RegPEX Functional Independence and Neutrality Policy

1. Purpose and Scope

This document defines how RegPEX Internet Exchange Point (IXP) maintains a fair, transparent, and neutral environment for all members, given that the operating entity also participates in the exchange as a member and serves as the inter-site transport provider.

RegPEX operates under the 3C1B Telekomünikasyon A.Ş. legal entity, which holds an Infrastructure Operations (AIH) licence issued by the Information and Communication Technologies Authority (BTK) of Türkiye. 3C1B is also RegPEX's founding member (AS6823) and the provider of DWDM inter-POP transport circuits.

This multi-role structure is a regulatory and practical reality — there is no separate IXP licence category under Turkish law — and is consistent with how many successful exchanges started internationally. This policy documents the mechanisms that make the arrangement transparent and auditable for all members.

2. Definitions

3. Legal Framework and Regulatory Compliance

3.1 Licence Status

RegPEX operates under the AIH licence granted to 3C1B pursuant to Law No. 5809 on Electronic Communications and the BTK Authorisation Regulation. No separate IXP-specific licence category currently exists under Turkish law; the AIH licence is the applicable authorisation.

3.2 Competition Law Compliance

3C1B acknowledges its obligations under Law No. 4054 on the Protection of Competition and commits to:

• Applying access conditions to the RegPEX fabric equally and without discrimination for all members.
• Ensuring that 3C1B's ISP activities do not restrict other members' access to IX services.
• Keeping traffic engineering decisions on the IX fabric independent of 3C1B's commercial interests.

3.3 Regulatory Notifications

The functional separation structure described in this policy is consistent with operator information filed with BTK. Material structural changes will be notified to BTK as required by applicable regulations.

4. The Three Roles of 3C1B and Their Boundaries

3C1B performs three functionally distinct roles within the RegPEX ecosystem. Each role is governed by separate rules, decision mechanisms, and accountability protocols.

4.1 Role A — IX Operator

3C1B operates RegPEX under its AIH licence. In this role it:

• Builds and operates IX infrastructure (switches, route servers, monitoring).
• Evaluates membership applications against technical requirements.
• Maintains peering policy, AUP, and technical requirements documents.
• Retains the right to intervene for network security purposes.

Boundary: In its IX Operator role, 3C1B may not grant the Founding Member any privilege in terms of rules, access, or pricing.

4.2 Role B — DWDM Transport Provider

3C1B provides the inter-site DWDM circuits connecting RegPEX POPs. In this role it:

• Operates circuits between Ankara ODTÜ, Istanbul, Sofia, and other POPs.
• Is obligated to meet the circuit quality and SLA commitments documented in the wholesale transport agreement.
• May not inspect, shape, or prioritise traffic on the IX fabric in its capacity as transport provider.

Boundary: 3C1B in its transport role may not prevent another IX member or third party from providing DWDM or alternative connectivity on the same routes. RegPEX retains the right to migrate to an alternative transport provider.

Transport SLA: The circuit parameters (capacity, MTU, uptime) committed by 3C1B as transport provider are defined in a separate wholesale service agreement between RegPEX and 3C1B, a summary of which is published on the RegPEX website.

4.3 Role C — Founding Member (AS6823)

3C1B's ISP division connects to RegPEX as a member under AS6823. In this role it:

• Is subject to the same technical requirements and policies as all other members.
• Signs a separate membership agreement.
• Receives IP address and port allocation on equal terms via the peering LAN.
• Is subject to identical route server filtering rules as all other members.

Boundary: Founding Member status confers no membership exemption, discounted fee, priority port allocation, or policy exception.

5. Functional Separation Mechanisms

5.1 Financial Separation

RegPEX is tracked as a separate cost/revenue centre in 3C1B's accounting system:

• Investment and operational costs attributable to IX infrastructure are reported separately from 3C1B's ISP activities.
• Fees paid for transport circuits are documented at market-consistent rates.
• An annual income/expenditure summary is shared with members.

5.2 Operational Separation

• NOC access logging: All configuration changes to the IX fabric are logged with user identity, timestamp, and change detail. Logs are reviewed periodically.
• Functional independence of personnel: Staff making IX operational decisions are operationally independent from 3C1B's ISP sales and marketing units.
• Change management: Any configuration change affecting the IX fabric follows the change management process defined in docs/noc-procedures.md. No exceptional change may be made in favour of 3C1B's ISP business.

5.3 Technical Separation

Technical boundaries are detailed in docs/ix-iss-separation-policy.md. Summary rules:

The IX fabric is configured so that carrying 3C1B ISP traffic is technically impossible. This is documented in the infra/junos/ configuration files.

6. Traffic Neutrality

RegPEX treats all members' traffic equally. Under no circumstances may:

• Any member's traffic be prioritised or delayed relative to another's.
• 3C1B ISP's competitors receive different treatment on the IX fabric.
• QoS or traffic shaping settings be applied asymmetrically across members.
• Route server filtering rules be applied differently to specific members or AS groups.

Violation of this principle may also constitute a breach of Law No. 4054 on the part of RegPEX management.

7. Pricing Neutrality

• Membership fees are calculated from the same tariff schedule for all members (policies/en/pricing.mdx).
• Founding Member status does not entitle 3C1B to any fee waiver or discount.
• Fees paid to 3C1B for transport circuits are proportionate to documented wholesale market rates.
• Changes to the pricing policy notify 3C1B in its Founding Member capacity at the same time as all other members.

8. Governance and Oversight

8.1 Current Structure

RegPEX is currently governed within 3C1B's internal management structure. Decisions concerning IX operations are made pursuant to defined decision protocols and the principles set out in this policy.

8.2 Complaint Mechanism

A member with a substantiated complaint that the neutrality or equal treatment principles of this policy have been breached may:

1. Submit the complaint in writing to legal@regpex.tr.
2. Receive a written response from RegPEX management within fifteen (15) business days.
3. If the response is unsatisfactory, the right to lodge a complaint with BTK is reserved.

9. Transparency Commitments

RegPEX keeps the following information publicly available on an ongoing basis:

10. Policy Breach and Consequences

A breach of this policy — particularly violations of traffic neutrality and equal treatment principles — may result in:

1. Removal of the relevant personnel from IX operational duties.
2. Member notification and public disclosure.
3. Member compensation claims.
4. Notification to BTK.
5. The obligation to report to the Competition Authority (Rekabet Kurumu).

11. Policy Changes

• Changes to this policy are announced at least 60 days in advance (twice the 30-day notice period applicable to other RegPEX policies).

12. Contact

• Neutrality and complaints: Contact Form — include "Neutrality Complaint" in the subject field
• General policy enquiries: Contact Form
• NOC: noc@regpex.tr / +90 (312) 988 00 00

This policy documents RegPEX's functional independence and equal treatment principles for all members. Independent legal advice is recommended in situations requiring legal interpretation. Document last updated: 2026-03-24.