Policies |
Summary of our positions and commitment |
Anti-bribery and Corruption Policy |
The Anti-bribery and Corruption Policy is a governance policy that formally communicates MTN Nigeria’s stance towards the prevention of Bribery and Corruption practices. It also displays MTN Nigeria’s commitment to conducting MTN Nigeria’s business in an ethical, transparent and acceptable manner in compliance with the legislation and negotiations of the jurisdictions in which the company operates. The policy is implemented to ensure that all payments, procurements, transactions, gifts and rewards are not used for unlawful bribery practices and that any agreement with a third party by an MTN Nigeria staff or director was made in good faith. It prohibits the offering or receiving of a financial or other advantage, either directly or indirectly, for the purpose of an undue benefit or reward improper decisions from a person or company, regardless of whether they are a government or public official, private person, company or anyone acting on MTN Nigeria’s behalf. |
Board Appointment and Succession Planning Policy |
(Document is confidential) |
Conduct Passport |
The MTN Nigeria Conduct Passport Policy is the foundation for setting the tone regarding our code of conduct. MTN Nigeria’s values lead to success and underpin our relationship and trust with employees, directors, customers, business partners, government, shareholders, communities, and society. It emphasises the company’s commitment to its operations and demonstrates the standard of ethics and conduct to be met by individuals employed by MTN Nigeria or entities that are engaged in business with the company. The MTN Nigeria Conduct Passport is an essential tool in achieving the vision and driving the Ambition 2025 strategy forward. It encourages general conduct and encourages all employees and staff to act in accordance with MTN Nigeria’s values and protect the brand and reputation of the company. It covers all policies, including anti-harassment, corruption, bribery, disciplinary policy, recruitment, selection and talent management, environment, compliance and governance, among others. |
Conflict of Interest Policy |
The Conflict of Interest Policy is a governance policy defined in the MTN Nigeria Master Policy that arose as a safeguard against employees having personal or business interests that have the potential to influence the independence and objectivity of their decision-making due to associations from which they may derive a benefit. MTN Nigeria recognises that the management of conflicts of interest is of high importance in promoting ethical conduct. The declaration of the conflicts of interest policy is therefore essential in protecting the integrity and objectivity of MTN Nigeria’s decision-making process and strengthening confidence among stakeholders. The policy aims to ensure employees’ compliance with key principles and standards. However, this Policy does not seek to discourage employees from contributing to outside activities that benefit society but rather provides guidance for ethical conduct in relation to their obligations to MTN Nigeria. |
Digital Rights Policy |
MTN Nigeria’s Digital Rights Policy is also a governance policy updated to reflect the national priorities and realities of the country’s cyber domain. It is in line with MTN Nigeria’s vision of leading the delivery of a bold, new digital world to its customers and its belief that everyone deserves the benefits of a modern, connected life. The policy serves to demonstrate the federal government’s commitment to effectively harness the benefits and opportunities of the dynamic threats and emergent challenges. As a responsible corporate organisation and citizen, MTN Nigeria, through the framework of this policy, would align its strategy and operations to ensure that the digital rights of Nigerian citizens are respected in line with the provisions of the extant laws while complying with the laws, policies and strategies of the Federal Republic of Nigeria and other stakeholder for the purpose of achieving a secure digital environment. The specific aspects the Digital Rights Policy would address include freedom of expression, digital inclusion and access, online safety and net neutrality. |
Document Management, Data Retention and Archiving Policy |
The MTN Nigeria Document Management, Data Retention and Archiving Policy is implemented to ensure effective management of documents within the organisation. The policy’s purpose is to state the standouts required for the preparation and control of documents as well as the methods for identification, storage, protection and retrieval of all internal documents and data. The policy also aims to outline the guidelines for retaining and destroying specific data, documents, or information in MTN Nigeria and guide employees and third parties working with MTN Nigeria regarding the minimum required for the retention period for the different types of data.
