Case now with the OAIC. The TIO has referred related matters to its Systemics Team (potential for an ACMA escalation).
Analysts are probing TPG’s governance and disclosure. And now, the company’s CEO has allegedly contacted a complainant’s workplace to “resolve” the issue.
The question on everyone’s mind:
When will TPG Telecom address its continuous disclosure obligations under Listing Rule 3.1/3.1B?
Background: Why Continuous Disclosure Matters
ASX Listing Rule 3.1 requires that any information a reasonable person would expect to have a material effect on the price or value of a company’s securities must be disclosed immediately.
If an officer of an ASX-listed company becomes aware of market-sensitive information, regulatory escalation, governance failings, and/or potential privacy breaches, it must not be buried.
For Context
Possible Matters Requiring Disclosure
TPG Telecom (ASX: TPG) faces a series of converging developments that appear material under Listing Rule 3.1 / 3.1B:
1️⃣ National Media Exposure
2GB’s Drive program brought mainstream attention to billing, credit-management and systemic-error concerns at Vodafone Australia / TPG Telecom.
The host described the situation as “Robodebt Mark II” and added, “It shouldn’t be this hard to get the billing right.”
This level of national coverage directly affects public perception, regulatory risk, and brand value. 2GB is Sydney’s largest radio station by cumulative audience with the segment estimated to reach at least 212,000+ listeners, before increasing to listeners on the podcast, as per the latest GFK’s Radio Ratings Survey 6 2025.
You can listen to that segment here, at the 31 minute mark.
2️⃣ Questionable Public Representations
However, data suggests churn is significantly higher, CAC is front-loaded, tenure is less than half that of Netflix, and profitability assumptions and revenue predictability may have been overstated. Worst of all, some felix cohorts may be canabilising market share from the more profitable Vodafone postpaid segment, meaning each incremental subscriber results in an instant loss at the Group level.
A formal submission covering these concerns has been lodged with ASX Compliance and acknowledged.
If the internal data contradicts the public narrative, it raises questions about whether investors have received a complete picture of Felix Mobile’s underlying economics. That gap, if material, engages questions about continuous disclosure obligations under ASX Listing Rule 3.1.
3️⃣ Escalating Complaint Trends
The Telecommunications Industry Ombudsman (TIO) confirmed in writing that Vodafone Australia/TPG Telecom complaints have been referred to its Systemics Team, which considers referrals to the Australian Communications and Media Authority (ACMA) for systemic related complaints and patterns.
That delta alone may warrant disclosure.
4️⃣ Privacy and Compliance Exposure
An OAIC complaint alleging breaches of APP 10, 12 and 13 (accuracy, access, and correction), along with other breaches of other Australian Privacy Principles and the Privacy Act, has been formally accepted into Intake and is awaiting case allocation (confirmed in writing).
Depending on findings, OAIC outcomes can be enforceable under the Privacy Act 1988 (Cth) and may be referred to the Federal Court, a clear potential material risk to shareholders.
5️⃣ Public and Regulatory Momentum
The voda.fail campaign has now surpassed 1.5+ million views in seven weeks, with hundreds of affected consumers coming forward describing similar issues in billing, coverage, and credit-management. This includes vulnerable customers, including the elderly, widows, and domestic violence survivors.
The scale and virality create ongoing reputational pressure with direct investor relevance.
6️⃣ Alleged Executive Conduct
It has been alleged that TPG Telecom’s CEO, Iñaki Berroeta, personally contacted the complainant’s workplace to “discuss” and “resolve” the matter this week.
If correct, this represents an extraordinary governance lapse and potential privacy breach.
Such contact raises obvious questions about whether it was intended to influence an active regulatory process, and whether it falls within the conduct protections under the Corporations Act whistleblower framework.
Such contact serves no legitimate business purpose, falls outside authorised complaint channels, and raises serious questions about internal culture, judgment, and disclosure control.
Material Factors That May Warrant ASX Disclosure
- Regulatory escalation: OAIC acceptance, TIO Systemics referral, and potential furure ACMA involvement.
- Mainstream scrutiny: 2GB broadcast, 1.5+ million social impressions, and broker commentary citing structural risks.
- Operational transparency: Removal of churn % and ARPU metrics, undermining investor visibility post-MOCN.
- Dividend headroom: Persistent concern that dividend payouts have exceeded sustainable free cash flow in the last few years.
- Governance signals: Alleged off-channel CEO conduct that could breach ASX Corporate Governance Principle 3 obligations for lawful, ethical, and responsible culture.
- Dealer-channel exposure: Industry chatter and market murmurs suggest variability in third-party sales conduct via the dealer channel, pointing to possible compliance and disclosure risks if dealer practices are not tightly governed in line with the Australian Consumer Law (ACL).
“Disclosure delayed is confidence destroyed.
Markets can forgive mistakes — they don’t forgive silence.”
Board and Chair Accountability
The obligation to maintain an ethical culture rests squarely with the Chair of the Board and non-executive directors.
Under Principle 3 of the ASX Corporate Governance Council’s Principles and Recommendations, the board must “instil and continually reinforce a culture of acting lawfully, ethically and responsibly.”
If senior-executive behaviour or disclosure control fails that standard, the Chair must ensure immediate correction and transparent communication with shareholders.
Regulatory Pathways for Concerned Shareholders
Investors or members of the public may raise potential disclosure or director-duty concerns directly with:
- ASX Compliance: for possible continuous-disclosure or governance-principle breaches.
- ASIC: using its misconduct-reporting form for suspected failures of directors’ duties under the Corporations Act 2001 (Cth).
These are the proper, lawful avenues for transparency, unlike any attempt to contact or pressure a complainant’s employer.
Executive Conduct and Governance Red Flags
If confirmed, the alleged CEO contact with a complainant’s workplace represents a severe breakdown of ethical and governance judgment.
Contact between a listed company executive and a complainant’s employer during active regulatory proceedings raises serious questions about governance boundaries and appropriate escalation channels.
Such behaviour may engage privacy law, raise questions about disclosure controls, and breach the ethical-culture obligations of the ASX Corporate Governance Principles.
The board must investigate and disclose any verified incident without delay.
We Will Not Be Bullied or Intimidated into Silence
Consumers, shareholders, and whistleblowers deserve protection, not pressure.
This campaign will continue to shine light on misconduct, misrepresentation, and regulatory evasion until transparency is restored.
Right of Reply
TPG Telecom Limited and its representatives are invited to provide clarification or correction with supporting evidence. All verified statements will be published transparently.
Disclaimer
This publication is provided for informational and educational purposes only.
It reflects the author’s independent analysis and opinion based on publicly available data and regulator correspondence.
It does not constitute financial advice or a recommendation to buy, hold or sell any security.
Readers should conduct their own research and seek professional advice before making investment decisions.
References to media coverage reflect publicly published articles and the author’s experience engaging with those outlets. No allegation of improper conduct by any journalist or media organisation is made.
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