COMPLIANCE

In 2007 e-learning programs has been launched on business ethics and anti-corruption compliance, which is continuously updated with current topics. The business ethics programme is mandatory for all employees of the Group; to the anti-corruption e-Learning course employees are selected and invited after a risk based assessment.

Suppliers are required to register themselves on the Makedonski Telekom Procurement site thereby acknowledging the Supplier Code of Conduct and anti-corruption clause.

Makedonski Telekom’s management is committed to establish and maintain an adequate internal control system to ensure the reliability of the financial reports. Our internal control system is designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in conformity with International Financial Reporting Standards (“IFRS”).

Transaction Level Controls describe the controls built into our business processes that have been designed and operated to ensure that material misstatements in each significant financial account and disclosure within the financial statements are prevented or detected in a timely manner. Parallel we document and evaluate the fundamental controls of internal control system based on the methodology of Deutsche Telekom.

In line with the criteria of the adopted internal control framework, management evaluates the effectiveness of internal control system within each financial year. Complete evaluation of our internal control system is based on the method established in “Internal Control—Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The operation of the internal control system is supported also by the independent internal audit function. Beyond tasks regarding the risk based internal audit work plan, contributes to the enhancement of the internal control processes and to the reduction of existing risks through ad-hoc audits. The Internal Audit area follows up the implementation of the measures defined on the basis of the audits. The Board of Directors and the Audit Committee receives regular reports on the findings of the audits; measures, based on the findings and fulfillment of tasks.

A formal changes management system is applied continuously to monitor the design and effectiveness of the Compliance Program and to tailor it to the changes and new challenges in the business trends, environment and legislations.

Compliance Officer also provides quarterly reports to the Management Committee, Board of Directors and Audit Committee on the progress and results of the Compliance Program.

In the period from 2010 to 2021 Deutsche Telekom Group has done four certifications by which external auditors revised and confirmed the design of the Compliance Management System.

The results are available at: link.

The Company takes the Code of Conduct and its detailed regulation seriously and consider its enforcement to be among our highest priorities, but it is also acknowledged that it is sometimes difficult to know right from wrong. That’s why the employees are encouraged to initiate open communication through an internally available Ask me! portal.