The policy covers various aspects of document management, data retention and archiving processes and procedures. They include:
- Data Management
- Data and Document Ownership
- Data Inventories
- Data retention and Archiving
- Accidental Loss
- Approval and Maintenance
- Data/Department Destruction
- Data Security
- Retention and Archiving Exception
- Storage
Data such as personal data should be kept up-to-date and accurate and should only be retained if necessary. |
Information Security Policy |
The Information Security Policy is fundamental to MTN Nigeria’s daily operations of success. MTN Nigeria has instituted an organisation-wide information security program to address the security needs across the business. The policy focuses on maintaining an effective and efficient security posture for MTN Nigeria and everyone related to or working for and with MTN Nigeria, ensuring a reasonable and appropriate level of security awareness and protection throughout the organisation and infrastructure, as well as maintaining a solid security foundation. This policy aims to ensure proper management of information security, proper awareness of the information security policies, procedures, guidelines and standards and promotion of user awareness. |
Risk Escalation and Acceptance Policy |
The MTN Nigeria Risk Escalation and Acceptance Policy sets out the principles to provide the minimum requirements and guidelines of risks to ensure consistent and timely escalation and acceptance of all relevant risk events to various levels of management within MTN Nigeria. The policy is intended as a reference document to guide management as a standard approach for escalating and accepting risks. It covers the four response strategies: treat, tolerate, transfer, and terminate. The policy’s goal is to ensure that risks are managed to acceptable levels and align with the organisation’s risk appetite through risk response, monitoring, timely escalation, and reporting to the right levels within MTN structures. In some cases where response plans may not work, the risk acceptance process policy would be undertaken. |
Whistleblowing Policy |
The MTN Nigeria Whistleblowing Policy encourages all employees and third parties to report any incident of fraud, misconduct, bribery or any misappropriation by any internal or external party by or against MTN Nigeria via whistleblowing facility. To ensure that anonymity is provided to a whistle-blower, MTN Nigeria has acquired the services of an independent external service provider to manage the whistleblowing facility on behalf of the company. Employees can report any improper activity timeously, and each transgression is protected and treated as confidential. |
Data Governance Policy |
The Data Governance Policy consolidates the integral parts of our enterprise data governance processes and practices, such as Data Governance Processes, Data Migration Framework Policy and DaaS Platform Retention Policy.
- Data Governance Processes
These data policies are a collection of principles that describe the rules to control the integrity, security, quality, and usage of data during its lifecycle. It also defines the roles and responsibilities of MTNN staff, contractors, and consultants with internal and external parties in relation to data access, retrieval, storage, disposal, and backup of MTNN’s data assets.
- Data Migration Framework Policy
This framework document outlines a practical roadmap for managing data migration projects. It gives a high-level overview for those individuals not familiar with data migration and serves as a reference for those individuals familiar with the topic.
- DaaS Platform Retention Policy
DaaS is a best-in-class Big Data platform which collects, integrates & presents MTN’s Data Assets to the business. It’s a powering insights platform that provides MTN with the opportunity for both internal & external monetisation and a differentiated competitive advantage in our markets. The policy covers all transaction data (i.e. E-layer), summarised data (i.e. BSL, 5by5, Usage Cluster, etc.), and user schema categories on the DaaS Platform. It applies to providing the guiding retention principles applicable to the platform. It also ensures compliance and regulatory requirements on data retention and protection are met during the processing, managing, moving, protecting, and archiving of various business data according to its unique characteristics such as age, usage patterns, regulatory and compliance protection rules and archiving policies; security and disaster protection rule. |
Data Privacy and Protection Policy |
The Data Privacy and Protection Policy supports MTN Nigeria in establishing and maintaining an adequate and consistent level of data privacy and protection across the business. The policy sets out the minimum expectations that MTN Nigeria should comply with when processing Personal Data of Data Subjects and aims to ensure the ethical and responsible collection, use, and management of Personal Data entrusted to MTN Nigeria. It also explains MTN Nigeria’s key privacy principles fair and lawful basis for processing personal data. We also appointed a Data Protection Officer in line with the requirements of the Nigeria Data Protection Act, 2023. |
Responsible Advertising and Marketing Policy |
The MTN Nigeria Responsible Advertising and Marketing Policy is an operational policy that outlines MTN Nigeria’s commitment to accurate, non-offensive, appropriate, consistent and inclusive marketing efforts. It ensures that MTN’s marketing practises and processes are sound and done in a responsible manner to avoid any reputational and brand damage. The policy ensures that MTN’s marketing efforts, to the extent feasible, are representative and inclusive, aligning with our values of diversity and inclusion and free of violence, discrimination, and harmful stereotypes. The policy applies to all MTN Nigeria affiliates, partners, consultants and service providers across all forms of advertising and marketing materials including written, digital, social media, audio, verbal, electronic or any media platform, being guided by applicable regulations such as Companies and Allied Matters Act (CAMA) 2020, Nigerian Communications Act, 2003, Nigerian Communication Commission (NCC) Code on Corporate Governance, NGX Listings Requirements and Advertising Regulatory Council of Nigeria (ARCON) Act No. 23 of 2022. |