2011
MTN Group
Corporate Ethics
Ethical code versus reality
ABSTRACT: This document analyzes the culture of corporate ethics in the MTN
Group. The first section offers a definition of business ethics as branch of
ethics, while the second section looks at popular ethical practices (straw men)
in relation to philosophical ethics. The MTN Group Code of Ethics is
summarised in the third section and followed in the fourth section by an
assessment of the Groups ethical practices in reality. A set of
recommendations, in section five, precedes the conclusion.
PLEASE NOTE HOW I HAVE RE-WRITTEN THE ABSTRACT!!!
Karabo Harry
0315956W
5/13/2011
Dear K:
A fine report – well researched.
Two significant and related problems exist with the current draft.
First, it’s not clear that you use the ethical framework to be found in Hill, or
developed in our class, to create an ethical framework of your own. It’s not
entirely clear that you understand the key concepts – eg, you appear to treat
Kantian and deontological ethics as if they were identical in this assignment.
Second, a clear ethical framework does not inform your analysis. You simply
describe – often quite rightly – MTN’s behaviour as ethically repugnant.
That said, your paper does contrast MTN’s Code of Ethics with its actual practice
of ethics. Your evaluations and conclusions – throughout the paper -- are both
interesting and damning. Therein lies the real strength of the paper. Had you
been able to tie the literature review and your own ethical framework to the
critiques of MTNs practices, you would have had an even stronger paper.
Grade: 70.
Shap shap

Stu
Table of Contents
1.
Introduction .................................................................................................................................... 5
2.
Popular ethical practises ................................................................................................................. 6
2.1.
Straw men ethics: ................................................................................................................... 6
2.2.
Other views on ethics: ............................................................................................................ 6
3.
MTN Group: Code of Ethics............................................................................................................. 7
4.
Corporate ethics in practice ............................................................................................................ 7
4.1. MTN Group Code of ethics........................................................................................................... 7
4.2 Expansion strategy: The MENA region.......................................................................................... 8
4.3. MTN Group: On competition and tariffs .................................................................................... 10
5.
Recommendations ........................................................................................................................ 12
6.
Conclusion ..................................................................................................................................... 13
7.
References .................................................................................................................................... 13
Appendix ............................................................................................................................................... 14
3.1. Introduction. .............................................................................................................................. 14
3.1.1. Purpose. .............................................................................................................................. 14
3.1.2. Policy ................................................................................................................................... 14
3.1.3. Understanding the Code. .................................................................................................... 14
3.2. Compliance with the laws and regulations. ............................................................................... 14
3.3. Conflict of interest. .................................................................................................................... 14
3.3.1. Outside activities, employment and directorships. ............................................................ 15
3.3.2. Relationship with clients, customers and suppliers. ........................................................... 15
3.3.3. Gifts, Hospitality and favours .............................................................................................. 15
3.4. Employment equity. ................................................................................................................... 16
3.5. Environmental responsibility. .................................................................................................... 17
3.6. Political support. ........................................................................................................................ 17
3.7. Group's funds and property. ...................................................................................................... 17
3.8. Group's records. ......................................................................................................................... 17
3.9. Dealing with outside persons and organizations. ...................................................................... 17
3.10. Privacy and confidentiality. ...................................................................................................... 18
3.11. Contravention of the Code. ..................................................................................................... 18
1. Introduction
Within philosophy there are numerous sub-disciplines. Broadly speaking ethics is the branch
that discusses issues of morality. Morality deals with notions of good and bad, justice,
fairness, right and wrong, and the way we develop and apply our values. Meta-ethics is
concerned with various theories that promote ideas of what constitute the good. Normative
ethics applies standards or norms and reaches conclusions about what we ought to do.
Business ethics is an area within normative ethics that is concerned with the special moral
issues and concerns that arise in business. (Gibson, 2007)
Businesses operate within a country, environment and society. Depending on the industry
the business is in, its operations might have negative, positive or no externalities 1 .
Businesses that have negative externalities have a greater moral obligation towards the
communities they operate within owing to the social costs of those externalities. In the past
some businesses have made super economic profits at the expense of stakeholders, without
any regard to the social costs. These companies have engaged in fraudulent, corrupt and
other unethical practises. As a result, the ethical practices of businesses have come under
greater scrutiny, giving birth to regulatory bodies that seek to enforce ethical business
practices.
The notion of business ethics can be conceived of in two distinct mannersIndividuals uphold
ethics of the companies that employ them and not personal ethics: This culminates in
employees making decision based on company protocol “maximise profits” and not person
judgment even if the latter is ethically more sound than the former.
or

