Sustaining a Culture of Compliance & Ethics
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 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.
But economic prosperity cannot occur for all citizens where corruption exists. Corruption reduces opportunity, decreases economic prosperity, and slows the dynamic growth necessary to lift people up the economic ladder. At Millicom we are committed to creating this economic growth by, in part, reducing corruption. We are dedicated to operating in a clean and transparent manner and to fostering clean business and corruption reduction in the countries where we operate.
This dedication rests with each and every one of our employees. 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.
As our CEO, Mauricio Ramos has stated, “By fostering a culture of ethics and compliance from the top, across all our lines of business, we help everyone make the right decisions, and our business becomes more agile, responsive, and competitive.”
As the Chairman of our Board, Tom Boardman, stated, “During 2017, we continued building and enhancing our compliance program, supported by the Executive Committee and our Compliance and Business Ethics team. On behalf of the Board, I would like to reconfirm our commitment to strong corporate governance, and supporting the success and strength that comes with a culture of compliance and strong internal control. We firmly believe that Millicom can lead the way in its dedication to ethics and compliance in all our markets.”
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 trainings 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.
Chief Ethics and Compliance Officer
HL Rogers is Executive Vice President and Chief Ethics and Compliance Officer for Millicom. As the leader of Millicom’s Compliance function, he is committed to maintaining a world-class compliance program. He reports directly to the Millicom 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 Information Security.
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 Director Odilon Almeida with Chairman Tom Boardman and director Janet Davidson 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 Company’s Compliance function, including the activities performed by the Compliance Team and its interaction with the rest of the organization;
• Monitors the results of investigations resulting from cases brought through the Company’s ethics line or otherwise;
• Oversees allocation of resources and personnel to the Compliance area;
• Assesses the Company’s performance in the Compliance area; and
• Ensures that the Company maintains proper standards of business conduct.
Management representatives invited to attend the Compliance and Business Conduct Committee include the Millicom CEO, the Chief Compliance and Ethics Officer, General Counsel, and Group CFO. Mr. Almeida has stated, “The Board of Millicom continues to assign the highest priority to upholding compliance and standards of business conduct across every level of the organization. The Board’s core objective is to reinforce a culture of compliance that is practiced wholeheartedly by every employee, across all ranks, with no exceptions.”