Denys Lementar

• Responsible for leading the Integrity and Compliance program in the Middle East & Africa, Europe and Central
Asia regions (30+countries) with a focus on ABAC, ethics, culture and corporate governance
• Implementing recommendations of and cooperating with the US DOJ as a result of 200M USD FCPA settlement
• Leading and conducting the group-wide Compliance risk assessment, incl. all territories where company operates
• Working closely with strategic business groups and functional leadership to mitigate anti-bribery and anti
corruption risks across the regions, regularly update country leaders on changes in the regulatory domain
• Overseeing the vetting and onboarding of third parties (vendors; suppliers; sales intermediaries; customers)
• Leading development of the Ethics Ambassadors Program in designated regions
• Development and implementation of Compliance training plans

• Designing and implementing Compliance program with a focus on anti-bribery and anti-corruption, anti-money
laundering, sanctions and export controls, data privacy, ethics, culture and corporate governance
• Developing and implementing new versions of compliance policies and procedures (Group Code of Conduct,
Compliance Charter, Anti-Bribery & Anti-Corruption, Conflict of Interest, Gifts & Hospitality, Anti-Money
Laundering, Sanctions & Export Controls, Whistleblowing, Investigations, Data Privacy and Protection)
• Developing and conducting Code of Conduct and compliance related trainings (both online and face-to-face)
• Performing risk assessments, monitoring and testing of the compliance program
• Providing oversight of the compliance hotline, leading in conducting and managing internal investigations in
coordination with all relevant functions
• Advising management team and employees on various сompliance matters and changes in the legislation
• Digitalization of сompliance program (development of the gifts and hospitality, conflicts of interest registers,
whistleblowing hotline and other compliance tools)
• Data Protection Officer, leading the development of Data Privacy and Protection program across the group

• Designing and implementing compliance program at VEONs Ukrainian operational company Kyivstar in line with
the 10 Hallmarks of an Effective Compliance Program
• Implementing recommendations of and cooperating with the US DOJ & SEC Monitor team as a result of 795M USD
FCPA settlement
• Monitoring compliance program against Code of Conduct, policies and applicable anti-corruption regulations
• Developing and maintaining policies and procedures for the general operation of the compliance program (Code
of Conduct, Anti-Bribery & Anti-Corruption, Gifts & Hospitality, Conflicts of Interest, Commercial Sponsorship,
Social Investments and Charitable Contributions, Free Services)
• Providing consultation and trainings on FCPA, UK Bribery Act, international legislation, gifts & hospitality, social
investments, free services, anti-bribery and anti-corruption matters to the companys managements team
• Reviewing sponsorships social investments and donations
• Launching and developing internal network of Compliance Ambassadors (60 volunteers who help to develop
compliance program inside the company)
• Due diligence & screening of key business partners and drafting contractual terms and conditions related to
business partners compliance warranties and obligations