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.
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.