A First-Rate Compliance Team
Beginning in 2012 MTS has sharpened the company’s focus on compliance by establishing a dedicated Business Ethics & Compliance Department, responsible for overseeing the integration of comprehensive compliance processes throughout the company’s business operations. The Department operates independently from other functions and reports directly to the Board of Directors and the Board’s Audit Committee. MTS maintains high level of compliance resources in order to enhance the efficiency and effectiveness of the compliance function.
Vice President for Business Ethics & Compliance
Leida Lukianova was appointed MTS Vice President for Business Ethics & Compliance in February 2020. In this role, she oversees MTS’s compliance activities across all of the Company’s operations, including defining and executing MTS’s anticorruption strategy, maintaining processes to strengthen MTS’s culture of integrity, including leadership engagement, risk assessment, and employee training and communication.
Prior to joining MTS, Leida served as Ethics & Compliance Counsel at VEON, responsible for coordinating corporate compliance processes in Russia and Eurasia, as well as implementing the recommendations of the company’s independent monitor. From 2008–2017, she advised Russian and global companies as an attorney at Baker & McKenzie, covering pretrial settlements and court cases with both private parties and government agencies. While at Baker & McKenzie, she also served as an external advisor on compliance matters to VEON during 2016–2017.
In 2006–2008, she worked as an attorney at DLA Piper, and from 2005–2006 as a legal adviser at a Russian auditor. She earlier worked as a specialist on legal matters and a manager of a tax agency legal department.
Leida graduated from Novgorod State University with degrees in Jurisprudence (2001) and Accounting Analysis & Audit (2005). She holds a certificate in Governance, Risk, and Compliance from the International Compliance Association (ICA).
The Business Ethics & Compliance Department oversees and sets the standards for MTS Group compliance activities across all of the Company’s operations, including defining and executing MTS’s anti-corruption strategy, maintaining processes to strengthen MTS’s culture of integrity, and governing the hallmarks of the corporate compliance program. The compliance team offers best practices in compliance matters and ensures that the standards of the corporate compliance program are properly rolled out Group-wide.
The department is combined of dedicated functional units responsible for managing the core focus areas of MTS’s compliance program, including:
- High-level commitment
- Proper oversight and independence
- Periodic risk assessment
- Training and communication
- Policies and procedures
- Monitoring and testing
- Third parties review
- M&A (including integration of the ABC program in newly established entities)
- Internal investigations
- Enforcement and discipline
While performing its activities, the Business Ethics & Compliance Department works in close cooperation with other MTS functions, including legal, security, internal audit, and human resources.
Leida Lukianova is Vice President for Business Ethics & Compliance, in which capacity she oversees MTS’s anti-bribery compliance and business ethics program carried out by a team of around 100 dedicated employees spread across the company’s headquarters, regional branches, and various subsidiaries. In addition, she coordinates the company’s Compliance Ambassador Program, which engages employees of other functions to provide dual-role support to the compliance function.
Concerns from stakeholders regarding compliance matters can be sent via the MTS Unified Compliance Hotline. Other written inquiries can be addressed to the MTS Business Ethics & Compliance Department at:
Business Ethics & Compliance Department, MTS PJSC
Pankratievsky lane, 12/12