Individuals uphold a single set of ethics that applies throughout their lives: This
notion of business ethics is not relevant. Individuals act ethically even if it means
losing their jobs. (Gibson, 2007)
Costs or benefits of business operations that are borne or enjoyed by parties not directly
involved in the business activities, third-party effects or spill-over effects
1
2. Popular ethical practises
A summary of some of the popular ethics theories is given below and shall be referred to
throughout the documents.
2.1. Straw men ethics:
“Business ethics scholars raise straw men approaches primarily to demonstrate that they
offer inappropriate guidelines for ethical decision making in multinational enterprises”.(Hill,
2011)

Friedman Doctrine: ‘Business of Business is Business’. This notion asserts that the
only social responsibility a business has is to make profits while abiding by the law.

Cultural Relativism: ‘When in Rome do as the Romans do’. A view that sees ethics as
nothing more than a cultural construct, as cultures differ from one place to another
so do ethics.

The Righteous Moralist: Practicing home country ethical standards in a foreign
country. An ethical practice that occurs when a Multi National Enterprise tries to
enforce its home country’s business ethics in an emerging market context.

The Naive Immoralist: Do what other MNCs are practicing in a foreign country. The
view that if the majority is practicing similar behaviour then it is justifiable to follow
suit (Hill, 2011).
2.2. Other views on ethics:

Kantian: treat people as ends themselves not as means to an end.

Utilitarian: an action is justified ethically if it yields the best results for the majority.
This ethical point of view is all about selecting an action whose consequences leaves
most people better off even if some people are left worse off.

Ubuntu: an African philosophy that enforces respect, development and
consideration of everyone in society for the benefit of the collective.

Deontological ethics: derived from the Greek word for “duty”, deontological ethics
stresses the ethical centrality of such things as duties, principles, and obligations. It
denies that all ethical judgements can be made in terms of consequences. (Gibson,
2007)

