq 
International and Yes decided, on March 16, 2022, to cancel the merger/spin-
off plan and to approve an alternative outline, according to which activity will 
be  reduced  Bezeq  International's  ISP  in  the  private  segment  following  the 
cancellation of the separation between broadband infrastructure service and 
Internet access service (ISP), and ISP activity will be established in Yes for the 
purpose of selling "triple" packages to customers ("the Alternative Outline"), 
while  aiming  to  achieve,  as  much  as  possible,  the  strategic,  business  and 
economic purposes that underpinned the decision to promote the structural 
change, including, among other things, adapting the activity to the structure 
of the industry and the changing regulation, focusing on increasing revenue 
and growth, and increasing operational synergy and streamlining. 

According  to  the  alternative  outline,  Bezeq  expects  that  the  business 
objectives that were the basis of the spin-off/merger plan will be achieved, as 
Yes  is  expected  to  become  a  "triple"  sales  arm  that  combines  fiber  and 
television,  and  at  the  end  of  the  move,  Bezeq  International  will  become  a 
growth-oriented ICT company. Also, the Alternative Outline lies the potential 
for a significant reduction in Bezeq International's expenses and investments 
in the ISP field at the same time as an accelerated reduction in this activity. 

In  June  2022,  Yes  received,  following  its  request  to  the  Ministry  of 
Communications,  a  special  license  for  Internet  access  services  (ISP)  and  it 
began  providing  such  services  while  focusing  on  selling  combined  Internet 
and TV plans to customers. 

 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

12.2. 

Yes TV and Communications Services Ltd. (Yes) 

12.2.1. 

Yes  is  a  wholly  owned  (100%)  subsidiary  of  Bezeq.  Bezeq  consolidates  the 
statements of Yes as of March 23, 2015. 

Bezeq  has  an  assessment  agreement  and  taxation  decision  with  the  Tax 
Authority  regarding  financing  income,  owner  loans,  Yes  losses  and  merger 
(see also Note 7.2). 

12.2.2. 

As of December 31, 2023, Yes has accumulated a loss balance of NIS 8,134 
million since its establishment, shareholder’s equity balance of NIS 73 million, 
and a working equity deficit of NIS 150 million. Also, as of December 31 2023, 
Yes  has  off-balance  sheet  commitments  in  the  cumulative  amount  of 
approximately NIS 938 million for the purchase of space segments, content, 
fixed assets and other assets up to and including the year 2027 (see Note 18). 

Based  on  the  valuation  conducted  as  of  December  31,  2023,  Yes’s  total 
enterprise value is a negative value in the amount of approximately  NIS 24 
million  (compared  to  a  negative  enterprise  value  of  NIS  103  million  as  of 
December 31, 2022) (see Note 10.5), which results, among other things, from 
Yes’s  forecasts  to  continue  accumulating  operating  losses  in  2024  and 
beyond. 

In  March  2024,  Bezeq’s  Board  of  Directors  approved  a  credit  facility  or 
investment in Yes’s equity in the amount of NIS 40 million, for a period of 15 
months, starting on January 1, 2024 and ending on March 31, 2025, instead 
of previous commitments, the last of which was given in November 2023. It 
should be noted that during the year 2023, Yes did not make any use of the 
credit facilities provided by Bezeq. 

Yes’s Management estimates that the funding sources at its disposal, which 
include,  among  other  things,  the  continuation  of  the  existing  policy  of  a 
working  equity deficit  and the credit framework and investments in  equity 
from Bezeq will satisfy the needs of Yes’s operations until December 31, 2024. 

12.2.3. 

See Note 10.5 regarding the impairment of assets recognized by Yes as part 
of the statements as of December 31, 2023. 

12.3.  Bezeq International Ltd. 

12.3.1. 

Eliminating the separation between a broadband infrastructure service and 
an Internet access service (ISP): 

On June 20, 2021, a decision was made by the Minister of Communications 
regarding  the  cancellation  of  the  separation  between  a  broadband 
infrastructure service and an Internet access service (ISP), including in relation 
to private customers. According to the decision, starting from the determined 
date, the restriction on infrastructure owners offering Internet access service 
to private customers will be lifted. Also, it is no longer possible to sell services 
in  a  split  format,  but  customers  who  receive  service  in  a  split/semi-split 
configuration  will  be  able  to  continue  to  consume  Internet  services  in  this 
way.  It  should  be  noted  that  the  cancellation  of  the  aforementioned 
separation  has  reduced  the  number  of  subscribers  who  do  not  use  ISP 
services, and it is expected to bring about further reduction in next years. 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

12.3.2. 

12.3.3. 

The  move,  which  is  expected  to  continue  to  damage  Bezeq  International's 
results, was taken into account in the cash flow forecast which was used to 
examine the impairment as described in Note 10.6 above. 

See Note 10.6 below regarding the impairment of assets recognized by Bezeq 
International within the statements for December 31, 2023. 

In  February  2022,  Bezeq  International  acquired  77%  of  the  shares  of 
CloudEdge  Ltd.,  which  specializes  in  providing  public  cloud  computing 
solutions for Microsoft products. The goodwill created by the purchase was 
fully allocated to CloudEdge operations. 

12.3.4. 

See  Note  16.5.4  regarding  the  voluntary  retirement  plan  at  Bezeq 
International  which  was  approved  by  Bezeq  International's  Board  of 
Directors. 

12.4.  Pelephone Ltd. 

As part of Pelephone's activities and preparation for global trends in the roaming services 
market, which include, among other things, a more widespread use of eSIM technology 
in  these  services,  on  October  18,  2023,  Pelephone’s  Board  of  Directors  approved  the 
acquisition  of  full  ownership  in  the  company  "Roamability",  which  specializes  in 
providing  solutions  in  the  global  roaming  services  market,  including  wholesale,  and 
including the provision of a platform for managing and selling these services. Pelephone 
has completed the purchase of 100% of the control and ownership rights in Roamability 
(an  American  company  and  an  Israeli  company)  in  exchange  for  an  amount  that  is 
immaterial at the Bezeq Group level. As of the date of publication of the consolidated 
financial statements, the surplus cost allocation (PPA) work has not yet been completed. 

12.5.  The Company's control over Bezeq 

The Company holds the control permit in Bezeq and controls Bezeq based on two facts: 
1) The Company holds significantly more voting rights than any other shareholder while 
the  rest  of  Bezeq's  holdings  are  very  dispersed.  2)  Israeli  law  and  regulation  require 
obtaining government approval for any Israeli institutional entity that wishes to increase 
its  holding  to  over  7.5%  in  Bezeq  or  wishes  to  take  actions  together  with  another 
shareholder for the purpose of appointing a director in Bezeq or in order to influence the 
making of current operational decisions in Bezeq. Through these limitations and through 
the  Company's  representatives  on  Bezeq's  Board  of  Directors,  the  regulatory  regime 
guarantees that no individual or entity will interfere in the control of Bezeq, except for 
the holder of the control permit. 

12.6.  Purchase of additional Bezeq shares by the Company 

12.6.1. 

12.6.2. 

12.6.3. 

On December 28, 2022, the Company purchased 2,530,000 ordinary shares 
of the Bezeq subsidiary in a total amount of about NIS 15 million and at an 
average price of NIS 5.95 per share. 

During  the  second  quarter  of  2023,  the  Company  purchased  7,807,995 
ordinary shares of the Bezeq subsidiary for a total amount of approximately 
NIS 37 million and at an average price of NIS 4.71 per share. 

On January 31, 2024, after the balance sheet date, the Company purchased 
3,120,000 ordinary shares of the subsidiary Bezeq. The Company purchased 
shares  as  mentioned  in  exchange  for  payment  of  a  total  amount  of 
approximately NIS 15 million and at an average price of NIS 4.82 per share. 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

After the aforementioned purchase and as of the date of the Statements, the 
Company owns 27.19% of the issued share capital and voting rights in Bezeq. 

12.7.  Dividend distribution by Bezeq 

12.7.1. 

Bezeq’s dividend distribution policy 

On  March  12,  2024,  Bezeq’s  Board  of  Directors  decided  to  update  Bezeq's 
dividend policy so that Bezeq will distribute every six months 70% of the semi-
annual profit (after tax) according to its consolidated statements starting with 
the  next  distribution  (for  the  second  half  of  2023),  this  in  view  of  the 
improvement trend in the business results, and the continued decrease in the 
scope of its debt, and in accordance with its forecasts regarding its business 
results for the coming years. 

Also, Bezeq will strive to increase its dividend policy in the future, subject to 
maintaining its credit rating in the AA group. 

its  own  merits 

The approval of Bezeq's dividend policy does not oblige Bezeq to distribute a 
dividend  to  Bezeq's  shareholders,  and  each  specific  distribution  will  be 
examined  on 
in  accordance  with  the  conditions  of 
implementation  of  the  dividend  distribution  policy  as  stated  above.  In 
addition, the approval of the aforementioned policy does not prevent Bezeq’s 
Board of Directors from periodically reviewing the dividend distribution policy 
for  Bezeq  shareholders,  taking  into  account,  among  other  things,  the 
provisions  of  the  law,  Bezeq's  business  situation,  its  plans,  and  its  equity 
structure,  and  while  maintaining  a  balance  between  ensuring  Bezeq's 
financial strength and stability, including its debt level and credit rating, and 
continuing to unlock value to Bezeq's shareholders through regular dividend 
distribution. 

Bezeq's  Board  of  Directors  considers  it  important  to  maintain  the  balance 
between ensuring Bezeq's financial strength and stability, while maintaining 
a  rating  in  Bezeq's  current  rating  group  [AA]  over  time,  and  continuing  to 
unlock value to its shareholders through regular dividend distribution. 

Bezeq's Board of Directors was presented, among other things, with Bezeq's 
and Bezeq Group's forecasts, as well as sensitivity analyzes for unexpected 
adverse events in Bezeq's and Bezeq Group's business. After the Bezeq Board 
of  Directors  examined  all  of  the  above,  the  Board  of  Directors  determined 
that  this  decision  reflects  the  correct  balance  between  these  needs  as 
described above. 

12.7.2. 

Dividends distribution 

A.  On  April  20,  2023,  the  general  assembly  of  Bezeq's  shareholders 
approved (following the recommendation of Bezeq’s Board of Directors 
of  March  13,  2023)  the  distribution  of  a  cash  dividend  to  Bezeq's 
shareholders in the total amount of NIS 246 million (which, as of the day 
determining  the  distribution,  is  NIS  0.088922  per  share).  The  dividend 
was paid on May 11, 2023. The Company's share of the aforementioned 
dividend is approximately NIS 66 million. 

B.  On September 14, 2023, the general assembly of Bezeq's shareholders 
(following the recommendation of Bezeq’s Board of Directors of August 
8,  2023)  approved  the  distribution  of  a  cash  dividend  to  Bezeq's 
shareholders in a total amount of NIS 392 million (which, as of the day 

 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

determining the distribution, is NIS 0.1416805 per share). The dividend 
was  paid  on  October  11,  2023.  The  Company's  share  of  the 
aforementioned dividend is approximately NIS 106 million. 

C.  On March 12, 2024, Bezeq's Board of Directors decided to recommend 
to  the  general  assembly  of  Bezeq's  shareholders  to  distribute  a  cash 
dividend to Bezeq's shareholders in the total amount of NIS 374 million. 
As  of  the  date  of  approval  of  the  statements,  the  aforementioned 
dividend had not yet been approved by Bezeq's general assembly. The 
expected  share  of  the  Company  in  the  aforementioned  dividend  (if 
approved by Bezeq’s general assembly) is about NIS 102 million. 

 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

12.8.  Non-controlling interests 

The  following  table  shows  data  regarding  the  investees  in  the  Group,  including 
adjustments to fair value made on the day of purchase with the exception of goodwill, 
the non-controlling interests are material to the Group: 

December 31 

Percentage 
of 
ownership 
held  by  the 
non-
controlling 
interests 
% 

Non-
current 
assets 

Current 
liabilities 

Non-
current 
liabilities 

Net assets 

Current 
assets 
NIS millions 

Book 
value 
of 
the  non-
controlling 
interests 

2022 

2023 

72.92 

73.19 

3,489 

3,464 

11,429 

10,988 

3,678 

3,534 

8,260 

8,512 

2,980 

2,406 

2,257 

1,842 

Year ended December 31 

Revenues   
NIS millions 

Net profit 

Other 
comprehen
sive income 

Comprehen
sive income 

Profit 
attributed 
to 
non-
controlling 
interests 

Comprehen
sive  income 
attributed 
to 
non-
controlling 
interests 

2023 

2022 

2021 

9,103 

8,986 

8,821 

1,189 

1,000 

1,182 

12 

50 

36 

1,201 

1,050 

1,218 

867 

733 

867 

876 

770 

893 

Year ended December 31 

Cash flow from 
financing 
activities 
(without 
dividend to 
non-controlling 
interests) 

NIS millions 

Dividend 
to non-
controlli
ng 
interests 

Total 
increase 
(decrease) in 
cash and 
cash 
equivalent 

Cash flow 
from 
current 
operations 

Cash flow 
from 
investing 
activities 

2023 

2022 

2021 

3,440 

3,503 

2,839 

 )
1,835
(

 )

1,585

(

 )

1,646

(

 )
1,715
(

 )

1,758

(

 )

1,060

(

 )
(466

)

(392

- 

 )
(576

)

(232

133 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

13.  Debentures, loans and credit 

13.1.  Composition 

Current liabilities 
Current debenture liabilities 
Current loan liabilities 

Non-current liabilities 
Debentures 
Loans  

Total debentures, loans and credit 

13.2. 

Terms of Debentures and loans 

December 
2023 

31, 

December 
2022 

31, 

NIS millions 

NIS millions 

842 
232 
1,074 

5,823 
2,006 
7,829 

8,903 

835  
 86  
921  

6,121  
2,136  
8,257  

9,178  

December 31, 2023 
Book balance 
NIS millions 

Par value 
NIS millions 

December 31, 2022 
Book balance 
NIS millions 

Par value 
NIS millions 

Bank loans at Bezeq: 
Unlinked loans, bearing fixed interest 

Unlinked loans, bearing variable interest 
Total banks loans at Bezeq 
Loans from financial institutions at Bezeq: 
Unlinked loans, bearing fixed interest 
Total financial institutions loans of Bezeq 

799 

699 
1,498 

740 
740 

799 

700 
1,499 

740 
740 

707 

698 
1,405 

817 
817 

706 

700 
1,406 

817 
817 

Total loans in Bezeq 

2,238 

2,239 

2,222 

2,223 

Interest rate range 

 - 

3.2%
4.95%
Prime+  0.11%  - 
Prime+0.53% 

3.22%

4%-

Public debentures of the Company: 
Series C – unlinked, bearing fixed interest 
Series F – unlinked, bearing fixed interest 
Total public debentures of the Company 
Public debentures of Bezeq: 
Series 9 - unlinked, bearing fixed interest 
Series  10  -  linked  to  the  consumer  price 
index, bearing fixed interest 
Series 11 - unlinked, bearing fixed interest 
Series  12  -  linked  to  the  consumer  price 
index, bearing fixed interest 
Series 13 - unlinked, bearing fixed interest 
Series  14  -  linked  to  the  consumer  price 
index, bearing fixed interest 
Total public debentures of Bezeq 

Total debentures 

Total loans and debentures 

- 
1,940 
1,940 

1,073 

593 
839 

1,378 
380 

462 
4,725 

6,665 

8,903 

- 
2,010 
2,010 

1,065 

529 
835 

1,269 
430 

478 
4,606 

6,616 

8,855 

480 
1,425 
1,905 

1,616 

861 
838 

1,330 
198 

208 
5,051 

6,956 

9,178 

497 
1,472 
1,969 

1,597 

794 
835 

1,269 
200 

200 
4,895 

6,864 

9,087 

3.85% 
3.65% 

3.65% 

2.2% 
3.2% 

1.7% 
2.79% 

0.58% 

 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

13.2.1. 

On January 11, 2024, Bezeq completed a public offering of debentures (series 
11  and  13)  by  way  of  expanding  series  traded  on  the  stock  exchange, 
according to a shelf offer report dated January 10, 2024, which was published 
according to a shelf prospectus published on May 9, 2023. In this framework, 
NIS 567,877,000 par value debentures (series 11) were issued to the public 
for a total of NIS 539 million and NIS 432,123,000 par value debentures (series 
13) for a total of NIS 353 million. 

13.3.  Debentures issued by the Company 

On  January  10,  2022,  the  Company  exchanged  about  417  million  par  value  Series  C 
debentures in exchange for about 432 million par value Series F debentures. 

On June 30, 2022, the Company made a partial early repayment of about 100 million par 
value Series C debentures plus accrued interest up to the vesting date. 

During the third quarter of 2022, B Communications 2 Limited Partnership transferred 
to the Company the balance of the Company's series C debentures which were held by 
it in the amount of approximately NIS 10 million,. After the debentures were transferred 
to  the  Company,  the  said  debentures  were  removed  from  the  stock  exchange 
clearinghouse and deleted from the trading cycle. 

On  June  22,  2023,  the  Company  issued  to  institutional  entities  and  the  public 
approximately NIS 538 million in series F debentures for approximately NIS 500 million 
net  (after  issuance  expenses).  The  net  proceeds  of  the  issuance  of  the  series  F 
debentures were used by the Company for early full and final repayment of the balance 
of Series C debentures (plus accrued interest until vesting) on July 20, 2023. 

In accordance with the terms of debentures series C and F, the Company undertook to 
deposit semi-annual interest for the various debenture series in an escrow account for 
the benefit of the bondholders. As of December 31, 2023, approximately NIS 36 million 
are deposited in the trust accounts for the benefit of the holders of Series C debentures. 

As of December 31, 2023, the remaining par value of the series C debentures is NIS 497 
million and the remaining par value of the series F debentures is NIS 2,010 million. 

Below are the financial standards to which the Company committed in connection with 
the debenture series: 

A.  Debt-to-asset ratio (LTV): 

The debt-to-asset ratio will be calculated for the first time 24 months after the date 
of  the  Searchlight-Forer  transaction  (December  2,  2019)  and  will  not  exceed  the 
following thresholds for two consecutive quarters: 

The ratio will not cross the 80% threshold until November 30, 2023 and will not cross 
the  75%  threshold  from  December  1,  2023  until  the  date  of  the  last  debenture 
principal payment. 

As of December 31, 2023, the Company meets the debt-to-asset ratio. 

B.  Restrictions on dividend distribution: 

The Company undertook not to distribute a dividend to its shareholders and/or to 
buy  back  its  shares  and/or  make  any  other  distribution  as  defined  in  the  Israeli 
Companies Law, 5759-1999, unless all the conditions detailed below are met: 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

1.  The Company is not in violation of any of the financial standards. 

2.  There is no ground for immediate payment when the decision to carry out the 

distribution is made, and no such ground exists as a result of this distribution. 

3.  The debt-to-asset ratio after the distribution shall not exceed 70% for series F 

debentures. 

C.  Lien on Bezeq shares: 

Series F debentures have a first-class lien on 728,373,713 Bezeq shares held by the 
Company. 

D.  Control of Bezeq: 

The Company has committed to directly and/or indirectly hold at least 25% of the 
issued and paid-up share capital of Bezeq, unless regulatory approval is received in 
the  form  of  a  permit/authorization  allowing  to  decrease  the  above-mentioned 
holdings. 

E.  Control of the Company: 

Searchlight and the Forer Family have committed to refrain from transferring control 
of the Company (directly or indirectly) to another entity that has not received all the 
required regulatory approvals in advance, should such approvals be required, at the 
relevant time. 

13.3. 

Loans and debentures issued by Bezeq 

The following is a breakdown of the conditions that Bezeq has committed to in relation 
to the loans received and the debentures issued: 

13.3.1. 

In relation to Bezeq's total debt, accepted grounds for immediate repayment 
of  the  debentures  and  loans  were  included,  including  events  of  default, 
failure  to  pay,  liquidation  or  receivership  procedures,  etc.  A  right  to 
immediate  repayment  was  also  established  in  the  event  that  a  third-party 
lender demanded the immediate repayment of Bezeq’s debts towards him as 
a result of a default in an amount that exceeds the stipulated amount. 

In addition, Bezeq has committed not to create additional liens on its assets 
unless  the  bondholders'  consent  is  obtained  in  advance,  in  a  special 
resolution,  allowing  Bezeq  to  create  the  lien  in  favor  of  the  third  party,  or 
Bezeq will simultaneously create liens in favor of all lenders (negative lien). 
The lien includes exceptions, among other things, regarding the lien of assets 
that will be purchased or expanded by Bezeq, if the obligations for which the 
lien is secured were created for the purpose of purchasing or expanding said 
assets and regarding symbolic liens. 

institutions  whose  balance  as  of  December  31,  2023 

In relation to Bezeq's public debentures, to loans from banks whose balance 
as of December 31, 2023 is approximately NIS 1.5 billion, and to loans from 
financial 
is 
approximately NIS 0.7 billion, Bezeq has committed that in the event that it 
commits  to  a  party  any  obligation  in  connection  with  compliance  with 
financial standards, Bezeq will also obligate the aforementioned lenders with 
the same obligation (subject to certain exceptions). 

In relation to Bezeq's public debentures, as well as in relation to loans from 
financial institutions in the amount of approximately NIS 0.7 billion, a reason 
for 
the 
telecommunications segment ceases to be the Group's main field of activity. 

repayment  was 

the  event 

immediate 

included 

that 

in 

13.3.2. 

13.3.3. 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

13.3.4. 

13.3.5. 

In  relation  to  Bezeq's  public  debentures,  and  in  relation  to  loans  from 
financial institutions in the amount of approximately NIS 0.8 billion, Bezeq has 
committed to the lenders to act so that, as far as it is within its control, such 
debentures  will  be  monitored  by  Bezeq's  rating  from  level  one  at  least,  as 
long as there are debentures in circulation from such series or loan balance, 
respectively. 

In relation to debentures from Series 9-14, as well as in relation to loans from 
financial institutions in the amount of approximately NIS 0.7 billion, grounds 
for immediate repayment was included in the event of a change in control, as 
a result of which the controlling shareholders of Bezeq (as defined in the said 
agreements) would cease to have control over it and transfer control to party 
C  (“the  Transferee"),  with  the  exception  of:  (1)  transfer  of  control  to  the 
Transferee who received permission to control Bezeq in accordance with the 
provisions of the Communications Law and/or the Communications Order, or 
(2) transfer of control in which the Transferee holds control together with the 
controlling shareholders of Bezeq and on the condition that the proportion of 
the holdings of the controlling shareholders of Bezeq in Bezeq shares is not 
less  than  50.01%  of  the  total  Bezeq  shares  held  by  the  controlling 
shareholders  who  hold  together,  or  (3)  a  change  of  control  that  will  be 
approved by the meeting of bondholders / lenders. 

13.3.6. 

In addition to Series 9-14 debentures, and in relation to loans from financial 
institutions  amounting  to  approximately  NIS  0.7  billion,  grounds  for 
immediate repayment of the debentures were included in the event that a 
"going concern" note is recorded in Bezeq's statements for a period of two 
consecutive quarters, in the event  of a  deterioration substantial in Bezeq's 
business  compared  to  its  situation  at  the  time  of  issuance,  and  there  is  a 
tangible concern that Bezeq will not be able to repay the debentures/loans 
when due (as stated in Article 35T1(a)(1) of the Securities Law). 

As of December 31, 2023 and the date of approval of the statements, Bezeq met all of 
its  obligations  as  stated,  there  were  no  grounds  for  setting  up  credit  for  immediate 
repayment and no financial benchmarks were established as detailed above. 

 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

13.4.  Transactions in liabilities arising from financing activities 

Debentures 
(including 
accrued 
interest) 
NIS millions 

Loans (including 
accrued 
interest) 
NIS millions 

Balance as of January 1, 2022 

8,165 

1,912 

Changes as a result of cash flows from financing activities 
Proceeds  from  issuing  debentures  and  receiving  loans,  minus 
transaction costs 

Repayment of debentures and loans 

Interests paid 

Total net cash derived from (used for) financing activities 

Financing expenses imputed to the income statement 

Balance as of December 31, 2022 

Changes as a result of cash flows from financing activities 
Proceeds  from  issuing  debentures  and  receiving  loans,  minus 
transaction costs 

Repayment of debentures and loans 

Interests paid 

Total net cash used for financing activities 

Financing expenses imputed to the income statement 

Balance as of December 31, 2023 

- 

 )

1,333

(

)

(240

 )

1,573

(

384 

6,976 

915 

 )
1,326
(

 )
(219

 )
(630

336 

6,682 

400 

(83)

(67)

250 

69 

2,231 

100 

(83 )

(93 )

(76 )

98 

2,253 

Total 
NIS millions 

10,077 

400 

 )

1,416

(

)

(307

 )

1,323

(

453 

9,207 

1,015 

 )
1,409
(

 )
(312

 )
(706

434 

8,935 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

14.  Trade payables 

December 31 , 2023  December 31 , 2022 

NIS millions 

NIS millions 

Suppliers 

Open debts and expenses payable * 
Total suppliers 

894 
894 

Liabilities to employees and other liabilities for wages and salaries  373 
Deferred revenue 
224 
Institutions   
95 
4 
Derivate instruments 
Accrued interest 
32 
Current tax liabilities 
72 
64 
Others 
864 
Total current payables including derivatives 

Total and current trade payables 

Deferred revenue due to a government grant ** 
Deferred revenue 
Derivatives 
Others 
Total non-current payables 

1,757 

47 
92 
3 
18 
160 

903 
903 

367 
171 
92 
1 
29 
12 
23 
695 

1,598 

53 
76 
- 
22 
151 

Total current and non-current trade payables 

1,917 

1,749 

* Of which the balance of suppliers who are related parties and interested parties as of December 31, 2023 is NIS 
1 million (as of December 31, 2022 - NIS 2 million). 
** See Note 10.1. 

