Zero tolerance against corruption and fraud

Being a culture driven company, it is in our DNA to always behave and act according to our values. Therefore, it is of highest importance that we adhere to and comply with all given legislations and regulations as well as setting our own bar for how to act and behave in society – always with highest possible ethics.

The specific legal definition of fraud and corruption varies by legal jurisdiction, so Tele2 has adopted our definitions in order to be clear with what they mean in our organisation.

Tele2 corruption definition:
The offering, giving, soliciting, or acceptance of an inducement or reward which may influence any person to act inappropriately.

Tele2 fraud definition:
By deceiving Tele2 or its stakeholders with intention to get unlawful gain.

Corruption and fraud are risks that potentially could have a significant negative impact of business and society at large. Therefore it is of high importance to have implemented processes and controls to prevent and detect corruption and fraud within Tele2’s sphere of influence. Below is a description of Tele2’s system for managing corruption and fraud as well as roles and responsibilities supporting our zero tolerance.

Legal compliance and Code of Conduct (CoC)
Tele2 complies with local laws and regulations in each country of operation. The CoC sets up a minimum company-wide requirement acting as an umbrella for our whole business. If provisions in other laws, regulations or rules, be it local, national or international, have a more stringent position to the CR matters mentioned in the CoC, those shall be observed and complied with. In situations where national law for some reason is inadequate and neither the law nor the CoC gives guidance, the minimum requirement for us is to follow the OECD guidelines for multinational enterprises. In cases of conflict between our CoC, or OECD guidelines, and a mandatory local regulation, the regulation shall prevail.

Tele2’s CoC is, among other sources, based on the ten principles in the United Nations (UN) Global Compact (UNGC) where the 10th principle is covering anti-corruption. In Tele2’s code we have a specific section about business integrity covering anti-corruption. To give guidance and support for business operations Tele2 has defined a supervisory threshold of 50 EUR for gifts and benefits. All new employees have to read, understand and sign the CoC. By signing it, the employees also agree to make sure that consultant, suppliers and business partners adhere and comply with Tele2’s standards.

Business Partner Code of Conduct
As part of Tele2’s CR work, and to ensure a high ethical standard, Tele2 expect its Business Partners (suppliers, consultants and other categories) to adopt equally, or higher, requirements. Those requirements have been clearly formulated in Tele2’s Business Partner (BP) CoC. In order to do business with Tele2, we expect our Business Partner to sign, implement and comply with the code. Tele2, or the external party that Tele2 appoints, will occasionally perform CoC audits on compliance with the elements included in the code.

Other steering documents
The steering documents below are complementary to the CoC and are preventive for corruption and fraud. Whilst this list is not exhaustive it contains a summary of the current relevant policies affecting our zero tolerance for corruption and fraud:

  • Tele2 Whistle Blower Policy
  • Group Credit Policy
  • Group Treasury Policy
  • Group Purchasing Policy
  • Group Security Policy

Pre-employment screening
As part of the recruitment process Tele2 is conducting extended pre-employment screening on selected positions such as certain roles in the security team. The purpose of the extended pre-employment screening is to ascertain whether a prospective employee is fit to work in a given proposed role.

Internal control system with four lines of defense
Our internal organizational structure is designed to control our operations, including the risk of corruption and fraud, on three different levels.

First line of defense: Our managers
In Tele2, it is every manager’s responsibility to ensure compliance with the zero tolerance policy against corruption and fraud. It is the managers’ responsibility to establish control mechanisms to detect and mitigate risks of corruption and fraud.

Second line of defense: Cross-functional departments and central functions
Tele2 has various cross-functional departments and central functions (e.g. local and group security and fraud departments, legal departments, financial reporting and controlling departments) that, through their specific area of responsibility and expertise, also help to ensure compliance to the CoC and other steering documents.

Third line of defense: Group Internal Control
Group Internal Control (the internal audit department) is responsible for auditing processes and operations within the entire Tele2 Group and to highlight issues, including compliance issues, of any kind to appropriate instances. Group Internal Control also work closely with the Group Security department to make sure any suspicions of corruption or fraud gets picked up by them for further investigation when needed, and to receive risk input from them prior to the audits. The Director Group Internal Control reports regularly to the Tele2 AB BoD through the Audit Committee.



Whistle blowing and incident reporting systems
Employees are encouraged and obliged to raise concerns, at the earliest possible stage, about any indications of corruption or fraud.

Tele2 offers employees and other stakeholders the option of several reporting channels, such as:

  • Tele2 Whistleblower Policy
  • Tele2 Security Incident Report System
  • Contact with Group Security or local Security Manager
  • Contact with any Leadership Team member
  • Contact with Manager

Disciplinary actions
Any employee of Tele2 involved in corruption or fraud activities will be subject to the strictest disciplinary measures including termination of employment and reporting to the authorities for criminal investigation.

UNGC anti-corruption e-learning

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