Code of Conduct New

“We compete fairly.”

We are committed to fostering a fair competitive marketplace that benefits our customers, stakeholders, and the industry.

We believe in competing vigorously but fairly, adhering to the highest ethical standards and all applicable laws and regulations.
We strictly prohibit any form of anti-competitive practices, including but not limited to:

• Collusion: Engaging in agreements with competitors to fix prices, rig bids, or allocate markets or customers etc.
• Monopolistic Behavior: Abusing a dominant market position to restrict competition or create barriers to entry.
• Tying and Bundling: Forcing customers to buy unwanted services as a condition for obtaining desired services.
• Exclusive Agreements: Entering into contracts that unfairly limit the ability of our partners or customers to do business with our competitors.
• Information Exchange: Limit sharing commercially sensitive information with competitors.

We obtain a written approval from Head of Legal before joining a Trade Association or Industry Forum. 

Should any conversation with a current or potential competitor transition to an inappropriate or anti-competitive topic, we promptly withdraw from the discussion and report the incident to our Legal Department and/or the Integrity Hotline.

We are obligated to report any suspected breaches of competition laws to the Legal Department without delay, which will then escalate the matter to the appropriate authorities when necessary.

“We maintain accurate financial records and comply with all disclosure standards.”

We are committed to upholding the highest standards of financial integrity and transparency to maintain the trust of our shareholders, customers, Business Partners, and employees.

We expect all employees, contractors, and partners to adhere to these standards to ensure the trust of our stakeholders and the sustainability of our business.

We strictly comply with all applicable financial laws, regulations, and company policies. This includes adhering to accounting standards and practices that apply to our business.

We adhere to all internal control procedures to safeguard company assets and ensure accurate financial reporting. This includes complying with authorization protocols and ensuring proper documentation for all financial transactions.

We abstain from creating fraudulent records, falsifying documents, destroying records, engaging in anti-money laundering activities, or participating in any actions that misrepresent facts, transactions, or financial data.

We ensure the decisions are made in accordance with the Authorization matrix and implemented segregation of duties to maintain proper oversight and control.

We promptly report any observed fraud, suspicious transactions, financial or accounting irregularities, misreporting of financial information, or misuse of company resources to the Integrity Hotline.

We avoid anti-money laundering and the breaching of any anti-money laundering laws in Myanmar.

These include:

• conversion or transfer of money and property, knowing or having reason to know that it is money and property that are the proceeds of crime, for the purpose of disguising or concealing the illicit origin of the money or property
• concealment or disguise of the true nature, source, location and disposition, movement or ownership of or right with respect to money and property, knowing or having reason to know that such money and property are proceeds of crime 
• acquisition, possession or use of money and property, knowing or having reason to know, at the time of receipt, that such money and property are the proceeds of crime
• participation in, association with, aiding, abetting, facilitating, managing, counseling and being a member of an organized group to commit or conspiracy to commit any offence as stipulated above.

“We expect to work with responsible business partners.”

We recognize that our achievements are closely linked to the success and integrity of our Business Partners. 

We are dedicated to cultivating mutually beneficial relationships founded on trust, transparency, and shared values. Our business partners encompass suppliers, vendors, contractors, consultants, and other third parties who contribute to our operations and services to drive positive change, foster innovation, and create value for our customers and communities. It is also imperative to note that the actions of our business partners can impact on our reputation and expose us to legal risks.

We expect our Business Partners to adhere to the same high standards of integrity and ethical behavior that we uphold.

We conduct thorough due diligence when selecting our Business Partners to ensure they share our values and commitment to ethical and responsible practices in their business operations.

We comply with applicable trade controls including sanctions regimes and import-export requirements.

All business partners must comply with all applicable local, national, and international laws and regulations. This includes, but is not limited to, Anti-Money Laundering Law, Labor Law, Environmental Conservation Law, and Anti-Corruption Law.

We unequivocally expect our business partners to comply with all relevant Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) regulations and ensure their practices do not facilitate or support money laundering or financial crime.

We expect our business partners to uphold human rights with fair wages and safe workplace and encourage to operate sustainably and responsible manners by minimizing environmental impacts, reducing waste, and supporting climate change initiatives.

We are committed to preventing and detecting any form of money laundering and financial crime by performing due diligence on our business partners and transactions, reporting suspicious activities, and maintaining accurate records.

