Anti-bribery and corruption

Some of our markets are among the most challenging in the world to do business in due to bribery and corruption. In addition, the telecommunications industry is exposed to a high risk of corruption.
Strategic objective

2018 Goals

2015 Outcome

  • Best in class anti-bribery and corruption (ABC) program.
  • Zero tolerance for unethical business conduct.

  • All employees are aware of our ABC requirements.
  • All employees are familiar with the channels on how to report concerns and potential violations.
  • Certified ethics and compliance professionals in all region Eurasia markets (by end of 2016).
  • Over 3,200 employees received ABC face to face training, and almost 5,500 completed ABC e-learning.
  • According to the Responsible Business Index survey, employees are aware of how, and confident about, speaking up.
  • 3 ethics and compliance officers in region Eurasia completed compliance certification or accreditation.
Context

In the last few years we have understood the depth of the unethical and possibly illegal business practices in region Eurasia. The way that these markets have been entered, for example by selecting partners with unclear ultimate beneficial owners, is not in line with current responsible business practices. To remediate the issues we have worked extensively with analyzing our risks, investigating potential fraud and corruption schemes, training employees and building a culture where no one is afraid of speaking up when they see potential or actual corrupt practices.

Despite the decision to leave the region over time, we will continue our efforts to fight corruption with an unchanged focus, in the region and throughout the group. See more in “Responsible exit from region Eurasia.”

»Because it is a regulated industry that requires government approvals and necessitates large capital outlays, the telecommunications industry is particularly susceptible to a range of corrupt practices. Key areas where the threat of corruption is significant include the licensing process, market regulation and price setting, the supply chain, and third-party management and customer services. Corrupt practices in the sector are familiar: bribery, misuse of gifts and entertainment, political corruption, cronyism, nepotism and conflict of interest, money laundering, corporate misconduct, and lack of integrity.«

Assessing the World’s Largest Telecommunications Companies report, Transparency International, 2015


»TeliaSonera does not accept any form of bribery or corrupt business practices.«

 
Governance

Zero tolerance against bribery and corruption

We are committed to fighting corruption in all of its forms and to do business with the highest sense of transparency and integrity. We do not accept bribery or corruption in any form. This message is enforced by the Board of Directors, CEO and Group Executive Management. Our group anti-bribery and corruption (ABC) policy is shared with government representatives and other stakeholders.

Our ABC program

To ensure compliance with laws and ethical standards and to manage the risk of corruption and unethical business practices, we launched the ABC program in 2013. The ABC program is implemented using a risk-based approach throughout the group, with focus on region Eurasia. It is based on TeliaSonera’s compliance framework and includes the key elements of an effective compliance program and adequate procedures as set forth in the U.S. Sentencing Guidelines and the UK Bribery Act Adequate Procedures. We have since its launch taken firm action to better understand and improve control of risks and contextual challenges by increasing awareness of issues, implementing control mechanisms, improving processes and carrying out extensive training efforts.

Ethics and compliance network

The ABC program is managed by the group ethics and compliance office, which is responsible for the program design and annual plan as well as follow-up and reporting. Program implementation is the responsibility of local line organizations as well as group functions, with strong support from the ethics and compliance network. This network includes some 30 employees: group and regional ethics and compliance officers, a dedicated officer or coordinator in each local company, due diligence experts in high risk jurisdictions and the group special investigations office. In addition, the supply chain excellence team in group procurement works with ensuring compliance in the supply chain and supplier due diligence. See more in “Responsible procurement.

 


»TeliaSonera employees and representatives are bound – in all activities – to the code of ethics and conduct as well as to policies, instructions, local laws and legislation with extraterritorial reach.«

Activities during the year

Risk assessment

Together with law firm Mannheimer Swartling, we developed an ABC self-assessment tool. Based on the country and operational risk assessment templates used in 2014, it includes assessment of governance, risk and compliance in relation to ABC. The tool will be used to assess the corruption risk in country operations and how well existing governance and control mechanisms are mitigating it.

Organization

All country ethics and compliance officers and due diligence experts in region Eurasia are required to complete anti-bribery or compliance certification through TRACE or SCCE. Three employees were certified during 2015 and five have enrolled for certification to be completed in 2016.

Policies and procedures

Based on lessons learned and frequently asked questions, we updated the ABC policy and instruction to provide more precise requirements for third parties as well as guidelines for gifts and hospitality. New group instructions on internal investigations and on interaction with government authorities were also introduced.

The ABC self-assessment tool will enable more transparent follow-up on actual compliance and implementation of the ABC policy and related instructions. The purpose is to find a transparent way to assess and communicate how well the guiding documents have been implemented and adhered to in practice.