Rights Theories: the recognition that all humans have rights2 by virtue of being
human, these rights transcend beyond culture, norms and society. Compliance of the
rules stated in the Universal Declaration of Human Rights (UDHR). Moral agents3
have a duty to see to it that these human rights are not violated.
3. MTN Group: Code of Ethics
Please refer to the Appendix to see a summary of the MTN Group Code of Ethics.
4. Corporate ethics in practice
Some of the ethical issues that Multi National Corporations (MNCs) face on a daily basis
include; employment practices, human rights, environmental pollution, corruption and
moral obligation (Hill, 2011). Any violation of these ethical issues might lend a business in
serious trouble with the law, ethics enforcing bodies such as the United National Global
Compact (UNGC) and activist, culminating in reputational damage or worse. Hence it's in the
best interest of a company to practice nothing but the best business ethics.
4.1. MTN Group Code of ethics
The MTN Group code of ethics does address some of the issues outlined above;
a) Environmental responsibility, (Appendix, section 3.5.) MTN Group environmental
drive is run like a well oiled machine. The Groups Environmental Management
Program is committed to using best industry practises when building infrastructure,
other initiatives include minimisation of waste, prevention of pollution and
responsible land management, including managing the impact on flora, fauna, water
and wildlife (Group, 2005). The MTN SA Group is an ISO 14001 Certificated
Company4.(Pienaar, 2011)
b) Anti-corruption is the key underlying theme that runs throughout the Code of Ethics.
The MTN Group does not take lightly to unlawful activities such as fraud, money
laundering, bribery etc. The Ethical Code states in black and white that anyone in
2
Those rights that individuals have simply in virtue of being human being, also called natural or moral rights
A moral agent is any person or institutions capable of moral action such a government of corporation.
3
4
contravention of the code shall be dealt with either by dismissal or handed over to
the law depending on the contravention.
c) The Employment equity section (Appendix, section 3.4) talks about the Groups
employment practices looking at; discrimination, disability, illness and Black
Economic Empowerment. The Group BBBEE competent across the following
spectrum; equity ownership, management, employment equity, skills development,
procurement, enterprise development, and corporate social investment (Group,
2011a). MTN Group also participated in a BEE shares scheme called ‘Zakhele’, which
a Zulu word for build it yourself.
d) The code of ethics does not address the Groups moral obligation however the MTN
group does engage in Corporate Social Responsibility (CSR) and Corporate Social
Investment (CSI) programs. (Group, 2011b)
The MTN Group Code of Ethics however fails to address human rights issues, the company
stance on competition as well as a pricing structure (regulated to an extent). These issues
are quite important in the South African Telecommunications industry because of the small
number of key players and the potential for market growth.
4.2 Expansion strategy: The MENA region.
Currently MTN Group Limited (MTN Group) has mobile licenses across 21 countries in Africa
and the Middle East. The Group operates in the following three regions: (Group, 2011b)

South and East Africa (SEA), which includes: MTN South Africa, MTN Swaziland, MTN
Zambia, MTN Uganda, MTN Rwanda and Mascom Botswana.

West and Central Africa (WECA), which includes: MTN Nigeria, MTN Cameroon,
MTN Congo-Brazzaville, MTN Cote d’Ivoire, MTN Benin, MTN Ghana, MTN GuineaBissau, MTN Guinea Conakry and Lonestar Liberia, and

