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 Member Advisory Committee

Formation threshold

The committee is established within ninety (90) days of the date on which both of the following conditions are met simultaneously:

1. At least three (3) independent members: At least three active members who have no capital, management, or exclusive commercial relationship with 3C1B and who do not procure RegPEX infrastructure, transit services, or DWDM circuits from 3C1B.
2. At least five (5) total active members: Including 3C1B as Founding Member.

Independence is assessed by RegPEX management; disputes are handled through the complaint mechanism (§8.3).

Decision authority boundaries

The committee's authority is divided into two categories:

Binding decisions — the committee decides directly:

• Setting spending priorities within the existing IX operating budget (the revenue pool collected from member fees)
• Proposing and approving changes to peering policy, AUP, and technical requirements documents (pricing excluded)
• Accepting or rejecting new membership applications
• Managing complaint processes under this policy

Advisory decisions — the committee recommends, 3C1B decides:

• Opening a new POP or closing an existing one
• Infrastructure investments (new hardware, capacity upgrades, new software licences)
• Changing the transport provider or adding an additional provider
• Changes to the pricing tariff
• Changes to this policy document itself

For advisory matters, 3C1B is obliged to consider the committee's recommendation; however, the final decision and financial responsibility remain with 3C1B. If 3C1B rejects a committee recommendation, it must notify the committee in writing with its reasons, and those reasons are appended to the meeting minutes.

Budget relationship

The committee's binding decision authority is limited to the operating budget funded by member fees. The committee may not commit expenditure beyond that budget or make new capital investment decisions. Investment decisions — as the party that builds the infrastructure, holds the licence, and bears the financial risk — rest exclusively with 3C1B.

Procedural rules

• Each active member has equal voting rights. 3C1B's Founding Member status confers no additional vote.
• Meetings are held at least every six (6) months; an extraordinary meeting may be convened within fifteen (15) days upon any member's written request.
• Binding decisions are adopted by a simple majority of members present; in the event of a tie, the chairperson's vote is decisive.
• Meeting minutes are distributed to all members within ten (10) business days.

8.3 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. Escalate to the Member Advisory Committee (once established) if the response is unsatisfactory.
4. Lodge a complaint with BTK as a further escalation step.

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).
• Changes are presented to the Member Advisory Committee (once established).
• Sections 6 and 7 concerning traffic neutrality and equal treatment may not be amended in a restrictive manner without the approval of four-fifths (4/5) of members.

12. Independent National IXP — Good Faith Statement

RegPEX was founded with a vision of supporting the development of Turkey’s internet ecosystem. In line with that vision, 3C1B makes the following public good faith commitment.

In the event that a national internet exchange point operating under an independent non-profit association or foundation, covering Turkey as a whole, and open to all IX participants on equal terms:

• Is actively and operationally running, and
• Has its operational independence and governance structure clearly visible to existing RegPEX members,

RegPEX will conduct a member survey asking all current active members whether they wish to join such a structure.

Survey and decision framework:

• The survey is distributed to all active members on equal terms and remains open for at least 30 days.
• If two-thirds (66.7%) of voting members express a wish to join and the independent IXP explicitly consents to the integration, RegPEX will initiate a formal working process towards integration.
• The conditions, scope, and timeline of that working process will be determined through negotiation between the parties; this clause creates no obligation to transfer or any specific commitment.
• Survey results will be shared with all members.

This clause is not legally binding on any party. It is a good faith statement by RegPEX in support of Turkey’s internet ecosystem.

13. Contact

• Neutrality and complaints: Contact Form — include "Neutrality Complaint" in the subject field
• General policy enquiries: Contact Form
• NOC: noc@regpex.tr / +90 (312) 486 01 86

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.