Integrity in Our Workplace and Community

Equal Opportunity, Discrimination, and Harassment

Our workforce is as diverse as our customers, and our success depends on embracing and respecting diversity.

We strive to provide the proper environment and resources to promote everyone’s performance and growth. We must all foster a positive work environment by treating one another professionally. The Company does not tolerate harassment or discrimination of any kind. Millicom will take corrective action, including possible termination and/or legal action, for violations of Millicom’s Principles for a Positive Work Environment. For more information, please consult our Employee Handbook.

Millicom is an equal opportunity employer and treats every applicant and Employee equally and fairly. We base hiring, promotion, discipline, compensation, and termination decisions solely on merit, performance, and business considerations. We strictly prohibit discrimination in employment or employment-related decisions based on race, color, gender, age, national or ethnic origin, religion, creed, disability, sexual orientation, marital status, political status, citizenship, or any other status protected by law.

Together we can make our work environment stronger, Speak Up if you witness or experience anything that causes concern. Please refer to the Speak Up! section of this document and to our Speak Up Policy.

Health, Safety, and Environmental Protection

Millicom strives to provide a safe and healthy work environment by minimizing safety incidents everywhere we do business.

Employees must refuse and immediately report any work that could be reasonably perceived to endanger the health or safety of anyone and/or any of the Company’s installations or assets. Employees should also encourage others to stop any unsafe behavior.

We are all responsible for our safety and the safety of those around us. The use of drugs and abuse of alcohol restricts the ability to think clearly, make sound decisions, and act quickly, and therefore will not be tolerated. Millicom strictly prohibits substance abuse in the work environment, and illegal substance abuse at all times.

We all have a duty to protect the environment when at work and to contribute to the realization of the Company’s environmental targets for all operations to reduce adverse impacts on the environment. Millicom’s environmental targets include the use of environmentally friendly technologies, the reduction of energy use and dependency on fossil fuels in offices and in our network, and recycling or reuse of electronic waste.

We aim to protect the environment by promoting the sustainable use of natural resources and by complying with environmental legislation in the countries in which we operate. For more information on Millicom’s health, safety, and environmental protection policies, please consult our Environment Policy; Health, Safety & Environment Manual; and Millicom Waste Management Guidelines.

Human Rights and Fair Labor Conditions

Millicom promotes human rights on a global basis, as defined in the UN Guiding Principles for Business and Human Rights, the International Bill of Human Rights, and Children’s Rights and Business Principles.

The Company does not tolerate the use of child, forced, indentured, or involuntary labor where we conduct business. We will only do business with others that support human rights and uphold labor laws.

The Company pays fair wages and respects local regulations regarding working hours and conditions, including overtime pay.

Millicom respects the right to associate freely, to join or not join trade unions, to seek other forms of representation, and to voice concerns relating to employment conditions without fear of reprisal.

Data Privacy and Protection of Confidential Information

Data Privacy

We are committed to safeguarding the privacy, confidentiality, and security of the information entrusted to us by our customers and our colleagues.

Millicom collects and uses personal information only for lawful purposes and complies with laws applicable to the processing of such. Employees should limit access to customer and Employee information to the strict minimum necessary and prevent unauthorized persons from accessing any such information. Employees are expected to comply with all Company policies, guidelines, and procedures concerning the use and protection of Customer and Employee information. For more information, please refer to Millicom’s Global Privacy Policy.

To ensure our continued success, we must keep our Company’s intellectual, physical, and financial corporate assets properly protected. Employees must use Company information and resources both responsibly and appropriately. Disclosing sensitive information outside the Company could hurt the Company’s competitive position and its shareholders.

 

Confidential Information

In the course of our work, many of us have access to confidential information, such as: business plans, contract terms, rates, or fees offered to certain customers, strategic plans, marketing strategies, technological innovations, financial information, patent applications, employee and salary information, proprietary work methods and procedures, and trade secrets.

Do not disclose any confidential information to anyone outside the Company, including Third Parties, unless disclosure is for a legitimate business purpose and properly authorized. In some situations, it may be necessary to have a written confidentiality agreement. Consult the Legal Department for any questions about situations requiring a written confidentiality agreement. You may only use confidential information in the performance of employment duties. Even within the Company and among co-workers, only share confidential information on a need-to-know basis – that means someone is allowed to have the information and needs it to do their job.

Millicom’s investment in technology requires strong protection of its resulting intellectual property assets. Intellectual property is created when one of us conceives of an idea, device, technique, or process that is related to the Company’s business. Any such intellectual property is the exclusive property of Millicom.

If you have been granted access to confidential materials from a third party, such as a prior employer, abide by any obligation to keep those materials confidential. Upon termination of employment for any reason, do not copy or retain any documents or data stored in any form containing Millicom’s confidential or proprietary information.


Information Technology Resources and Electronic Communications

We all have an obligation to protect the Company’s information when using the Company’s information technology resources. Appropriate measures of protection and awareness are necessary to safeguard this information and prevent compromise in the normal course of business, either by accident or by intentional misconduct.

To minimize the risk of accidental or wrongful disclosure of personal information, confidential trade secrets, or sensitive business information, the Company has adopted the Acceptable Use Policy to govern the use of Company’s information technology devices and resources.

Social Media

The internet provides us unique opportunities to participate in interactive discussions and share information on particular topics using a wide variety of social media channels. Millicom’ s Employee Social Media Policy provides guidelines to help us exercise care when participating in social media, while minimizing any risks to the Company’s confidential and proprietary information, reputation, and brands.

Only specifically authorized Employees may use social media to speak on Millicom’ s behalf. This means that when you are using your own social media, make it clear that the opinions expressed there are your own. Make sure that you are not using social media in such a way that your connections might attribute your words to the Company.

Consult the Employee Social Media Policy to learn more about these guidelines.

Insider Trading

We have an ethical and legal obligation to maintain the confidentiality of all Company information and prevent insider trading. Any violation of insider trading laws and regulations could subject us to personal liability and make us face administrative and/or criminal penalties. In addition, these violations could result in corrective action, up to and including termination.

Anyone who has Inside Information about Millicom may not:

  • Buy or sell the Company’s shares or other securities;
  • Recommend the purchase or sale of any Company securities;
  • Disclose Inside information to persons within the Company whose jobs do not require them to have that information, or outside of the Company to other persons, including family, friends, Third Parties, investors, and expert consulting firms; or
  • Assist anyone engaged in the above activities.

Anyone who has material non-public information about a company with which Millicom does business (for example, a customer or supplier) may not trade in that company’s securities until such information becomes public or is no longer of an inside nature. For more information, please consult our Millicom Insider Trading Policy.

Inside Information is any information that an investor would consider important in making a decision to buy, hold, or sell securities.

Financial Transparency and Reporting

Employees have an obligation to protect and maintain the records necessary for financial and operational needs and comply with applicable legal and regulatory requirements. Millicom must be able to retrieve any Company records identified for retention, whether in physical or electronic form, quickly and reliably.

Millicom’s integrity depends on the accuracy and completeness of our financial records. Fraudulent or deceptive reporting destroys the trust placed in our Company by investors, our colleagues, and other stakeholders. Report any falsification, omission, or inaccuracy of reported information upon discovery. The Company has a responsibility to provide full and accurate information to regulators and shareholders. Information that we provide regulators, and our other public communications will be full, fair, accurate, timely, and understandable.