Fostering a Culture of Compliance

MTS strives to maintain and enhance a strong corporate culture that encourages employees to fully embrace best corporate practices in business ethics and compliance in everything they do. The Company is committed to nurturing a corporate environment where each employee takes personal responsibility in acting legally and ethically when carrying out their work.

The MTS Business Ethics & Compliance Department works closely with the company’s senior leadership team to support a culture of compliance by empowering employees to be ambassadors in supporting the strengthening of the company’s efforts in the sphere of compliance.

The company has four core pillars in nurturing its culture of compliance:

Effective Compliance Training

MTS’s training programs aim to instill an inclusive, compliance-focused culture across the company’s organizational structure, reinforcing employee knowledge of the standards and principles of compliant behavior.

At MTS, we focus on developing and delivering robust and impactful compliance training to employees and external partners. Since 2012, we have conducted extensive in-person training sessions — both scheduled and ad hoc — as well as engaged tens of thousands of employees with online educational webinars, which are based on a risk-oriented approach.

At MTS, we believe simple compliance is effective compliance. That’s why we take a smart approach in ensuring that the target audience receives customized training that addresses concrete, specific issues that are particularly relevant for the contemporary regional business environment. Since 2021, MTS has launched a new online corporate university platform that provides extensive opportunities to attend engaging compliance sessions in a convenient format. The platform features a user-friendly structure and training sequence and is accessible from both desktop computers and mobile devices.

In 2021:

  • More than 25,500 employees of MTS PJSC completed e-training in the Code of Business Conduct and Ethics.
  • More than 5 500 employees completed targeted compliance training in 2021
  • Over 1,800 counterparties completed training in various formats.
 

For more details, please see the 2021 MTS Annual Report.

Employee Communication and Guidelines

MTS aims to provide timely and ongoing communication and guidelines to employees to keep them up-to-date and informed about changing regulatory requirements as well as the company’s own compliance requirements.

Compliance topics were actively covered in internal communications, in particular:

  • posts and information materials in the compliance groups
  • interactive banners on the corporate portal
  • engaging the entire employee base in a variety of activities during an annual Day of Ethics and Compliance
  • permanent communication columns, namely “Compliance from A to Z” and “Lessons learned from Internal Investigations”
  • compliance comics

In addition, the senior management team and managers also play an active role in directly addressing employees on compliance matters in order to set a clear tone from the top and tone at the middle by sharing their values, insights, and compliance best practices. For example, in 2021, more than 400 “tone-in-the-middle” events were held with the participation of more than 57.3 thousand employees.

MTS also recognizes that sometimes employees require additional guidance in certain cases. That’s why we have a team of experienced compliance managers to provide employees with situation-specific consulting and expert assistance when needed. Employees can find their contact details on the company’s internal web portal and/or can reach out via a dedicated email inbox for guidance on compliance issues. Apart from personal support, the company also operates an automated chat bot and a Q&A section on its internal portal, which serve as a source of commonly asked questions related to compliance.

Encouraging Reporting of Concerns

Employees, suppliers, and vendors are often the first to notice suspicious activities, making them an invaluable front-line source for detecting compliance violations. MTS encourages employees and external partners to easily, safely, and confidently report misconduct, concerns, and other sensitive issues via the company’s multi-channel compliance hotline.

To report potential or suspected violations of the MTS Code of Business Conduct & Ethics, as well as concerns regarding corruption, fraud, or other legal violations related to the Company's activities, please contact the third-party-operated MTS Group Unified Hotline by email (external.hotline.mts@b1.ru) or by toll-free phone in Russia (8-800-234-44-18). Toll-free numbers from certain other countries can be found on the hotline webpage at hotline-mts.b1.ru. Please note that the MTS Group Unified Hotline is maintained by an independent third party.

You can also report concerns by filling out a simple form on the website:

When accepting and reviewing submissions, the company guarantees confidentiality and non-disclosure of personal data of those reporting a concern. You may also report violations anonymously. At the same time, it should be noted that the deliberate provision of false or misleading information is prohibited. In addition, MTS seeks to prevent and will not tolerate retaliatory actions against bona fide persons reporting violations.

Customer inquiries regarding the Company’s connectivity or other subscription services, as well as issues related to quality of service, are outside the scope of the MTS Group Unified Hotline. For customer service issues, please contact the MTS Customer Support Center by phone in Russia at 8-800-250-08-90.

Reacting to Misconduct and Compliance Investigations

The top priority for MTS is to ensure that allegations of non-compliance with merit are properly investigated and corrected. MTS conducts investigations in a thorough, expeditious, and objective manner.

MTS’s policy on internal investigations ensures uniform and appropriate handling of all cases of misconduct, adequately protecting the confidentiality of the persons and information involved. Disciplinary actions may be taken based on the results of internal investigations or the decisions of the MTS Disciplinary Committee. The Disciplinary Committee is a permanent body that deals with anticorruption and other substantial violations and is dedicated to enhancing the Company’s compliance culture. Among the Committees functions is analyzing the causes and dynamics of violations with the aim to ensure the adequacy and monitor the effectiveness of corrective actions in order to prevent misconduct in the future.

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