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In this section we cover three key aspects of business ethics: corporate governance, anti-bribery and anti-corruption, and transparency.

Corporate Governance

VEON is a public company listed on the NASDAQ, and is subject to all of the applicable listing and disclosure requirements as a foreign private issuer. VEON is also subject to the applicable Securities and Exchange Commission reporting requirements, including filing an annual report on Form 20-F each year, with audited consolidated financial statements.

Our Supervisory Board has authority for strategic decisions for the Group. Shareholder approval policies and procedures are also in line with applicable requirements. The Supervisory Board has a number of committees, including the Finance and Strategy Committee, the Nominating and Corporate Governance Committee, the Compensation Committee, and the Audit Committee.

Further information on our approach to corporate governance, the members of our leadership teams and the Supervisory Board and its committees is available in the Form 20-F and our corporate website. 

RiskClarity Survey

Nearly 32,049 employees participated in the company’s third RiskClarity survey, helping to assess how our corporate culture is developing. The ‘Integrity Index’ measures attitudes and perceptions about seven key drivers influencing a business’s ethical climate. Our overall integrity score was assessed at 5.51 out of 7.00, with all seven drivers showing improvement.

Anti-bribery and anti-corruption

As our company evolves and new business risks emerge, we have continued to strengthen the governance, policies and procedures focused on anti-bribery and anti-corruption compliance, with a particular emphasis on building a strong compliance team and carrying out extensive training and awareness-raising across the business

We recognize that a strong and comprehensive approach to compliance is needed to protect our business and our stakeholders. We have put in place a risk management, compliance, and governance structure that includes a focus on bribery and corruption risks, which extends from the group level to each operating company. This will remain a key focus as we regard it as a critical part of our future development and a particular focus of our senior management team. 

Transparency relating to disclosures on anti-bribery and anti-corruption

In November 2015, Transparency International (Hungary) published its report ranking the 35 largest telecoms companies (29 operators and six equipment suppliers) on the reporting of the measures they take to prevent corruption, information on subsidiaries and holdings, and key financial information. VEON ranked eighth out of the 35 businesses assessed, scoring 88% for disclosures relating to its anti corruption program.

On February 18, 2016, VEON announced agreements with the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Justice (DOJ), and the Dutch Public Prosecution Service (Openbaar Ministerie) (OM) relating to the previously disclosed investigations under the U.S. Foreign Corrupt Practices Act and relevant Dutch laws, pertaining to VEON’s business in Uzbekistan and prior dealings with Takilant Ltd. The relevant agreements have been approved by the authorities and relevant courts. 

As part of the agreements, VEON paid fines and disgorgements to the SEC, DOJ and OM in an aggregate amount of USD795 million. VEON has agreed to a deferred prosecution agreement with the DOJ, a consent with the SEC, and a settlement agreement with OM. In addition, VEON’s subsidiary in Uzbekistan, Unitel LLC, has entered a guilty plea with the DOJ. VEON has also agreed to oversight by an independent compliance monitor to promote continued, and regular, compliance enhancements across the Company and its subsidiaries. VEON’s cooperation in the investigation and actions in rapidly resolving this matter, together with substantial upgrades to its compliance program, have been recognized by the authorities in the settlements.

Our comprehensive Group Compliance Charter sets out the organization, operation and governance of compliance management for the Group, including the role and responsibilities of our global Risk, Ethics and Assurance Committee, the Group Compliance Program and Group Compliance Function. The Group Chief Compliance Officer reports to the Group Chief Executive Officer, also having direct access to the Audit Committee of the Supervisory Board of Directors to which he reports at least quarterly. 

We have compliance officers across our headquarters and business units, covering all our operations. Compliance officers in our BUs report with a solid line to the Group Chief Compliance officer. Our compliance roadmap covers: risk analysis; policies and procedures related to key risk areas; organization and commitment (including appropriate messaging from senior management); training and awareness; screening; record-keeping and controls; reporting; internal audit and monitoring; remedial and corrective actions; and program leadership. 

