LEARNED
COMPLIANCE CASE
CASE NO.1:
An employee anonymously reported inappropriate behavior “abusive language and
harassment” against Manager “A”. The conduct was in clear conflicts with our values and
violation of VimpelCom Code of Conduct. An internal investigation disclosed that Manager
A, used inappropriate language even in front of customers, in team meetings with the
presence of female staff. Manager “A” extended job threats as a tool to discipline his team
and used abusive language as if it was an acceptable conduct for achieving results.
THE CONSEQUENCES:
Manager:
• The Manager had attended VimpelCom Code of Conduct Training and was well aware of
the principles of integrity and the expected behaviors during interaction with employees.
• The Manager have had several counseling sessions in the past with his Line Manager with
no improvement in his behavior.
• Team members demonstrated fear of retaliation for reporting and lack of senior
management to take appropriate action against the Manager.
Manager received a termination letter.
CASE NO.2:
The senior management and compliance helpline received an anonymous complaint
accusing two employees A & B, having committed fraud, misused authority with involvement
in corruption. The allegations referred to inappropriate behavior as well as conflicts of
interest. After intense and detailed investigations it became apparent that the anonymous
complainant had acted in bad faith. None of the false accusations could be confirmed.
THE CONSEQUENCES:
COMPLIANCEOPEDIA
The compliance organization communicated a formal support letter in favor of the
employees “A & B” after it had concluded its investigation.
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