We treat all Business Partners with respect and in a fair and transparent manner.

“We act responsibly when engaging externally.”

We use social media to share our personal perspectives thoughtfully and ensure that we only represent the company when explicitly authorized to do so.

Employees are encouraged to share non-confidential news, milestones and achievements related to ATOM on their social media account(s).

Only authorized spokespersons are permitted to communicate on behalf of the company. They are responsible for ensuring that all public statements are consistent with our company's policies and values.

All media inquiries should be directed to the Corporate Communication.

All external communications must comply with applicable laws, regulations, and industry standards.

All employees must adhere to Corporate Communication Policy and social media guidelines and seek guidance if unsure about the appropriateness of any communication.

All employees are advised to inform Corporate Communications for sponsorship and donation when approached by external party, stakeholders.

We do not discuss sensitive or confidential information that we have learned from our employment in public or social media.

We always provide truthful and accurate information to Public Officials, following the ATOM’s policies and procedures.

We comply with laws and rules that apply to Public Officials, including those on business courtesies when ATOM is engaging in a commercial or approval process.

ATOM does not take political positions or associate with political movements and does not support political parties, neither in the form of direct financial support nor paid time.

We may participate in political activity as a private citizen provided that it is lawful, but we do not use company funds and/ or resources or paid time for those activities.

“We avoid business courtesies that could be perceived as impacting business decisions.”

Business gifts and modest entertainment are commonly employed to build goodwill and strengthen professional relationships among business associates. In certain circumstances, it may be appropriate to provide or accept occasional meals, small company tokens, or participate in sporting and cultural events. 

However, it is important to recognize that gifts, hospitality, social events, seminars, entertainment, meals and beverages also have the potential to be misused for bribery. They can either serve as direct bribes or create opportunities for bribery by enticing individuals. Additionally, they may facilitate the development or maintenance of relationships within a bribery scheme.

We unequivocally prohibit the offering or acceptance of business courtesies that could, or might be perceived to, improperly influence a business decision.

We never offer or accept cash or cash equivalents, or expensive and extravagant gifts.

We permit the exchange of gifts solely as promotional items of minimal value, and only when it is customary and appropriate to do so.

We may offer or accept hospitality only when the business purpose is explicit, the costs are reasonable, and the context is open and transparent; however, we strongly prefer to cover our own costs.

Business courtesies must not be extended to family members or close friends under any circumstances.

We are required to discuss any offering or acceptance of business courtesies with our immediate line manager.

We seek exceptions only in special circumstances subject to a prior review by the Chief Business Risk Officer and/or prior written approval by the Chief Executive Officer.

“We avoid conflict of interests.”

A conflict of interest may arise when an individual utilizes their position at ATOM to pursue personal advantages, including those for themselves, their family, or associates, which could potentially conflict with ATOM’s interests.  Actual conflict of interest as well as perceived conflict of interest must be avoided.

A conflict of interest will undermine our value, our culture and our behavior expected in fulfilling duties and responsibilities at ATOM.

A conflict of interest can hinder an individual’s ability to discharge their duties impartially and effectively. 

A conflict of interest can exist even in the absence of unethical behavior, the perception of undue influence in decision-making processes must be avoided. 

Hence, ATOM expects that all of its directors’ officers’ and employees’ actions and decisions will be made objectively and in the best interests of the Company.

We must therefore avoid conflicts of interest and not be influenced by personal or external business interests that could affect our commitment to ATOMs best interests.

We are strictly prohibited from using our positions at ATOM, confidential information, assets, or any other resources for personal gain or to benefit associated individuals.

We are required to disclose any relationship that could impact our decisions as ATOM employees, including the relationship with employees, suppliers, business partners and employees of competitors etc.

We do not hold external duties or positions/engagements that could affect, or be perceived to affect, our responsibility to act in best interests of ATOM.

We are required to report any actual, potential and perceived conflict of interest with ATOM, as soon as we become aware, to the Line Manager and to Ethics and Compliance.  

We are required to obtain written approval from our line manager before accepting external directorships, duties, or other material assignments, and we keep records in accordance with company procedures.

“We provide a safe and secure workplace.”

We are dedicated to fostering a 'Safety First' and 'People First' culture. This commitment extends across our value chain and involves collaboration with our suppliers to identify and mitigate health, safety, and security risks.