15.  Provisions 

Customer lawsuits 
NIS millions 

Additional lawsuits 
NIS millions 

and 
Dismantling 
removing  cellular 
sites and liability 
NIS millions 

Total 
NIS millions 

Balance as of January 1, 2023 

Provisions created 

Provisions exercised 

Provisions cancelled 

Balance as of December 31, 2023 

Presented  in  the  statement  on  the 
financial position as follows: 

Current provisions 

Non-current provisions 

Total 

87 

14 

(16 )

(1 )

84 

84 

- 

84 

For details regarding lawsuits, see Note 17. 

75 

21 

- 

(75 )

21 

21 

- 

21 

43 

2 

- 

(10 )

35 

6 

29 

35 

205 

37 

(16 )

(86 )

140 

111 

29 

140 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

16.  Employee benefits 

Employee  benefits  include  severance  benefits,  post-employment  benefits,  other  long-term 
benefits, and short-term benefits. See also Note 26 regarding share-based compensation. 

16.1.  Composition of the liabilities for employee benefits 

2023 

2022 

Note 

NIS millions 

NIS millions 

Current liabilities for: 

Vacation   

Sickness 

for  early 

Provision for early retirement plan at Bezeq 
Provision 
transferred from working for the State at Bezeq 
Provision for streamlining and early retirement plan at 
Pelephone, Bezeq International, and Yes 

retirement  of  employees 

16.4 

16.5.1 

109 

112 

66 

16.5.2 

- 

16.5.3-16.5.5 

38 

Current maturity of benefits for retirees 

16.3.3 

Total current liabilities for employee benefits 

Non-current liabilities for: 

Provision for amendment of employee agreement 

16.1.1 

Liabilities for benefits to retirees 
Severance pay, net (see composition below) 
Early notice and pension 
Provision for streamlining and early retirement plan at 
Pelephone, Bezeq International, and Yes 

16.3.3 

16.3.1 

16.3.2 

16.5.3 

Total non-current liabilities for employee benefits 

Total liabilities for employee benefits 

The  following  is  the  composition  of  the  liability  for 
severance pay: 

Liability for severance pay 

Fair value of plan assets 

7 

332 

70 

102 

50 

29 

- 

251 

583   

200 

 )105( 

50 

 108 

 114 

 93 

 10 

 67 

 7 

 399 

- 

107 

52 

28 

14 

 201 

600 

 201 

(149) 

 52 

16.1.1. 

On August 6, 2023 and on August 8, 2023, the Audit Committee of the Bezeq 
Board of Directors and the Bezeq Board of Directors (respectively) approved 
an  amendment  to  the  collective  agreement  between  Bezeq  and  the 
Employees  Organization  and  the  Histadrut  (“the  Amendment").  The 
Amendment states, among other things, that a special bonus will be paid to 
Bezeq employees in the amount of NIS 75 million, for past services, most of 
which is conditional on the dates and conditions stipulated in the agreement 
depending on the change in the percentage of holdings of the current control 
permit  holders  in  Bezeq  (or  the  expiration/cancellation/transfer  of  the 
control  permit)  ("the  Conditions").  The  Amendment  to  the  agreement  was 
approved by the general assembly of Bezeq's shareholders on September 14, 
2023.  As  a  result  of  the  signing  and  approval  of  the  Amendment  to  the 
agreement, Bezeq recorded a one-off provision of NIS 75 million for the full 
amount of the special grant. During the month of December 2023, Bezeq paid 
approximately NIS 5 million as part of the agreement. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
   
 
   
 
 
   
 
 
   
 
 
   
   
 
   
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

16.2.  Defined deposit plans 

Lability for benefits for employees of retirement age for their period of service in Bezeq 
and  the  consolidated  companies  and  for  the  employees  to  whom  Article  14  of  the 
Severance Compensation Law, 5723-1963 ("Severance Compensation Law") applies, fully 
covered by current payments to pension funds and insurance companies. 

Deposits recognized as an expense for a 
defined deposit plan 

220 

211  

218  

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

For  some  of  the  employees,  the  Group  has  an  obligation  to  complete  severance 
compensation beyond the amount accumulated in the severance fund in the name of 
the employees (see Note 16.3.1 below). 

16.3.  Defined benefit plans 

Liabilities regarding defined benefit plans in the Group include the following liabilities: 

16.3.1. 

16.3.2. 

16.3.3. 

The  liability  for  severance  pay  for  the  balance  of  the  liability  that  is  not 
covered by deposits and/or insurance policies in accordance with the existing 
employment  agreements and the Law on Severance Pay. In respect of this 
part of the liability, there is a reserve deposited in the name of Bezeq Group 
companies  in  pension  funds  and  insurance  companies.  The  reserves  in 
pension  funds  and  insurance  companies  include  linkage  differences  and 
accrued interest. Withdrawal of the reserves is conditional upon compliance 
with the provisions detailed in the Severance Compensation Law. 

A  liability  according  to  the  personal  employment  agreements  of  senior 
employees  in  the  Bezeq  Group  to  pay  a  benefit  for  early  notice  upon 
termination of the employee-employer relationship. In addition, Bezeq has a 
liability  towards  a  number  of  senior  employees  who  are  entitled  to  early 
retirement conditions (pension and retirement grants) that do not depend on 
the existing retirement agreements for all employees. 

Bezeq retirees receive benefits, apart from the pension payments, the main 
ones being a  holiday present (adjacent to the exchange rate of the dollar), 
financing  the  maintenance  of  the  pensioners'  clubs  and  social  activities. 
Bezeq's  liability  for  these  costs  accrues  during  the  work  period.  Bezeq 
includes  in  its statements  the  liabilities  for  the  expected  costs  in  the  post-
employment period. 

16.4.  Provision for sick leave 

The statements included a provision for redemption and exercise of sick days. The right 
to accrue sick days was taken into account for all employees of the Group, and the right 
to  redeem  sick  days  only  for  eligible  employees  in  accordance  with  the  conditions 
stipulated in the employment agreements. The provision was calculated on the basis of 
an actuarial calculation that includes the assumption of a positive accumulation of days 
for most employees and exercise of days using the "last in first out" (LIFO) method. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

16.5.  Benefits for early retirement and dismissal 

16.5.1. 

In accordance with the collective agreement between Bezeq and the workers' 
organization and the new General Workers' Union of December 2006 and in 
accordance with amendment number 6 to the agreement of December 2021, 
Bezeq  was  entitled,  at  its  discretion,  to  terminate  the  work  of  up  to  50 
permanent and veteran employees in each of the years 2026 - 2021. The right 
of Bezeq is cumulative over the years and this is in addition to the retirement 
quota  of  approximately  300  permanent  employees  remaining  from  the 
previous agreement, whose employment Bezeq can terminate at the end of 
the current agreement period. 

Bezeq recognizes the expense for early retirement when Bezeq has made a 
clear  commitment,  with  no  actual  possibility  of  cancellation,  to  dismiss 
employees before they reach the accepted retirement date, according to a 
defined  plan.  The  collective  agreement  gives  Bezeq  the  right  to  dismiss 
employees but does not create a clear commitment for Bezeq without a real 
possibility of cancellation. Therefore, the expenses for early retirement are 
recognized in Bezeq's books at the time the plan is approved. 

On December 13, 2023, Bezeq's Board of Directors approved, as part of the 
retirement  of 
implementation  of  Bezeq's 
approximately 50 permanent and veteran employees on an early retirement 
track at a total cost of up to approximately NIS 55 million. In light of the above, 
Bezeq recorded in its statements for Q4/2023 an expense of approximately 
NIS 55 million. 

streamlining  plan, 

the 

16.5.2. 

16.5.3. 

On December 16, 2018, an early retirement plan was approved, until the end 
of 2021, for all Bezeq employees who were transferred to the company from 
the Ministry of Communications (94 employees). The balance of the provision 
for the liability to retire the aforementioned employees as of December 31, 
2022 is NIS 10 million and is due in 2023. 

Labor relations at Pelephone are regulated by a collective agreement signed 
between Pelephone and the New General Workers' Histadrut - the Union of 
Cellular, Internet and High-Tech Workers (“the Histadrut") and the Pelephone 
Employees’ Committee. The agreement applies to all Pelephone employees, 
with the exception of senior managers and certain employees in pre-defined 
positions 

On December 6, 2022, Pelephone signed a renewal of the existing collective 
agreement,  which  includes  the  provision  of  salary  increases  and  bonuses, 
improvement  of  ancillary  conditions,  voluntary  retirement  and  the 
settlement of labor disputes announced by the General Workers' Union and 
the  employees’  representatives,  while  maintaining  industrial  peace  during 
the period of validity of the agreement in the matters regulated therein, for 
the  period  starting  From  December  6,  2022  to  December  31,  2025  ("the 
Agreement"). 

As part  of the agreement, all open labor disputes were removed, with the 
exception of the issue of appointing a representative on the Pelephone Board 
of Directors on behalf of the employees, regarding which it was stipulated in 
the agreement that it will be discussed later. 

In  December  2022,  the  Group  recognized  one-time  expenses  totaling 
approximately NIS 32 million, these expenses include expenses for employee 
retirement as well as one-time signing bonuses. 

 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

In 2023, the Group recognized expenses in the amount of approximately NIS 
7 million in respect of retirement expenses. 

16.5.4. 

Labor relations at Bezeq International are regulated by a collective agreement 
signed  between  Bezeq  International  and  the  New  General  Workers'  Union 
("Histadrut")  and  the  Workers'  Committee  at  Bezeq  International.  The 
agreement applies to all Bezeq International employees, with the exception 
of senior managers and certain employees in pre-defined positions. 

On October 3, 2022, Bezeq International's Board of Directors approved the 
implementation  of  the  agreements  reached  with  the  Histadrut  and  Bezeq 
International's  employee  representatives  (in  the  framework  of  conducting 
negotiations  to  regulate  the  rights  of  employees)  regarding  a  plan  for  the 
voluntary  retirement  of  Bezeq  International  employees  during  the  years 
2022-2024 (hereinafter "Voluntary Retirement Plan"). 

Following  the  approval  of  the  Voluntary  Retirement  Plan,  on  December  6, 
2022, Bezeq International's Management, the Histadrut and the Employees’ 
Committee signed a new collective agreement for Bezeq International until 
the end of 2025. 

In the agreement signed, Bezeq International’s Management and Employees’ 
Committee  reached  an  understanding  regarding  the  voluntary  retirement 
processes  and  the  granting  of  appropriate  conditions  to  the  retiring 
employees,  including  a  180%  retirement  bonus.  In  addition,  it  was  agreed 
upon salary increases at a rate of 9% during the period of the agreement (3% 
each year), a commitment to conduct negotiations regarding the requirement 
of the employee representatives to appoint an employee representative on 
the  Company's  Board  of  Directors,  increased  participation  in  meals,  the 
provision  of  a  signing  bonus  and  additional  rights.  In  2023  and  2022,  the 
Group  recorded  voluntary  retirement  expenses  of  approximately  NIS  12 
million and approximately NIS 62 million, respectively. 

16.5.5. 

Yes  is  bound  by  a  collective  agreement  between  itself  and  the  National 
Workers' Histadrut and the employees’ committees at Bezeq. The balance of 
the provision for early retirement for this agreement as of December 31, 2023 
is approximately NIS 3 million. 

16.6.  Actuarial assumptions 

The main actuarial assumptions regarding defined benefit plans as of the reporting date 
are: 

16.6.1. 

16.6.2. 

The mortality rates as well as future decreases in mortality rates are based on 
the rates published in the Pension Circular 2023-9-18 of the Capital Market 
Authority. 

The departure rates were determined based on the past experience of Bezeq 
and the consolidated companies while distinguishing between the different 
employee  populations  and  according  to  the  years  of  seniority.  Departure 
rates include a distinction between departures that grant entitlement to full 
severance pay and departures that do not grant full severance pay. 

16.6.3. 

The  (nominal)  discount  rate  is  based  on  the  yield  of  high-quality  linked 
corporate debentures with a duration similar to that of the gross liability. 

The following are the main discount rates: 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

Severance pay 

Retiree benefits 

31, 

December 
2023 
Average 
discount rate 

31, 

December 
2022 
Average 
discount rate 

5.9% 

5.6% 

5.2% 

5.2% 

16.6.4. 

Assumptions  regarding  salary  updates  for  the  purpose  of  calculating  the 
liabilities  were  made  on  the  basis  of  Management's  estimates  while 
distinguishing between the groups of employees. The main assumptions (in 
nominal terms) regarding salary updates of main employee groups are: 

Veteran permanent 
Bezeq employees 

New permanent Bezeq 
employees 
Non-permanent Bezeq 
employees 
Employees of 
Pelephone, Bezeq 
International and Yes 

Annual salary increase assumption 
The  calculation  was  based  on  individual  assumptions  regarding 
the expected salary increase for the years 2024 to 2026, resulting 
from  the  collective  agreement  signed  in  August  2015  and 
December 2020. 
Average update of 5.8% for young employees gradually decreases 
to 2.7% at age 66. 
6.4%  for  young    employees  gradually  decreases  to  0.1%,  2%  (in 
real terms) for senior workers. 
The  rates  of  salary  increases  were  determined  based  on  the 
collective agreements that were signed. The average annual salary 
increase rate is between 1% and 4%. 

16.6.5. 

Detailed  weighted  average  duration  of  liabilities  for  key  post-employment 
benefits: 

Severance pay 

Retiree benefits 

December 
2023 

31, 

December 
2022 

31, 

Years 

11 

13 

Years 

 11 

 14 

16.6 

Sensitivity analysis for main actuarial assumptions 

The  following  is  the  analysis  of  the  possible  impact  of  the  changes  in  main  actuarial 
assumptions on employee benefit liabilities. The calculation is made in relation to each 
discount separately, assuming that the other discounts remain unchanged. 

December 31, 2023  December 31, 2022 

NIS millions 

NIS millions 

Discount rate - 0.5% addition 

Future salary increase rate - 0.5% addition 

Employee turnover rate - 5% addition 

Mortality rate assumption - 5% increase 

 )18( 

20 

14 

 )2( 

(20) 

 22 

 5 

(2) 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

17.  Contingent liabilities 

In the course of the current business, lawsuits have been filed against  the Group companies or 
various lawsuits are pending against it (hereinafter in this section: "lawsuits"). 

In the opinion of the managements of the Group companies, which is based, among other things, 
on legal opinions regarding the possibility of legal claims, adequate provisions were included in 
the statements (as detailed in Note 15), where provisions were required, to cover the exposure 
as a result of the aforementioned lawsuits. 

In the opinion of the managements of the Group companies, the amount of additional exposure 
(beyond the aforementioned provisions), as of December 31, 2023, due to lawsuits filed against 
the  Group  companies  on  various  issues  and  the  probability  of  their  materialization  is  not 
expected, amounted to a total of about NIS 1.8 billion. In addition, there is additional exposure in 
the amount of approximately NIS 2.6 billion for claims whose chances cannot yet be assessed at 
this stage. 

Also,  motions  were  submitted  against  the  Group  companies  to  recognize  the  lawsuits as  class 
actions that did not specify an exact claim amount in the lawsuit, in respect of which the Group 
has additional exposure beyond the above. 

The additional exposure amounts in this note are nominal. 

17.1. 

The  following  is  a  description  of  the  contingent  liabilities of  the  Group  in  effect  as  of 
December 31, 2023, classified according to groups with similar characteristics: 

The 
exposure 
amount  for 
claims 
whose 
chances 
cannot  yet 
be assessed 

Provision 
balance 

Additional 
exposure 
amount 

Lawsuits group 

Lawsuits essence 

NIS millions 

Customer lawsuits  Mainly motions for approval of class actions (and 
actions on their behalf) concerning allegations of 
unlawful  collection  of  funds  and  damage  to  the 
provision  of  services  provided  by  the  Group 
companies. 
Lawsuits  in  which  liability  of  the  Group 
companies  is  claimed  in  connection  with 
their operation and/or investments. 
Mainly  individual  claims  filed  by  employees 
and 
the  Group 
former  employees  of 
concerning various payments. 

Enterprise and 
company claims 

Claims by 
employees and 
former employees 
of the group 
companies 
Miscellaneous 

Other  lawsuits,  including  tort  claims  (with 
the exception of claims for which there is no 
dispute regarding the existence of insurance 
coverage), 
infrastructure, 
suppliers, etc. 

estate, 

real 

Total lawsuits against the Company and the consolidated companies )3( 

84 

1,701 

787 

 )2( 20 

68 

)1( 1,808 

- 

2 

- 

1 
105 

23 
1,794 

4 
2,599 

 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

(1)  Including two motions for approval of a class action with a total amount of approximately NIS 
1.8 billion filed in June 2017 against the Company, Bezeq, officers of the Bezeq Group, as well 
as companies from the  group  formerly controlling  the Company and  Bezeq, regarding the 
transaction for the purchase of Yes’s shares by Bezeq from Eurocom DBS Ltd. According to 
the Court's decision, it is expected that a consolidated motion will be submitted to replace 
these two motions. The procedure is delayed due to the criminal procedure that is ongoing 
following the investigation by the Securities Authority (as described in Note 1.3) and at the 
request of the Attorney General at this stage, until July 20, 2024. 

(2)  On  May  23,  2023,  the  Company  signed  a  settlement  agreement  in  the  amount  of 
approximately USD 5.5 million in respect of two motions for the approval of class actions filed 
in June 2017, among other things, against the Company, Bezeq, officers in the Bezeq Group, 
as well as companies from the then controlling group of the company and Bezeq regarding 
the  purchase  transaction  of  Yes  shares  By  Bezeq  from  Eurocom  DBS  Ltd.  The  settlement 
amount does not include offsetting the insurance company's participation by virtue of the 
officers' insurance. 

At this stage, the settlement agreement has been submitted to the District Court in Tel Aviv 
(Economic  Department)  for  approval,  and  it  is  uncertain  that  it  will  be  approved.  To  the 
extent  that  the  settlement  agreement  is  approved,  this  will  end  the  involvement  of  the 
Company  and  Shaul  Elovich  (only  in  his  capacity  as  controlling  shareholder  and  former 
Chairman of the Company's Board of Directors) and Or  Elovich (in his capacity as a former 
director in the Company only) in the motions for approval. 

The  provision  in  the  Company's  books  for  the  aforementioned  settlement  minus  the 
expected receipt from the insurance company in the amount of approximately NIS 19 million 
was credited to other expenses in the income statement in the second quarter of 2023. 

(3)  In addition, see Note 6.6. 

18.  Contracts 

18.1. 

Yes is bound by agreements for the purchase of space segments (as detailed in Note 18.2 
below), content and copyrights, until the end of 2027 onwards. The amounts of future 
contracts as of December 31, 2023 are as follows: 

Space segments 

Content and copyrights 

Total 

Year ended December 31 
2024 
2025 
2026 
2027 

NIS millions 
91 
69 
11 
- 
171 

NIS millions 
225 
124 
87 
88 
524 

NIS millions 
316 
193 
98 
88 
695 

18.2.  According to an agreement with Space Communications Ltd. (hereafter - "Space") from 
2013,  as  amended  (including  an  amendment  from  January  2023),  Yes  leases  space 
segments in "Amos" series satellites (hereafter - "Space Agreement"). 

In accordance with the provisions of the Space Agreement, Yes leases space segments in 
the "Amos 3" satellites (the estimated end of its life is at the beginning of 2026), as well 
as  in  the  "Amos  7"  satellite,  in  which  Space  has  the  right  to  lease  space  segments 
according to an agreement between itself and the owner of the rights to this satellite, 
and which is leased to Yes until February 2025 (or until the end of its life, whichever is 
earlier). 

 
 
 
 
 
 
 
  
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

Leased space segments - according to the Space Agreement, and subject to unavailability 
events, until the end of the "Amos 7" lease period, Yes will lease 12 space segments from 
Space, in accordance with the distribution between the relevant satellites established in 
the  agreement  according  to  the  different  periods,  and  then  Yes  will  lease  ten  space 
segments  from  "Amos"  3".  The  agreement  also  regulates  the  provision  of  back-up 
sections for the leased space segments during the period of the agreement, under the 
conditions and limitations stipulated therein. 

Early termination of the agreement - according to the Space Agreement, Bezeq is entitled 
to announce an early termination of the Space Agreement without cause, subject to a 
12-month advance notice and payment for the lease in "Amos 7" plus partial payment of 
the balance of the lease in the space segments in "Amos 3". 

The  cellular  infrastructure  equipment  in  the  UMTS/HSPA  and  LTE  and  5G  networks  is 
manufactured  by  LM  Ericsson  Israel  Ltd.  ("Ericsson"),  which  serves  as  Pelephone's 
supplier for the deployment of the  4G (LTE) and  5G radio network. Also, Ericsson is a 
substantial provider of Pelephone in the field of microwave transmission. Pelephone has 
multi-year  agreements  for  maintenance,  support  and  software  upgrades  for  the 
UMTS/HSPA  network,  as  well  as  an  agreement  for  the  purchase  of  4G  (LTE)  and  5G 
equipment  with  Ericsson,  and  in  its  opinion,  it  may  depend  on  it  in  connection  with 
network support and expansion.  As of December 31, 2023, Pelephone has contracted 
with  Ericsson  for  the  purchase  of  end  equipment  and  the  receipt  of  aforementioned 
services for a total amount of approximately NIS 7 million. 

In April 2021, Pelephone's new engagement agreement with International Distribution 
Apple  ("Apple")  for  the  purchase  and  distribution  of  iPhones  entered  into  force, 
according  to  which  Pelephone  committed  to  purchase  a  minimum  annual  quantity  of 
devices for three more years at the prices that will be in effect with the manufacturer at 
the time of the actual purchases. As of the reporting date, Pelephone is in the process of 
extending the contract agreement for another year until March 31, 2025. 

For the purpose of its activities, Bezeq International usually acquires unlimited capacity 
usage  rights  (IRU)  from  service  providers.  During  the  Q1/2021,  Bezeq  International 
signed  an  agreement  to  extend  the  capacity  usage  periods  until  July  2030  with  the 
provider.  In  respect  of  the  rights  of  use,  Bezeq  International  pays  payments  that  are 
spread over annual payments throughout the period of use of the capacities. During the 
first quarter of 2023, Bezeq International signed a new agreement for the purchase  of 
capacity usage rights service for a period of 10 years with the supplier. In respect of the 
rights of use, Bezeq International pays payments that are spread over annual payments 
throughout the period of use of the capacities. The remaining engagement according to 
the agreement as of December 31, 2022 is USD 11.7 million (in 2021 -  USD 5.9 million). 

The Bezeq Group companies have contracts for December 31, 2023 for the purchase of 
end equipment, PP&E, intangible assets and other assets in the amount of approximately 
NIS 448 million. 

Law,  with 

the  amendment  of 

Further to what was stated in  Note 9.4 above regarding the deployment of an optical 
fiber  network  by  Bezeq,  in  accordance  with  the  provisions  of  Article  14C  of  the 
Communications 
the 
telecommunications companies including Bezeq and its subsidiaries Pelephone, Yes, and 
Bezeq International are obligated to pay a rate of 0.5% of their annual revenue during 
the  deployment  period  to  the  incentive  fund.  The  incentive  fund  is  managed  by  the 
Accountant  General  at  the  Ministry  of  Finance,  for  the  benefit  of  encouraging  the 
deployment of fiber while participating in the commission in statistical areas that are not 
included  in  the  deployment  areas  chosen  by  Bezeq.  The  Minister  of  Communications 
with the consent of the Minister of Finance and the approval of the Economic Committee 

the  Bezeq 

license, 

18.3. 

18.4. 

18.5. 

18.6. 

18.7. 

 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

can  change  this  rate.  On  July  31,  2023,  the  Communications  Order  (Bezeq  and 
Broadcasting) (Rate of Annual Payment to the Incentive Fund) (Provisional Order), 5783-
2023 was published, according to which, following the examination carried out by the 
Ministry of Communications, it was determined within the framework of a provisional 
order, that in 2023 the payment rate of the entities liable to the incentive fund will be at 
a rate of 0% instead of 0.5%. Further to the provisional order, there will be a decrease of 
approximately NIS 40 million in the Group's expenses in 2023 compared to 2022. 

18.8. 

For information regarding contracts with related parties, see Note 29. 

19.  Collateral, liens and guaranties 

Bezeq Group's policy is to provide tender and performance guaranties and guarantees according 
to  law.  In  addition,  Bezeq  provides,  as  needed,  bank  guarantees  for  bank  obligations  of 
consolidated companies. 

19.1.  Bezeq  Group  companies  provided  guaranties  to  the  Ministry  of  Communications  in 
connection  with  guaranteeing  the  terms  of  their  licenses  in  a  total  amount  of 
approximately NIS 132 million (of which approximately NIS 59 million are linked to the 
Consumer Price Index). 

19.2.  Bezeq Group companies provided bank guarantees to third parties in the total amount 
of approximately NIS 220 million (including a guarantee in the amount of approximately 
NIS 131 million for the Sakia complex. For details, see Note 6.6). 

19.3. 

Limitations on the creation of liens on the assets of Bezeq Group companies: 

19.3.1. 

