Responsible Business - Integrity & Transparency A Journey from Resistance to Engagement Michaela Ahlberg Chief Ethics & Compliance Officer TeliaSonera Relation Identifier 0.1 Draft

“Unfortunately from what has emerged in the Norton Rose Fulbright review the current Board can point out that several transactions, and actions during the period mentioned above have been conducted in a manner inconsistent with sound business practice and TeliaSonera’s ethical requirements. It cannot even be ruled out that certain conduct has been in violation of the law. It is not only about single transactions, it is about a pattern where deficient transactions have been repeated on different levels.” Marie Ehrling, AGM 2014 Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

Commitment to Responsible Business Anti-corruption Freedom of Expression Customer Privacy Occupational Health and Safety Sustainability in The Supply Chain Environmental Responsibility We strive to be fully accountable and transparent towards our stakeholders. It is crucial that we can show how we run an ethical and responsible business. We achieve this through: Living by the letter and spirit of the law. Adhering to international norms and guidelines for ethical business practices. Ensuring that our suppliers and partners understand and live by our standards and requirements. Integrating good governance practices and best in class compliance in our daily operations. “TeliaSonera is a great company with a strong commitment to conducting ethical and responsible business. At TeliaSonera we do not accept bribery or corruption in any form. It is our duty to prevent and fight corruption and to act as corporate ambassadors and with the highest sense of transparency and integrity – wherever we operate. Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

2017-04-172017-04-17 Compliance Framework- a Structured Approach Designed to follow international standards for an effective, adequate and achievable compliance program. All focus areas report according to the Compliance framework to ensure consistency in policy implementation and follow-up. The Group E&C Office is responsible for driving the work - the line organisation is responsible for practical implementation and application. Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

Tone From the Top and Management Oversight TS Board Sustainability and Ethics Committee Group GREC Group Executive management Escalation and report GREC = Governance Risk Ethics Compliance Regional GREC Regional management Implementation and roll-out Country GREC Country management Follow-up and Compliance Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

Third Party Management Steps: Compliance Perspective Third party engagement Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

Decentralized purchasing organisation Lack of real engagement from previous local management Weak local competence in anti-corruption and third party risks Group Procurement Policy adoption reluctance Poor quality of information and lack of IT solutions and support Risk categorisation of vendors difficult and ad hoc Roles and responsibilities were unclear. The use of Intermediaries Procurement management is Change management !

Three Basic Questions Is the program well designed Is it being applied in good faith Does it work Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

Integrated Compliance Acknowledgement Cooperation Resistance Acceptance Engaged compliance Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB

Training and Effective Communication New Code of Conduct New Policy Management Training based on: Ethical dilemmas Ethical decision-making Leadership Open Sustainability Presentation Stockholm 8 April, 2015 #TeliaSonera @TeliaSoneraAB