We have carried out compliance risk assessments in all of our markets with the assistance of independent external counsel, and also put in place an Investigations & Disciplinary Committee. We are reinforcing the importance of our compliance program with both educational videos on key compliance topics, and reinforcing the ‘tone at the top’ regarding the importance of anti-corruption/anti-bribery compliance with a variety of approaches, including a video message from our Group CEO.

Our Code of Conduct provides group-wide standards designed primarily to deter wrongdoing and promote honest and ethical conduct, compliance with applicable governmental laws, rules and regulations, prompt internal reporting of violations, and accountability for adherence to the Code. The Code of Conduct reinforces the company’s requirements for compliance with all applicable laws, including the US Foreign Corrupt Practices Act (FCPA) and other applicable anti-corruption laws and regulations, as well as adherence to all company accounting policies and controls. 

The Code states that, in addition to applying to its employees, officers and directors, VEON expects ‘anyone doing business on the company’s behalf’ – a category that includes agents and other third parties – to also comply with anti-bribery and anti-corruption laws. To reinforce this, in December 2015, we launched the Due Diligence Business Partner Compliance and Screening Procedure. This Procedure is an addition to the range of policies and procedures (addressing issues such as conflicts of interest, gifts and hospitality, incident management and investigation, and social investment project approval) that support the Group Anti-Bribery and Corruption Policy. We also implemented our M&A Due Diligence guidelines relating to compliance issues. As part of our headquarters ‘Supplier Day’, the importance of both our anti-bribery and anti-corruption program, and our Supplier Code of Conduct, were emphasized to our global strategic suppliers. 

VEON maintains several confidential "SpeakUp" tools that allow employees and third parties to raise concerns, anonymously if desired, about potential violations of the law, VEON’s Code of Conduct, and/or its policies or procedures. All concerns raised are duly reviewed and, if appropriate, investigated.

VEON continues to strengthen our ethical culture and foster individual accountability by placing emphasis on compliance training, both at our headquarters and throughout the Operating Companies. We train employees worldwide on the Code of Conduct that includes a specific module on anti-corruption/anti-bribery compliance. Veon provides key employees with additional, targeted anti-corruption training, and the Supervisory Board receives tailored compliance training with focus on risks and topics relevant to Board oversight.


Disclosing our performance to a broad range of stakeholders is a strategic objective for the company. At VEON, we are constantly trying to improve and enhance our annual disclosures.

We report in line with the GRI and UNGC principles. We also align to the Dutch Transparency Benchmark – a government rating of the annual CR disclosures of the 500 largest companies in the Netherlands. Based on more than 40 criteria, the assessment scores each company based on its  transparency. We improved our score in 2016, with 154 points (sector average 117), ranking us 71, compared to 128 in 2015. 

Wind Tre published the Wind Transparency Forum, which aims to inspire users through innovative initiatives in transparency and open data. During the year, the business also won a social reporting award for its CR report.

Our Code of Conduct

Our Code of Conduct is a statement of legal and ethical principles that apply to all VEON companies, operations and employees. It defines our values and what is and is not acceptable in the areas of health, safety and security, how we interact with employees, customers, business partners, competitors, governments and communities, and how our assets and information are used. We have a commitment to integrity, highlighted in our values, and our Code of Conduct represents a commitment to doing what is right. By working for VEON, our employees agree to uphold this commitment and our Code is shared and referred to regularly as a core part of our culture.

In addition to the high standards that we have set for ourselves, we have high expectations for our partners. We seek to work with suppliers who are providing innovative, high quality products and services at competitive prices, and who are committed to making their own operations more sustainable through the management of their environmental, human rights and ethical business performance. These expectations are outlined in our Business Partner Code of Conduct.

Awards and ratings for Corporate Website

VEON’s corporate website is designed to provide timely and accurate information to all key corporate stakeholders. The website uses responsive design, ensuring the layout adjusts for all screen sizes. 

Since its launch, VEON’s corporate website has received 10 international awards, including two honoring it as best-in-class among participating telecom-related sites. Most recently, it was ranked the top corporate website in the Netherlands by Comprend in its annual 2015 Webranking review. 

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