Training and communication

New employees in region Eurasia must take part in ABC face to face training. During the year, over 3,200 new and previous employees received this training. Additionally, employees in high risk functions (e.g. management teams, legal, procurement, government relations and public sales) receive annual training on ethical dilemmas and decision-making. We also included an ABC e-learning course developed by TRACE International in our training library, which is available to all employees. During the year, almost 5,500 employees completed the TRACE course.

We launched the Responsible Business Index (RBI) survey to understand employee awareness of the code of ethics and conduct, ABC-related principles, processes for reporting violations and more. The results show that employees are generally aware of the main principles and reporting channels and express confidence in using them. See more about the results in “Sustainability in TeliaSonera.”

Third-party due care

The purpose of third-party due care is to enforce our ABC principles throughout the supply chain and to all third parties we engage with. Our policy requires risk-based due diligence on third parties and inclusion of an anti-corruption clause in high risk engagement contracts.

In 2014, we initiated a “backlog” project to look into third party engagements that we entered into prior to the implementation of the due diligence process. The project applies a risk-based approach to third-party screening and payment analysis to ensure that business relations with high risk third parties are thoroughly investigated and that appropriate actions are taken in a timely manner.

In 2015, more than 41,000 third-party business relations in Azercell in Azerbaijan, Kcell in Kazakhstan and Ucell in Uzbekistan were identified, with in-depth due diligence performed on 1,100 of these. As a result of the analysis, several contracts were terminated or re-negotiated, payments were frozen and suppliers blocked for further use.

Challenging areas continue to be dealers, distributors and site leasers. The risks do not relate to the financial magnitude but rather the nature and volume of contracts.

Whistle-blowing and special investigations

Lessons learned from internal cases were integrated into training courses to ensure that we use relevant dilemmas and cases. Training was provided to senior management and employees involved in investigations. See more about cases during the year in Corporate Governance, section “Enterprise risk management (ERM) framework.”

Continuous improvement

We follow up on internal ABC awareness through RBI, local surveys in conjunction with training, Speak-Up Line cases and employee dialog. The input gathered is used to define further remedial and improvement actions and integrate them into our plans and training.

External engagement includes involvement with organizations such as TRACE International and the Transparency International Telecommunications Integrity Initiative, which was launched in November together with Transparency International Hungary. The purpose of the initiative is to facilitate industry-wide dialog on corruption risks and best practices in the telecommunications industry.

We will continue to engage an Independent Compliance Advisor (ICA) from the Free Group at least until the investigations of the authorities in the Netherlands, Sweden and the U.S. (Department of Justice, and Securities and Exchange Commission) have been concluded.

Planned activities in 2016

In 2015, we applied for “Ethisphere” certification of the ABC program. The process will run for approximately four months, after which we will receive independent certification of our program structure and implementation and recommendations for further improvement.

We will complete the “backlog” project in the other region Eurasia countries, with handover from the group ethics and compliance office to country organizations.

During the first half of 2016, country ethics and compliance officers will facilitate ABC assessments together with country management which will result in country-specific action plans. This is an important step to decide on priorities for regions Sweden and Europe.

The dialog with the World Economic Forum and Partnering against Corruption Initiative will continue, as well as our involvement in forums such as the C5 anti-corruption conferences. In February 2016, we will host the first meeting of the Telecommunications Integrity Initiative.

We will also sponsor the TRACE scholarship program, which fully funds one student from Eurasia/CIS to pursue studies in the US or the UK for one year. The studies will be connected to advancing commercial transparency and anti-bribery compliance standards.

CASE:

Third party due diligence gives No-Go

Because the telecommunications industry is heavily regulated, operators need to interact frequently with regulatory authorities. One such interaction is the need to update regulatory records – a standard procedure as networks are constantly updated.

In early 2015, when one of our operators applied to update regulatory records, an alternative process was proposed. This time, the operator was not only asked to submit the documents, but the person at the regulatory agency proposed the company to use a specific consultant to prepare the necessary documents and file the application. In addition we were told that the consultant had to perform a feasibility study to assess the details of what should be updated. The regulatory authority explained that this would make the process more efficient for the company.

The local company acted in line with the procurement process and escalated a due diligence request to group level. During this process, several critical issues were noted: there were no legal requirements or official processes for the feasibility study proposed, and there was a possible conflict of interest between the person at the regulatory authority and the proposed consultant. The risk for breaching the group ABC policy was evident, and the due diligence process resulted in a “no-go” decision.

© TeliaSonera 2015
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