In accordance with the Bezeq’s license, the license and any part of it cannot 
be  transferred,  pledged  or  foreclosed.  Transfer,  pledge  or  foreclosure  of 
property  from  the  license  assets  that  were  not  expressly  permitted  in  the 
license require the approval of the Minister who may, in special cases, permit 
the transfer of a license due to structural changes, if he is convinced that all 
the conditions that were met by the transferor are met by the owner of the 
transferred license. Also, to the extent that a third party is granted rights in 
the  assets  used  for  the  purpose  of  providing  Bezeq’s  services,  Bezeq  must 
ensure that a situation does not arise in which the exercise of the rights in 
said asset may harm the performance of Bezeq’s obligations according to the 
license. 

19.3.2. 

In accordance with Pelephone's mobile radio telephone license, Pelephone is 
not  allowed  to  sell,  lease,  or  mortgage  any  of  the  assets  used  for  the 
execution  of  the 
license,  unless  the  consent  of  the  Minister  of 
Communications has been given under the terms determined by him, after 
he has assumed that the exercise of the rights by the third party will not cause 
harm  to  the  provision  of  services  according  to  the  license,  as  long  as  the 
licensee  is  obligated  to  provide  these  services  under  the  provisions  of  the 
license, except: 

A.  A lien on any of the license's assets in favor of a bank operating legally in 
Israel,  in  order  to  obtain  bank  credit,  provided  that  it  has  notified  the 
Ministry of Communications of the lien it intends to register, according 
to which the lien agreement includes a clause guaranteeing that in any 
case the exercise of the rights by the bank will not cause any harm to the 
provision of services under the license. 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

19.3.3. 

19.3.4. 

B.  Sale  of  equipment  items  when  performing  an  upgrade  procedure, 

including sale of equipment using the trade in method. 

C.  Sale,  lease,  encumbrance  or  transfer  of  the  license  assets  to  a  cellular 

radio infrastructure licensee of which Pelephone is a customer. 

In accordance with Bezeq International’s license, it is not allowed to sell, rent 
or mortgage any of the assets necessary to guarantee the licensee's services, 
unless the Minister of Communications has given his consent to this after he 
has assumed that the exercise of the rights by the third party will not cause 
damage  to  the  provision  of  the  services  according  to  the 
license. 
Notwithstanding  the  foregoing,  Bezeq  International  may  pledge  any  of  the 
license assets in favor of a bank operating legally in Israel, in order to obtain 
bank credit, provided that it gives advance notice of the pledge it intends to 
make,  and  the  pledge  agreement  includes  a  clause  guaranteeing  that  the 
exercise  of  the  rights  by  the  bank  will  not  cause  harm  to  the  provision  of 
services under the license. 

In  relation  to  Yes’s  broadcasting  license,  the  Communications  Law  and  the 
license provisions establish limitations in relation to the transfer, foreclosure 
and pledge of the license and license assets. The broadcasting license requires 
obtaining the approval of the Minister in relation to certain changes in the 
maintenance of means of control in  Yes and imposes reporting obligations 
regarding  the  holders  of  the  means  of  control;  There  are  also  certain 
limitations 
license  to  perform  uplink  operations 
(transmission  of  transmissions  from  the  Yes  transmission  center  to  the 
transmission  satellite  and  performing  related  setup  and  operation 
operations). 

in  relation  to  the 

19.4.  As for the conditions the Group has committed to in connection with loans and credit, 

see Note 13. 

 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

20.  Equity 

20.1.  Shareholders’ equity 

Ordinary shares NIS 0.1 par value each 

Ordinary shares 

December 31, 2023  December 31, 2022 

Registered share capital 

Issued and paid up share capital 

Treasury shares 

300,000,000 

300,000,000  

116,335,793 

116,335,793  

 )

10,673,530

(

 )
9,080,317

(

Issued and paid up share capital, net 

105,662,263 

107,255,476  

20.1.1. 

20.1.2. 

20.1.3. 

During  the  year  2022,  the  Company  purchased  a  total  of  7,603,514  of  its 
shares as part of buyback plans for a total amount of approximately NIS 121 
million. 

On August  8, 2023, the Company's Board of Directors approved a  buyback 
plan  of  the  Company's  shares  up  to  NIS  30  million.  As  part  of  the 
aforementioned  buyback  plan,  the  company  purchased  1,593,213  of  its 
shares for approximately NIS 23 million. 

On March 12, 2024, the Company's Board of Directors approved an additional 
purchase plan of the Company's shares in the amount of up to NIS 25 million, 
which will begin on March 17, 2024 and end: (1) upon purchase in the amount 
of 25 million NIS; or (2) on June 30, 2024, whichever is earlier. 

20.1.4. 

As of December 31, December 2023, Searchlight and the Forer family about 
66.24% and 12.54%, respectively, of the Company's issued and paid-up share 
capital. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

21.  Revenues 

Landline national interior communication - Bezeq Fixed Lines 

Year ended December 31 
2022 
2023 
NIS millions 
NIS millions 

2021 
NIS millions 

Internet - infrastructure 

Data transmission and communication 

Landline telephony 

Cloud and digital services 

other services 

Cellular communication - Pelephone 

Cellular services and end equipment 

Sale of end equipment 

Multi-channel TV - Yes 

Internet  services  (ISP)  and  international  communication 
services and ICT solutions - Bezeq International 

Others 

1,907 
974 
632 
349 
295 
4,157 

1,724 
585 
2,309 

1,308 

1,139 

190 

9,103 

1,729  
 897  
 762  
 331  
 261  
3,980  

1,755  
 604  
2,359  

1,277  

1,183  

 187  

8,986  

 1,562 
 844 
 891 
 318 
 230 
3,845 

 1,606 
 643 
 2,249 

 1,270 

 1,186 

 271 

 8,821 

21.1.  Contract with customer recognized over time 

On December 21, 2022, Bezeq signed a long-term agreement with Partner Communications 
Ltd. ("Partner") for the provision of non-permanent right of use (IRU) service in the BSA fiber 
service (wholesale market) by Bezeq to Partner. In accordance with the agreement, Partner 
was granted a right of use a non-transferable and irrevocable right to provide service to its 
customers on 120,000 unspecified Bezeq fiber optic lines at a rate of 1 gigabyte download 
per line, for a period of 15 years starting on January 1, 2023 (the beginning of the right to 
use the lines will be done in phases for a period of up to five years). It should be noted that 
as  of  the  reporting  date,  Partner  insists  on  exercising  the  right  of  use  to  the  extent  of 
approximately 80%. 

The consideration for the provision of the service, which includes one-time payments and 
annual  payments,  is  expected  to  reach  a  total  amount  of  approximately  NIS  one  billion 
(approximately NIS 574 million for one-time payments, annual maintenance fees at the rate 
of 4% of the one-time payments for the lines for which the right of use will be granted until 
that year, and with the addition of interest and/or linkage differences according to the terms 
of the agreement), with most of the consideration amount expected to be paid during the 
first  9  years  of  the  agreement.  In  practice,  Partner  has  already  implemented  the  first  4 
tranches in the agreement. In light of these conditions, a material financing component was 
identified in the terms of the agreement. 

The agreement includes the option to increase the number of lines by up to 48 thousand 
additional  lines  under  the  same  conditions,  to  upgrade  rates  as  well  as  to  extend  the 
agreement  period  in  two  five-year  option  periods  each  with  less  lines  than  in  the  first 
agreement period. Increasing the content of the aforementioned agreement will result in a 
corresponding increase in the total financial scope of the agreement. The agreement also 
includes  a  price  protection  mechanism  for  Partner  in  a  way  that  weighs  the  price  of  the 
regulatory line, starting from the sixth year of the agreement. In light of these conditions, a 
material financing component was identified in the terms of the agreement. 

 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
   
   
 
 
 
   
   
 
 
 
   
   
 
 
   
   
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

22.  General and operating expenses 

Year ended December 31 
2022 
2023 
NIS millions 
NIS millions 

2021 
NIS millions 

to 

communication 

Connectivity 
operators in Israel and abroad 

and  payments 

End equipment and materials 

Content costs 

Marketing and general 

Structure and site maintenance 

Services and maintenance by subcontractors 

Vehicle maintenance* 

762 

825 

530 

439 

257 

504 

64 

 743  

 782  

 567  

 539  

 247  

 454  

 64  

 717  

 803  

 553  

 546  

 238  

 348  

 60  

3,381 

3,396  

3,265  

* General and operating expenses are presented minus expenses charged in 2023 to investments in PP&E 
and  intangible  assets  in  the  amount  of  NIS  51  million  (approximately  NIS  51  million  in  2022  and 
approximately NIS 49 million in 2021). 

23.  Salaries 

Total salaries and related expenses 

Share-based compensation 

Minus salaries credited to investments in PP&E and intangible 
assets 

24.  Other operating expenses (income), net 

Year ended December 31 
2023 
NIS millions 

2022 
NIS millions 

2,468 

10 

 )
(552

1,926 

2,395  

 12  

)

(530

1,877  

2021 
NIS millions 

2,416  

 27  

)

(555

1,888  

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

Capital gains (mainly from the sale of real estate) 

Receipts from settlement agreement 
Expenses for termination of employee-employer relations in 
early retirement at Bezeq (see Note 16.5.1) 
Expenses  due  to  the  termination  of  employer-employee 
relations with early retirement and a streamlining agreement 
at Pelephone, Bezeq International and YES (see Notes 16.5.3 
and 16.5.4) 

Provision (cancellation of provision) for claims 
One-off provision - amendment of collective agreement with 
the employees (see Note 16.1.1) 

Other income 

Other operating expenses (income), net 

(2 )

- 

57 

17 

44 

75 

(11 )

180 

(8)

- 

 78  

 102  

 55  

- 

(7)

 220  

)

(175

(5)

 95  

 37  

(23)

- 

(6)

(77)

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

25.  Financing expenses, net 

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

Interest expenses for financial liabilities 

Financing expenses for employee benefits 
Costs due to early repayment of loans and debentures (see 
Note 13) 

Linkage and exchange rate differentials 

Financing expenses for lease obligations 

Other financing expenses 
Change in fair value of financial assets measured at fair value 
through income 

Total financing expenses 

Income due to credit grossing in sales 

Financing income for employee benefits * 

Other financing income 
Change in fair value of financial assets measured at fair value 
through income 

Total financing income 

344 

10 

- 

92 

63 

9 

- 

518 

22 

- 

121 

26 

169 

 309  

- 

 26  

 125  

 43  

 19  

 8  

 530  

 20  

 40  

 49  

 23  

 132  

 395  

 7  

 34  

 49  

 40  

 8  

- 

 533  

 28  

- 

 16  

 11  

 55  

 478  
Financing expenses, net 
* Financing income recognized as a result of updating the discount rate according to which the liabilities 
for employee benefits are calculated as of December 31, 2022. 

 398  

349 

26.  Share-based compensation 

26.1. 

Terms of the Bezeq Group option plan 

During  the  year  2021,  Bezeq  allocated  64  million  options  to  officers,  executives  and 
senior employees in Bezeq and Bezeq's subsidiaries. The options were allocated to each 
offeree in three grants, each grant at the rate of one third of the total options allocated 
to the offeree. Each grant will become vested in four annual phases where a different 
exercise price is determined for each grant. The exercise of each option is subject to the 
fact that, after the vesting date of the option, the exercise price condition for the option 
has been met (the average of the closing prices of a Bezeq share in the period of at least 
30 consecutive trading days on the stock exchange preceding the test date is equal to or 
higher than the price that is a condition for exercise). 

During  the  year  2022,  Bezeq  allocated  approximately  7  million  additional  options  to 
officers, executives and senior employees at Bezeq and Bezeq's subsidiaries. The options 
were granted in 2 grants, each grant half of the total number of options for that offering. 
Each grant will become vested in four annual tranches where a different exercise price 
is determined for each grant. 

During  the  year  2023,  Bezeq  allocated  approximately  3  million  additional  options  to 
officers, managers, and senior employees in Bezeq and its subsidiaries. The options were 
granted  in  4  grants.  Each  grant  will  become  vested  in  four  annual  tranches  where  a 
different exercise price is determined for each grant. 

 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

26.2. 

Transfers the in number of options in Bezeq Group 

Balance in circulation at the beginning of the period 

Options granted during the year 

Options realized 

Options forfeited during the year due to the departure of the bidders 

Balance in circulation at the end of the period 

Options 
2023 
Millions 
57 

Options 
2022 
Millions 
 60  

3 

(5 )

(3 )

52 

 7  

- 

(10) 

 57  

28 

Exercisable  at  the  end  of  the  period  (subject  to  compliance  with  the  share 
exercise price conditions) 

15*

* As of the date of approval of the financial statements, approximately 14 million  
options met the share price conditions and are exercisable. 

26.3.  Details regarding the measurement of the fair value of a  share-based compensation 

plan in Bezeq Group 

The fair value of the options granted during 2021 in Bezeq Group, which was estimated 
by an external valuator while applying the Monte Carlo model, is about NIS 46 million, 
according to the vesting period and the conditions of exercise as detailed above. 

The fair value of the options granted during 2022 in Bezeq Group, which was estimated 
by an external valuator while applying the Monte Carlo model, is about NIS 13 million, 
according to the vesting period and the conditions of exercise as detailed above. 

The fair value of the options granted during the year 2023, which was estimated by an 
external  appraiser  applying  the  Monte  Carlo  model,  is  approximately  NIS  3  million, 
according to the vesting period and the conditions of exercise as detailed above. 

26.4. 

Salaries expenses recognized by Bezeq Group for share-based compensation 

Salary expenses 

Year ended December 31 

2023 

2022 

2021 

NIS millions 
10 

NIS millions 
 11 

NIS millions 
 27 

26.5.  Options granted to company officers 

During  the  year  2022,  the  Company  allocated  3,350,000  options  exercisable  into 
3,350,000 ordinary shares of the Company to Company officers. The vesting period of 
the options granted to the Company's officers is 3 years. 

Salaries expenses recognized by the Company for share-based compensation: 

Salary expenses 

Year ended December 31 

2023 

2022 

2021 

NIS thousands 
400 

NIS thousands 
 520 

NIS thousands 
280  

 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

27.  Profit per share 

The calculation of the basic and diluted profit per share was based on the profit attributed to the 
ordinary shareholders and according to the weighted average number of ordinary shares included 
in the calculation as follows: 

the 
Net  profit 
Company's shareholders (NIS millions) 

attributable 

to 

Weighted average of ordinary shares 

Balance as of January 1 (millions) 

Effect of buyback of shares 
Basic  weighted  average  of  ordinary 
shares as of December 31 (millions) 

Effect of share-based compensation 
Diluted  weighted  average  of  ordinary 
shares as of December 31 (millions) 

Basic profit per share (NIS) 

Diluted profit per share (NIS) 

2023 

2022 

2021 

187 

107 

(1 )

106 

- 

106 

1.75 

1.74 

 158  

 115  

(4)

 111  

 1  

 112  

1.42  

1.41  

 129  

 116  

- 

 116  

- 

 116  

1.11  

1.11  

 
 
 
 
 
   
   
 
 
 
 
   
   
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

28.  Segment reporting 

28.1. 

The Group operates in four different segments in the communications industry, in such 
a way that each company in the Group operates in a separate business segment. Each 
Company  provides  services  in  the  segment  in  which  it  operates  using  the  PP&E  and 
infrastructures it owns (see also Note 21). The infrastructure of each company is used to 
provide its services. Some of the Group companies use infrastructure owned by other 
Group companies. 

The  main  reporting  format,  according  to  business  segments,  is  based  on  the 
administrative and internal reporting structure of the Group. 

The business segments of Bezeq Group are as follows: 
1.  "Bezeq" 

Israel  Telecommunications  Corp.  Ltd.  – 

the 

landline 

interior 

communications; 

2.  Pelephone Communications Ltd. - cellular communications; 
3.  Bezeq International Ltd.  – Internet and international communication services and 
ICT  solutions  (information  and  communication  systems)  (hereinafter  -  "Bezeq 
International Services Sector"); 

4.  Yes TV and Communications Services Ltd. (Yes) - multi-channel TV. 

The rest of the Group companies are presented in the "Others" section. Other activities 
include  call  center  services  for  customers  (Bezeq  Online).  These  activities  are  not 
reported as reportable segments since they do not meet the quantitative thresholds in 
the reported years. 

Inter-segment pricing is determined according to the price established in transactions in 
the normal course of business. 

Results, assets and liabilities of a segment include items that can be directly allocated to 
the segment, as well as those that can be reasonably allocated. 

The results of the multi-channel TV segment are presented excluding the total effect of 
asset  impairment  described  in  Note  10.5  (proforma).  This  is  in  accordance  with  the 
manner 
in  which  the  Group's  main  operational  decision-maker  evaluates  the 
performance of the segments and makes decisions regarding the allocation of resources 
to said sectors. 

The capital expenditure of a segment is the total cost incurred during the period for the 
purchase of PP&E, intangible assets, and deferred expenses. 

 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

28.2.  Operating segments 

Year ended December 31, 2023 
Landline 
interior 
communication 

Cellular 
communication 

NIS millions 
4,157 
255 
4,412 

NIS millions 
2,309 
39 
2,348 

Bezeq 
International 
services 

NIS millions 
1,139 
73 
1,212 

Multichannel 
TV 

NIS millions 
1,308 
1 
1,309 

1,019 

549 

137 

244 

1,451 
370 
(114) 

256 

1,195 
294 
901 

9,311 
- 
9,189 

1,155 

196 
35 
(48) 

(13) 

209 
50 
159 

2,832 
- 
1,448 

365 

39 
17 
(7) 

10 

29 
- 
29 

991 
9 
779 

100 

(4 )
8 
(17) 

(9) 

5 
1 
4 

1,231 
- 
445 

192 

Others 

Adjustments 

Consolidated 

NIS millions 
190 
2 
192 

NIS millions 
- 
(370
 )
 )
(370

NIS millions 
9,103 
- 
9,103 

6 

(1 )
- 
- 

- 

(1) 
1 
(2) 

88 
- 
30 

5 

(88 )

1,867 

68 
88 
17 

105 

(37) 
- 
(37) 

332 
1,559 
2,016 

- 

1,749 
518 
 )
(169

349 

1,400 
346 
1,054 

14,785 
1,568 
13,907 

1,817 

Revenues from externals 
Inter-segmental revenues 
Total revenues 

Depreciation, 
impairments 

reductions 

and 

Segment  results  -  operating  profit 
(loss) 
Financing expenses 
Financing income 
Total  financing  expenses  (income), 
net 

Segment profit (loss) before income 
taxes 
Income taxes 
Segment results - net profit (loss) 

Segment assets 
Goodwill 
Segment liabilities 
Investments 
assets and deferred expenses 

in  PP&E, 

intangible 

*  The  results  of  the  multi-channel  TV  segment  are  presented  net  of  the  overall  impact  of  impairment 
recognized  as  of  2018.  This  is  in  accordance  with  how  the  Group's  chief  operating  decision  maker 
evaluates the segment's performance and makes decisions regarding the allocation of resources to the 
segment. In addition, see Note 31.4 regarding a summary of selected data from Yes’s statements. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

28.2.  Operating segments (Cont.) 

Year ended December 31, 2022 
Landline 
interior 
communication 

Cellular 
communication 

NIS millions 
3,980 
632  
4,30  
6

NIS millions 
2,359 
40 
2,399 

Bezeq 
International 
services 

NIS millions 
1,18  
3
56 
1,239 

Multichannel 
TV 

NIS millions 
1,277 
- 
1,277 

1,005 

532 

134 

274 

1,460 
424 
(92)

332 

1,128 
279 
849 

9,02  
0
- 
10,465 

193 
42 
(68)

(26)

219 
54 
165 

4,080 
- 
1,563 

1,156 

289 

(30)
9 
(8)

1 

(31)
1 
(32)

751 
9 
570 

122 

(48)
8 
(14)

(6)

(42)
1 
(43)

1,249 
- 
469 

189 

Others 

Adjustments 

Consolidated 

NIS millions 
718  
6 
193 

NIS millions 
- 
)
(428
)
(428

NIS millions 
8,986 
- 
8,986 

4 

6 
- 
- 

- 

6 
1 
5 

90 
- 
32 

10 

(81)

1,868 

44 
47 
50 

97 

(53)
- 
(53)

(903
)
1,559 
860 

- 

1,625 
530 
)
(132

398 

1,227 
336 
891 

14,287 
1,568 
13,959 

1,766 

Revenues from externals 
Inter-segmental revenues 
Total revenues 

Depreciation, 
impairments 

reductions 

and 

Segment  results  -  operating  profit 
(loss) 
Financing expenses 
Financing income 
Total  financing  expenses  (income), 
net 

Segment profit (loss) after financing 
expenses, net 
Income taxes 
Segment results - net profit (loss) 

Segment assets 
Goodwill 
Segment liabilities 
Investments 
assets and deferred expenses 

in  PP&E, 

intangible 

* The results of the multi-channel TV segment are presented net of the overall impact of impairment recognized 
as of 2018. This is in accordance with how the Group's chief operating decision maker evaluates the segment's 
performance and makes decisions regarding the allocation of resources to the segment. In addition, see Note 
31.4 regarding a summary of selected data from Yes’s statements. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

28.2.  Operating segments (Cont.) 

Year ended December 31, 2021 
Landline 
interior 
communication 

Cellular 
communication 

NIS millions 
3,845 
337 
4,182 

NIS millions 
2,249 
40 
2,289 

Bezeq 
International 
services 

NIS millions 
1,186 
51 
1,237 

Multichannel 
TV 

NIS millions 
1,270 
- 
1,270 

938 

577 

173 

292 

1,748 
357 
(15)

342 

1,406 
343 
1,063 

9,245 
- 
- 
11,415 

42 
23 
(65)

(42)

84 
20 
64 

4,452 
- 
- 
1,753 

1,197 

289 

22 
5 
(3)

2 

20 
12 
8 

778 
5 
- 
566 

111 

(41)
4 
(3)

1 

(42)
1 
(43)

1,293 
- 
- 
474 

188 

Others 

Adjustments 

Consolidated 

NIS millions 
271 
6 
277 

NIS millions 
- 
)
(434
)
(434

NIS millions 
8,821 
- 
8,821 

4 

27 
- 
- 

- 

27 
6 
21 

100 
- 
- 
37 

5 

(95)

1,889 

58 
144 
31 

175 

(117
)
- 
)
(117

(874
)
- 
1,560 
844 

- 

1,856 
533 
(55)

478 

1,378 
382 
996 

14,994 
5 
1,560 
15,089 

1,790 

Revenues from externals 
Inter-segmental revenues 
Total revenues 

Depreciation, 
impairments 

reductions 

and 

Segment  results  -  operating  profit 
(loss) 
Financing expenses 
Financing income 
Total  financing  expenses  (income), 
net 

Segment profit (loss) after financing 
expenses, net 
Income taxes 
Segment results - net profit (loss) 

Investment in affiliates 
Segment assets 
Goodwill 
Segment liabilities 
Investments 
assets and deferred expenses 

in  PP&E, 

intangible 

* The results of the multi-channel TV segment are presented net of the overall impact of impairment recognized 
as of 2018. This is in accordance with how the Group's chief operating decision maker evaluates the segment's 
performance and makes decisions regarding the allocation of resources to the segment. In addition, see Note 
31.4 regarding a summary of selected data from Yes’s statements. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

28.3.  Adjustments for reporting segments of revenue, income, assets and liabilities 

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

Revenues 

Revenues from reporting segments 

Revenues from other segments 

Cancellation of revenues from inter-segmental sales 

Consolidated revenues 

Operating profit 

Operating profit for reporting segments 

Financing expenses, net 

9,281 

192 

 )
(370

9,103 

1,682 

 )
(349

Adjustments for the multi-channel TV segment 
Profit  (loss)  for  activities  classified  in  the  Other  and 
other adjustments category 

98 

(31 )

Consolidated operating profit 

1,400 

9,221  

 193  

)

(428

8,986  

1,575  

)

(398

 56  

(6)

1,227  

8,978  

 277  

)

(434

8,821  

1,771  

)

(478

 72  

 13  

1,378  

December 
2023 

31, 

December 
2022 

31, 

NIS millions 

NIS millions 

Assets 

Assets of reporting segments 

Assets associated with activities classified in the Other category 

Goodwill not attributable to an activity segment 
Minus loss from asset impairment (see note 10), inter-segment assets and 
other adjustments 

Assets and cost overruns that are not attributed to a reporting segment 

Consolidated assets 

Liabilities 

Liabilities of reporting segments 

Liabilities associated with activities classified in the Other category 

Minus inter-segmental liabilities 

Liabilities related to non-reporting segments 

Consolidated liabilities 

14,374 

88 

1,559 

 )
(925

1,257 

16,353 

11,861 

30 

(210) 

2,226 

13,907 

15,109  

 90  

1,559  

 )

2,128

(

1,225  

15,855  

13,067  

 32  

 )

1,311

(

2,171  

13,959  

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

29.  Transactions with interested parties and related parties 

29.1. 

Identity of interested parties and related parties 

The Company's interested parties and related parties as defined in the Securities Law 
and  International  Accounting  Standard  24  regarding  related  parties  are  mainly 
Searchlight  and  TNR,  their  related  parties  affiliates,  directors  and  key  management 
personnel from the Company or Searchlight and TNR. 

It  should  be  noted  that  the  transactions  described  below  with  interested  parties  and 
related  parties  do  not  include  reference  to  what  is  stated  in  Note  1.3  regarding 
investigations by the Israel Securities Authority and the Israel Police or to their possible 
consequences. 

