Sustaining a Culture of Ethics & Compliance
At Millicom, we are committed to the highest level of ethics and compliance. Our commitment to compliance begins with each and every one of our employees. It provides our business with a competitive advantage and allows Millicom to be a social good in all of our markets. Just as infrastructure companies in prior generations built the roads and highways that connect the countries in which we operate and facilitated economic growth and development, Millicom builds digital highways. By connecting our markets through mobile services, broadband internet, and cable television, Millicom fosters economic growth and development. These digital highways create opportunities for people and communities to increase their economic stability and opportunity as well as the economic prosperity of the countries in which we operate.
At Millicom, we all are responsible for understanding the important legal and ethical issues that affect our business. All employees are expected to act with integrity at all times and make business happen the right way. Integrity means more than just complying with the law; it means acting in an ethical manner as described in the company’s Code of Conduct.
The CEO and Executive Team are committed to our Sangre Tigo and are actively involved in fostering a culture of ethics and compliance from the top across all our lines of business.
As the Chairman of our Board, José Antonio Ríos García stated during 2019 “On behalf of the Board, I would like to reaffirm our commitment to a culture of doing the right things in the right way, encompassed by “Sangre Tigo”, which builds our strength and success. We are proud to be a leader in ethics and compliance in our markets. We look forward to engaging with you and thank you for being part of the Millicom journey.”
In order to assist our employees and the external parties we interact with, the Compliance function is organized around three pillars: Prevent, Detect, and Respond.
Prevent: Every employee has a responsibility to prevent corruption in our company. In order to assist employees in this mission, we foster a strong compliance tone from the top of our business, conduct annual training to increase our Compliance IQ, and conduct compliance due diligence on our third parties as part of the on-boarding process.
Detect: We know that corruption and non-compliance can exist despite the best prevention efforts. Therefore, we build systems to detect corruption within our company. To this end we have a strong Investigations function that works to detect and respond to issues, and advises the Company on addressing risk; an anonymous ethics line for employees and others to report concerns; regular internal audit of all functions including Compliance; and are engaging in a process to conduct compliance due diligence on all third parties currently working with us.
Respond: Once corruption or non-compliance is detected, we move quickly to remove or remediate. Our Investigation function works efficiently to provide fair counsel and remedies that the Company can implement quickly. Internal Audit works with the business to develop action plans to address all of its findings, which they then implement. Third parties with significant findings in compliance due diligence are terminated or remediated. The performance of all of our senior management is measured by Compliance KPIs, requiring continual improvement to compliance-related issues.’
Global Compliance Officer
Salvador Escalon is the Chief Legal, Ethics and Compliance Officer. As the leader of Millicom’s Compliance function he is committed to maintaining a world-class compliance program. He reports directly to the Compliance and Business Conduct Committee of the Board of Directors, with a dotted line to the CEO. He leads a team of Compliance employees throughout the organization and in each of Millicom’s markets. He is responsible for Compliance, AML, and Strategic Response. Additional compliance support is provided by groups and individuals in areas such as Legal, Security, Internal Audit, Human Resources, Finance, Business Control, and Corporate Governance.
Compliance and Business Conduct Committee of the Board of Directors
In November 2015 the Millicom Board of Directors established the Compliance and Business Conduct Committee. The Committee is currently chaired by Odilon Almeida with Mercedes Johnson and Lars-Ake Norling as members.
Millicom’s Compliance and Business Conduct Committee oversees and makes recommendations to the Board regarding the Group’s compliance programs and standards of business conduct. More specifically, the Compliance and Business Conduct Committee:
- Monitors the Group’s Compliance Program, including the activities performed by the Compliance Team and its interaction with the rest of the organization
- Monitors the investigations resulting from cases brought through the Company’s ethics line or otherwise;
- Oversees the allocation of resources and personnel to the Compliance area.
- Assesses the Group’s performance in the Compliance area; and
- Ensures that the Group maintains proper standards of business conduct.
