MTS understands that decision-making in the modern business world is complex. Rather than anticipate all potential scenarios, the company instead focuses on equipping employees with a simple set of actionable guidelines on how they should approach decisions:

• Is it lawful?
• Is it fair and honest?
• Is it in the interests of the company?
• Does it comply with MTS’s internal policies?
• Do I have the necessary authority to make the decision?
• Would I feel comfortable if my actions were made public?

MTS managers are also directly responsible in ensuring their subordinates know and understand their responsibilities and — importantly — feel comfortable in raising a concern should it be necessary. 

Ensuring a Healthy Work Environment

As part of its commitment to human rights in the workplace, MTS strives to provide respectful, comfortable, and safe employment conditions for every employee. The company expects its teams to foster a favorable work environment, so that each and every employee may reach their full potential without being subjected to oppression, prejudice, and/or discrimination of any kind. MTS does not tolerate unacceptable behavior that creates a hostile work environment. The company is also committed to best practices in ensuring occupational health and safety in all work environments — whether in the office, in the store, or in the field. 

Managing Conflicts of Interest

MTS regards as unacceptable the influence of personal interests — or the appearance of such influence — on the ability of our employees to make fair and objective decisions. The company is committed to equipping employees with the tools to prevent such conflicts from obstructing a fair and objective decision-making process. Employees are encouraged to disclose any conflicts of interest, even if they may not ultimately be problematic, and refrain from further action until the conflict is resolved. MTS also provides employees with clear, simple guidance on acceptable business hospitality and receiving and giving gifts. MTS forbids gift giving in bad faith, for example, in order to obtain a competitive advantage.

Protecting Physical & Intellectual Property

MTS’s operations rely on substantial physical infrastructure as well as extensive intellectual property, which is a key competitive differentiator. MTS employees are required to protect the company’s assets — both material and non-material — against theft, damage, misuse, and improper disposal, including by third parties. The company also has clear guidelines aimed at safeguarding commercially sensitive data as well as ensuring the careful and responsible handling of personal data concerning customers, employees, or other individuals.

Fair trade

MTS’s reputation rests on the quality and safety of the company’s products, services, and operations. MTS is committed to adhering to fair practices throughout its business activities with the aim to prevent unethical behavior and potential harm to customers, partners, or other third parties.

The company disapproves of any competitive advantages gained via illegal and unethical methods, including through collusion and monopolistic or corrupt practices.

Standing Against Corruption & Bribery

MTS has a zero tolerance policy toward corruption and bribery in any form. Employees and persons acting on behalf of the company are prohibited from offering or accepting any illegal payments or benefits from any public or private persons. The company also has a blanket ban on participation in political activities, including funding parties and candidates for political office. To help mitigate any potential corruption risks, MTS maintains a strong set of internal compliance controls aimed at preventing and detecting bribery.

Ensuring Transparent Information Disclosure

MTS is committed to transparent communication with the investment community, including disclosing materially significant information in line with best practices for financial and non-financial reporting. The company aims to ensure that all officially disclosed information is accurate, timely, complete, understandable, and easily accessible to all interested parties.

Safeguarding Insider Information

As a publicly traded company, MTS employees and senior managers may have access to material non-public information (MNPI) that would potentially be market-moving if it were widely disseminated. The use of such insider information to obtain personal benefits or as advice to a third-party is both illegal and a violation of MTS policy. MTS provides guidance on how to appropriate handle sensitive information to employees with access to MNPI. 

MTS is deeply conscious of its responsibility to society and the environment and therefore aims to adhere to the principles of sustainable development. The company’s commitment to sustainability reflects its core value that a responsible and ethical business will be more successful over time. In addition, MTS supports the principle of ecological efficiency, striving to minimize the impact of the company's operations on the environment.

MTS aims to foster an inclusive corporate culture where concerns can be openly reported through trust-based dialogue. As part of that commitment, the company maintains a dedicated hotline for any person to report a suspected or potential compliance violation or other concern related to the Code of Conduct. For convenience, concerns may be submitted through one of several channels:

• For external stakeholders: via the third-party-operated MTS Unified Hotline either by webform (hotline-mts.ey.com), email (external.hotline.mts@ru.ey.com), or by toll-free phone in Russia (8 800 234 44 18).
• For employees: via the company’s internal corporate portal Pulse, the Our MTS employee app, the compliance@mts.ru inbox, an MTS compliance manager, and/or informing their direct supervisor or, if the report relates to their supervisor’s actions, by informing a senior manager.

When receiving and considering concerns, the company guarantees confidentiality and non-disclosure of personal data for senders. The company also undertakes not to allow retaliatory actions with respect to bona fide persons reporting suspected breaches.