Telenor Pakistan is against corruption. Telenor's Pakistan's Guidelines for Corporate Conduct state that employees shall not in any way be party to, assist in or be involved in corruption.

General
This regulation outlines various forms of corrupt activities that Telenors Pakistan's employees shall not become involved in and indicates how they should act in situations where there is a suspicion or danger of becoming involved in an act of corruption.

Corruption is not an unambiguous term, but the essence of corrupt operations is the illegal buying or selling of decision-making authority. Typical features of corrupt activities are:

• Abuse of the power which accompanies a position in an organisation
• An undue advantage (bribe) being offered, given, demanded or accepted in order to perpetrate the abuse
• The agreement between the involved parties is secret

Bribes
It is prohibited to offer, give, ask for or accept any form of bribe. In this context a bribe is when someone attempts to influence a party's business decision in an improper or illegal manner by offering that person some form of advantage.

Central to the assessment of whether or not a bribe is present is the value of what is offered, the motives of the party making the offer, whether there is openness within the organisation regarding the matter and the circumstances in general. If attempts are made to buy or sell decision-making authority by giving an inappropriate gift, or if that which is given could improperly influence the recipient's freedom to act or reach a decision, it may be a bribe.

It is unimportant whether the advantage is given directly to the decision-maker or to others, or if it is pecuniary or non-pecuniary.

Customary business related gifts are not bribes and you may give or receive such gifts. The same applies to participating in or sending/accepting invitations to customary business related gatherings, such as dinners, lunches or other forms of representation.

Telenor Pakistan does not normally consider expensive gifts as customary in a business context and for this reason you may not give or receive expensive gifts without prior consent from your immediate superior. The same applies to participation in or invitation to beyond the ordinary expensive arrangements such as travels or similar. If from a business point of view it is necessary for you to attend such an arrangement Telenor will normally cover the expenses.

A gift given or received or an arrangement made in connection with contract negotiations or similar situations is more likely to raise doubts as to its ability to improperly or illegally affect the recipient's business decision and therefore you should exercise extra caution in such situations.

If you are in doubt as to whether or not you may give or receive a gift, service or similar, contact your immediate superior for clarification. Such enquiries and clarifications should be documented.

Facilitation payments
Facilitation payments are normally small amounts paid to secure or expedite the performance of a routine or necessary action to which the payer has legal or other entitlement. In some countries such payments are commonplace. However, the distinction between facilitation payments and bribes is not clear, and accordingly extra caution should be exercised prior to making such a payment.

Facilitation payments shall be avoided as far as possible. Prior to making such a payment, an assessment should be made to ensure that it does not give Telenor Pakistan an unfair advantage or jeopardise the company's reputation. The assessment shall be carried out by those making the payment and should be documented.

All payments are to be documented and are to be entered in the accounts precisely and accurately.

Middlemen
In this context middlemen are external advisors, consultants or similar who act as a liaison or point of contact between Telenor Pakistan and a third party.

The use of middlemen is normal and desirable in many circumstances. Due care should be exercised with respect to the selection and use of middlemen so that Telenor Pakistan does not become involved in corruption.

When selecting middlemen the Telenor Pakistan's employee responsible for entering into the agreement must ensure that the middleman's reputation and expertise is satisfactory. Middlemen are to maintain the same ethical standards as those of Telenor Pakistan. When it is possible the agreement regarding the execution of the assignment shall be in writing.

Remuneration shall be commensurate to the service provided. All payments to middlemen shall be documented and are to be entered in the accounts precisely and accurately.

Use of lobbyists
Lobbyists are a special category of middlemen who are normally used to influence decision makers with public authorities, international organisations, etc. The use of middlemen in such circumstances is legitimate and often desirable. However, Telenor Pakistan shall not be involved in the illegal influencing of decision makers through middlemen.

Accordingly it shall be formally stated in the assignment contract that the middleman is not to conceal the fact that he or she represents Telenor from the party for which he/she is lobbying. In addition please see point four, second, third and fourth paragraph of the above regulations regarding middlemen. These also apply to the use of lobbyists and similar.

Relationship to public authorities
To avoid any suspicion that Telenor Pakisan's attempts to influence public authorities, international organisations, etc. in an improper or illegal manner, Telenor Pakistan employees shall exercise extra caution with respect to gifts or organising arrangements. If gifts are to be given to or arrangements made for representatives of public authorities, these shall be assessed as to their suitability, which includes the gift's value in relation to what the recipient may legitimately accept as stipulated in the recipient's organisation's internal regulations, whether there can be openness within the organisations regarding the matters and the circumstances in general. The assessment shall be carried out by the person responsible for giving the gift or organising the arrangement.

If you are in doubt as to whether you may give a gift or send an invitation to an arrangement, contact your immediate superior for clarification. Such enquiries and clarifications should be documented.

Notification obligation
If you find yourself to be in a situation where there are grounds to believe that corruption exists you must immediately inform your immediate superior or, if that is not possible, inform Telenor Pakistan's Compliance Officer.