29.2.  Balances with interested parties and related parties 

Related parties, net 

Right-of-use assets 

Current lease liability maturities 

Non-current lease liabilities 

As of December 31 

2023 

2022 

NIS millions 

NIS millions 

- 

2 

(1 )

(1 )

(1)

 2  

(1)

(2)

29.3.  Transactions with interested parties and related parties 

Revenue 
From related parties 
From affiliates 
Expenses 
To related parties 
To affiliates 
PP&E 
To related parties 

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

8 

- 

27 

1 
8 

 4  

- 

 24  

 1  
 4  

 10  

 1  

 33  

- 
 10  

29.3.1. 

Classification of transactions with officers and controlling shareholders in the 
Bezeq Group 

Bezeq's Audit Committee decided to adopt guidelines, standards and rules for 
the classification of a transaction by Bezeq or its consolidated company with 
officers  in  Bezeq  or  in  which  an  officer  of  Bezeq  has  a  personal  interest 
(hereinafter  -  "transaction  with  an  officer")  and  a  transaction  with  a 
controlling shareholder of Bezeq or in which the controlling shareholder has 
a personal interest (hereinafter - "transaction with a controlling owner") as a 
negligible transaction. 

The standards established in the procedure, as updated from time to time in 
accordance with its instructions, may be used by Bezeq, among other things, 
to classify a transaction as a negligible transaction as stipulated in Regulation 
41(a3)  of  the  Securities  Regulations  (Annual  Financial  Statements),  5770-

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
   
   
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

2010, and as a tool for examining the negligible nature of additional business 
relationships,  such  as:  the  existence  of  business  relationships  with  a 
candidate  for  office  as  an  external  director  or  an  independent  director 
Negligible as stated in the Companies Regulations (matters not constituting 
an  affiliation),  5767-2006  and  as  stated  in  Article  240(f)  of  the  Companies 
Law, 5759-1999 (“the Companies Law"). 

Bezeq and its consolidated companies enter into transactions from time to 
time with Bezeq officers and those who control it, including transactions of 
the types and characteristics as detailed below: 

1.  Sale of communication services and products by Bezeq Group companies 
- 
including:  various  basic  communication  services  (infrastructure, 
telephony, transmission and PRI) and hosting in server farms; provision 
of  cellular  services  and  value-added  services  and  sale  and  upgrade  of 
cellular end equipment; Internet access services, international telephony 
services, hosting services and data communication services; TV services. 

2.  Real  estate  lease,  management  and  purchase  agreements,  including, 
among  others:  lease  of  areas  used  for  communication  facilities  and 
warehouses. 

3.  Receiving consulting and training services for Bezeq Group companies or 

their employees. 

4.  Purchase of goods and services used by Bezeq Group companies in their 
activities, such as purchase of fuel and energy products, repair services, 
financial/banking services and more. 

In  the  absence  of  special  qualitative  considerations  arising  from  all  the 
circumstances  of  the  matter,  a  transaction  will  be  considered  a  negligible 
transaction to the extent that all of the following parameters are met: 

A.  The transaction is not an unusual transaction (that is, a transaction made 
in  the  normal  course  of  business,  under  market  conditions  and  which 
may not materially affect Bezeq's profitability, its assets or liabilities, all 
in accordance with Bezeq's procedures). 

B.  The  scope  of  the  contract  specified  in  it  in  Bezeq  (solo,  and  not  on  a 
consolidated basis) (or in any of the subsidiaries) will not exceed NIS 10 
million. 

C.  Bezeq is not required to report the transaction in an immediate report in 
accordance with Regulation 36 or Regulation 37a of the periodic report 
regulations or according to any other law. 

D.  The transaction does not include tenure and employment conditions (as 
defined  in  the  Companies  Law)  of  an  interested  party  or  a  relative 
thereof,  or  does  not  constitute  a  contract  as  stated  in  the  last  part  of 
Article 270(4) of the Companies Law (contract of a public company with 
its  controlling  shareholder  or  a  relative  thereof,  directly  or  indirectly, 
including through a company under his control, regarding his receipt of 
services from  the Company, and also if  he is its officer - regarding the 
conditions of his tenure and employment, and if he is a Bezeq employee 
and is not its officer - regarding his employment in Bezeq). 

 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

As a general rule, each transaction will be examined separately for the 
purpose of examining its compliance with the conditions for classification 
as a negligible transaction as detailed above. Notwithstanding the above, 
separate transactions that are part of the same contract or continuous 
transactions or very similar transactions that are carried out frequently 
and repeatedly or with the same entity and with corporations under its 
control  or  transactions  between  which  there  is  a  dependency  or 
condition, will be examined as one transaction on an annual basis for the 
purpose of their examination. 

The Audit Committee may, from time to time and at its discretion, change 
the above parameters for classifying a negligible transaction. 

In addition, the standards established by the Audit Committee and the 
Company's  Board  of  Directors  refer  to  the  conditions  under  which  a 
transaction  will  be  considered  an  unusual  transaction,  as  well  as 
conditions under which a contribution by the Company or  a subsidiary 
will not be considered an unusual transaction. 

Transactions listed in Article 270 (4) of the Companies Law that are not 
considered negligible transactions 

There were no such transactions during the reporting period. 

For  the  transactions  listed  in  Article  270(4)  of  the  Companies  Law 
concerning insurance and obligation to indemnify directors and officers 
of the Company, see Note 29.6 below. 

29.4. 

Benefits for key managerial personnel in the Group 

Benefits for the employment of key management personnel in the Group in 2021-2023 
include: 

Year ended December 31 
2023 
NIS thousands 

2022 
NIS thousands 

2021 
NIS thousands 

Number of key management personnel * 

Salaries ** 

Grant *** 

Share-based compensation 

6 

10,147 

6,910 

5,619 
22,676 

 6  

9,872  

 ***

7,262

6,197  
23,331  

 5  

9,403 

7,780  

13,530  
30,713  

* Key  management  personnel  in  the  Group  in  the  reporting  year  include  the  Chairman  of  the 
Company's  Board  of  Directors,  the  Company's  CEO,  the  former  Chairman  of  Bezeq’s  Board  of 
Directors, the CEO of Bezeq, the CEO of Pelephone, and the CEO of Pelephone and Yes, as well as 
the CEO of Bezeq International. 

**  In 2023, the changes in other provisions (included in the total salaries) mainly include a  decrease 
in provisions for advance notice to the Bezeq CEO in the amount of approximately NIS 1.1 million, 
offsetting an increase in the  provision for advance notice  to the former  Chairman of the Bezeq 
Board of Directors in the amount of approximately NIS 0.2 million. 

In 2022, the changes in other provisions (included in the total salary) mainly include provisions for 
advance  notice  to  the  CEO  of  Pelephone,  Bezeq  International,  and  Yes  in  the  amount  of 
approximately NIS 0.7 million. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

In 2021, the changes in other  provisions at  Bezeq (included in the total  salaries) mainly include 
provisions for vacation and sickness in the amount of approximately NIS 0.2 million. 

***  The amount includes an annual discretionary grant approved by Bezeq's general assembly on April 

28, 2022 for the year 2021. 

For information on share-based compensation, see Note 26. 

29.5.  Benefits for directors of the Company 

Year ended December 31 

2023 

2022 

2021 

NIS thousands 

NIS thousands 

NIS thousands 

Compensation for the members of the Board of 
Directors * 
Number of directors receiving  compensation **  6 

805 

 645  

 6  

 635  

 6  

*  The  directors’  compensation  of  the  Company's  CEO,  who  also  served  as  a  director  of  the  Company  until 
November  29,  2021,  as  well  as  the  compensation  of  the  Chairman  of  the  Company's  Board  of  Directors,  are 
presented in Note 29.4 above due to their being key management personnel. 
** In 2021, a new director was appointed on behalf of the controlling shareholder of the Company, as well as a 
retired external director, a new external director was appointed by the general assembly on January 24, 2022. 

29.6.  Additional benefits for directors and officers in the Company 

Date  of  the  approval  of 
the  general  assembly 
the 
(after 
receiving 
approval 
the 
Company's  Board  of 
unless 
Directors), 
otherwise specified 

of 

April 30, 2020 

April 30, 2020 

November 28, 2023 

of 

the 
Approval 
Company's  Board 
of 
Directors  in  accordance 
with  Regulation  1b1  of 
the 
Facilitation 
Regulations 

Nature of transaction 

Transaction amount 

of 

the 

Certificate 
Company's 
engagement  in  a  run-off  insurance 
liability  of 
policy  to  cover  the 
directors  and  officers  of 
the 
Company. 

to 

the 

Amendment 
letter  of 
commitment to indemnification and 
exemption  for  the  directors  and 
officers  of  the  Company  regarding 
the  maximum 
of 
indemnification. 

amount 

of 

the 

Certificate 
Company's  
engagement  in  an  insurance  policy 
to cover the liability of directors and 
officers  in  the  Company  and  its 
subsidiaries, in accordance with the 
Company's  compensation policy for 
the period until December 1, 2024. 

Liability limit of up to 10 million dollars 
per  claim  and  in  total  for  the  entire 
insurance  year,  plus  reasonable  legal 
expenses.  The  total  annual  premium  is 
about  USD  300k.  The  amount  of  the 
deductible for the Company is up to USD 
250k per case. 

Up  to  25%  of  the  Company's  equity 
according  to  the  Company's 
latest 
reports  published  before  the  actual 
indemnity was granted or a total of USD 
15 million, whichever is higher. 

in  total 

Liability limit of up to USD 20 million per 
for  the  entire 
claim  and 
insurance  year  plus  reasonable  legal 
expenses.  The  total  annual  premium  is 
approximately  USD 
The 
amount  of  the  deductible  for  the 
company is up to USD 150k in the case 
of claims outside the US and Canada, up 
to USD 250k in the case of claims in the 
US  In  Canada  and  up  to  USD  250K  per 
case for securities claims in Israel. 

421,825. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

30.  Financial instruments 

30.1.  General 

The Group is exposed to the following risks arising from the use of financial instruments: 

A.  Credit risk 
B.  Liquidity risk 
C.  Market risk (including currency risk, interest rate risk and inflation / Consumer Price 

Index risks). 

In  this  note,  quantitative  and  qualitative  information  is  given  regarding  the  Group's 
exposure to each of the above risks, an explanation of how the risks are managed and 
the measurement processes. 

30.2. 

Framework for financial risk management 

The comprehensive responsibility for establishing the group's financial risk management 
framework and overseeing it rests with the board of directors. The purpose of financial 
risk management in the group is to define and monitor the various risks on an ongoing 
basis  and  to  determine  the  level  of  risk  exposure  that  must  be  met  and  the  possible 
effects  resulting  from  this  exposure 
in  accordance  with  the  assessments  and 
expectations of the board of directors. 

The Group's policy is to manage, according to rules established by the Board of Directors, 
the exposure resulting from fluctuations in foreign exchange rates, changes in interest 
rates and changes in the Consumer Price Index. 

30.3.  Credit risk 

Management maintains ongoing monitoring of the Group's exposure to credit risks. Cash 
and  investments  in  deposits and  securities  are  deposited  in  highly  rated  banking  and 
non-banking  corporations,  and  there  are  also  investments  in  short-term  loans  and 
financial funds. 

Trade and other receivables 
The  Group's  Management  regularly  monitors  customer  debts  and  the  financial 
statements  include  provisions  for  loan-loss  that  adequately  reflect,  according  to 
Management's  assessment,  the  loss  grossing  in  debts  whose  collection  doubtful.  In 
addition, there is a wide spread of customer balances. 

Investments in financial assets 
To  the  extent  that  investments  are  made  in  securities,  they  are  made  in  liquid, 
marketable  and  low-risk  securities.  Transactions  involving  derivatives  are  conducted 
with entities with a high credit rating. 

As of the reporting date, there is no significant concentration of credit risks. 

30.4. 

Liquidity risk 

The  Group's policy for managing its liquidity is to ensure, as far as possible, sufficient 
liquidity to fulfill its existing and expected obligations when they come due, in a normal 
business scenario and under extreme conditions, without causing it unwanted losses or 
damage  to  its  goodwill.  The  cash  balances  held  by  the  Group  are  mainly  managed  in 
liquid investment channels, subject to the needs of financing current activities and debt 
service.  The  Group  regularly  examines  the  existing  and  expected  cash  needs  in  the 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

foreseeable range, even in the scenario of an unexpected deterioration in its business. 
These forecasts take into account, among other things, debt collection and circulation 
from banking and non-banking sources. According to the conclusions, proactive activity 
is carried out to minimize the risk. 

Regarding the terms of debentures issued and loans received by the Group companies, 
see Note 13 above. 

The Group has contractual obligations for purchases, PP&E, end equipment, and other 
current  services.  For  more  information  regarding  the  contracts,  see  Note  18  on 
contracts. 

The  following  are  the  contractual  repayment  dates  of  financial  obligations  that  have 
actually been received up to December 31, 2023, including estimated interest payments 
(based on consumer price index data and interest known as of December 31, 2023): 

As of December 31, 2023 

Book value 

Predicted 
cash flow 

H1/2024 

6202

  to  

5202  

8202  

9202
onwards 

H2/2024 
NIS millions 

Non-derivative financial liabilities 

Trade payables 

Loans  

Securities 

1,540 
2,238 
6,666 

1,540 
2,680 
7,500 

10,445 

11,720 

1,529 
254 
80 

1,863 

11 
58 
922 

991 

- 
366 
992 

1,358 

- 
1,271 
3,571 

4,842 

- 
731 
1,935 

2,666 

Financial 
respect 
of 
instruments 

liabilities 

in 
derivative 

3 

3 

- 

- 

- 

3 

- 

As of December 31, 2022 

Predicted 

2025

  to  

2028

Book value 

cash flow 

H1/2023 

H2/2023 

2024 

2027 

onwards 

NIS millions 

Non-derivative financial liabilities 

Trade payables 

Loans  

Debentures 

1,566 

1,906 

8,142 

1,566 

2,194 

9,158 

1,542 

85 

105 

24 

50 

997 

11,614 

12,918 

1,732 

1,071 

 - 

141 

1,135 

1,276 

 - 

1,042 

4,705 

5,747 

 - 

876 

2,216 

3,092 

30.5.  Market risks 

The  purpose  of  market  risk  management  is  to  manage  and  monitor  the  exposure  to 
market risks within acceptable parameters to prevent significant exposures to market 
risks that will affect the Group's results, its obligations and its cash flow. 

As part of the Group's exposure management policy, it was decided to determine a mix 
of  debt  exposure  to  interest  and  linkage  as  well  as  to  reduce  exposure  to  foreign 
exchange.  Accordingly,  during  its  normal  business,  the  Group  performs  full  or  partial 
hedging  operations  and  takes  into  account  the  effects  of  the  exposure  in  its 
considerations in determining the type of loans it takes and in managing its investment 
portfolio . 

 
 
 
 
 
 
 
   
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

30.5.1. 

Risk of exposure to Consumer Price Index (inflation) and foreign currency 

Consumer Price Index risk (inflation) 
Changes in the Consumer Price Index rate affect the Group's profitability and 
its future cash flows, mainly due to its index-linked obligations. As part of the 
implementation  of  a  policy  to  reduce  index  exposure,  the  Group  executes 
trades against the index. The hedging transactions are executed against the 
settlement  schedules  of  the  hedged  debt.  The  Company  applies  hedge 
accounting to these forward contracts. 

A significant portion of cash balances is invested in shekel deposits that are 
exposed to changes in real value as a result of changes in the Consumer Price 
Index. 

Foreign currency risk 
The Group is exposed to foreign currency risks mainly due to payments for 
the purchase of end equipment and PP&E denominated or linked in part to 
the dollar and the euro. In addition, the Group provides services to customers 
and  receives  services  from  suppliers  around  the  world  in  foreign  currency, 
mainly in dollars. The Group's policy is to reduce as much as possible purchase 
agreements  in  foreign  currency,  as  well  as  to  partially  hedge  the  dollar 
exposure through forward contracts against the dollar and management of 
dollar deposits. 

 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

The following is a statement on the financial situation according to linkage bases as of December 31, 
2023: 

As of December 31, 2023 

Linked  to 
price 
index 
NIS 
millions 

Unlinked 
NIS 
millions 

Foreign 
currency  
or 
linked 
to  foreign 
currency 
(mainly 
dollars) 
NIS 
millions 

Non-
monetary 
balances 
NIS 
millions 

Total 
balances 
NIS 
millions 

593 
1,199 
1,430 
53 
1 
3,276 

275 
- 
- 
- 

8 
283 
3,559 

779 
11 
1,269 
329 
91 
2,479 

5,620 
30 
214 
- 
- 
29 
5,893 
8,372 

- 
44 
- 
39 
- 
83 

171 
- 
- 
- 

31 
202 
285 

295 
422 
77 
- 
- 
794 

2,209 
1,575 
- 
- 
- 
- 
3,784 
4,578 

51 
5 
47 
9 
- 
112 

- 
- 
- 
- 

- 
- 
112 

- 
- 
192 
3 
20 
215 

- 
3 
37 
3 
- 
- 
43 
258 

- 
- 
- 
65 
81 
146 

- 
1,870 
6,828 
3,280 

273 
12,251 
12,397 

- 
- 
220 
- 
- 
220 

- 
- 
- 
157 
322 
- 
479 
699 

644 
1,248 
1,477 
616  
82 
3,617 

446 
1,870 
6,828 
3,280 

312 
12,736 
16,353 

1,074 
433 
1,758 
332 
111 
3,708 

7,829 
1,608 
251 
160 
322 
29 
10,199 
13,907 

 )
4,813
(

 )
4,293
(

 )
(146

11,698 

2,446 

 )
1,197
(

700 

497 

- 

- 

Current assets 
Cash and cash equivalents 
investments 
Trade receivables 
Other receivables 
Inventory 
Total current assets 
Non-current assets 
Trade receivables 
Right-of-use assets 
PP&E 
Intangible assets 
Deferred  expenses  and  non-current 
investments 
Total non-current assets 
Total assets 
Current liabilities 
Debentures, loans and credit 
Current maturities of lease liabilities 
Trade payables 
Employee benefits 
Provisions 
Total current liabilities 
Non-current liabilities 
Loans and debentures 
Lease liabilities 
Employee benefits 
Derivatives and other liabilities 
Deferred tax liabilities 
Provisions 
Total non-current liabilities 
Total liabilities 

Total disclosure in the statement of 
financial position 
index  and  foreign 
The  scope  of 
currency risk hedging transactions is 
as follows: 
Forward contracts (see Note 30.6) 

 
 
         
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

The following is a statement on the financial situation according to linkage bases as of December 31, 
2022: 

As of December 31, 2022 

Linked  to 
price 
index 
NIS 
millions 

Unlinked 
NIS 
millions 

Foreign 
currency  
or 
linked 
to  foreign 
currency 
(mainly 
dollars) 
NIS 
millions 

Non-
monetary 
balances 
NIS 
millions 

Total 
balances 
NIS 
millions 

733 
911 
1,395 
174 
- 
3,213 

314 
- 
- 
- 

60 
374 
3,587 
286 
635 
17 
1,217 
396 
168 
2,433 

6,127 
87 
164 
- 
- 
37 
6,415 
8,848 

- 
40 
- 
75 
 -  
115 

140 
- 
- 
- 

29 
169 
284 
- 
286 
439 
16 
- 
- 
741 

2,130 
1,362 
- 
- 
- 
- 
3,492 
4,233 

21 
22 
45 
- 
- 
88 

6 
- 
- 
- 

- 
6 
94 
- 
- 
- 
193 
3 
- 
196 

- 
3 
37 
- 
- 
- 
40 
236 

- 
- 
- 
40 
85 
125 

- 
1,746 
6,542 
3,251 

226 
11,765 
11,890 
921 
- 
- 
172 
- 
- 
172 

- 
- 
- 
151 
319 
- 
470 
642 

754 
973 
1,440 
289 
85 
3,541 

460 
1,746 
6,542 
3,251 

315 
12,314 
15,855 

921 
456 
1,598 
399 
168 
3,542 

8,257 
1,452 
201 
151 
319 
37 
10,417 
13,959 

 )

5,261

(

 )

3,949

(

)

(142

11,248 

1,896 

 )

1,004

(

635 

369 

- 

- 

Current assets 
Cash and cash equivalents 
investments 
Trade receivables 
Other receivables 
Inventory 
Total current assets 
Non-current assets 
Trade receivables 
Right-of-use assets 
PP&E 
Intangible assets 
Deferred  expenses  and  non-current 
investments 
Total non-current assets 
Total assets 
Current liabilities 
Debentures, loans and credit 
Current maturities of lease liabilities 
Trade payables 
Employee benefits 
Provisions 
Total current liabilities 
Non-current liabilities 
Loans and debentures 
Lease liabilities 
Employee benefits 
Derivatives and other liabilities 
Deferred tax liabilities 
Provisions 
Total non-current liabilities 
Total liabilities 

635 

Total disclosure in the statement of 
financial position 
index  and  foreign 
The  scope  of 
currency risk hedging transactions is 
as follows: 
Forward contracts (see Note 30.6) 

 
 
        
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

30.5.2. 

Data regarding the Consumer Price Index: 

In  2023,  the  known  Consumer  Price  Index  increased  by  3.3%  (in  2022  an 
increase of 5.3% and in 2021 a decrease of 2.4%). 

30.5.3. 

Sensitivity analyzes in relation to the change in the Consumer Price Index to 
the change in the dollar exchange rate 

An increase/decrease of 1% in the Consumer Price Index at the time of the 
report would not have materially affected the net profit and equity. 

An increase/decrease of 10% in the dollar exchange rate at the time of the 
report would not have materially affected the profit and equity. 

30.5.4. 

Interest rate risk 

As  of  December  31,  2023,  the  exposure  to  interest  rate  risk  due  to  a 
commitment for debt instruments bearing variable interest is low. 

A. 

Interest type 
The  following  is  a  breakdown  of  the  type  of  interest  of  the  Group's 
interest-bearing financial instruments. 

Fixed interest instruments 
Financial 
customers) 
Financial liabilities (loans and debentures) 

deposits 

(mainly 

assets 

Book value 

2023 

2022 

NIS millions 

NIS millions 

and 

1,389 

 )
8,274
(

 )
6,885
(

1,673  

 )

8,544

(

 )

6,871

(

Variable interest instruments 
Financial assets (loans and debentures) 

 )
(699

)

(698

B.  Fair value sensitivity analysis regarding fixed interest instruments 

The Group’s fixed interest assets and liabilities are not measured at fair 
value  through  income.  Therefore,  a  change  in  interest  rates  on  the 
reporting date will not have any effect on income. 

C.  Cash flow sensitivity analysis regarding instruments with variable interest 

rates 

A  1%  increase/decrease  in  interest  rates  at  the  reporting  date  would 
have had a negligible effect on profit and equity. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

30.6.  Hedging 

30.6.1. 

Cash flow hedge accounting 

Bezeq entered into forward contracts, as detailed in the table below, for the 
purpose  of  reducing  exposure  to  changes  in  the  Consumer  Price  Index  for 
index-linked debentures. These transactions hedge a specific cash flow of a 
part of the debentures and are recognized in accounting as a cash flow hedge. 
The  expiration  date  of  these  transactions  corresponds  to  the  disposal 
schedules of the bonds they were intended to protect. The fair value of the 
forward contracts is determined by using observable market data (level 2 in 
the fair value hierarchy). 

Nominal 
value 

Fair value 

Equity 
principal 
balance 

Hedged item 

Repayment dates 

Transactio
ns 

NIS millions  NIS millions  NIS millions 

As  of  December  31, 
2023 
Debentures Series 10  12.2023
Debentures Series 12  6.2026

 to 

12.2025  

 to 

6.2030  

As  of  December  31, 
2022 
Debentures Series 10  12.2023 to 

12.2025  

Debentures Series 12  6.2026

 to 

6.2030  

30.6.2. 

Economic hedging 

2 
10 
12 

3 

6 

9 

150 
550 
700 

225 

310 

535 

8 
20 
28 

9 

22 

31 

3 
8 
11 

6 

14 

20 

A.  Bezeq is involved in forward transactions in order to reduce exposure to 
changes  in  the  dollar  exchange  rate.  The  net  fair  value  of  these 
transactions as of December 31, 2023 is an asset of approximately NIS 1 
million (in 2022 - an asset of approximately NIS 8 million). 

B.  Yes is involved in forward transactions in order to reduce their exposure 
to  changes  in  the  dollar  exchange  rate.  The  net  fair  value  of  these 
transactions as of 12.31.2023 is a liability of approximately NIS 1 million 
(as of December 31, 2022 an asset of approximately NIS 4 million). 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

30.7. 

Financial instruments measured at fair value 

30.7.1. 

The table below presents an analysis of the financial instruments measured 
at fair value: 

December 
2023 

31, 

December 
2022 

31, 

NIS millions 

NIS millions 

Level  1  -  Investment  in  marketable  securities  measured  at 
fair value through income 

Level 2 – Forward contracts (see Note 30.7.2) 
* Reclassified. 

759 

25 

 159*

 42  

30.7.2. 

The fair value of forward contracts on  the Consumer Price Index or foreign 
currency is based on discounting the difference between the price stated in 
the forward contract and the price of the current  forward contract for the 
remaining  period  of  the  contract  until  redemption,  using  an  appropriate 
interest  rate (level 2) .  The  evaluation is carried  out  under the assumption 
that a market participant takes into account the credit risks of the parties in 
the pricing of such contracts. 

30.8. 

Financial instruments measured at fair value for disclosure purposes only 

The table below details the differences between the book  value and the fair  value of 
financial liabilities. 

The fair  value of  public  debentures is determined according to their quoted purchase 
price at the close of trading, as of the reporting date (level 1). 

