Compliance

 

Compliance

 

Compliance with the legislation in force, the Code of Conduct and the internal Policies is of great importance to our Company.

Ensuring Compliance is a priority of the Company’s Board of Directors.

Compliance stands for a solid commitment to the principles of integrity, transparency, justice, professionalism, team spirit, and of respect to the rules, principles which are essential to govern the functions of the Company.

On this purpose, the Management has adopted and implemented a Compliance Management System (C.M.S.), regarding the compliance of all (personnel and Management) with the legislation in force, with the Code of Conduct and with internal Policies, aiming to avoid risks and other legal consequences for the Company and its personnel. In so doing, the benefit is for all: the Company per se, the employees, the customers, the suppliers and the shareholders.

The effectiveness of the Compliance Management System relies on the commitment and the support of both management and employees.

The Company’s CMS is reviewed by independent external auditors, who confirm the effectiveness of the procedures supporting it.

The Compliance Management System is certified in accordance with the international standard ISO 37001:2016  (Anti-Bribery Management Systems), while it has also received an attestation as per ISO 19600:2014 (Compliance Management Systems) by the independent Certification body "TUV Hellas (TUV Nord) S.A.".

Telekom Albania's CMS is certified by independent auditors in 2013 and in 2016, according to the German Institute of Public Auditors [Institut der Wirtschaftsprüfer] Assurance Standard 980 (IDW AssS 980)”. The audits were mainly focused on anti-corruption and demonstrated the CMS’s effectiveness to identify corruption risks and prevent violations.

 

Key elements of the CMS

  • The prevention of misconduct in parallel with compliance with the policies provided for by the CMS. In this way, both the company and its personnel are protected from any legal consequences due to misconduct, while the reputational risks of the company are reduced. Prevention is achieved mainly through:
    • The employee’s training about the dangers involved by any breach of basic rules, such as those of corruption, fraud, misuse of personal data, the manipulation of financial statements, leakage of confidential business information, etc.
    • The channels that have been developed for the communication with employees, so that the latter can submit questions regarding the implementation of the Code of Conduct and the Policies, in case they are uncertain as to how they should handle issues that come up in their daily work.
  • The detection of compliance violations and the response to them.In order to provide the possibility of filing a tip–off regarding violations of Policies, regulations and of the legislation in force, the Company has established the Whistleblowing Policy and the relevant communication channels.

In the context of this Policy, employees or/and third persons may nominally or namelessly report to Telekom Albania Compliance Officer a tip – off or express a concern or a complaint regarding potential violations of the Company’s Policies or the legislation. Telekom Albania does not allow for any retaliation act on behalf of the management or other bodies of the Company, directly or indirectly against any person, who on good will, reports or expresses concern or complaint with regards to violation of policies or law.

Communication channels for complaints:

Please do not use these channels for complaints about products or services of the Company. These complaints should be directed to Customer Service. You may make a report via mail, email and telephone at:

Via Mail:

Telekom Albania sh.a.
Internal Audit & Compliance Office,
“Vangjel Noti” str., Laprake, Tirana, Albania

Via telephone: +35542275321

(Monday through Friday: 9 am until 5 pm)

Via e-mail at: complianceoffice@telekom.com.al

Via the Electronic Whistleblowing Form

 

The Department responsible for the planning and adoption of the CMS, reports directly to the Company’s Board of Director. The implementation of the CMS is monitored by the Compliance, Enterprise Risks & Corporate Governance Committee. The main purpose of the Committee is to support and monitor the implementation of the Compliance Management and Risk Management systems and Corporate Governance issues.

The CMS has been successfully reviewed by independent external auditors, who confirmed the effectiveness of the Company’s compliance procedures.

COMPLIANCE POLICIES

In the context of implementation of the Compliance Management System, the following Policies and Codes are in force:

CODE OF CONDUCT

Code of Conduct is the framework for guiding the behavior of all people in Telekom Albania. Specifically, the Code confirms our commitment to consistently comply with the laws and regulations governing the operation of the Company, as well as with the requirements relating to ethical behavior, and supports the success of our Company.

To download the Code of Conduct click here

WHISTLEBLOWING POLICY

Aims at managing cases related to malpractices or improprieties and infringements of Telekom Albania policies, procedures or applicable laws.

CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS

Defines the framework of conduct of the Senior Financial Officers, in order for honesty, integrity, transparency and ethical conduct by those persons to be promoted in the performance of their management responsibilities.

SUPPLIER CODE OF CONDUCT

Based on the Telekom Albania core values addressing business ethics, social and environmental commitments, the Company requires the Suppliers to adhere to the listed Principles (at the Code) which will be attached to the contract entered between the Company and the Supplier. The Supplier shall do its utmost to implement these Principles through its whole supply chain.

The Parties agree that adhering to this Supplier Code of Conduct is a main contractual obligation under the Contract. The Supplier shall bind its contractors and/or subcontractors (herein after referred to as “Subcontractors”) to the Principles of this Supplier Code of Conduct insofar as they are involved in provisioning deliverables under the Contract.  

To download the Supplier Code of Conduct click here

POLICY ON ΙNSIDER ΤRADING

This Policy sets the rules for non-abuse of privileged information by Company executives and regulates the manner of subscription, acquisition or sale of securities from Group companies.

DONATION POLICY

The Donation Policy defines the specific transparent and mandatory procedures to be followed by Telekom Albania Company when assessing and implementing Donations, based on the action areas defined by the Sustainable Development strategy.

SPONSORING POLICY

The Sponsoring Policy describes how to deal with Sponsorship issues by setting out clear criteria for implementing the procedure which needs to be followed by the Company in order to carry out Sponsorships, ensuring transparency regarding the efficient use of resources allocated for Sponsorships.

POLICY ON ACCEPTING AND GRANTING OF BENEFITS

This Policy provides a description of the rules and regulations of conduct with regard to the acceptance and offering of benefits in business dealings.

ANTI-FRAUD POLICY

This Policy is established to facilitate the development of controls that will aid in the detection and prevention of fraud against Company.

EVENT POLICY

This Policy describes the basic conditions, principles and rules of conduct to be observed in the conception, planning, execution and monitoring of events.

POLICY ON AVOIDING SEXUAL HARASSMENT

Target of this Policy is the prevention of sexual harassment acts, the awareness of managers and employees in relation with this issue, and the enhancement of confidence of employees regarding the support they shall have by their superiors in such cases.

POLICY ON AVOIDING CORRUPTION AND OTHER CONFLICTS OF INTEREST

This Policy provides the framework for avoiding corruption and other conflicts of interest in relationships with customers and business partners. 

POLICY ON EMPLOYEE RELATIONS

This policy specifies the key elements of employee relations within Company.

 

INTERNAL AUDIT

The Telekom Albania Internal Audit and Compliance function assists the Company to achieve its objectives by providing a systematic and scientific approach for the evaluation and improvement of the effectiveness of the risk management process. Internal Audit and Compliance Office main role is to continually assess the adequacy of internal controls, perform internal audits in all functions of the company, undertake audits of specific objectives according to management requests, confirm compliance with the company policies and procedures as well as the regulatory framework and report any deviations.