Management representatives invited to attend the Compliance and Business Conduct Committee include the Group CEO, Chief Legal, Ethics and Compliance Officer, VP Compliance, Group CFO, Chief External Affairs Officer, Head of Internal Audit, and Head of Risk Management.
Millicom operates a global compliance helpline – the Millicom Ethics Line. It is available to all colleagues and equally to third parties and allows them to raise genuine concerns or report potential or actual breaches of law, regulations, or company policies.
Sustaining a Culture of Compliance & Ethics
Millicom's range of mobile services, cable TV and broadband are available in 13 markets in Africa and Latin America, connecting people for the first time to the internet and making The Digital Lifestyle a reality for more than 53 million people.
The business is sustained by thousands of employees in our local operations and our regional offices and global headquarter.
We work in multiple geographies and as a natural part of our daily work we frequently interact with the local communities. Due to our unique geographic footprint, we face a diverse set of cultures, traditions and practices, laws and regulations.
At Millicom, we all are responsible for understanding the important legal and ethical issues that affect our business. All employees are expected to act with integrity at all times and Do Business the Right Way. Integrity means more than just complying with the law; it means acting in an ethical manner as described in the company’s Code of Conduct.
In order to assist our employees and the external parties we interact with, the Company provides a Global Compliance Framework with written policies and procedures as well as training and independent monitoring and assurance.
The Global Compliance Framework
The Global Compliance Framework is group-wide and consists of seven key elements. These elements are:
- Organisation & Culture: Tone from the top and fostering a culture of ethics & compliance.
- Risk Management: Identifying, assessing and managing risks associated with our business activities.
- Standards & Procedures: Written rules and principles to help employees and third parties do business the right way.
- Training & Communication: Providing induction and on-going training to employees and third parties where relevant.
- Monitoring & Evaluation: Internal and external reviews of our internal control environment and adherence to policies, laws and regulations.
- Case Management & Investigations: Standard process to detect any potential or alleged breaches of policies or laws and regulations and promptly respond and act upon such breaches.
- Reporting: Regular reports to the Executive Committee, the Audit Committee and the Board of Directors in order to provide assurance on the compliance framework.
- Transparency requirements: Millicom's UK tax strategy disclosure (PDF)
As appropriate, and consistent with laws and regulations, we will from time to time amend and update our policies to ensure compliance.
Global Compliance Officer
Linda Peralta serves as the Company's Global Compliance Officer and is responsible for overseeing Millicom’s global compliance programme.
The Global Compliance Officer works to address risk areas and ensure adherence to our policies and standards. Additional compliance support is provided by groups and individuals in areas such as Legal, Security, Internal Audit, Human Resources, Finance, Business Control and Corporate Governance.
The Global Compliance Officer reports to the General Counsel & Company Secretary and makes regular reports to the Millicom Executive Committee and to the Audit Committee of the Millicom Board of Directors.
The Global Compliance Officer heads the Compliance & Business Ethics department, which is responsible for administering all aspects of the Compliance Programme, including the policy governance framework, training programs and managing the Millicom Ethics Line.
Corporate Compliance Committee
Millicom has established a Corporate Compliance Committee to oversee the worldwide Compliance & Business Ethics Programme, promote a culture of compliance and ethics, effectively balance risk with business objectives, and provide clear rules and guidelines.
The Corporate Compliance Committee supports the Company’s efforts to ensure that its business is conducted appropriately in every country in which it operates around the world. The Corporate Compliance Committee’s responsibilities include reviewing key compliance risks and associated mitigation plans and ensuring that compliance and business ethics related strategic initiatives are appropriately prioritized, resourced and tracked.
The Global Compliance Officer acts as the Secretary of the Corporate Compliance Committee, which comprises all members of the Millicom Executive Committee. These senior leaders also promote cross-functional alignment of compliance activities through their membership on the Corporate Compliance Committee.