The  fair  value  of  non-traded  loans  and  debentures  is  measured  on  the  basis  of  the 
present  value  of  the  future  cash  flows  for  the  principal  and  interest  component, 
discounted according to the market interest rate appropriate for similar obligations plus 
the  required  adjustments  for  risk  premium  and  non-tradability  as  of  the  date  of  the 
statements (level 2). 

As of December 31, 2023 
Book  value 
(including 
accrued 
interest) 

Fair value 

Discount 
rate 
(weighted 
average) 

Book 
value 

Fair 
value 

As of December 31, 2022 

Discount 
rate 
(weighted 
average) 
% 

NIS millions 

% 

NIS millions 

from 

banks 

Loans 
institutional bodies (unlinked) 
Public 
(index-
debentures 
linked) 

and 

           1,546  

1,500  

4.31 

1,530 

1,462 

5.14 

           2,436  

2,387  

2.15 

2,402 

2,373 

1.82 

Public debentures (unlinked) 

           4,238  

4,148  

4.82 

4,569 

4,386 

4.95 

           8,220  

8,035  

8,501 

8,221 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
           
           
           
 
           
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

30.9.  Offsetting financial assets and financial liabilities 

The Group has agreements with various communication companies for the supply and 
receipt of communication services. According to some agreements, each party has the 
right to offset the amounts that each party owes. The table below shows the book value 
of offset balances as presented in the statement of financial position: 

December  31, 
2023 

December  31, 
2022 

NIS millions 

NIS millions 

Gross balance of trade and other receivables 

Offset amounts 
Balance of trade receivables presented in the statement of financial 
position 

Gross supplier balance 

Offset amounts 

68 

 )65( 

3 

73 

65 

Balance of suppliers presented in the statement of financial position 

8 

96  

)84( 

12  

98  

)84( 

14  

 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

31.  Summary  of  selected  data  from  the  statements  of  Bezeq  the  Israel 
Telecommunications  Corp.  Ltd.,  Pelephone  Communications  Ltd.,  Bezeq 
International Ltd. and Yes TV and Communications Services Ltd. 

31.1.  Bezeq the Israel Telecommunications Corp. Ltd. 

Data from the statement of financial position: 

Current property 

Non-current property 

Total property 

Current liabilities 

Non-current liabilities 

Total liabilities 

Equity   

Total liabilities and equity 

Data from the statement of income: 

Revenues 

Operating expenses 

Salaries 

Depreciation and amortization 

General and operating expenses 

Other operating expenses (income), net 

Total Operating expenses 

Operating profit 

Financing expenses (income) 

Financing expenses 

Financing income 

Financing expenses, net 

Profit after financing expenses, net 

Share in profits of investees, net 

Profit before income taxes 

Income taxes 

Profit for the year 

December 

31, 

December 

31, 

2023 

2022 

NIS millions 

NIS millions 

2,155 

9,226 

11,381 

2,317 

6,868 

9,185 

2,196 

11,381 

2,086  

10,002  

12,088  

2,148  

8,317  

10,465  

1,623  

12,088  

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

4,412 

4,306 

4,182 

1,028 

1,019 

769 

145 

2,961 

1,451 

370 

 )
(114

256 

1,195 

288 

1,483 

294 

1,189 

 970  

1,005  

 759  

 112  

2,846  

1,460  

 424  

(92)

 332  

1,128  

 151  

1,279  

 279  

1,000  

 934 

 938 

 667 

(105) 

 2,434 

 1,748 

 357 

(15) 

 342 

 1,406 

 120 

 1,526 

 343 

 1,183 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

31.2. 

Pelephone Communications Ltd. 

Data from the statement of financial position: 

Current property 

Non-current property 

Total property 

Current liabilities 

Non-current liabilities 

Total liabilities 

Equity   

Total liabilities and equity 

Data from the statement of income: 

Revenues 
Revenues from services 
Revenues from sale of end equipment 

Total revenues from services and sales 

Operating expenses 

General and operating expenses 
Salaries 

Depreciation and amortization 

Total operating expenses 

Other operating expenses, net 

Operating profit 

Financing expenses (income) 

Financing expenses 

Financing income 

Financing income, net 

Profit before income taxes 

Income taxes 

Profit for the year 

December 

31, 

December 

31, 

2023 

2022 

NIS millions 

NIS millions 

722 

2,110 

2,832 

659 

789 

1,448 

1,384 

2,832 

865  

3,215  

4,080  

684  

879  

1,563  

2,517  

4,080  

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

1,756 

592 

2,348 

1,278 

323 

549 

2,150 

2 

196 

35 

 )48( 

 )13( 

209 

50 

159 

1,791 

608 

2,399 

1,327 

314 

532 

2,173 

33 

193 

42 

)68( 

)26( 

219 

54 

165 

1,642 

647 

2,289 

1,346 

315 

577 

2,238 

9 

42 

23 

)65( 

)42( 

84 

20 

64 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

31.3. 

Bezeq International Ltd. 

Data from the statement of financial position: 

December 

31, 

December 

31, 

2023 

2022 

NIS millions 

NIS millions 

406 

594 

1,000 

391 

388 

779 

221 

1,000 

396  

364  

760  

431  

139  

570  

190  

760  

Current property 

Non-current property 

Total property 

Current liabilities 

Non-current liabilities 

Total liabilities 

Equity   

Total liabilities and equity 

Data from the statement of income: 

Revenue 
Operating expenses 

Operating, general and depreciation expenses 

Salaries 

Depreciation, amortization and impairments 

Other operating expenses, net 
Total operating expenses 

Operating profit (loss) 
Financing expenses (income) 
Financing expenses 

Financing income 

Financing expenses, net 

Profit (loss) before income taxes 
Income taxes 

Profit (loss) for the year 

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

1,212 

 1,239 

 1,237 

800 

216 

137 

20 

827 

237 

 134 

 71 

 799 

 237 

 173 

 6 

1,173 

 1,269 

 1,215 

39 

17 

 )7( 

10 

29 

- 

29 

(30) 

9 

)8( 

1 

(31) 

 1 

(32) 

 22 

 5 

(3) 

 2 

 20 

 12 

 8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
   
   
 
   
   
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

31.4.  Yes TV and Communications Services Ltd. (Yes) 

Data from the statement of financial position: 

December 

31, 

December 

31, 

2023 

2022 

NIS millions 

NIS millions 

235 

283 

518 

385 

60 

445 

73 

518 

196  

241  

437  

395  

74  

469  

)32( 

437  

Year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

1,309 

1,277 

1,270 

Current property 

Non-current property 

Total property 

Current liabilities 

Non-current liabilities 

Total liabilities 

Equity (deficit in equity)   

Total liabilities and equity (deficit in equity) 

Data from the statement of income: 

Revenues 
Operating expenses 

Operating, general and depreciation expenses 

Salaries 

Depreciation, amortization and impairments 

Other operating expenses (income), net 
Total operating expenses 

861 

193 

166 

(5) 

867 

200 

199 

3 

835 

188 

203 

12 

1,215 

1,269 

1,238 

Operating profit 
Financing expenses (income) 
Financing expenses 

Financing income 

Financing expenses (income), net 

Profit before income taxes 

Income taxes 

Profit for the year 

94 

8 

 )17( 

 )9( 

103 

1 

102 

8 

8 

)14( 

)6( 

14 

1 

13 

32 

4 

)3( 

1 

31 

1 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Consolidated Statements as of December 31, 2023 

32.  Material events during and after the reporting period 

32.1. 

Regarding  additional  purchase  of  Bezeq  subsidiary  shares  by  the  Company  after  the 
balance sheet date, see Note 12.6. 

32.2.  On January 25, 2024, Bezeq's Board of Directors approved Bezeq's entry into the field 
of  electricity  supply  and  Bezeq's  engagement  with  PowerGen  Ltd.  ("PowerGen"),  a 
company wholly owned by Generation Capital Ltd., which coordinates the fund’s energy 
in  a  non-binding  memorandum  of  understanding  regarding  strategic 
activities, 
cooperation  and  the  establishment  of  a  joint  venture  in the  field  of  electricity  supply 
("the MOU"). 

32.3. 

See Note 12.7 above regarding the decision of Bezeq’s Board of Directors dated March 
13, 2023 regarding Bezeq's dividend distribution policy and the resolution of the Bezeq 
Board of Directors to recommend to the Bezeq general assembly on the distribution of a 
dividend. 

32.4. 

Regarding the approval of another plan for the buyback of the Company's shares from 
March 12, 2024, see Note 20.1.3. 

 
 
 
 
 
 
Separate Financial Information for the Year Ended 
December 31, 2023 

 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
Separate Financial Information as of December 31, 2023 

Table of Contents 

Auditors' report 

Separate Financial Information 

Statement of Financial Position 

Income Statement  

Cash Flow Statement 

Notes to Separate Financial Information 

Page 

2 

3 

4 

5 

6 

 
 
 
 
 
 
 
 
 
Somekh Chaikin 
KPMG Millennium Tower  
17 HaArbaa Street P.O.B. 609 
Tel Aviv 6100601 
03 684 8000 

To 
Shareholders of B Communications Ltd. 

Dear Sir / Madame, 
Re:  Special  report  of  the  auditors  on  separate  financial  information  under  Regulation  9C  of  the  Securities  Regulations 
(Periodic and Immediate Reports), 5730-1970 

We audited the separate financial information presented in accordance with Regulation  38D of the Securities Regulations 
(Periodic and Immediate Reports), 5730-1970 of B. Communications Ltd. (hereinafter – “the Company") as of December 31, 
2023  and  2022  and  for  each  of  the  three  years  the  last  of  which  ended  on  December  31,  2023.  The  separate  financial 
information  is  within  the  responsibility  of  the  Company's  Board  of  Directors  and  Management.  It  is  our  responsibility  to 
provide an opinion on the separate financial information for said based on our review. 

We  conducted  our  audit  in  accordance  with  auditing  standards  accepted  in  Israel.  According  to  these  standards,  we  are 
required  to  plan  and  perform  the  audit  in  order  to  obtain  a  reasonable  degree  of  assurance  that  the  separate  financial 
information is not materially misrepresented. An audit includes a sample examination of evidence supporting the amounts 
and  details  included  in  the  separate  financial  information.  An  audit  also  includes  an  examination  of  the  accounting  rules 
applied in preparing the separate financial information and of the significant estimates made by the Company's Board of 
Directors  and  Management,  as  well  as  an  assessment  of  the  adequacy  of  the  presentation  of  the  separate  financial 
information. We believe that our audit and the other auditors' reports provide an adequate basis for our opinion. 

In  our  opinion,  based  on  our  audit,  the  separate  financial  information  has  been  prepared,  in  all  material  respects,  in 
accordance with the provisions of Regulation 9C of the Securities Regulations (Periodic and Immediate Reports), 5730-1970. 

Without limiting our above opinion, we draw attention to what is stated in Note 1 which refers to Note 1.3 to the consolidated 
statements, regarding the investigation by the Securities Authority and the Israel Police of a suspicion of committing offenses 
under the Securities Law and the Penal Code concerning, inter alia, transactions related to the former controlling shareholder 
and the transfer of the investigation file to the District Attorney's Office, and what is stated in this note regarding the filing of 
indictments against the former controlling shareholder in the Company in various offenses, among other things, for offenses 
of bribery and causing a misleading detail in immediate reporting, and regarding the filing of an indictment against the former 
controlling shareholder of the Company and former senior officers of the Bezeq Group, which attributes to the defendants 
obtainment by fraud, and reporting offenses under the Securities Law. Also, following the opening of the aforementioned 
investigation, a number of civil legal proceedings were opened against the Company, former officers of the Company, as well 
as companies from the group that previously controlled the Company, including motions for the approval of class actions. As 
stated in the above note, the Company is unable to assess the effects of the investigations, their findings and results on the 
Company as well as on the statements and estimates used in the preparation of these reports, if any. 

In addition, without limiting our above opinion, we draw attention to what is stated in Note 17 to the Company’s consolidated 
statements  regarding  claims  filed  against  Group  companies,  which  cannot  be  estimated  or  for  which  the  exposure 
cannot yet be calculated.  

Somekh Chaikin 
Certified Public Accountants 

March 12, 2024 

Somekh Chaikin, Israeli partnership and a member of the KPMG network of independent firms incorporated  u n d e r  
t h e   Swiss entity K P M G   I n t e r n a t i o n a l   C o o p e r a t i v e   ( " K P M G   I n t e r n a t i o n a l " )  

2 

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
Separate Financial Information as of December 31, 2023 

Separate Statement of Financial Position as of December 31, 

Assets 

Cash and cash equivalents 

Short-term investments and deposits 

Other receivables 

Total current assets 

Long-term deposits 

Investment in equity-accounted investee 

Total non-current assets 

Total assets  

Liabilities 

Payables and credit balances 

Provisions 

 Total current liabilities 

Debentures  

Total non-current liabilities 

2023 

2022 

Note 

NIS millions 

NIS millions 

3 

4 

5 

6 

7 

81 

43 

3 

127 

8 

2,022 

2,030 

2,157 

8 

20 

28 

1,940 

1,940 

13 

63 

1 

77 

27 

1,864 

1,891 

1,968 

9 

- 

9 

1,905 

1,905 

Total liabilities 

1,968 

1,914 

Shareholders' equity 

8 

189 

54 

Total liabilities and shareholders' equity 

2,157 

1,968 

Darren Glatt 
Chairman of the Board of Directors 

Tomer Raved 
CEO 

Itzik Tadmor 
CFO 

Date of approval of the financial statements: March 12, 2024 

The notes attached to the financial information constitute an integral part thereof. 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Separate Financial Information as of December 31, 2023 

Income Statement for the year ended December 31 

2023 

2022 

2021 

Note 

NIS millions 

NIS millions 

NIS millions 

Operating expenses 

Salaries 

General and operating expenses  

Other expenses 

Total operating expenses 

Operating loss 

Financing expenses (income) 

Financing expenses 

Financing income 

Financing expenses, net 

6 

9 

Loss after financing expenses, net 

in  net  profit  of  equity-accounted 

Share 
investee 

Net profit for the year  

Comprehensive income for the year ended December 31 

4 

7 

19 

30 

(30 )

110 

(5 )

105 

 )
135

(

322 

187 

5 

7 

- 

12 

(12)

106 

(9)

97 

5 

8 

- 

13 

(13)

184 

(10)

174 

)

(109

)

(187

267 

158 

316 

129 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

Net profit for the year 

Other comprehensive income, net of tax 

Total comprehensive income for the year 

187 

3 

190 

158 

13 

171 

129 

10 

139 

The notes attached to the financial information constitute an integral part thereof. 

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Separate Financial Information as of December 31, 2023 

Cash Flows Statement for the year ended December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

Cash flows from current activity 

Net profit for the year 

Adjustments to profit: 

Share in profits of equity-accounted investee, net 

Financing expenses, net 

Share-based compensation 

Change in trade payables 

Change in other receivables 

Change in provisions 

Net cash used for current activities 

Cash flows from investing activities 

Change in deposits and investments, net 

Investment in an affiliate 

Dividend received from subsidiary 

Interest and dividend received in cash 

Net cash derived from investing activities 

Cash flows from financing activities 

Issuance of debentures 

Repayment of debentures  

Buyback of shares 

Interest paid 

Early repayment fees 

Net cash used for financing activities 

Increase (decrease) in cash and cash equivalents 

Effect of changes in foreign currency exchange rate 

Cash and cash equivalents at the beginning of the period 

Cash and cash equivalents at the end of the period 

(*) Amount lower than NIS 1 million. 

187 

(322)

106 

* 

(1)

(3)

20 

(13)

40 

(37)

172 

4 

179 

500 

(497)

(23)

(76)

- 

(96)

70 

(2)

13 

81 

158 

(267)

49  

1 

2 

3 

- 

(9)

163 

(15)

143 

2 

293 

- 

(100)

(121)

(75)

- 

(296)

(12)

- 

25 

13 

129 

(316)

174 

- 

- 

10 

- 

(3)

66 

- 

- 

1 

67 

1,035 

(511,0)

(16)

(79)

(19)

(49)

(30) 

- 

55 

25 

The notes attached to the financial information constitute an integral part thereof

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Separate Financial Information as of December 31, 2023 

1.  General 

The  following  are  financial  data  from  the  Group's  consolidated  statements  as  of  December  31,  2023 
(hereinafter - "Consolidated Statements"), which are published as part of the periodic reports, attributed 
to  the  company  itself  (hereinafter  -  "Separate  Financial  Information"),  presented  in  accordance  with 
Regulation 9C (hereinafter - "the Regulation" ) and the tenth schedule (hereinafter – “the Tenth Schedule") 
to  the  Securities  Regulations  (Periodic  and  Immediate  Reporting),  5730-1970  regarding  the  separate 
financial information of the corporation. 

The separate financial information should be read together with the Consolidated Statements. 
In this separate financial information - 

"The Company" - "B Communications Ltd." 

"Included Company", "consolidated company", "the Group", "Investee", "related party": as these terms 
are defined in the Group’s 2023 Consolidated Statements. 

Regarding the investigation by the Securities Authority and the Police, see Note 1.3 to the Consolidated 
Statements. 

2.  Explanation  of  the  main  accounting  policies  applied  in  the  separate 

financial information 

The  accounting  policy  rules  detailed  in  the  Consolidated  Statements  were  consistently  applied  to  all 
periods presented in the separate financial information by the Company, including the manner in which 
the financial data  was classified within the  Consolidated Statements with the changes  required by the 
following: 

2.1.  Presentation of financial data 

The  data  on  the  financial  position,  revenue,  comprehensive  profit,  and  cash  flows  include 
information contained in the Consolidated Statements and attributed to the Company itself. The 
investment balances and the results of the operations of investees are handled according to the 
balance sheet value method. 

2.2.  New standards implemented during the period of the report 

Regarding  new  standards  implemented  during  the  reporting  period,  see  Note  3.14  to  the 
Consolidated Statements. 

6 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Separate Financial Information as of December 31, 2023 

3.  Short-term investments and deposits 

Investments in marketable securities 
Short-term deposits (1) 

* Reclassified 

(1) The deposits are due until December 2024. 

December 31, 2023 

December 31, 2022 

NIS millions 
14 
29 

43 

NIS millions 
8 
55* 

63 

4.  Consolidated companies 

Consolidated companies directly held by the Company: 

Company rights in equity 

Investment 
consolidated 
in 
company  (according  to  balance 
sheet value method) as of 

December  31, 
2023 
% 

December  31, 
2022 

December  31, 
2023 

December  31, 
2022 

% 

NIS millions 

NIS millions 

Bezeq 

%08.72

26.81% 

2,02  
2

2,02  
2

1,864 

1,864 

4.1. 

Investment in Bezeq 

A.  On December 28, 2022, the Company purchased 2,530,000 ordinary shares of the subsidiary 
Bezeq in a total amount of approximately NIS 15 million and at an average price of NIS 5.95 
per share. After the aforementioned purchase, the Company held 26.81% of the issued share 
capital and voting rights in Bezeq. 

B.  During the second quarter of 2023, the Company purchased 7,807,995 ordinary shares of 
the subsidiary Bezeq for a total amount of approximately NIS 37 million and at an average 
price of NIS 4.71 per share. After the aforementioned purchase, the Company held 27.08% 
of the issued share capital and voting rights in Bezeq. 

C.  On  January  31,  2024,  after  the  balance  sheet  date,  the  Company  purchased  3,120,000 
ordinary  shares  of  the  subsidiary  Bezeq  in  exchange  for  payment  of  a  total  amount  of 
approximately  NIS  15  million  and  at  an  average  price  of  NIS  4.82  per  share.  After  the 
aforementioned purchase and as of the date of the financial statements, the Company holds 
27.19% of the issued share equity and voting rights in Bezeq. 

4.1.  Bezeq’s dividend distribution policy 

On March 12, 2024, Bezeq’s Board of Directors decided to update Bezeq's dividend policy so that 
Bezeq will distribute every six months 70% of the semi-annual profit (after tax), according to its 
consolidated statements, starting with the next distribution (for the second half of 2023), this is 
in view of the improvement trend in the business results, and the continued decrease in the scope 
of its debt, and in accordance with its forecasts regarding its business results for the coming years. 

7 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Separate Financial Information as of December 31, 2023 

4.  Consolidated companies (Cont.) 

Also, Bezeq will strive to increase its dividend policy in the future, subject to maintaining its credit 
rating in the AA group. 

The implementation of the dividend distribution policy is subject to the provisions of any law, 
including  the  distribution  tests  set  forth  in  the  Companies  Law,  all  taking  into  account  the 
expected cash flow, Bezeq's needs and obligations, Bezeq's cash balances, plans, and condition, 
as they will be from time to time and subject to the approval of the general assembly of Bezeq's 
shareholders regarding any specific distribution, as stipulated in Bezeq regulations. 

The approval of Bezeq's dividend policy does not oblige Bezeq to distribute a dividend to Bezeq's 
shareholders, and each specific distribution will be examined individually in accordance with the 
conditions of implementation of the dividend distribution policy as stated above. In addition, the 
approval  of  the  aforementioned  policy  does  not  prevent  Bezeq’s  Board  of  Directors  from 
periodically reviewing the dividend distribution policy to Bezeq shareholders, taking into account, 
among other things, the provisions of the law, Bezeq's business situation and its plans and its 
equity structure, and while maintaining a balance between ensuring Bezeq's financial strength 
and  stability,  including  its  debt  level  and  credit  rating,  and  continuing  to  maximize  value  for 
Bezeq's shareholders through regular dividend distribution. 

Bezeq's  Board  of  Directors  considers  it  important  to  maintain  the  balance  between  ensuring 
Bezeq's financial strength and stability, while maintaining a rating in Bezeq's current rating group 
[AA] over time and continuing to maximize value for its shareholders through regular dividend 
distribution. 

Bezeq's Board of Directors was presented, among other things, with Bezeq's and Bezeq Group's 
forecasts,  as  well  as  sensitivity  analyses  for  unexpected  adverse  events  in  Bezeq's  and  Bezeq 
Group's  businesses.  After  Bezeq’s  Board  of  Directors  examined  all  of  the  above,  the  Board  of 
Directors  determined  that  this  decision  reflects  the  correct  balance  between  these  needs  as 
described above. 

4.1.  Dividend distribution by Bezeq 

A.  On  April  20,  2023,  the  general  assembly  of  Bezeq's  shareholders  (following  the 
recommendation  of  the  Bezeq’s  Board  of  Directors  of  March  13,  2023)  approved  the 
distribution of a cash dividend to Bezeq's shareholders in the total amount of NIS 246 million 
(which, as of the day determining the distribution, constitutes NIS 0.088922 per share). The 
dividend was paid on May 16, 2022. The Company's share of the aforementioned dividend is 
approximately NIS 66 million. 

B.  On  September  14,  2022,  the  general  assembly  of  Bezeq's  shareholders  (following  the 
recommendation  of  the  Bezeq  Board  of  Directors  of  August  8,  2023)  approved  the 
distribution of a cash dividend to Bezeq's shareholders in a total amount of NIS 392 million 
(which, as of the day determining the distribution, is 0.1416805 NIS per share). The dividend 
was  paid  on  October  11,  2023.  The  Company's  share  of  the  aforementioned  dividend  is 
approximately NIS 106 million. 

C.  On March 12, 2023, the Bezeq Board of Directors recommended to the general assembly of 
Bezeq's shareholders to distribute a cash dividend to Bezeq's shareholders in a total amount 
of NIS 374 million. As of the date of approval of the Statements, the aforementioned dividend 
has not yet been approved by Bezeq's general assembly. The Company's expected share of 
the aforementioned dividend (if approved by Bezeq’s general assembly) is approximately NIS 
102 million. 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Separate Financial Information as of December 31, 2023 

5.  Trade payables 

Trade and other payables 

Interest payable 

6.  Contingent liabilities 

December 31, 2023 

December 31, 2022 

NIS millions 

NIS millions 

2 

6 

8 

3 

6 

9 

On May 23, 2023, the Company signed a settlement agreement in the amount of approximately USD 5.5 
million in respect of two motions for the approval of class actions filed in June 2017, among other things, 
against the Company, Bezeq, officers in the Bezeq Group, as well as companies from the then controlling 
group of the company and Bezeq regarding the purchase transaction of Yes shares By Bezeq from Eurocom 
DBS  Ltd.  The  settlement  amount  does  not  include  offsetting  the  insurance  company's participation  by 
virtue of the officers' insurance. 

At this stage, the settlement agreement has been submitted to the District Court in Tel Aviv (Economic 
Department) for approval, and it is uncertain that it will be approved. To the extent that the settlement 
agreement  is  approved,  this  will  end  the  involvement  of  the  Company  and  Shaul  Elovich  (only  in  his 
capacity as controlling  shareholder and former  Chairman of the  Company's  Board of  Directors) and Or 
Elovich (in his capacity as a former director in the Company only) in the motions for approval. 

The provision in the Company's books for the aforementioned settlement minus the expected receipt from 
the insurance company in the amount of approximately NIS 19 million was credited to other expenses in 
the income statement in the second quarter of 2023. 

See also Note 17 in the Company's consolidated financial statements. 

7.  Debentures 

December 31, 2023 

December 31, 2022 

Carrying amount  
NIS millions 

Par value 
NIS millions 

Carrying amount 
NIS millions 

Par value 
NIS millions 

Debentures issued to the public: 
Debentures Series C 
Debentures Series F 

Total debentures 

- 
1,940 

1,940 

- 
2,010 

2,010 

480 
1,425 

1,905 

497 
1,472 

1,969 

7.1. 

7.2. 

On January 10, 2022, the Company made an exchange of approximately NIS 417 million par value 
in  series  C  debentures  in  exchange  for  approximately  NIS  432  million  par  value  in  series  F 
debentures. 

