Anti-bribery and corruption
- Best-in-class anti-bribery and corruption (ABC) program
- Zero tolerance for unethical business practices
- Third-party ABC due care guidelines issued
- Case-based ABC training on third-party due care guidelines conducted for ethics and compliance professionals in region Eurasia
- Seven group and six country ethics and compliance officers and two third-party due diligence specialists certified
- Approximately 2,500 employees completed ABC e-learning
- All employees are aware of our ABC requirements
- All employees are familiar with how to report concerns and potential violations
- Certified ethics and compliance professionals in all region Eurasia markets
- Test design, implementation and effectiveness of the ABC program
- Revise methodology for periodic ABC risk self-assessments
- Train local ethics and compliance officers to strengthen capacity to carry out risk self-assessments
- Develop ABC action plans for core markets
- Revise framework and content for ABC training program
This focus area is governed by the Group policy – Anti-bribery and corruption.
The ABC program
The ABC program provides a systematic way of implementing the ABC policy and related instructions. The program is based on the compliance framework and includes the key elements of an effective compliance program and adequate procedures as set forth in the US Sentencing Guidelines and the UK Bribery Act Adequate Procedures. Telia Company’s Board, Group Executive Management and chief ethics and compliance officer oversee the progress and governance related to implementation of the program. Since it was launched in 2013, we have taken firm action to better understand and improve control of risks and contextual challenges by increasing awareness of ABC risks, implementing control mechanisms, improving thirdparty engagement and other processes, and carrying out extensive training. The ABC program is supported by the group-wide whistleblowing process and Speak-Up Line.
The program has been implemented using a risk-based approach, with the focus in 2017 on region Eurasia. Core markets follow the same implementation framework but with appropriate adjustments for the level of risk.
Ethics and compliance network
The ABC program is managed by the group ethics and compliance office, which is responsible for program design and annual planning as well as follow-up and reporting to the group Governance, Risk, Ethics and Compliance (GREC) meetings and to the Audit and Responsible Business Committee.
Program implementation is the responsibility of local organizations as well as group functions, with strong support from the ethics and compliance network. This network includes group and regional ethics and compliance officers, dedicated officers or coordinators in each local company who act as focal points for other compliance activities including GREC meetings, due diligence experts in high risk markets and the group special investigations office which handles internal investigations related to potential corruption or fraud.
All country ethics and compliance officers are required to complete external anti-bribery or compliance certification, and due diligence experts are encouraged to do the same. By the end of 2017, a total of seven group and six country ethics and compliance officers and two third-party due diligence specialists were certified.
In addition, approximately 2,500 employees in defined target groups completed ABC-specific e-learning.
Work during the year
ABC risk assessments
Companies in region Eurasia continued to follow up on the implementation of ABC action plans based on the results of ABC risk self-assessments carried out in 2016. Progress is monitored quarterly and reported to the region GREC meetings.
Companies in core markets carried out risk selfassessments during the fourth quarter. Action plans will be developed and reviewed in 2018.
Third-party due care
Since 2014, we have been running retrospective due diligence projects on existing suppliers and third-party engagements in region Eurasia. The aim has been to understand and mitigate ABC risks in our supply chain and in other high-risk third-party engagements that we entered into prior to the implementation of an adequate ABC due care process.
Geocell in Georgia and Moldcell in Moldova started their backlog projects in 2017. Backlog processes were completed in Azercell in Azerbaijan, Kcell in Kazakhstan and Ucell in Uzbekistan. Results were summarized in closure reports available for use by local management as well as ethics and compliance professionals and due diligence officers. Cases involving potential corruption concerns were referred to the special investigations office.
The closure report for Tcell in Tajikistan was completed ahead of the divestment and the findings were handed over to the new owner.
New third-party due care guidelines
The ABC program was strengthened by the introduction of third party due care guidelines. The document sets forth principles and describes the checks that should be performed to meet the ABC requirements of third party due care. The primary goal is to gain knowledge of business partners and achieve reasonable assurance that existing and prospective third parties do not and will not engage in corrupt practices.
In connection with the introduction of the guide-lines, case-based advanced ABC training was developed and a first round of training was conducted for ethics and compliance professionals
in region Eurasia. The training material includes:
- A case study of a listed company’s failures to adhere to local corruption legislation
- Methodology in identifying and determining high-risk third parties
- Levels of due diligence to apply in accordance with the associated risk
- Examples of potential corruption red flags
It also includes best practice built on experience and knowledge from our own operations and investigations, recommendations on mitigation actions and recommendations for the separate stages of the third party management process, such as pre-engagement and post-engagement controls, selection, negotiation, contracting, payment approval and service delivery.