IR_vivacom_2018-en-01.pdf

3.3.

Compliance

Internal control

TheManagingBoardofVIVACOMexercises independent

supervision over the activities and the internal control

establishedbytheCompanyincludingviatheestablished

Internal Audit Department. The objective of the internal

control system is to manage rather than eliminate

the risk of failure to achieve corporate objectives.

Independent Audit Committee

The members of the independent audit committee

are appointed with resolution of the sole owner of the

Company. The independent audit committee has the

following responsibilities:

monitoring the financial reporting process, the

effectiveness of the internal control systems and

risk management systems of the Company;

consulting with and monitoring external auditors

regarding the extent of their independent financial

audit of the Company and ensuring that the external

auditors are in compliance with the requirements

of the Law and the Code of Ethics of professional

accountants, as well as monitoring the provision

of any additional services provided by the external

auditors; and

recommending to the shareholders the

appointment of the external auditors.

VIVACOM is subject to local, regional and international

laws and regulations, regulatory controls and

practices. Our legal and regulatory compliance experts

are monitoring and adapting to significant and rapid

changes in a wide range of legal and compliance areas,

to ensure that the code and our internal regulations

remain suited for purpose and are properly applied.

We make sure that all employees are aware of, and

comply with, laws and regulations that are relevant

to their specific role, as well as the Code of Ethics and

related internal regulations.

Code of Ethics

Our Code of Ethics entered into force on July 1, 2010. It

guides the employees to act responsibly, ethically and

lawfully and in compliance with the Code of Ethics,

all other policies, laws and regulations that apply

to the Company, as well as our strategic values, our

fundamental principles and rules for doing business.

Communication on the code starts for new employees

from the moment they join VIVACOM and includes

training, which enables them to fully acquaint

themselves with the compliance framework and

the code. We also run campaigns and other training

activities throughout the organisation regularly to

raise awareness of employees in their workplace

behaviour as well as their personal and social

behaviour. We have appointed business compliance

officers and set up compliance committee.

Reporting helpline is available 24 hours a day, which

encourages employees to report alleged breaches of

the Code of Ethics. All alleged breaches of the code

that are brought to the attention of the compliance

committee are investigated.

3. GOVERNANCE AND

COMPLIANCE

ANNUALREPORT

2018

INTEGRATED