On June 30, 2022, the Company made a partial early repayment of approximately NIS 100 million 
par value in Series C debentures (plus accrued interest up to the maturity date). 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Separate Financial Information as of December 31, 2023 

7.3. 

7.4. 

During  the  third  quarter  of  2022,  B  Communications  2  Limited  Partnership  transferred  to  the 
Company the balance of the Company's Series C debentures, which were held by it in the amount 
of approximately NIS 10 million. After the debentures were transferred to the Company, the said 
debentures  were  withdrawn  from  the  Stock  Exchange  clearinghouse  and  delisted  from  the 
trading cycle. 

On June 22, 2023, the Company issued to institutional entities and the public approximately NIS 
538  million  in  series  F  debentures  for  a  net  of  approximately  NIS  500  million  (after  issuance 
expenses).  The  net  proceeds  of  the  issuance  of  the  series  F  debentures  were  used  by  the 
Company for early full and final repayment of the balance of series C debentures (plus accrued 
interest up to the maturity date) on July 20, 2023. 

7.5. 

For more details, see Note 13 to the Consolidated Statements. 

8.  Shareholders’ equity 

Ordinary shares of NIS 0.1 par value 

Registered share capital 

Issued and paid-up share capital 

Treasury shares 

Issued and paid-up share capital, net 

Ordinary shares 

December 31, 2023  December 31, 2022 

300,000,000 

300,000,000 

116,335,793 
 )
10,673,530
(

105,662,263 

116,335,793 
 )
9,080,317

(

107,255,476 

8.1. 

8.2. 

8.3. 

During the year 2022, the Company purchased a total of 7,603,514 of its shares as part of buyback 
plans for a total amount of approximately NIS 121 million. 

On August 8, 2023, the Company's Board of Directors approved a buyback plan of the Company's 
shares up to NIS 30 million. As part of the aforementioned buyback plan, the Company purchased 
1,593,213 of its shares for approximately NIS 23 million. 

On March 12, 2024, the Company's Board of Directors approved an additional buyback plan of 
the Company's shares in the amount of up to NIS 25 million, which will begin on March 13, 2024 
and end: (1) upon purchase in the amount of NIS 25 million; or (2) on June 30, 2024, whichever 
is earlier. 

8.4. 

As of December 31, 2023, Searchlight and the Forer family held 66.24% and 12.54%, respectively, 
of the Company's issued and paid-up share capital. 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Separate Financial Information as of December 31, 2023 

9.  Financing expenses 

Year 

ended 

Year 

ended 

Year 

ended 

December 31 

December 31 

December 31 

2023 

2022 

2021 

NIS millions 

NIS millions 

NIS millions 

98 
- 

8 
- 
106 

2 

- 
7 
9 

97 

165 
- 

- 
19 
184 

3 

7 
- 
10 

174 

Interest expenses 
Exchange rate differences 
Change  in  fair  value  of  financial  assets 
measured at fair value through income 
Early repayment fees 
Total financing expenses 

108 
2 

- 
110 

Profits from investments in marketable 
securities and bank deposits 

Change  in  fair  value  of  financial  assets 
measured at fair value through income 
Income from debenture exchange 
Total financing income 

Financing expenses. Net 

10.  Income tax 

4 

1 
- 
5 

105 

The Company has final tax assessments until 2018. 

11.  Share-based compensation 

During  the  year  2022,  the  Company  allocated  3,350,000  options  exercisable  into  3,350,000  ordinary 
Company shares to Company officers. The vesting period of the options granted to the Company's officers 
is 3 years. 

Salaries expenses recognized by the Company for share-based compensation: 

Year ended December 31 

2023 

2022 

2021 

NIS thousands  NIS thousands  NIS thousands 

Salaries expenses 

400 

520 

280 

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to Separate Financial Information as of December 31, 2023 

12.  Liquidity risk 

The  following  are  the  forecasted  repayment  dates  of  financial  liabilities,  including  interest  payment 
estimate (based on the interest data know as of December 31, 2023): 

December 31, 2023 

Carrying 
amount 

Contractual 
cash flow 

Q1/2024 

Q2/2024 

2025 

2026 

NIS millions 

Non-derivative financial commitments 
Trade and other payables 
Debentures 
Total 

8 
1,94  
0
1,94  
8

8 
2,223 
2,231 

8 
31 
39 

- 
36 
36 

- 
73 
73 

- 
2,083 
2,083 

13.  Events during and after the reporting period 

13.1. 

13.2. 

13.3. 

13.4. 

13.5. 

Regarding the additional purchase of shares of the subsidiary Bezeq by the Company after the 
balance sheet date, see Note 4.1. 

Regarding  the  investigation  by  the  Securities  Authority  and  the  police,  see  Note  1.3  to  the 
Consolidated Statements. 

For information regarding the decision of the Bezeq Board of Directors dated March  12, 2024 
regarding the update of Bezeq's dividend distribution policy and the decision of the Bezeq Board 
of Directors to recommend to the Bezeq general assembly on the distribution of a dividend, see 
Note 4.3. 

Regarding the approval of another plan for the buyback of the Company's shares from March 12, 
2024, see Note 8.3. 

For information regarding material events during and after the reporting period, see Note 32 to 
the Consolidated Statements. 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

  Chapter D

Additional Details about the Corporation 
and Corporate Governance Questionnaire 

for the Period ended December 31, 2023 

- 1-

Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Regulation 10a: Condensed statements of consolidated quarterly income for each of 
the quarters in the reported year  
See Section 1.3 of the Board of Directors’ report attached in the second part of this 
report.  

Regulation 10c: Use of proceeds from securities  
According to the Company's shelf prospectus dated January 7, 20211, on June 22, 2023 
(Ref.: 2023-01-007660), the Company published a shelf offer report for the issuance 
and registration of up to NIS 621,520,000 par value debentures (series 6), by way of 
expansion of a traded series that was issued for the first time according to a shelf offer 
report  dated  July  5,  2021.  The  total  (gross)  expected  proceeds  from  the 
aforementioned  offer  is  in  the  amount  of  approximately  NIS  504  million,  and  the 
Company intends to use the proceeds from the issue for partial or full early repayment 
of  the  debentures  (series  C)  of  the  Company.  On  June  22,  2023,  the  Company 
announced that upon the completion of the issuance of the Company’s debentures 
(series 6) as mentioned above, the Company will make a full early redemption of the 
debentures  (series  3)  and  that the  redemption will  be  carried  out on  July  20,  2023 
(Ref.:  2023-  01-058786).  For  more  details  about  the  expansion  of  the  Company's 
debentures (series 6) and early redemption of the Company's debentures (series 3), 
see Regulation 20 below. 

Regulation 11: List of investments in subsidiaries as of the date of the statement of 
the financial position 

Company 
Name 

Name of 
holder 

Share 
type 

Number of 
shares held 

Total par 
value 

Rate of 
holding 
of  the 
issued 
capital 
and 
voting 
rights 

Rate of 
holding of   
the right 
to appoint 
directors 

Value in the 
Company's 
separate 
financial 
statement 
(NIS 
millions) 

The 
Company 

Ordinary 
NIS 1 par 
value 

Bezeq the 
Israel 
Telecommunic
ations 
Corporation 
Ltd. ("Bezeq") 

752,411,708 

752,411,708  27.19% 

27.19% 

2,022 

1 Which was extended until January 7, 2024, as published in the Company's immediate report dated 
February 13, 2023, (Ref.: 2023-01-016701), which is included in this report by way of reference. 

- 2-

  
 
 
 
 
 
 
 
 
 
 
 
 
Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Regulation 12: Changes in investments in subsidiaries during the reported period 

A.  On April 3, 2023, the Company purchased 2,100,000 ordinary shares of NIS 1 par 
value of Bezeq, in transactions during trading on the stock exchange, in exchange 
for payment of a total amount of approximately NIS 10 million and at an average 
price of NIS 4.75 per Bezeq share. 

B.  On May 28, 2023, the Company purchased 1,417,995 ordinary shares of NIS 1 par 
value  of  Bezeq,  as  part  of  stock  exchange  trading  transactions,  in  exchange  for 
payment of a total amount of approximately NIS 6.8 million and at an average price 
of 4.77 per Bezeq share. 

C.  On May 30, 2023, the Company purchased 2,090,000 ordinary shares of NIS 1 par 
value  of  Bezeq,  as  part  of  stock  exchange  trading  transactions,  in  exchange  for 
payment of a total amount of approximately NIS 10 million and at an average price 
of 4.79 per Bezeq share. 

D.  On June 28, 2023, the Company purchased 1,100,000 ordinary shares of NIS 1 par 
value  of  Bezeq,  as  part  of  stock  exchange  trading  transactions,  in  exchange  for 
payment of a total amount of about NIS 5 million and at an average price of 4.542 
per Bezeq share. 

E.  On January 31, 2024, the Company purchased 3,120,000 ordinary shares of NIS 1 
par value of Bezeq, as part of stock exchange trading transactions, in exchange for 
payment of a total amount of approximately NIS 15 million and at an average price 
of 4.82 per Bezeq share. 

Regulation 13: Revenue of subsidiaries and revenue of the corporation therefrom as 
of the date of the statement of financial position (NIS millions)  
Profit for the period  Comprehensive 
Company name 

Dividend  Management 

Bezeq 

1,189 

profit for the 
period 
1,201 

638 

fee  

- 

Interest 
revenue  

- 

Regulation 20: Trading on the stock exchange  
On June 22, 2023, the Company issued 538,000,000 par value debentures (series 6), 
according to a shelf offer report, in exchange for NIS 503,568,000. The proceeds of the 
net  issuance  of  the  debentures  (series  6)  were  used  by  the  Company  for  full  early 
redemption of debentures (series C), as detailed below. 
On July 20, 2023, the company made a full early redemption of the bonds (series C). 
For more details, see immediate reports published by the company on June 22, 2023 
and July 20, 2023 (Refs.: 2023-01-058351 and 2023-01-068611, respectively), which 
are included in this report by way of reference. 

- 3-

  
 
 
 
 
 
 
Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Regulation 21: Compensation for related parties and senior officers 
The following is a breakdown of the compensation paid by the Company, or paid by 
the companies under its control (including commitments to provide  compensation), 
during  the  year  2023:  (1)  to  each  of  the  five  holders  of  the  highest  compensation 
among the senior officers in the Company or in the companies under its control, and 
which  were  given  to  them  in  connection  with  their  office  in  the  Company  or  in  a 
company under its control , whether the payments were made by the Company or by 
a  company  under  its  control or  whether by  another;  and  (2)  rewards  for  the three 
senior officers with the highest compensation in the Company itself, which were given 
to them in connection with their office in the Company. 

Details of compensation persons 

Compensation (NIS thousands) 

Total 
(NIS 
thousands) 

Section 
below 

Name 

Position 

Sex 

Job 
volume 

Tomer Raved 
Itzik Tadmor 

Ilan Chaikin 

Gil Sharon5 

Ran Guron6 
Directors 

CEO4 
CFO 
Internal 
auditor 
Bezeq 
Chariman 
Bezeq CEO 
Director 

Male 
Male 
Male 

Male 

Full-time 
Full-time 

Full-time 

Full-time 

Male 
- 

Full-time 
Full-time 

Holding 
rate in 
the 
corporati
on equity 
- 
- 

- 

- 

- 
- 

Salary2 

Bonus3 

Share-
based 
payment 

Other 

Total 

1,454 
708 
56 

410 
264 
- 

384 
16 
- 

2,421 

2,228 

765 

2,639 
908 

2,099 
- 

879 
- 

381 
- 
- 

- 

- 
- 

2,629 
987 
56 

3,884 

5,617 
908 

A 
B 

C 

D 

E 
F 

2 Regarding senior executives at Bezeq, wage amounts include the cost of wages (employer cost) and the ancillary 
wage components, including benefits and social conditions, such as coverage of telephone expenses, a personal 
vehicle  of  the  type  customary  in  the  Group  (cost  of  leasing  or  depreciation  expenses  and  reimbursement  of 
expenses instead of using a company vehicle), study fund (for some of the managers), deposit in a pension fund and 
deposits  due  to  termination  of  employee-employer  relationship  (for  employees  subject  to  Article  14  of  the 
Compensation  Law),  reimbursement  of  expenses  and  quota  of  vacation  days,  sick  and  annual  convalescence  as 
customary,  expenses  for  holiday  gift  to  employee  (grossing  amount),  fees  for  membership  in  professional 
organizations paid for the employee (outside the employee's occupation) and also, to the extent that a loan was 
made to the employee - the value of the grossing benefit in the interest that the loan bears.  
3   Regarding  senior  executives  at  Bezeq  ,  the  bonus  amounts  listed  in  the  table  are  as  recognized  in  the  2023 
statements and include a performance-dependant bonus as well as special bonuses (for details regarding each of 
the officers see details in sections D-E after the table below), all in accordance with Bezeq’s compensation policy. 
The  performance-dependent  bonus  that  appears  in  the  table  is  for  the  year  2023  (but  not  yet  paid  to  senior 
executives  as  of  the  date  of  the  report)  and  includes  a  contingent  portion  that  will  be  paid  in  practice  to  the 
aforementioned  Bezeq  officers  according  to  the  distribution  described  in  the  notes  to  the  table.  During  2023, 
bonuses were paid to the above officers for 2022, the amount of which [including a contingent portion not paid in 
practice  in  2022,  but  paid  in  practice  in  2024  (if  any)  is  included  in  the  corresponding  table  in  Bezeq’s  annual 
statements for 2021 (as published on March 23, 2022). 
4 As of January 1, 2024, he also serves as the Chairman of Bezeq's Board of Directors. For more details, see 
immediate report published by the Company (Ref.: 2023-01-110518). 
5 Ceased to serve as chairman of Bezeq's Board of Directors as of January 1, 2024. For more details, see 
immediate report published by Bezeq (Ref.: 2024-01-000288). 
6 His term is expected to end on March 31, 2024, or at another date agreed between him and Bezeq. For more 
details, see immediate report published by the Company (Ref.: 2024-01-016624). 

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Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

The group did not pay any of the office bearers listed in the table above payments for the year 2023 
which were not listed in the aforementioned table and which were not recognized in the statements 
for the reporting year. 

The following is a breakdown of the terms of engagement with the stakeholders and officers listed in 
the table above:  

a.  Tomer Raved 

Mr. Raved has served as the Company's CEO since January 2020, and also served as a director in 
the Company from January 2020 to November 2021, as a director in Bezeq starting in May 2020, 
and as of January 1, 2024, Mr. Raved serves as Chairman of Bezeq’s Board of Directors. According 
to  the  employment  agreement  with  Mr.  Raved,  which  was  approved  at  the  Company's  general 
assembly  on  February  13,  2020,  Mr.  Raved  is  entitled  to  a  monthly  salary  as  well  as  social  and 
ancillary  benefits  as  accepted  by  the  Company  and  in  accordance  with  the  Company's 
compensation policy (recovery fees, training fund, pension, sick pay, vacation days, mobile phone, 
business expenses and national insurance, excluding vehicle expenses). 

In addition, Mr. Raved is entitled to an annual bonus of up to 12 salaries subject to meeting the 
targets, where according to the Company's approved compensation policy, a rate of 65% of the 
aforementioned annual bonus will be paid subject to meeting the target of improving the debt-to-
asset ratio (LTV) of at least 5% compared to last year; rate of 10% of the annual bonus will be paid 
subject to meeting budget targets set by the Company's Board of Directors and 25% of the annual 
bonus will be paid at the discretion of the Company's Board of Directors. In this regard, it should 
be noted that following Mr. Raved's appointment as Chairman of Bezeq’s Board of Directors, on 
March 12, 2024, Mr. Raved announced to the Company that he is waiving the grant rate conditional 
on the debt-to-asset ratio improvement target for 2023 and as long as he also serves as Chairman 
of the Bezeq Board of Directors. 

In  addition,  in  respect  of  his  office  as  a  director  in  Bezeq,  Mr.  Raved  is  entitled  to  an  annual 
compensation  and  a  participation  fee  in  the  amount  determined  by  an  external  expert  in 
accordance  with  the  Compensation  Regulations,  as  they  will  be  from  time  to  time  and  in 
accordance with Bezeq’s classification at the relevant time.  

In addition, Mr. Raved is entitled to be included in the liability insurance for directors and officers 
and for indemnification as is customary in the Company, as are all other officers in the Company. 

As of the date of the report, Mr. Raved was granted 5,927,362 unlisted options, exercisable into 
the Company's shares, which as of the date of publication fo this report, amount to approximately 
2.23% of the issued and paid-up share equity of the Company, fully diluted. It should be noted that 
out of the total options held by Mr. Raved, a total of 2,677,362 unlisted options were allocated as 
part  of  a  previous  allocation  ("the  Previous  Allocation"),  and  Mr.  Raved  signed  an  irrevocable 
commitment according to which he undertakes not to exercise the options allocated to him as part 
of  the  Previous  Allocation.  For  more  details  about  the  terms  of  the  remaining  options,  see  the 
meeting  notice  published  by  the  Company  on  June  22,  2022  (Ref.:  2022-01-077395),  which  is 
included in this report by way of reference ("the Option Allocation Notice"). 

The  employment  agreement  with  Mr.  Raved  can  be  terminated  by  the  Company  with  up  to  6 
months notice. Mr. Raved may terminate his employment at any time with 30 days notice. 

b. 

Itzik Tadmor 

As of January 2019, Mr. Tadmor is employed as the Company's CFO. According to the employment 
agreement with him, in addition to his monthly salary, Mr. Tadmor is entitled to social and ancillary 
benefits as customary (vacation days, executive insurance, study fund, etc.). In accordance with the 
employment agreement with him, he is entitled to a retention grant for his work in the Company 
until December 2023. Starting in 2024, Mr. Tadmor will be entitled to a grant of up to 6 salaries 
conditional on meeting the targets to be set. 

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Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Also,  Mr.  Tadmor  is  entitled  to  be  included  in  the  directors'  and  officers'  liability  insurance 
arrangement and indemnity as is customary in the company, like the other officers in the company. 

In  July  2022,  Mr.  Tadmor  was  granted  100,000  unlisted  options  exercisable  into  the  company's 
shares,  which,  as  of  the  publication  date  of  this  report,  constitute  approximately  0.09%  of  the 
company's fully diluted issued and paid-up share equity. For more details about the terms of the 
granted options, see the call for the allocation of options, as defined above. 

The employment agreement with Mr. Tadmor can be terminated at any time with 3 months notice 
by either party. 

c. 

Ilan Chaikin  

Ilan Chaikin is employed as the internal auditor of the Company. Mr. Chaikin is entitled to a fee at 
a rate of NIS 240 per hour plus VAT. During 2023, Mr. Chaikin’s fee amounted to approximately NIS 
56K. For further details, see Section 2.5 of the Company's Board of Directors' report as of December 
31, 2023, in Chapter B of the periodic report. 

d.  Gil Sharon 

Gil Sharon served as Chairman of the Bezeq Board of Directors, as well as as the Chairman of the 
Bezeq  Boards  of  Directors  of  all  subsidiaries  in  Bezeq  Group  as  of  August  27,  2020  and  until 
December 31, 20237. The employment agreement with Mr. Gil Sharon, dated December 10, 2020, 
was for an unlimited period with the right of either party to terminate it at any time and for any 
reason, with 3 months' advance notice by any of the parties. 

For his office, Mr. Gil Sharon was entitled to the main conditions mentioned in the "general terms 
of  employment  for  officers"  above;  entitled  to  a  monthly  salary  (gross)  in  the  amount  of 
approximately NIS 170K (linked to the Consumer Price Index, starting on January 1, 2023)8; as well 
as a possibility of eligibility for an annual performance-dependent cash grant (starting in 2022).9 

On January 18, 2021, Bezeq's general assembly approved to grant  12,000,000 options to Mr. Gil 
Sharon. For additional details regarding the terms of office and employment of Mr. Gil Sharon as 
Chairman of the Company’s Board of Directors, see the Bezeq general assembly convening report 
as  published  on  December  12,  2020,  which  is  hereby  referenced,  and  for  additional  details 
regarding  the  terms  of  said  options,  see  the  amended  report  regarding  the  outline  for granting 
options to employees and the material private offer report dated May 9, 2022. The fair value of the 
options at the time of their grant (calculated according to the Monte Carlo model) is approximately 
NIS  9.3  million.  On  January  31,  2024,  upon  the  termination  of  Mr.  Sharon's  employment 
relationship, and in accordance with Bezeq's capital compensation plan, 3,000,000 options of the 
total number of options as mentioned expired. 

Mr. Sharon's  annual performance-dependent  grant targets for 202310 as Chairman of the  Bezeq 

7 The advance notice period of the Chairman of the Board of Directors is from November 1, 2023, and ended, in 
accordance with his employment agreement, at the end of three months from that date, that is, from January 31, 
2024. 
8 For details about the approval of the shareholders’ assembly to link the salary of the Chairman of the Board of 
Directors to the consumer price index, see the Bezeq general assembly convening report dated June 22, 2023, 
which is hereby included by way of reference. 
9 For details about the addition of the annual performance-based cash bonus component to the Chairman of the 
Bezeq Board of Directors, see the Bezeq general assembly summons report dated March 14, 2022, as well as the 
revised report dated April 14, 2022, which are hereby included by way of reference. 
10 In accordance with the amendment of the compensation policy and the terms of office and employment of the 
Chairman of the Bezeq Board of Directors, as approved by the Bezeq general assembly on April 28, 2022 (for 

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Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Board  of  Directors  were  determined  in  advance  as  part  of  the  compensation  policy  for  officers 
approved  by  the  general  assembly  and  by  the  Bezeq  Board  of  Directors  in  December  2022  and 
included: Group-adjusted EBITDA11 target weighing 50% in the grant calculation; Group-adjusted 
net profit target weighing 25%; and a Group-adjusted free cash flow (FCF) target weighing 25%. The 
compliance  rate  of  the  Chairman  of  the  Board  of  Directors  in  the  set  of  grant  targets  for  2023 
amounted  to  approxmately  118%.  The  threshold  condition  for  eligibility  to  the  annual 
performance-dependent grant was that the Group-adjusted EBITDA results (neutralizing the effects 
of IFRS16) for 2023 (NIS 3,441.5 million) did not decrease by more than 40% of the Group-adjusted 
EBITDA results (neutralizing the effects of IFRS16)  in 2022 (NIS 3,404.8 million) – this condition has 
been met. 

The ceiling of the performance-dependent grant to the Chairman of the Bezeq Board of Directors 
is limited in accordance with the provisions of Bezeq's  compensation policy at up to 75% of the 
annual base salary (9 salaries). Accordingly, the grant that was approved for the Chairman of the 
Bezeq  Board  of  Directors  for  the  year  2023  is  75%  of  the  annual  salary.  For  the  purpose  of 
calculating the achievement of targets for the year 2023, in accordance with Bezeq's compensation 
policy, the Compensation Committee and Bezeq's Board of Directors approved the exclusion of the 
following events from the calculation of performance for the purpose of the grant: the update of 
the  collective  wage  in  the  economy,  the  decision  of  the  Board  of  Directors  to  increase  the 
investment budget for the establishment of a joint server farm for the Company and Pelephone 
and to increase the fiber deployment target of Bezeq for this year, the awarding of a "reserve grant" 
to the Group's employees  who were recruited  for reserve service during the  war, and also, the 
effects of the "Iron Swords" war on the results of 2023. 

In accordance with the terms of employment, Mr. Sharon is entitled to a non-compete period for 
two months after the end of the employee-employer relationship. For this period, Mr. Gil Sharon 
was awarded a non-compete grant in the amount of two monthly salaries (gross), including social 
conditions. During this period, Mr. Sharon will not compete with Bezeq’s activity that exists at that 
time or with its businesses (including the businesses of the Company's subsidiaries or affiliates), 
and will refrain from founding, managing, operating, or having control over any entity whose main 
activity is similar to or competes with Bezeq's activities at the time of termination of the contract.  

On February 5, 2024, the Bezeq general assembly approved an appreciation grant in the amount of 
three monthly salaries (gross) to Mr. Gil Sharon, as a token of appreciation and  gratitude for his 
performance and contribution to Bezeq. For more details about the grant, see the Bezeq general 
meeting summons report dated December 28, 2023, as well as a revised report dated February 1, 
2024, which are hereby included by way of reference. 

more details, see the general assembly convening report of March 23, 2022, as amended on April 14, 2022, which 
is hereby included by way of reference). 
11 Adjusted EBITDA for the purposes of determining compensation - calculated as EBITDA neutralizing other 
operating expenses/revenue (net), losses/gains from depreciation/appreciation (including losses from continuous 
impairment), the effects of implementing the international financial reporting standard IFRS16 "Leases", and 
neutralizing expenses for payments in respect of an equity compensation plan. 

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Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

e.  Ran Guron 

Mr. Guron serves as CEO of Bezeq as of June 19, 2022. Mr. Ran Guron's employment agreement, 
dated May 8, 2022, is for an unlimited period, with either party eligible to terminate it at any time 
with six months' advance notice. February 25, 2024, Mr. Guron announced the end of his term as 
CEO of Bezeq. The end date of his term is expected to be on March 31, 2024, or at another date 
agreed between the parties12. 

In respect of his term in office, Mr. Guron is entitled to the main terms as stated in the "General 
Terms of Employment for Officers" above; Entitled to a monthly salary of approximately NIS 153K 
(adjacent to the Consumer Price Index); For more details about the terms of office and employment 
of Mr. Ran Guron as CEO of Bezeq, see the Bezeq general assembly convening report dated August 
10, 2022, which is hereby included by way of reference. 

