Some of our markets are among the most challenging in the world when it comes to doing business due to bribery and corruption. In addition, the telecommunications industry is exposed to a high risk of corruption. We are committed to fighting corruption in all of its forms and to doing business with the highest sense of transparency and integrity. We do not accept bribery or corruption in any form.
- 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 for reporting concerns and potential violations.
- Certified ethics and compliance professionals in all region Eurasia companies (by end of 2016).
- Over 2,000 employees received ABC face to face training, and over 4,300 completed ABC e-learning.
- Review of compliance framework and ABC program carried out by Ethisphere.
- Due to the relocation of two region Eurasia ethics and compliance officers to group level, the number of markets with certified professionals remained at three.
In the last few years, we have come to understand the scale of the unethical and possibly illegal business practices in region Eurasia. The way that these markets were entered, for example by selecting partners with unclear ultimate beneficial owners, is not in line with our current responsible business practices. We have worked extensively to analyze our corruption risks, investigate potential fraud and corruption schemes, educate employees and build a culture where people are expected to speak up when they see potential or actual corrupt practices. Our work to fight corruption continues in the region by ensuring that sufficient capacity and knowledge is in place to continue this work under new ownership.
Although risks are lower in regions Sweden and Europe, we need to ensure solid anti-bribery and corruption (ABC) practices throughout our own operations and supply chain. As we mature, we are moving beyond awareness and training to process development and implementation. This supports the integration of ethical business conduct into everyday work and decision-making.
The ABC program
Telia Company's Board of Directors, Group Executive Management and chief ethics and compliance officer set the tone from the top and are responsible for the governance and compliance frameworks required to implement the ABC program.
The ABC program provides a systematic way of implementing the group ABC policy and instructions. The program is based on our 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 in 2013 taken firm action to better understand and improve control of risks and contextual challenges by increasing awareness of ABC risks, implementing control mechanisms, improving third party engagement and other processes, and carrying out extensive training. The ABC program is supported by the group-wide whistle-blowing process and Speak-Up Line.
The program is implemented using a risk-based approach, still focused in 2016 on region Eurasia. Regions Sweden and Europe started implementation in 2015 and are following the same implementation framework but with appropriate adjustments for the level of risk. The roll-outs shall be completed group-wide by 2018.
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 to the group Governance, Risk, Ethics and Compliance (GREC) meetings and to the Board of Directors.
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 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 anti-bribery or compliance certification through TRACE or SCCE, and due diligence experts are encouraged to do the same. By the end of 2016, a total of seven group and three country ethics and compliance officers, and one third party due diligence specialist, had been certified.
Work during the year
ABC risk assessments
Region Eurasia companies received prority in the execution of independent country, institutional and operational ABC risk assessments in 2013 and 2014. Risk mitigation action plans were formulated and implemented in the region during 2015. In 2016, follow-up first generation self-risk assessments were conducted in region Eurasia, and action plans updated. Self-risk assessments were also carried out in regions Sweden and Europe for the first time. These will be reviewed and supplemented during 2017.
The results from the risk assessments were analyzed together with input from third party due care processes and Speak-Up Line cases. Risk areas and action points were:
- Review the level of understanding of and compliance with policies and instructions regarding sponsorships, donations, gifts and hospitality.
- Quantify and fulfil resource and capacity building requirements for effective third party ABC risk management.
- Improve the quality of ABC training for employees and third parties.
- Extend the rollout of the conflict of interest (COI) registration tool, implement COI analysis and monitoring, and ensure that information can be accessed and shared for COI risk management purposes.
- Identify ABC risks in the customer due diligence process.
Policies and instructions
Local companies in region Eurasia established a framework for continuous self-monitoring of the adoption and implementation of group policies and instructions. Compliance status is reported quarterly in country and regional GREC meetings. This effort will be extended to regions Sweden and Europe in 2017.
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 ABC policy requires risk-based due diligence on third parties and inclusion of an anti-corruption clause in high risk engagement contracts.
During 2016, we continued the “backlog” projects which started in 2014 in region Eurasia. The projects reviewed third party engagements that we entered into prior to the implementation of an adequate due care process. The projects applied a risk-based approach to third-party screening and payment analysis, to ensure that business relations with high risk third parties were thoroughly reviewed and where necessary investigated, and that remedial actions - which could include freezing payments, terminating or re-negotiating contracts and permanent blocking - were taken as required.
By the end of the year, the backlog processes were completed or closing off in Kcell in Kazakhstan, Azercell in Azerbaijan, Ucell in Uzbekistan and Tcell in Tajikistan. Backlog cases raising potential corruption concerns were referred to the special investigations office for attention. Geocell in Georgia and Moldcell in Moldova will carry out their backlog projects in 2017.
The ABC program in region Eurasia was also strengthened by the implementation of the third party due care processes covering new and renewed third party engagements. Read more in "Responsible procurement".
In June, we engaged the Ethisphere Institute to review our ABC program and compliance framework. The best practice review was based on interviews, document review and benchmarking against peer groups, US and UK anti-bribery legislation and guidelines, UN and OECD guidance among others. According to Ethisphere’s assessment:
“Telia Company has made incredible progress since 2013 in developing its ethics and compliance program, most notably its anti-corruption program. Telia Company appears to be very engaged in implementing a best practice ethics and compliance program.”
Ethisphere’s recommendations will inform the planning of ABC program activities in 2017.
In May, we hosted the first Telecommunications Industry Integrity Initiative forum together with Transparency International Hungary. Eight companies including Orange, Vodafone, Ericsson and Nokia participated. The second meeting was held at Orange in January 2017. On the agenda were matters such as new bribery and corruption legislation, best practices sharing and drafting a charter for the Initiative. The initiative will be open for additional telecom companies to join.
Telia Company is also a member of TRACE International. We sponsored the TRACE scholarship program which fully funds one student from the CIS region to pursue ABC studies in the the US or the UK for one year.
Planned work in 2017
Work in 2017 will include:
- Based on learning from 2016, improve the ABC risk self-assessment tool and the competence of local ethics and compliance officers to carry out the assessment.
- Local ethics and compliance officers guided by the group ABC program lead will develop an annual plan for the ABC program for their operations. The group program lead monitors the progress of the program implementation on the local and regional levels.
- Multi-year advanced training plan for roles exposed to high corruption risks, to create a better understanding how to prevent, detect and report such risks.
- Basic ABC e-learning included as part of roll-out of the new Code of Responsible Business Conduct.
- Expand ABC training to third parties.
- Accelerated capacity building for third party due care in region Eurasia.
- Certification of the remaining ethics and compliance officers in region Eurasia and other ethics and compliance professionals elsewhere in the group.
- Testing the design, implementation and effectiveness of the ABC program.
Telia Company has made incredible progress since 2013 in developing its ethics and compliance program, most notably its anti-corruption program. Telia Company appears to be very engaged in implementing a best practice ethics and compliance program.
Source: Ethisphere Institute