We are committed to providing a healthy, safe, and secure working environment and empower our employees with the 'Right to Stop' authority to address any hazardous activity.

We adhere to all applicable Health Safety and Security Legislation, Guidelines, and internationally recognized Standards, including those for electromagnetic fields in network operations.

We promote a proactive culture of Health Safety and Security Incident Reporting, encouraging transparency and learning from all incidents, near-misses, unsafe acts, and conditions. This approach supports continuous improvement and knowledge sharing.

Transport safety is a major focus for us, and we are committed to promoting compliance with transport safety standards at both corporate and regional levels.

We have a strict zero-tolerance policy for the use of drugs and alcohol in the workplace.  Employees must not be under the influence of substances that impair their ability to perform their duties safely.    

“We demonstrate dignity and respect at workplace.”

We uphold and support labour rights as fundamental human rights. This includes ensuring fair pay, benefits, and freedom of association for all employees and partners associated with ATOM.

We prioritize the physical, emotional, and psychological wellbeing of all employees. We are dedicated to creating a supportive and respectful working environment where everyone is protected from harassment, intimidation, discrimination, or threats of violence for any reason, including actions based on gender, sexual orientation or identity, race, disability, national origin, religious beliefs, or citizenship.

We promote equality and inclusion in all employment practices, recognizing that employee diversity enhances our perspectives and enables us to better meet the needs of our customers.

We value and respect employees’ unique ideas and differences. We actively listen to diverse perspectives and evaluate them based solely on their merits.]

We cultivate a work environment characterized by respect, honesty, and professionalism.

We always dress neatly and appropriately in the workplace.

We consider sexual harassment, including incidents occurring outside the workplace due to employment responsibilities or relationships, entirely unacceptable and will not tolerate it under any circumstances.

We do not engage in conversations or send communications of any kind that contain offensive name-calling, jokes, slurs, stereotyping or threats, nor do we display or share offensive pictures, cartoons, drawings, or gestures.

We confront any incidents of harassment or inappropriate behavior and proactively protect our work environment.

We do not use alcohol or illegal drugs in the workplace, or abuse prescription medication, and we never purchase sexual services on business trips or other assignments.

We do not retaliate against any employee, Business Partner, or customer for raising a good faith concern.

We are committed to ensuring that no individual or group of colleagues is intentionally excluded from relevant discussions without proper justification.

“We are committed to protecting the environment and contributing to the prevention of climate change.”

ATOM recognizes the profound impact that climate change has on our world, our communities, and our business operations. As a responsible telecommunications operator, we are dedicated to contributing positively to environmental sustainability and addressing climate change through actionable and measurable commitments.

Environmental Stewardship

• We adhere to all applicable local regulations and internationally recognized environmental standards.
• We maintain transparency by reporting on the impact of our activities on climate and environmental conditions were required.
• We report any observed incidents that may adversely affect the climate or environment.

Sustainable Practices

• We are dedicated to minimizing our consumption of resources, including energy, water, and raw materials. 
• We strive to limit greenhouse gas emissions arising from our operations through reasonable and effective measures.
• We consider our suppliers’ climate and environmental impact and assess them based on responsible business practices when procuring products and services.
• We support sustainable waste management including making reasonable efforts to minimize our waste.

“We respect human rights.”

We are committed to respecting and promoting human rights in all aspects of our operations. We believe that safeguarding human rights is not only a moral obligation but also essential for our success and sustainability as a responsible business. Our commitment aligns with internationally recognized human rights standards and principles.

We affirm that all individuals are entitled to human rights without discrimination, as outlined in international conventions and local legislation.

We work proactively respecting and supporting the rights of children.
We are dedicated to upholding the human rights of our employees, the employees of our business partners, and our customers. We ensure that, to the best possible extent, we neither violate these rights nor become complicit in any violations by others.

We are committed to conducting our business in a fair and non-discriminatory manner and encourage our business partners to uphold and respect human rights.

We strive to address and positively influence societal challenges related to individual human rights, including children's rights, through our business practices.

We avoid engaging with business partners known to violate human rights laws, ensuring our business relationships align with our values.

We maintain a strict policy against retaliation towards individuals who make good faith reports of human rights violations related to our operations. Such reports should be made to the Integrity Hotline, where they will be handled with the utmost confidentiality and seriousness. 