Middle East and North Africa (MENA), which includes MTN: Irancell, MTN
Afghanistan, MTN Cyprus, MTN Sudan, MTN Syria and MTN Yemen.
When a company expands into a new region as part of its globalisation strategy, an ethical
strategy should at least inform that decision, this is necessary because some countries don’t
respect human rights. South Africa pre 1994 is quintessential of this fact. One can dispute
the ethics of MNCs that traded in South Africa during the apartheid era; were their
globalisation strategy informed to an extent by an ethical strategy? Were profits put before
human rights and political unrest issues? Was it judicious to invest in such a country? What
reputational damage could it deal to the business? Will investing in a country with serious
human rights issues mean that the company supports the current status quo or regime?
These are some of the ethical questions corporations need to ask when going into a new
region.
Looking at the MENA region (excluding Cyprus), which is plagued by political, social and
economical issues. Afghanistan, Iran, Syria, Sudan and Yemen according to the 2011 Index
of Economic Freedom all scored below the world average for economic freedom (Journal,
2011). This index measures economic freedom5 in 183 countries using the following criteria:
business freedom, trade freedom, fiscal freedom, government spending, monetary
freedom, investment freedom, financial freedom, property rights freedom, freedom from
corruption and labour freedom.
The scale below is used to rank countries;
DISTRIBUTION OF GLOBAL ECONOMIC FREEDOM
100-80
79.9-70
free
mostly free
69.9-60
moderately free
59.9-50
49.9-0
N/A
mostly un-free
repressed
not ranked
Table 1: Economic freedom index rankings (Journal, 2011)
Both Afghanistan and Sudan were not ranked owing to unreliable data. Iran, Syria and
Yemen came well below the world average, as seen below.
5
Economic freedom is the fundamental right of every human to control his or her own labour and property. In
an economically free society, individuals are free to work, produce, consume, and invest in any way they
please, with that freedom both protected by the state and unconstrained by the state. In economically free
societies, governments
Figure 1: Graphical representation of the Economic Freedom Index (freedom, 2011)
These countries are non-members States of the United Nations (UN) (Rights, 2011). Human
rights issues such as arrests and detentions, rape and other torture, unfair trials,
discrimination against women, freedom of expression and association, cruel, inhumane and
degrading punishments, discrimination of ethnic and religious minorities are quite prevalent
(International, 2011).
The MTN Group expansion strategy is a ‘low penetration and high population’, coupled with
a ferocious appetite for risk. The Group takes a neutral position and practices cultural
relativism (Rajha, 2011). Thus social unrest, human rights issues and political instability play
a meagre role if any.
This form of corporate expansion strategy can be viewed as applying two variations of straw
men ethics (Friedman doctrine and Cultural Relativism). On these accounts, every business
may move into regions which have a potential to yield profits. However one can argue that
this should be coupled with an intention to create change or improve the well being and
livelihoods of individuals and groups within those countries. The MTN Group is a South
African company, a move into a countries that don’t value human rights is in conflict with
South African history, given the injustice that the apartheid system dealt the country.
Investing in countries that don’t respect human rights for pure economic profit motives is
ethically repugnant..
4.3. MTN Group: On competition and tariffs
The South African Competition Commission has launched an investigation of possible
collusion between the MTN Group and Vodacom. The Commission claims that the two
major mobile network providers in South Africa have been engaging in anti-competitive
practices to keep Cell C out of the game. In a telephone interview with Reuters, Nandi
Mokoena (Competition Commission’s manager of strategy and stakeholder relations) told
Reuters that the mobile operators were being under investigation for price collusion.
(Lourie, 2009)
This matter is still under investigation however a survey conducted by The South African
Foundation on Telecommunications (fixed and mobile calls costs) Prices in South Africa,
revealing that South Africa has some of the highest prices in the whole world compared to
our peer group. (Foundation, 2005). Other sources showed this fact. (act, 2011)
...”Last year the department commissioned an international benchmark study to see how
South Africa compared to five countries - Chile, South Korea, India, Brazil and Malaysia - in
terms of cost, usage, access and quality of services. Some of the startling findings include:”

Mobile tariffs are the most expensive in South Africa;

Mobile broadband tariffs for high volumes are the most expensive in South Africa;

South Africa has the second highest SMS prices; and

All of the countries have maximum broadband speeds that are faster than South
Africa. (Pather, 2009)
Some call the telecom industry in South Africa an “easy-money industry”. It is obviously
ethical for a company to make profits. However business practice become unethical when
excessive profits are gained by exploiting workers, consumers, the environment or engaging
in anti-competitive behaviour. Profits look especially questionable when CEOs and directors
operating in emerging markets get paid inflated salaries and bonuses (Businessweek, 2011).
Telecoms Executives Total Salary
Executive
Total salary 2009/2010
Phuthuma Nhleko (MTN CEO)
R15,694,000
Rob Shuter (Vodacom CFO)
R14,205,882 (includes sign-on and restraint of trade bonus)
Pieter Uys (Vodacom CEO)
R10,700,571
Shameel Joosub (Vodacom SA MD) R9,452,685
Sifiso Dabengwa (MTN Executive) R8,291,000
Table 2: Telecoms executive salaries (Mybroadband, 2010)
The MTN Group takes a stance that when technology is new in a country prices are often
high because the initial infrastructure investment should be recouped (Rajha, 2011). The
regulator seems blasé about the pricing structure for SA telecoms. The Government has
stepped in and asked MTN and Vodacom to slash tariffs before 2012.
The MTN Group currently boast 147.265 million subscribers and an average income per
subscriber of R137 (Report, 2011). The group has been in business for over a decade and
reaped massive profits -- surely the capital costs incurred can’t still be used as an excuse to
over-charge clients. This conclusion is buttressed by the fact that the broadband speed
provided is one of the slowest in the world when compared to peer group countries. Surely,
capital costs ought to be invested to increase broadband width,
Cell C has been viewed as a free-rider by both MTN and Vodacom. Both firms state that Cell
C can afford to charge low fees because they are using MTN and Vodacom infrastructure.
This thought process is used to justify the interconnection cost of R1.25 that the two big
network providers charge.
5. Recommendations
At the heart of most unethical business practices lies flawed Decision making processes,
leadership, unrealistic performance goals, organisation culture and personal ethics (Hill,
2011). The MTN Group Code of Ethics covers some of the key issues quite well. However
more can be done.
The Group should look into including the following into their code:

