In recent years, we have invested heavily in implementing a systematic framework for responsible business in our operations. This work has covered the entire group, but the greatest impact has been on our subsidiaries in region Eurasia.
With the announcement in September that we are leaving region Eurasia over time, we need to uphold our efforts and high standards as long as we have management control of the companies involved, to prepare them for divestment and ensure a responsible exit. After we hand over management control to new owners, we will have limited possibilities to influence their business practices. However, we can share our knowledge and emphasize to prospective buyers the importance of running the operations in a sustainable and responsible manner.
Increased responsible business efforts
During the last few years, we have significantly developed the expertise, capabilities and confidence of our companies and employees in the region through implementing:
- Anti-bribery and corruption face to face training of all employees, and dilemma training for high-risk functions
- Ethics and compliance officers in all countries
- A process for assessing and escalating non-conventional government requests with potential serious impacts on freedom of expression and privacy
- Privacy officers responsible for customer privacy risk assessments and mitigation plans
- Independently hosted Speak-Up Line in local languages
- Localized group templates and tools including:
- Anti-bribery and corruption risk assessment tools
- Due diligence questionnaires and third-party management tool
- Risk assessment template for sponsorships and donations
- Control framework and self-assessment tool for risks within financial processes
- Dialog with local authorities on the importance of transparency in how donations to public funds are used
The group ethics and compliance office is closely involved in the divestment process to ensure that we identify and mitigate any risk of corruption or unethical transactions. This is done through:
- Due diligence on potential buyers, shareholders and directors as well as any agents or local partners involved, including control of ultimate beneficial owners
- Initial pre-signing compliance review of policies, processes and compliance programs of the potential buyers
- Actively sharing our compliance framework, policies and procedures
- Participation in company presentations to present our compliance framework and show our commitment to responsible business
To ensure a thorough understanding of the risks related to divestment, we will carry out human rights impact assessments in all our Eurasian markets. These will provide valuable recommendations for mitigation actions during and after the exit process. See more in “Human rights impact assessments – focus on region Eurasia.”
Ensuring employee safety
We recognize that many employees in the region have made great efforts to promote responsible business in areas such as freedom of expression and privacy, other human rights and in anti-bribery and corruption – areas that in many respects are controversial in their home countries. Speaking up may, during or after the divestment process, expose these employees personally or professionally to unfair treatment or even danger. We consider the fair treatment and safety of our employees to be of the utmost importance. For this reason, we are taking necessary action to ensure that we identify and support these individuals.
Sharing lessons learned
We will continue to share lessons learned from the region within our industry, for example, through the Telecommunications Industry Dialogue and the Telecommunications Integrity Initiative. We will also actively seek to include the new owners in these dialogs and initiatives.