“We protect personal data of our customers, employees, and business partners.”

We are dedicated to safeguarding the privacy and security of our customers' personal information. As a telecommunication operator, we recognize the critical importance of preserving the confidentiality and integrity of the data entrusted to us. This section delineates our approach to data privacy and the core principles we uphold to ensure the highest standards of protection.

We are committed to safeguarding the personal data and ensuring its use strictly for legitimate business purposes.  Personal data includes employee, customer, and Business Partner information such as phone numbers, e-mail addresses, physical addresses, locations, call and payment history, salaries, and health information.

We adhere to ATOM’s Privacy Policy to regulate the management of personal information across the company.

We are committed to processing data with stringent access controls, robust security measures, and comprehensive data protection protocols.

Personal data will only be shared with individuals or entities who have a specific business purpose related to our telecommunication services, unless such sharing has been explicitly authorized or is mandated by legal requirements.

We apply privacy measures to business partners to maintain data protection standards.

“We keep information secured and safeguard company assets.”

Confidentiality is essential for maintaining our reputation and safeguarding our interests in competitive and regulatory environments, as well as for preserving the integrity of our assets.

At ATOM, safeguarding our information and ensuring business security is fundamental to maintaining the trust of our clients, partners, and employees. We are committed to protecting our information assets from threats, whether internal or external, deliberate or accidental.

We are obligated to handle all information according to the security classifications outlined in our company policy.

We may have access to confidential information regarding the company, customers, or business partners and are required to handle it with the highest level of discretion and care.

We ensure confidential information is protected from unauthorized access, sharing it only when formally authorized and for legitimate business purposes.

While we/ encourage knowledge sharing, we exercise caution with confidential information and avoid discussing sensitive topics in public areas.

We treat information from third parties with the same level of confidentiality and care as our own information.

We identify and protect records of high corporate value and adhere to both internal and external requirements for document retention.

We ensure that all information from ATOM is reliable and correct and complies with high professional and ethical standards.

We use ATOM’s approved systems and adhere to requirements for information processing.

We always assess the security risks and follow security policies and requirements when we perform business decisions.

We promptly report any security incidents, which can impact our assets significantly, affecting financial, operational, and reputational aspects, in accordance with company procedures, laws, and regulations.

We protect company assets with the same care as our own, guarding them against loss, damage, theft, waste, and misuse.

We limit access to company assets to what is necessary for job functions, follow proper access protocols, and do not share access credentials, including PINs and passwords.

We safeguard our intellectual property and uphold the intellectual property rights of others with the highest level of respect and integrity.

We must adhere to the Business Security Policy, Information Security and Physical Security Manual and seek guidance if unsure about the appropriate actions.

“ATOM does not tolerate retaliation of any kind against those who speak up in good faith.”

When there is any doubt or question on the activities regard to the compliance to the Code of Conduct, employees should ask their line managers and Ethics and Compliance Function. 

It is the responsibility of employees to report any activities that is believed to be breach of our Code of Conduct or applicable laws and such course of action will help ATOM Myanmar Limited to maintain the position of prudent and responsible telecom operator. 

It is also understood that reporting the breaches to Line Manager and/or Ethics and Compliance Function may sometimes require courage to come forward. Hence, an Integrity Hotline, 24/7 web-based system open to employees and business partners, has been established to protect the privacy of individuals who report a concern, and individuals who are the subject of a reported concern. The report person can remain anonymous to keep confidential unless it is agreed to do so.

All the reports, from either in person or Integrity Hotline, are treated with high confidentiality, and a very restricted number of people are allowed access to them.  The reports shall be taken seriously and given fair and objective follow-up. 

In all cases, the Ethics and Compliance Function supports Ethics and Compliance Committee in resolving the investigated concerns to determine whether disciplinary or corrective actions are required. Anyone who violates the law, the Code, or ATOM Policies or Manuals may be subjected to disciplinary action, up to and including termination of employment. 

It is important to remember that we can all report suspected unethical or illegal behavior without fear of retaliation.  Reported matters must be respectful, honest and free from derogatory language and discrimination and must adhere to the principle of this very Code of Conduct it is trying to uphold.  Although anonymity is allowed and an avenue is provided to remain anonymous, the best results are always achieved through open discussion and coming forward in person.  We encourage being courageous and coming forward in person to achieve the best results for ATOM.