Doing Business with Integrity
Our Customers and Third Parties
From its inception, Millicom has been committed to providing customers with the highest quality digital services and content.
We have built close partnerships with our Third Parties in order to reach our common goal of connecting people and improving the lives of our customers. Millicom has also developed a Supplier Code of Conduct applicable to our Third Parties, including Third Party Intermediaries (“TPIs”), Agents, Vendors, and contracted staff, and we expect all Third Parties to act ethically and in a manner consistent with our Code.
When hiring a Third Party, make sure you have taken the right steps to ensure the Third Party is aware of, and complies with, our Supplier Code of Conduct, has a reputation for integrity, and acts in a responsible manner consistent with our Code and customer focus. By holding our Third Parties to the highest ethical standards, we cultivate long-term relationships and foster trust with our customers. For more information regarding Millicom’s expectations for Third Parties, please consult our Compliance policies.
Zero Tolerance for Bribery and Corruption
Anti-Corruption in Business Practices
Our success depends on the superiority of our digital content and services and the dedication of our people, and never on bribery or other means of corruption.
We must always abide by all local anti- corruption laws wherever we operate and never engage in corruption. Millicom strictly prohibits all forms of corruption. If we receive a bribery request from a Government Official or Private Party, we must immediately contact the Ethics & Compliance Department.
Interacting with Government Officials
We succeed based on the merits of our products and services—never because of corrupt payments. We should never offer, pay (or promise to pay), or authorize the payment of a bribe to obtain or retain an improper business advantage or influence an official action. Likewise, we ourselves cannot request, accept, or agree to accept anything of value if the item is intended or appears to be intended to gain an improper business advantage.
Our interactions with Government Officials carry greater risk because of their potential influence over official actions. The Company prohibits us from offering or providing any hospitality or other expense to a Government Official. If you interact with Government Officials, consult with the Ethics and Compliance Department, and be familiar with the following policies:
Anti-Corruption Policy, Gifts & Hospitality Policy, Government Interactions Policy.
Facilitating Payments
In some countries, Government Officials commonly request “facilitating payments” (sometimes called “grease payments”), which are payments made to Government Officials to expedite performance of a routine, non-discretionary government action. Millicom strictly prohibits all facilitating payments. Employees, Business Partners, TPIs, or other Third Parties of the Company who receive a request from a Government Official for a facilitating payment, whether directly or indirectly, must immediately contact the Ethics & Compliance Department.
For more information regarding facilitating payments,
please consult our Anti-Corruption Policy.
Gifts and Hospitality
Millicom earns business the right way. We never offer or accept gifts or other business hospitality in exchange for business.
That means that, without written approval from Millicom’s VP Ethics & Compliance, you may not offer or accept a gift on the Company’s behalf or because of your job at Millicom. Millicom provides a framework to ensure that any hospitality offered or received complies with our internal policies.
Millicom expects that none of us will use our affiliation or position with the Company to give or receive hospitality of any kind that may be seen to compromise Millicom’s position or the recipient’s personal judgment and integrity. The offering of hospitality is a customary practice to establish or consolidate business relationships and is generally lawful and acceptable when done in good faith and without expectation of receiving something in exchange.
This can be a complicated area. For further guidance regarding what constitutes appropriate hospitality, please check our Anti-Corruption Policy, and Gifts & Hospitality Policy, or contact the Ethics & Compliance Department.
Company Property and Preventing Fraud
We are expected to protect Millicom’s property and assets and, where applicable, those of its customers. Acts of dishonesty involving theft and any other intentional malicious or dishonest activity or omission that could result in financial loss and/or reputational damage to any Millicom operation will be treated as fraud. Falsification, alteration, or substitution of records for the purpose of concealing or aiding such acts is prohibited. Millicom has a zero-tolerance approach to fraud and where appropriate will report fraud cases to relevant external parties.
For more information, please consult the Millicom Group Fraud Policy.
Conflicts of Interest
We must put the interests of Millicom and our customers before our own personal gain. Each of us should avoid situations that create or appear to create conflicts of interest with the Company’s interests.
The appearance of a conflict or unethical behavior can be just as damaging to the Company’s reputation as an actual conflict.
A conflict of interest may arise when personal interests, activities, or relationships affect an individual’s responsibilities and loyalty to the Company.
If you believe a conflict of interest may exist, whether actual, perceived, or potential, immediately contact a line manager, Human Resources, or the Ethics & Compliance Department. For more information on conflicts of interest, please consult our Conflicts of Interest Policy. Remember – most conflicts can be mitigated if they are disclosed. If you have a concern about a conflict of interest, get the help you need to resolve it so that it doesn’t create an issue for you or Millicom.
Competition
Millicom ensures our business practices comply with anti-trust laws in order to encourage free competition and the proper operation of our countries’ free market systems.
That means that none of us should make any agreement or understanding (whether express or implied) with any competitor regarding:
- Prices or terms of sale;
- Allocation of customers, territories, products, or product development opportunities;
- Limitation or restriction of production or output;
- The exchange of price, cost, production, or other competitive information; or
- Any other action that would reduce competition between the Company and its competitors.
Do not discuss with competitors the Company’s current or future prices, costs, production data, or the boycott of any customer or supplier. For more information on anti-trust issues, please consult our Anti- Trust and Competition Law Handbook.
Trade Controls and Anti-Boycott
Many of the countries in which we operate have trade control laws and regulations that govern the import, temporary import, export, or re-export of products and services. We must strictly comply with all trade control laws and regulations that apply to us, wherever we do business, including:
Export Controls, Sanctions, Anti-boycott regulations, as well as customs laws and regulations.
This can be a challenging topic, If you have any questions, contact the Legal Department for help.
Anti-Money Laundering and Countering Terrorism Financing
We are committed to preventing criminals from abusing our business systems and processes to further unlawful activities, such as money laundering and terrorism.
Always follow appropriate due diligence procedures designed to prevent someone from using our Company to disguise criminal transactions or engage in any type of money laundering activity.
For more information regarding Millicom’s anti-money laundering and countering terrorism financing rules, please consult our Millicom Global Anti Money Laundering and Counter Terrorist Financing Policy (“AML/CTF”) and Know Your Customer Processes.
Sponsorships, Donations, and Political Contributions
Sponsorships and Donations
We support and strive to improve the communities and environments in which we work. We must ensure, however, that all sponsorships and donations have a legitimate purpose and are made for the right reason. Various departments must review and approve all proposed sponsorships and donations in accordance with our Sponsorships & Donations Policy. For more information regarding sponsorships and donations, please consult our Sponsorships & Donations Policy and Sponsorships & Donations Policy.
Political Contributions
Millicom is politically neutral, is not directly or indirectly affiliated with any political party, and all political messages that may be delivered using our services do not reflect Millicom’s opinion.
That means we cannot use Company funds or assets to support a cause or candidate, and we cannot campaign for an issue or candidate or party while we are at work. For more information regarding political contributions, please consult our Sponsorships & Donations Policy and Anti-Corruption Policy.