On December 10, 2020, during his office as CEO of the subsidiaries - Pelephone, Yes, and Bezeq 
International,  the  Bezeq  Board  of  Directors,  and  each  of  the  Boards  of  Directors  of  the 
aforementioned  subsidiaries,  approved  the  allocation  of  9,000,000  options  to  Mr.  Guron.  The 
aforementioned  options  were  granted  on  January  18,  2021,  after  Bezeq's  general  assembly’s 
approval to increase Bezeq’s registered shareholders’ equity. For more details about the terms of 
the options, see Bezeq’s amended report regarding the outline for granting options employees and 
the material private offer report dated May 9, 2022. The fair value of the options at the time they 
were granted (calculated according to the Monte Carlo model) is about NIS 6.9 million. On August 
25, 2024, with the termination of Mr. Guron's employment relationship, and in accordance with 
Bezeq's equity compensation plan, 782,877 options of the total number of options as mentioned 
will expire. 

The goals of the annual performance-based bonus of Mr. Gouraon for 2023 as CEO of Bezeq were 
determined in advance by the Company’s Board of Directors in December 2022 and included: an 
adjusted EBITDA target  for the  Company (solo) that weighs 50% in the calculation of the grant; 
Adjusted profit after tax target for the Company (Solo) that weighs 20%; Adjusted free flow target 
(FCF)13 for the Company (solo) that weighs 20%; and a manager evaluation target that weighs 10%. 
The threshold condition for receiving the grant was that the adjusted EBITDA results for 2023 (NIS 
2,501.9 million) did not decrease by more than 40% from the adjusted EBITDA results for 2022 (NIS 
2,474.8 million) - this condition was met. 

Bezeq’s CEO's compliance rate with the annual performance-dependent grant targets for the year 
2023  was  108%.  Accordingly,  the  rate  of  the  Bezeq  CEO's  annual  grant  for  the  year  2023  is 
approximately 108% of his annual salary. For the purpose of calculating the achievement of targets 
for the year 2023, in accordance with Bezeq's compensation policy, the Compensation Committee 
and Bezeq's Board of Directors approved the exclusion of the following events from the calculation 
of performance for the purpose of the grant: a collective wage agreement in the economy, which 
was not included in the Company's budget for 2023, the Board of Directors' decision to increase 
the investment budget for the establishment of a joint server farm for Bezeq and Pelephone and 
increasing  Bezeq's  fiber  deployment  target  for  this  year,  awarding  a  "reserve  grant"  to  Bezeq 
employees who were drafted into reserve service during the war. 

12 The advance notice period of the CEO of the Company is from February 25, 2024 and will end, in accordance 
with his employment agreement, at the end of 6 months from this date, that is, on August 25, 2024. 
13 Adjusted free cash flow (FCF) - calculated as cash generated from current operations, deducting cash for the 
purchase/sale of PP&E and intangible assets (net), and deducting payments for leases. 

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Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Retirement  arrangements:  On  March  3,  2024  and  on  March  12,  2024,  the  Compensation 
Committee  and  the  Bezeq  Board  of  Directors,  respectively,  decided  to  grant  Mr.  Guron  a 
retirement  grant  in  the  amount  of  3  gross  monthly  salaries  for  his  great  contribution  to  Bezeq 
Group during his 18 years of office in the Group in various senior positions. Also, the Compensation 
Committee  and  Bezeq's  Board  of  Directors  decided  to  approve,  in  accordance  with  Bezeq's 
compensation policy, the release of the conditional parts of the performance-dependent grant for 
the year 2023 to Mr. Guron. 

f.  Directors 

Each  director  (including  the  Chairman  of  the  Board  of  Directors)  is  entitled  to  an  annual 
compensation  and a participation  compensation  for each meeting, in the maximum amount, in 
accordance with the Company’s classification under to the Compensation Regulations. Directors 
with financial accounting expertise, as this term is defined in the Companies Regulations (Terms 
and Tests for a Director with Accounting and Financial Expertise and for a Director with Professional 
Competence), 5765-2005 are entitled to external expert director annual compensation, as stated 
in  the  Compensation  Regulations.  In  addition,  the  directors  are  entitled  to  be  included  in  the 
arrangement for liability insurance of directors and officers and indemnification as is customary in 
the Company, as are all other officers in the Company. In 2023,  compensation  was paid to the 
directors of the Company in accordance with the Compensation Regulations in the amount of NIS 
720k. 

Regulation 21a: The controlling shareholder in the corporation 
On December 2, 2019, a debt settlement was completed between the Company and its bondholders, 
under which Searchlight II BZQ LP and a corporation controlled by the Forer family (TNR Investments 
Ltd.) acquired control of the Company (and consequently, Bezeq). The company owns Bezeq Directly. 
In this regard, see also Bezeq's immediate report dated December 2, 2019 regarding the Company's 
announcement of the completion of the said transaction, as well as Bezeq's immediate reports dated 
January  2,  2020  regarding  holdings  of  stakeholders  and  those  who  became  stakeholders  in  the 
corporation. 

As of the date of completion of the debt settlement as aforesaid, the controlling owners of the Company 
are Searchlight II BZQ L.P, a limited partnership incorporated in the Cayman Islands ("Searchlight") and 
TNR. Investments Ltd. ("TNR"), a private company incorporated in Israel. The final general partner of 
Searchlight is Searchlight Capital Partners II GP, LLC, a limited liability company incorporated in the State 
of Delaware, which is held by a number of individuals including Eric Zinterhofer, Erol Uzumeri and Oliver 
Harmaann, with the latter being among the only ones to receive the Company's control permit from 
the Ministry of Communications. TNR is fully owned and controlled by Mr. David Forer (50%) and Mrs. 
Michal Forer (50%). Searchlight and TNR are considered controlling shareholders in the Company by 
virtue of a control permit dated November 11, 2019 and by virtue of a voting agreement between them 
which confers on them a cumulative holding, as of the date of this report, of approximately 78.78% of 
the voting rights in the Company. 

To the best of the Company's knowledge, the shareholders' agreement between Searchlight and TNR 
includes, among other things, a provision according to which as long as the holdings of an "Israeli entity" 
in Bezeq's controlling shareholder are required, Searchlight will grant TNR power of attorney in respect 
of the amount of shares that will allow TNR to vote at the general meetings of the Company, an amount 
of shares equal to: (a) the amount of shares held by TNR on the effective date of the meeting, or (b) the 
amount of shares reflecting 19% of the issued capital and voting rights in the Company on the effective 
date of the meeting, whichever is highest. To the best of the Company's knowledge, the shareholders' 
agreement includes additional provisions, including a commitment by Searchlight to refrain from voting 
for the approval of certain issues without the consent of TNR. 

For details regarding the control permit, see Section 1.1.4 in Chapter A of the periodic report. 

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Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Regulation 22: Transactions with the controlling shareholder 
For  details, to the best  of the Company's knowledge, regarding any transaction with the controlling 
shareholder in the Company, or such that the controlling shareholder in the Company has a personal 
interest  in  the  approval  thereof,  which  the  Company,  the  companies  controlled  thereby  or  related 
thereto entered into in the reporting year or after to the end of the reporting year and until the date of 
submission of this report, or it is still valid at the date of the report, as well as for details regarding 
Bezeq’s neglibility procedure, see Note 29 to the statements. 

Regulation 24: Holdings of related parties and senior executives 
For details regarding the status of the holdings of interested parties in the Company, see an immediate 
report  dated  October  5,  2023  (Ref.:  2023-01-092227),  which  is  included  in  this  report  by  way  of 
reference. 

Regulation 24a: Registered capital, issued capital and convertible securities 
For  details  regarding  the  registered  equity,  the  issued  equity  and  the  convertible  securities  of  the 
Company,  see  immediate  report  dated  December  13,  2023  (Ref.:  2023-01-113020)  included  in  this 
report by way of reference. 

Regulation 24b: Register of shareholders 
For the Company's shareholder register, see immediate report dated December 13, 2023 (Ref.: 2023-
01-113020) included in this report by way of reference. 

Regulation 25a: Registered address of the corporation 
Address: 144 Menachem Begin St., Tel Aviv 
Phone: 03-6796101 Fax: 03-6796111 
Email: tomer@bcomm.co.il 

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Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Regulation 26: The directors of the corporation 

Last  name  and  first 
name  

ID number 

Date of birth 

Address for the service 
of court documents 

Citizenship 

Education 

Darren Glatt, Chairman 

Phil Bacal 

Ran Forer 

Efrat Duvdevani 

Ajit V. Pai 

Efrat Makov 

Stephen Joseph 

549871770 

(foreign 

HP037044 

(foreign 

066522772 

238248730 

536841734

023044365 

551988678 (foreign passport) 

passport) 

passport) 

(Foreign passport) 

November 18, 1975 

September 13, 1985 

September 2, 1984 

JUNE 10, 1968 

January 10, 1973 

June 17, 1968 

April 10, 1980 

144  Menachem  Begin 

144  Menachem  Begin 

2  Haysur 

St., 

Ramat 

48  Hanasi  Ben  Zvi  St., 

Arlington,  Old  Dominion 

118 HaTamar Road, Moshav 

144  Menachem  Begin  Road, 

Road,  Tel  Aviv 

(at  B. 

Road,  Tel  Aviv 

(at  B. 

Hasharon, 4703006 

Herzliya, 4639948 

Drive, 4868, 22207 

Ben Shemen, 73115 

Tel 

Aviv 

(at 

B. 

Communications) 

Communications) 

Communications) 

American 

Canadian 

Israeli 

Israeli 

American 

Israeli 

British 

BACCY, 

George 

MBA Richard Ivey School of 

Degree in Law, IDC Herzliya, 

Degree 

in 

International 

B.A., Social Studies, Harvard 

B.A. 

In  Economics  and 

BSc  in  Business  and  Financial 

Washington 

University 

Business  at  the  University 

B.A. 

in  Management,  IDC 

Relations  and  English,  The 

University; 

Accounting  from  Tel  Aviv 

Economics 

from 

Leeds 

MBA,  Harvard  Business 

of Western Ontario. 

Herzliya,LL.M.  Commercial 

Hebrew  University;  Degree 

J.D  Law  Studies,  University 

University. 

Israeli 

CPA 

University, KPMG. 

School 

Law  (cum  laude),  Tel  Aviv 

in 

Public 

Policy 

- 

of Chicago Law School 

license 

(1993),  American 

University,  M.Sc.  General 

Management  and  Finance, 

CPA license (New York State) 

Management, 

Stanford 

Tel Aviv University 

(1995). 

University,  Semester  in  Law 

at Berkeley University 

Occupation 
past five years  

for 

the 

Partner  in  the  Searchlight 

CEO  of  bullet 

Trade 

VP of Business Development 

CEO of the Peres Center for 

Partner 

in 

Searchlight 

Jewelry 

Designer 

CFO  and  VP  of  Operations  at 

Capital  Partners  and  head 

Services, 

Partner 

in 

at  the  Neopharm  Group, 

Peace and Innovation. 

Capital Partners. 

(Independent Business). 

Ocean  Outdoor  Group  (LSE: 

of 

investments 

in 

Searchlight 

Capital 

Business 

Development 

Chairman of the FCC 

Director 

in  the  following 

OOUT). 

infrastructure, 

Partners. 

Manager 

at 

Celgene 

companies: 

- 11-

  
 
 
 
 
 
 
  
 
Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Corporation. 

  BioLight  Life  Sciences  Ltd 

(2011-2020); 

Anchiano 

Therapeutics 

Ltd 

(2018-

2020);  Kamada  Ltd  (2018-

2019);  iSPAC  1  Ltd  (2021-

present);  Allot  Ltd  (2021-

present); Ceragon Ltd (2022-

present). 

communications,  media 

and technology. Director in 

the  following  companies: 

Bezeq,  Mainstream  Fiber 

Network 

(Chairman), 

Wecom  Fiber  (Chairman), 

All 

Points 

Broadband 

(Chairman), 

Adams 

Outdoor 

Advertising. 

Formerly, also a director in 

the  following  companies: 

Rackspace,  MediaMath, 

Ocean 

Outdoor, 

160over90, 

Charter 

Communications, 

PatientPoint, 

Veritable 

Maritime, Core Media. 

Serves as  a director  in 
other corporations 

Bezeq,  Mainstream  Fiber 

Roots  Corporation,  Care 

Bezeq, ADO Group, Advisory 

All Points Broadband,  

Network,  Webcom  Fiber, 

Advantage,  Bullet  Trade 

Board  of 

the 

Tel-Aviv 

Mainstream Fiber Networks,  

All 

Points 

Broadband, 

Services, TouchTunes 

University 

Alumni 

Adams 

Outdoor 

Organization 

Advertising 

Wecom Fiber,  

Ziply Fiber,  

America’s  Public  Television 

Stations, EdgeQ  

Atoll Holdco Ltd, 

Scp 

Acquisition 

Topco 

Limited,  

Scp 

Acquisition  Midco 

Limited,  

Scp Acquisition Bidco Limited,  

Ocean Topo Limited,  

Ocean Bidco Limited,  

- 12-

  
 
 
 
 
Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Ocean Outdoor UK Limited,  

Signature Outdoor Limited,  

Mediaco Outdoor Limited,  

Forrest 

Outdoor  Media 

Limited, 

Ocean 

Brands 

Limited 

Forrest  Media 

(Holdings) 

Limited,  

Forrest Media Limited,  

DKTD Media B.V,  

Ngage Media B.V, 

Interbest B.v, 

Global  Agencies  Stockholm 

AB,  

Gudfar& son AB,  

Visual  Art  &  Global  Agencies 

Sweden AB,  

Visual 

Art 

International 

Holding AB,  

Visual Art Sweden AB,  

Visual Art Sweden Holding AB,  

Visual  Art  Denmark  City 

Reklame A/S,  

Visual  Art  Norway  AS.  Visual 

Art  USA 

Inc,  Visual  Art 

Germany  GmbH,  Visual  Art 

Finland Oy 

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Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Has  accounting  and 
financial expertise 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

the  director  an 
Is 
the 
of 
employee 
its 
corporation,  of 
subsidiary, 
its 
of 
affiliated  company  or 
of 
stakeholder 
a 
therein 

Yes, see details of 

Yes, see details of 

Yes, the director serves as 

No 

Yes, 

see 

details 

of 

No 

occupation in the last five 

occupation in the last five 

VP of Business 

occupation  in  the  last  five 

years. 

years. 

Development of the 

years. 

Neopharm Group, whose 

controlling shareholders, 

David and Michal Forer, are 

also controlling 

shareholders of TNR 

Investments Ltd., which 

owns the joint controlling 

interest in the Company. 

Yes 

No 

Is the director a family 
member  of  another 
the 
stakeholder 
corporation 

in 

No 

No 

Yes, the director serves as 

No 

No 

No 

No 

VP of Business 

Development and officer in 

Neopharm Group, of which 

his parents, David and 

Michal Forer, are the 

controlling shareholders 

and TNR Investments Ltd., 

which owns the joint 

controlling interest in the 

Company. 

- 14-

  
 
 
Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

in 

Membership 
committee 
committees  of 
Board of Directors 

a 
or 
the 

No 

Is  this  member  of  the 
Board  of  Directors  an 
outside director 

Does the Company see 

the  director  as  an 

independent director 

No 

No 

No 

No 

The Committee for the 

No 

The  Committee 

for 

the 

The  Committee 

for 

the 

Examination of Financial 

Statements; The Audit 

Examination  of  Financial 

Examination 

of 

Financial 

Statements; 

The 

Audit 

Statements; 

The 

Audit 

Committee; Compensation 

Committee;  Compensation 

Committee; 

Compensation 

Committee; 

Committee; 

Committee; 

No 

No 

No 

No 

Yes 

Yes 

No 

No 

Yes 

Yes 

No 

Yes 

- 15-

  
 
 
 
 
Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Regulation 26 A: Senior officers 

Name of senior officer 

Itzik Tadmor 

Dudu Mizrahi 

Ilan Chaikin 

Role in the Company, 
subsidiary, affiliate or 
related party 

Chief Financial 
Officer 

Date of birth 

Education 

Main occupations in the last 
5 years and a list of the 
corporations in which he 
serves as a director 

February 14, 
1981 
BA in Accounting 
and Economics, 
Tel Aviv 
University. 

MBA in Business 
Administration, 
Tel Aviv 
University. 

CFO of B 
Communications 
Ltd. 

Internal Auditor 

November 21, 
1954 
Bachelor's degree 
in Economics and 
Accounting, Tel 
Aviv University. 

Managing partner 
at CPA Chaikin 
Cohen Rubin & Co. 

CEO of the 
Company and 
Chairman of the 
Board of Directors 
of Bezeq 
April 18, 1985 

Double major in 
Law and 
Economics from 
the Tel Aviv 
University; MBA - 
Stern School of 
Business 

The Company's 
CEO and Chairman 
of the Board of 
Directors of Bezeq  

Director and Vice 
President of the 
Telecom and 
Technology Group 
at RBC Investment 
Bank in New York. 

No 

No 

No 

Is he a related party in the 
Company or a family 
member of another senior 
official or of another related 
party in the Company 

Regulation 27: Independent authorized signatory 
The Company's CEO, Mr. Tomer Raved, is an independent signatory authorized by the Company, as this 
is term defined in the law. 
Without derogating from the above, for the purpose of making money transfers in any amount from 
the Company's accounts in banks, the signatures of Mr. Tomer Raved, the Company's CEO, and Mr. Itzik 
Tadmor, the Company's CFO, are required. 

Regulation 27: The accountant of the corporation  
Somekh Chaikin, CPA 
Address: 17 HaArbaa St.,, KPMG Millennium Tower, Tel Aviv 6473917 
Tel: 03-6848000 

- 16-

  
 
 
 
 
 
 
 
 
 
 
 
 
Chapter D (Additional Details on the Corporation) for the Periodic Report for the Year 2023 

Regulation 28: Amendment of the Company's Articles of Association 
In the reporting year, no changes were made to the company's Articles of Association. 

Regulation 29 (a): The recommendations and resolutions of the directors before the general 
meeting, and their resolutions that do not require the approval of a general meeting in matters 
specified in Regulation 29(a) 

A.  On  June  20,  2023,  the  Company's  Board  of  Directors  approved  a  full  early  redemption,  at  the 
company's  initiative,  of  the  remaining  debentures  (series  C)  of  the  Company,  subject  to  the 
completion of the issuance of additional  debentures (series F) of the Company according to the 
shelf offer report. On June 22, 2023, the  Company announced the existence of the precondition 
for  full  early  redemption  of  the  Company's  debentures  (series  C),  and  accordingly,  that  the 
redemption will take place on July 20, 2023. For details, see the Company's reports of June 21, 2023 
and of June 22, 2023 (Refs.: 2023-01-058162 and 2023-01-058786). 

B.  On August 8, 2023, the Company's Board of Directors approved a buyback plan of the Company's 
shares in the amount of up to NIS 30 million, which will begin on August 13, 2023 and end upon: 
(1) purchase in the amount of  NIS 30 million; or (2) the end of the trading day on November 1, 
2023,  whichever  is  earlier.  In  accordance  with  the  aforementioned  buyback  plan,  the  Company 
purchased shares for a  total amount  of approximately NIS 23 million. For  more details, see the 
Company's report dated August 9, 2023 (Ref.: 2023-01-073822) , which is included in this report by 
way of reference. 

Regulation 29 (b): Resolutions of the general assembly that were not adopted in accordance with the 
recommendations of the directors in the matters listed in Sub-regulation (a) above 
During the reporting year, resolutions were not adopted at the Company's general assembly that were 
not  in  accordance  with  the  recommendations  of  the  Board  of  Directors  in  the  matters  detailed  in 
Regulation 29(a). 

Regulation 29 (c): Resolutions of a special general assembly  
During the reporting period, no resolutions were made at a special general assembly of the Company's 
shareholders. 

Regulation 29A (4): Exemption, insurance, or obligation to indemnify officers  
For details regarding exemption, insurance or indemnification obligation for officers, See Note 29.6 to 
the statements.  

  March 12, 2024 
Date 

_______________________________ 

B Communications Ltd. 

Name and role of signatories: 

Tomer Raved, CEO 
Darren Glatt, Chairman of the Board of Directors 

- 17-

  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CORPORATE GOVERNANCE QUESTIONNAIRE  1 

BOARD OF DIRECTORS INDEPENDENCE 

1. 

In each reporting year, two or more external directors served in the corporation. 

This question can be answered "Correct" if the period of time in which two external directors did not 
serve does not exceed 90 days, as stated in Article 363A (b) (10) of the Companies Law, but any answer 
(Correct / Incorrect) must state the period of time (days) in which the corporation did not have two or 
more external directors in the reporting year (including a term of office approved retrospectively, while 
separating between the various external directors): 

Director A: 0. 

Director B: 0. 

The number of external directors serving in the corporation as of the date of publication of this 
questionnaire: 2. 

 Correct 
√ 

Incorrect 

1 Published as part of legislative proposals to improve the statements on March 16, 2014.  

1 

 
 
 
 
 
 
 
2. 

3. 

4. 

The rate2 of independent directors3 serving in the corporation as of the publication of this 
questionnaire: 3/7.  

The rate of independent directors determined In the Articles of Association4 of the corporation5: 
______. 

 Irrelevant (not provided for in the Articles of Association). 

In the reporting year, an examination was conducted with the external directors (and the independent 
directors) and it was found that in the reporting year they complied with the provision of Article 240 (b) 
and (f) of the Companies Law regarding the lack of affiliation of the external (and independent) 
directors serving in the corporation and they meet the conditions required for serving as an external (or 
independent) director. 

All directors who served in the corporation during the reporting year are not subordinated6 to the CEO, 
directly or indirectly (except for a director who is an employee representative if the corporation has 
employee representation). 

If you answered "Incorrect" (namely, the director is subordinated to the CEO as mentioned) – indicate 
the rate of directors that do not meet the aforesaid limitation: _____. 

_____ 

_____ 

√ 

√ 

2In this questionnaire, "rate" - a certain number out of the total. For example 3/8. 
3 Including "external directors" as defined in the Companies Law. 
4 For the purposes of this question - "Articles of Association" including according to a specific legal provision applicable to the corporation (for example in a banking corporation - the 
directives of the Supervisor of Banks). 
5 A debenture company is not required to answer this section. 
6 For the purposes of this question - the very office of a director of a holding corporation controlled by the corporation will not be considered "subordinate", on the other hand, the office of a 
director of a corporation serving as an officer (other than a director) and / or an employee of the corporation controlled by the corporation will be considered "subordinate".  

2 

 
 
 
 
 
 
5. 

6. 

√ 

√ 

All the directors who announced the existence of a personal interest in approving a transaction on the 
agenda of the meeting, did not attend the discussion and did not participate in such vote (except for 
discussion and / or voting in the circumstances under Article 278 (b) of the Companies Law): 

If Your answer is "Incorrect"-  

Was it for the purpose of presenting a particular subject thereby in accordance with the provisions of 
Article 278 (a): 

 Yes 

 No (mark x in the appropriate box). 

Indicate the rate of meetings at which such directors were present at the discussion and / or 
participated in the vote, except in the circumstances as stated in paragraph a: _____. 

1. 
The controlling shareholder (including his relative and / or someone on his behalf), who is not a director 
or other senior officer in the corporation, was not present at the Board of Directors meetings held in 
the reporting year. 

If your answer is "incorrect" (i.e., a controlling shareholder and / or relative and / or someone on his 
behalf who is not a board member and / or a senior official in the corporation was present at such 
board meetings) - indicate the following details regarding the presence of any additional person at 
Board of Directors meetings: 

Identity: _____. 

Position in the corporation (if any): _____. 

3 

 
 
 
 
Details of the affiliation to the controlling shareholder (if the person present is not the controlling 
shareholder himself): _____. 

Was it for the purpose of presenting a certain subject thereby:  Yes  No (mark x in the appropriate box) 

The rate of presence7 thereof in meetings of the Board of Directors that took place in the reporting year 
for the purpose of presenting a certain subject thereby: _____, Other presence: _____ 

 Irrelevant (there is no controlling shareholder in the corporation). 

QUALIFICATIONS AND SKILLS OF THE DIRECTORS 

7. 

There are no provisions in the corporation's articles of association that restrict the possibility of 
immediately terminating the office of all directors in the corporation, who are not external directors (in 
this matter - determination by a simple majority is not considered a restriction)8.  

If Your answer is "incorrect" (namely, there is a restriction as mentioned), indicate -   

Correct 
√ 

Incorrect 

7 While separating between the controlling shareholder, his relative and / or someone on his behalf. 

8 A debenture company is not required to comply with this section. 

4 

 
 
 
 
 
 
 
 
 
A. 

The period of time stipulated in the articles of association for the term of office of a director: 

B. 

C. 

The required majority set forth in the articles of association for the termination of office of the 
directors: 

A statutory quorum set forth in the articles of association at the general meeting for the purpose 
for the termination of office of the directors: 

D. 

The majority required to amend these provisions in the articles of association: 

The corporation prepared a training program for new directors, in the field of the corporation's business 
and in the field of law applicable to the corporation and the directors, and also arranged a follow-up 
program for the training of incumbent directors, adapted, among other things, to the director's position 
in the corporation. 

If your answer is "correct" - indicate whether the plan was implemented in the reporting year:  Yes 
No (Mark x in the appropriate box)  

√ 

A 
A. 

The corporation has a required minimum number of directors on the Board of Directors who must 
have accounting and financial expertise. 

√ 

If your answer is "correct" – indicate the minimum number determined: 

8. 

9. 

5 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
B. 

