As part of VimpelCom Group, VimpelCom Lao Company Limited is committed to a strong ethical culture and to the promotion of all legal and ethical principles that apply to all VimpelCom companies and operations.
Our Code of Conduct (English and Lao versions) 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 requirements in the Code of Conduct apply to VimpelCom, including its direct and indirect subsidiaries, any joint ventures controlled by VimpelCom, and all their employees, officer and directors. VimpelCom 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.
Joint ventures where VimpelCom does not have a controlling interest will be expected to comply with the Code of Conduct or comparable principles of business conduct and ethics. In addition, VimpelCom aims to work only with contractors who embrace standards of ethical behavior that are consistent with our own.
In addition the Supplier Code of Conduct has been developed with reference to good practice within the ICT sector (developed through extensive stakeholder input) including existing codes such as the EICC Code of Conduct, the Joint Audit Cooperation Supply Chain Sustainability Guidelines, as well as source documents such as ILO Conventions (e.g. ILO Convention 138 in relation to child labor).
This Code sets out our minimum compliance standards for our Suppliers. The Suppliers are expected to ensure the compliance of their subsidiaries and any local agents who act as licensed/authorized re-sellers of their products and services. The Suppliers are also expected to promote the principles of this document to their own first tier suppliers.
To reinforce this, in December 2015, our CEO Jean-Yves Charlier recently approved the VimpelCom Group 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.
Strengthening our ethical culture is fundamental to achieving our Excelerate ambition of transforming VimpelCom into a world-class digital operator. As part of this drive, we’re launching a new digital portal – Securimate – to help ensure we only ever work with approved, ethical business partners. Here’s what you need to know…
About the Business Partner Compliance Procedure
The procedure requires employees involved in identifying, selecting and approving a business partner to conduct a risk-based compliance assessment prior to completing the local procurement process and engaging a business partner. In brief, the following steps must be followed:
- Justification and scoping
- Gathering information from the business partner
- Conducting a risk assessment and screening
- Securing necessary approvals
- Ensuring an appropriate contract is in place
All VimpelCom employees, including all VimpelCom Business Units and Operating Companies, must follow the Business Partner Compliance Procedure when engaging a new business partner or renewing an existing contract.
To ensure the Business Partner Compliance Procedure is embedded in the organization, we rolled out Securimate in April 2016.This is a digital portal that will enable all steps of the business partner compliance process to be rapidly and effectively managed and monitored. Any employee engaging a new business partner or renewing an existing contract must follow the Securimate process.
Find out more
You can find out more about Securimate here. If you have any questions about any aspect of our Business Partner Compliance Procedure or Securimate, please contact Group Compliance or your local Compliance Officer at the following email address: firstname.lastname@example.org.