Number of directors who served in the corporation during the reporting year 

_________ 

_________ 

With accounting and financial expertise9: 47. 

With Professional qualifications10: 0. 

In the event of changes in the number of directors as stated in the reporting year, indicate the 
lowest number (except in a time period of 60 days of change) of directors of any type who served 
in the reporting year. 

10. 

A. 

Throughout the reporting year, the Board of Directors included members of both sexes. 

√ 

If your answer is "incorrect" – indicate the period of time (days) in which the aforesaid did not 
exist: _____. 

This question can be answered "correct" if the period of time in which directors of both sexes did 
not serve does not exceed 60 days, however in any answer (correct / incorrect), indicate the 
period of time (days) in which directors of both sexes did not serve: _____. 

9 After the evaluation of the Board of Directors, in accordance with the provisions of the Companies Regulations (conditions and tests for a director with accounting and financial expertise 
and for a director with professional Qualification), 5765-2005. 
10 See Footnote 9.  

6 

 
 
 
 
B. 

The number of directors of any sex serving on the corporation's Board of Directors as of the date 
of publication of this questionnaire:  

_____ 

_____ 

Men: 5, women: 2. 

BOARD MEETINGS (AND CONVENING A GENERAL MEETING)  

11. 

A. 

Number of board meetings held during each quarter of the reporting year: 

First quarter (2023): 3 

Second quarter: 6 

Third quarter: 4 

Fourth quarter: 5 

Correct 

Incorrect 

_____ 

_____ 

B. 

Next to each of the names of the directors who served in the corporation during the reporting year, 
indicate the rate11 of participation in the meetings of the Board of Directors (in this paragraph - including 
the meetings of the committees of the Board of Directors of which he is a member, and as indicated 

_____ 

_____ 

7 

See H.S. 2.

11

 
 
 
  
 
 
 
 
 
 
 
 
 
 
below) that took place during the reporting year (and with reference to term of office): See note at the 
end of the questionnaire. 

(Add lines according to the number of directors).  

Director’s name 

Rate of his 
participation in 
the meetings 
of the Board of 
Directors 

Rate of 
his 
participa
tion in 
meeting
s of the 
Audit 
Committ
ee 12 

Rate of his participation 
in meetings of the 
Committee for 
Examining the financial 
statements 13   

Rate of his 
participation in 
meetings of the 
Compensation 
Committee14  

Rate of his 
participation in 
meetings of other 
Board of Directors 
committees in which 
he is a member 
(indicate the name of 
the committee) 

Darren Glatt 

94% 

Phil Bacal 

89% 

12 Regarding the company director in this committee. 

13 Regarding the company director in this committee. 

14 Regarding the company director in this committee. 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Ran Forer 

100% 

Stephen Joseph  

83% 

100% 

75% 

100% 

Michael Clare 

83% 

100% 

100% 

100% 

Efrat Makov 

100% 

100% 

100% 

100% 

Ajit Pai 

67% 

12. 

1. 

In the reporting year, the Board of Directors held at least one discussion regarding the management of 
the corporation's business by the CEO and his subordinates, without their presence, and they were given 
an opportunity to express their position. 

√ 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SEPARATION BETWEEN THE FUNCTIONS OF THE  CEO AND THE CHAIRMAN OF THE BOARD  

Correct 
√ 

Incorrect 

13. 

Throughout the reporting year, a chairman of the board served in the corporation. 

This question can be answered "correct" if the period of time in which a chairman of the 
board did not serve in the corporation does not exceed 60 days as stated in Article 363A (2) 
of the Companies Law, but in any answer (correct / incorrect), indicate the period (days) in 
which a chairman of the board did not serve in the corporation as aforesaid: [__]. 

14. 

Throughout the reporting year, a CEO served in the corporation. 

√ 

This question can be answered "correct" if the period of time in which a CEO did not serve in 
the corporation does not exceed 60 days as stated in Article 363A (2) of the Companies Law, 
but in any answer (correct / incorrect), indicate the period (days) in which a CEO did not 
serve in the corporation as aforesaid: [__]. 

15. 

In a corporation in which the chairman of the board also serves as the CEO of the corporation 
and / or exercises his powers, the duplication of office is approved in accordance with the 
provisions of Article 121 (c) of the Companies Law15. 

 Irrelevant (if there is no such dual office in the corporation). 

15 In a bond company - approval in accordance with Article 121 (d) of the Companies Law. 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
16. 

The CEO Is not a relative of the chairman of the Board of Directors.  

If your answer is "incorrect" (i.e., the CEO is a relative of the chairman of the board)-  

A. 

B. 

Indicate the family relation between the parties: _____. 

The office was approved in accordance with Article 121 (c) of the Companies Law16: 

 Yes 

 No 

(mark x in the appropriate box) 

17. 

A controlling shareholder or his relative does not serve as CEO or senior executive officer in 

the corporation, except as a director.  

 Irrelevant (the corporation has no controlling shareholder). 

_____ 

_____ 

√ 

_____ 

_____ 

√ 

16 In a debenture company - approval in accordance with Article 121 (d) of the Companies Law. 

11 

 
 
 
 
 
 
 
 
 
 AUDIT COMMITTEE 

18. 

In the reporting year, on the Audit Committee did not serve - 

Correct 
_____ 

Incorrect 
_____ 

A. 

A controlling shareholder or his relative. 

 Irrelevant (the corporation has no controlling shareholder). 

B. 

Chairman of the Board of Directors. 

C. 

A director employed by the corporation or by the controlling shareholder of the 

corporation or by a corporation under his control. 

D. 

A director who regularly provides services to the corporation or controlling 

shareholder of the corporation or corporation under its control. 

E. 

A director whose main livelihood depends on the controlling shareholder. 

 Irrelevant (the corporation has no controlling shareholder). 

√ 

√ 

√ 

√ 

√ 

√ 

19. 

A person who is not allowed to be a member of the Audit Committee, including a controlling 

shareholder or his relative, was not present at the reporting year at the meetings of the Audit 

Committee, except in accordance with the provisions of Article 115 (e) of the Companies Law. 

12 

 
 
 
 
 
 
 
 
 
 
 
 
20. 

The legal quorum for discussion and decision-making at all Audit Committee meetings held in 

the reporting year was a majority of committee members, with the majority present being 

independent directors and at least one of them being an external director. 

If your answer is "incorrect" - indicate the rate of meetings in which the said requirement was 

not met: _____.  

21. 

In the year of the report, the Audit Committee held at least one meeting in the presence of the 

internal auditor and the auditor and without the presence of officers of the corporation who are not 

members of the committee, regarding deficiencies in the business management of the corporation.  

22. 

All meetings of the Audit Committee attended by those who are not allowed to be members of the 

committee, were with the approval of the committee chairman and / or at the request of the 

committee (regarding the legal advisor and the corporation secretary who is not a controlling 

shareholder or his relative).  

23. 

In the reporting year, arrangements were established by the Audit Committee regarding the manner in 

which the corporation's employees' complaints were handled in connection with deficiencies in the 

conduct of its business and regarding the protection to be given to the employees who complained as 

aforesaid. 

√ 

√ 

√ 

√ 

13 

 
 
 
 
 
24. 

The Audit Committee (and / or the Committee for the Examination of the Financial Statements) was of 

the opinion that the scope of the auditor's work and his fees in relation to the financial statements in 

the reporting year were adequate for carrying out proper audit and review work. 

√ 

FUNCTIONS OF THE COMMITTEE FOR EXAMINING THE FINANCIAL STATEMENTS (HEREINAFTER  - THE COMMITTEE) IN ITS 
PRELIMINARY WORK FOR THE APPROVAL OF THE FINANCIAL STATEMENTS  

25. 

A. 

Indicate the period of time (in days) determined by the Board of Directors as a reasonable 

time to submit the Committee's recommendations prior to the discussion of the Board of 

Directors for approval of the financial statements: 3 days when approving the periodic 

statements and 2 days when approving the quarterly statements. 

Correct 
_____ 

Incorrect 
_____ 

The number of days that have actually elapsed between the date of the transfer of the 

_____ 

_____ 

B. 

recommendations to the Board of Directors and the date of the Board of Directors’ discussion: 

First quarter statements (year 2023): 1 day. 

Second quarter statements: 5 days. 

Third quarter statements: 5 days.  

14 

 
 
 
 
 
 
 
Annual statements: 1 days. 

C. 

The number of days that have elapsed between the date of submission of the draft financial 

statements to the directors and the date of the discussion of the Board of Directors of the 

approval of the financial statements: 

First quarter statements (year 2023): 5 days. 

Second quarter statement: 5 days.  

Third quarter statements: 5 days.  

Annual statements: 4 days.  

26. 

The corporation's auditor attended all meetings of the Committee and the Board of Directors, at which 

the corporation's financial statements relating to the periods included in the reporting year were 

√ 

discussed. 

If your answer is "incorrect", indicate the participation rate: ______  

27. 

In  the  Committee,  all  the  conditions  listed  below  were  met  throughout  the  reporting  year  until  the 
publication of the annual statements: 

_____ 

_____ 

A. 

The  number  of  its  members  was  not  less  than  three  (at  the  time  of  the  discussion  in  the 

√ 

Committee and the approval of the statements as aforesaid ). 

15 

 
 
 
 
 
 
B. 

C. 

D. 

E. 

F. 

G. 

It complied  with all the conditions set  out  in Article 115 (b) and (c) of the Companies  Law 
(regarding the office of members of the Audit Committee). 

The chairman of the Committee is an external director. 

All its members are directors and most of its members are independent directors.  

All its members have the ability to read and understand financial statements and at least one 
of the independent directors has accounting and financial expertise.  

Committee members gave a statement prior to their appointments. 

The legal quorum for discussion and decision-making in the Committee was the majority of its 
members, provided that the majority of those present were independent directors, including 
at least one external director. . 

√ 

√ 

√ 

√ 

√ 

√ 

If your answer is "incorrect" regarding one or more of the subsections of this question, indicate in relation 

to which statements (periodic / quarterly) the said condition was not met and the condition that was not 

_____ 

_____ 

met. 

16 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 COMPENSATION COMMITTEE  

Correct 

Incorrect 

28. 

The  Committee  consisted  of,  in  the  reporting  year,  at  least  three  members  and  the  external 

directors constituted a majority (at the time of the Committee's deliberations). 

 Irrelevant (No discussion took place). 

29. 

The  terms  of  office  and  employment  of  all  members  of  the  Compensation  Committee  in  the 

reporting  year  are 

in  accordance  with  the  Companies  Regulations  (Rules  regarding 

Compensation and Expenses for an External Director), 5769-2000. 

√ 

√ 

30. 

In the reporting year, on the Compensation Committee did not serve - 

_____ 

_____ 

A. 

The controlling shareholder or his relative 

 Irrelevant (the corporation has no controlling shareholder). 

B. 

Chairman of the Board of Directors. 

√ 

√ 

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
C. 

A  director  employed  by  the  corporation  or  by  the  controlling  shareholder  of  the 

corporation or by a corporation under his control. 

D. 

A  director  who  regularly  provides  services  to  the  corporation  or  to  the  controlling 

shareholder of the corporation or to a corporation under his control. 

E. 

A director whose main livelihood depends on the controlling shareholder. 

 Irrelevant (the corporation has no controlling shareholder). 

The controlling shareholder or his relative were not present in the reporting year at the 
meetings of the Compensation Committee unless the chairman of the Committee determined 
that either of them was required to present a particular subject. 

The Compensation Committee and the Board of Directors did not exercise their authority under Articles 
267A (c), 272 (c) (3) and 272 (c1) (1) (c) to approve a transaction or compensation policy, despite the 
opposition of the general assembly. 

If your answer is "incorrect" indicate - 

Type of transaction approved as stated: ______ 

The number of times their authority was used in the reporting year: ______  

√ 

√ 

√ 

√ 

√ 

31. 

32. 

18 

 
 
 
 
 
 
INTERNAL AUDITOR 

Correct 

Incorrect 

33. 

The Chairman of the Board of Directors or the CEO of the corporation is the organizational supervisor of 

the internal auditor of the corporation. 

34. 

The Chairman of the Board of Directors or the Audit Committee approved the work plan in the reporting 

year. 

In addition, indicate the audit topics that the Internal Auditor dealt with in the reporting year: 
Implementation by the supervision procedure by the internal auditor and debt management. 
(mark x in the appropriate box).  

√ 

√ 

35. 

Scope of employment of the internal auditor in the corporation in the reporting year (in hours17): 200 

_____ 

_____ 

hours. 

In the reporting year, a discussion took place (in the Audit Committee or on the Board of Directors) of 

√ 

the Internal Auditor's findings.  

17 Including working hours invested in investee corporations and audits outside Israel, and as appropriate, both by the Company's internal auditor and by the internal auditors of the 

Company's subsidiaries. 

19 

 
 
 
 
 
 
 
36. 

The internal auditor is not a stakeholder in the corporation, a relative of such, an auditor or anyone on 

his  behalf,  nor  does  he  maintain  material  business  relationships  with  the  corporation,  its  controlling 

shareholder, or a relative or corporations under their control.  

√ 

INTERESTED PARTY TRANSACTIONS 

Correct 

Incorrect 

√ 

37. 

The controlling shareholder or his relative (including a company under his control) is not employed by 

the corporation or provides it with management services. 

If your answer is "incorrect" (namely, the controlling shareholder or his relative is employed by the 

corporation or provides it with management services) indicate - 

- Number of relatives (including the controlling shareholder) employed by the corporation (including 

companies under their control and / or through management companies): 

- Have the employment agreements and / or the management services as aforesaid been approved 

by the organs established by law:  

 Yes  

 No 

20 

 
 
 
 
 
(mark x in the appropriate box) 

 Irrelevant (In a corporation nothing husband control). _____. 

38. 

To the best of the corporation's knowledge, the controlling shareholder has no other business in the 

√ 

corporation's field of activity (in one or more fields). See note at the end of the questionnaire. 

If your answer is "incorrect" - indicate whether an arrangement has been established to delimit 

activities between the corporation and its controlling shareholder. 

 Yes 

 No 

(there is to mark x In the box Appropriate) 

 No relevant (the corporation has no controlling shareholder). 

21 

 
 
 
 
 
 
 
 
Closing notes to the questionnaire: 

1.  Meetings of the Board of Directors (and convening a general assembly) 

Section 11B - It should be noted that in the column on the participation rate in meetings of additional board committees, the reference 
is to permanent board committees only and does not include non-permanent committees established on an ad hoc basis for certain 
issues. It should be noted that in the number of meetings of the Board of Directors and its committees, the meetings held during the 
reporting year were considered, with reference to the term of office of each of the directors on the board and in each of the committees, 
as the case may be. 

2.  Stakeholder transactions 

Section 38 - Searchlight Group, which owns the Company, has holdings in many communications companies around the world (mainly in 
the United States). As stated in Section 1.8 of Chapter A of this report, Bezeq Group's strategy as of this date is to focus on the local 
market in Israel only. 

Chairman of the Board of Directors: ___________  

Chairman of the Audit Committee: ___________ 

Chairman of the Committee for Examining the Financial Statements: ___________ 

22 

 
 
 
 
 
 
Chapter E 

Report on the Effectiveness of Internal Control over 

Financial Reporting and Disclosure 

for the Year ended December 31, 2023 

- 1-

(1)  Report on the internal control over financial reporting and disclosure: 

Annual  report  on  the  effectiveness  of  internal  control  over  financial  reporting  and 

disclosure  pursuant  to  Regulation  9b(a)  a  of  the  Securities  Regulations  (Periodic  and 

Immediate Reports), 5730-1970: 

Management, under the supervision of the Board of Directors of B Communications Ltd. 

(hereinafter - "the Corporation" or "the Company"), is responsible for determining and 

maintaining adequate internal control over the financial reporting and disclosure in the 

Corporation. 

For this purpose, the members of Management are: 

1. 

2. 

Tomer Raved, CEO. 

Itzik Tadmor, CFO.  

In addition to the said members of Management, serving in the Company are: 

1. 

Ilan Chaikin, Internal Auditor. 

2.  Lital Aharoni, Comptroller. 

Internal control over financial reporting and disclosure includes controls and procedures 

existing in the Corporation, designed by or under the supervision of the CFO and CEO in 

the field of finance, or by the person actually performing the said functions, supervised by 

the Corporation's Board of Directors, which are intended to provide a reasonable degree 

of assurance regarding the reliability of the financial reporting and the preparation of the 

reports in accordance with the provisions of the law, and to ensure that information that 

the  Corporation  is  required  to  disclose  in  reports  it  publishes  under  the  provisions  is 

collected,  processed,  summarized  and  reported  on  the  date  and  in  the  format  as 

prescribed by law. 

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Internal  control  includes,  inter  alia,  controls  and  procedures  designed  to  ensure  that 

information the disclosure of which by the Corporation is required, are accumulated and 

transmitted to the Corporation's Management, including the CEO and senior executives in 

the field of finance or to those actually performing the said functions, in order to enable 

decisions with regard to the disclosure requirement to be made at the appropriate time. 

Due to its structural limitations, internal control over financial reporting and disclosure is 

not  intended  to  provide  absolute  assurance  that  misrepresentation  or  omission  of 

information in the statements will be avoided or discovered. 

Management, under the supervision of the Board of Directors, performed an examination 

and  evaluation  of  the  internal  control  over  financial  reporting  and  disclosure  in  the 

corporation and its effectiveness; 

The assessment of the effectiveness of the internal control over the financial reporting and 

disclosure  carried  out  by  Management  under  the  supervision  of  the  Board  of  Directors 

included: 

1.  Mapping and identifying the relevant business units, accounts, and processes that the 

Corporation considers very essential for financial reporting and disclosure; 

2.  Examining and updating the reporting and disclosure risks; 

3.  Updating the documentation of the controls that respond to the risks that have been 

identified, as well as the documentation of new controls; 

4.  Testing and evaluating the effectiveness of the aforementioned controls; 

5.  Overall assessment of the effectiveness of internal control. 

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The model for assessing the effectiveness of internal control over financial reporting and 

disclosure was based on the following components: 

1.  Controls at the organization level (Entity Level Controls); 

2.  The process of editing and closing the reports; 

3.  General controls of information systems (ITGC); 

4.  Controls over cash and debt management process; 

Based  on  the  evaluation  of  the  effectiveness  performed  by  Management  under  the 

supervision  of  the  board of  directors  as  detailed  above,  the  Board of Directors  and  the 

Corporation's Management concluded that the internal control over the financial reporting 

and disclosure in the Corporation as of December 31, 2023 is effective. 

Regarding  the  investigations  by  the  Israel  Securities  Authority  and  the  Israel  Police,  as 

detailed  in  Section  1.1.7  of  the  chapter  describing  the  Corporation's  business  in  this 

periodic  report,  the  Corporation  does  not  have  complete  information  regarding  the 

investigations  (mainly  regarding  transactions  related  to  the  previous  controlling 

shareholder of the Company and Bezeq and the former chairman of the Bezeq Board of 

Directors,  Mr.  Shaul  Elovich,  regarding  the  purchase  of  Yes  shares  and  the  provision  of 

satellite communication services to Yes), their content, materials, and the evidence in the 

possession of the law authorities in this case (although in January 2021, Bezeq received the 

core of the investigation material in connection with Case 4000, and although on February 

1, 2024, an agreement was signed between the State of Israel and Bezeq for the conditional 

cessation of proceedings). Accordingly, the Corporation is still unable to assess the effects 

of  the  investigations,  findings,  and  results  on  the  Corporation,  as  well  as  the  financial 

statements and estimates used in the preparation of these reports, if any. 

**** 

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(1)  Executive statements: 

(a)  Statement  of  the  CEO  pursuant  to  Regulation  9b(d)(1)  of  the  Securities  Regulations 

(Periodic and Immediate Reports), 5730-1970: 

I, Tomer Raved, declare that: 

(1)  I  examined  the  annual  report  of  B  Communications  Ltd.  (hereinafter  –  the 

“Corporation”) for year 2023 (hereinafter - "the Statements"); 

(2)  To my knowledge, the Statements do not include any misrepresentation of a material 

fact  and  do  not  lack  a  presentation  of  a  material  fact  necessary  so  that  the 

presentations  included  in  them,  in  light  of  the  circumstances  in  which  those 

representations were included, will not be misleading with respect to the reporting 

period; 

(3)  To my knowledge, the financial statements and other financial information contained 

in the Statements adequately reflect, in all material respects, the financial position, 

results of operations and cash flows of the Corporation for the dates and periods to 

which the statements relate; 

(4)  I revealed to the Corporation's Auditor, the Board of Directors, the Audit Committee 

and the committee for examining the Corporation's financial statements, based on 

my  most  recent  assessment  of  the  internal  control  over  financial  reporting  and 

disclosure: 

(A)  Any significant deficiencies and material vulnerabilities in the determination or 

exercise of internal control over the financial reporting and disclosure that are 

likely to adversely affect the Corporation's ability to collect, process, summarize 

or report financial information in a manner that casts doubt  on the financial 

reporting reliability and preparation of financial statements; and- 

(B)  Any  fraud,  whether  material  or 

immaterial, 

involving  the  CEO  or  his 

subordinates directly or involving other employees who have a significant role 

in the internal control over financial reporting and disclosure; 

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(5)  I, alone or with others in the Corporation: 

(A)  Have established controls and procedures, or have verified the determination 

and  existence of  controls and  procedures  under my supervision,  designed to 

ensure  that  material  information  relating  to  the  Corporation,  including  its 

subsidiaries  as  defined 

in  the  Securities  Regulations  (Annual  Financial 

Statements),  5770-2010,  is  brought  to  my  attention  by  others  in  the 

Corporation and its subsidiaries, in particular during the preparation period of 

the Reports; - 

(B)  Have  established controls and procedures, or verified  the  determination and 

existence  of  controls  and  procedures  under  my  supervision,  designed  to 

reasonably ensure the reliability of the financial reporting and the preparation 

of  the  financial  statements  in  accordance  with  the  provisions  of  the  law, 

including in accordance with generally accepted accounting principles; 

(C) 

I evaluated the effectiveness of the internal control over financial reporting and 

disclosure,  and  presented  in  this  report  the  conclusions  of  the  Board  of 

Directors and Management regarding the effectiveness of the aforementioned 

internal control as of the date of the Statements. 

Nothing  in  the  foregoing  shall  derogate  from  my  liability  or  the  liability  of  any  other 

person, under any law. 

Date: March 12, 2024 

_______________________ 

Tomer Raved, CEO 

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(b)  Statement  of  the  most  senior  officer  in  the  field  of  finance  pursuant  to  Regulation 

9b(d)(2) of the Securities Regulations (Periodic and Immediate Reports), 5730-1970: 

I, Itzik Tadmor, declare that: 

(1)  I  examined  the  statements  and  the  other  financial  information  contained  in  the 

statements of B Communications Ltd. (hereinafter – “the Corporation") for the year 

2023 (hereinafter – “the Statements"); 

(2)  To  the  best  of  my  knowledge,  the  Statements  and  the  other  financial  information 

contained in the Statements do not include any misrepresentation of a material fact 

and do not lack a presentation of a material fact necessary so that the presentations 

included in them, in light of the circumstances in which those representations were 

included, will not be misleading with respect to the reporting period; 

(3)  To  the  best  of  my  knowledge,  the  Statements  and  the  other  financial  information 

contained in the Statements adequately reflect, in all material respects, the financial 

position,  results  of operations  and  cash  flows  of  the  corporation  for the  dates  and 

periods to which the Statements relate; 

(4)  I revealed to the Corporation's Auditor, the Board of Directors, the Audit Committee 

and the committee for examining the Corporation's financial statements, based on my 

most recent assessment of the internal control over financial reporting and disclosure: 

(A)  Any significant deficiencies and material vulnerabitlies in the determination or 

exercise of internal control over financial reporting and disclosure as it relates to 

Statements and other financial information contained in the Statements that are 

likely to adversely affect a Corporation's ability to collect, process, summarize or 

report financial information In such a way as to cast doubt on the reliability of 

the  financial  reporting  and  the  preparation  of  the  financial  statements  in 

accordance with the provisions of the law; And - 

(B)  Any fraud, whether material or immaterial, involving the CEO or his subordinates 

directly or involving other employees who have a significant role in the internal 

control over financial reporting and disclosure; 

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(5) 

I, alone or with others in the Corporation: 

(A)  Have established controls and procedures, or have verified the determination 

and  existence of  controls and  procedures  under my supervision,  designed to 

ensure  that  material  information  relating  to  the  Corporation,  including  its 

subsidiaries  as  defined 

in  the  Securities  Regulations  (Annual  Financial 

Statements),  5770-2010,  is  brought  to  my  attention  by  others  in  the 

Corporation and its subsidiaries, in particular during the preparation period of 

the Statements; And -  

(B)  Have  established controls and procedures, or verified the determination and 

existence  of  controls  and  procedures  under  my  supervision,  designed  to 

reasonably ensure the reliability of the financial reporting and the preparation 

of  the  financial  statements  in  accordance  with  the  provisions  of  the  law, 

including in accordance with generally accepted accounting principles; And - 

(C) 

I evaluated the effectiveness of the internal control over financial reporting and 

disclosure,  insofar  as  it  relates  to  the  Statements  and  the  other  financial 

information contained in the Statements as of the date of the Statements; My 

conclusions  regarding  my  evaluation  as  mentioned  were  brought  before  the 

Board of Directors and Management and are included in this Report. 

Nothing  in  the  foregoing  shall  derogate  from  my  liability  or  the  liability  of  any  other 

person, under any law. 

Date: March 12, 2024 

_______________________ 

Itzik Tadmor, Chief Financial Officer 

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