Human rights

Competition policy

Fair pricing declaration

Responsible marketing practices
MTN should look into incorporating an ethical strategy that informs some of their
expansion strategies. It is not good enough in this day and age to do business purely for
monetary gains especially in emerging markets, as Henry Ford eloquently put it;
“A business that makes nothing but money is a poor business”.
6. Conclusion
Business ethics have been an extremely contentious issue for years. Business practices are
not getting any better because regulatory bodies are not stringent when enforcing the law.
Greed and corruption fuels corporate decision making processes, profit maximisation comes
before ethical practices undermining consumer’s intelligence. Corporations have failed to
show initiative to be ethical on their accord hence Regulators and Governments should
intervene because the social cost is borne by the stakeholders not executives.
7. References
act, B. (2011) SOUTH AFRICA TELECOMS 'AMONG WORLD'S MOST COSTLY', SAYS NEW SURVEY, (Last
updated on), accessed 302, from http://www.balancingact-africa.com/news/en/issue-no302/telecoms/south-africa-telecom/en.
Businessweek, B. ( 2011),
Foundation, S. A. (2005) Telecommunications prices in South Africa An international peer group
comparison, (Last updated on, from
http://www.businessleadership.org.za/documents/12568Telecomm_web.pdf.
freedom, I. o. e. (2011) Visualize the Scores,
Gibson, K. (2007) Ethics and Business, Cambridge University Press, Cambridge.
Group, M. (2005) Integrated Business Report, (Last updated on, from
http://annualreport.mtn.com/sr_environmental.htm#01.
Group, M. (2011a) BEE Overview, (Last updated on, from
http://www.mtnsp.co.za/MTNBusiness/BEE/Pages/BEEOverview.aspx.
Group, M. (2011b) MTN Group Website, (Last updated on, from
http://www.mtn.com/Pages/Home.aspx.
Hill, C. W. L. (2011) International Business: Competing in the Global Marketplace, Eighth ed.,
MacGraw-Hill, New York.
International, A. (2011) Human Rights in Countries, (Last updated on, from
http://www.amnestyusa.org/our-work/countries.
Journal, T. H. F. T. W. S. (2011) 2011 Index of Economic Freedom, (Last updated on 2011), accessed
May, 2011, from http://www.heritage.org/Index/ranking.
Lourie, G. (2009) REFILE-UPDATE 2-Vodacom, MTN deny price collusion allegations, (Last updated on,
from http://in.reuters.com/article/2009/10/15/safrica-mobile-idINLF50086120091015.
Mackintosh, M. M. R. (2011) Code of Ethics, In GROUP”, M. G. L. A. S. A. T. (ed.),
Mybroadband (2010) Telecom Executives Total Salary,
Pather, B. N. a. S. (2009) Cellphone firms forced to slash their prices (Last updated on, from
http://www.timeslive.co.za/sundaytimes/article145720.ece.
Pienaar, K. (2011) MTN’s Environmental Policy (Last updated on, from
http://www.mtn.co.za/AboutMTN/EnvironmentalSustainability/Pages/default.aspx.
Rajha, Y.-R. C. (2011) MTN Group Business Ethics, Telephone conversation ed., Johannesburg.
Report, B. (2011) MTN subscribers rise 4% to 147m, (Last updated on, from
http://www.iol.co.za/business/companies/mtn-subscribers-rise-4-to-147m-1.1065438.
Rights, U. N. H. (2011) Human Rights by Country, (Last updated on, from
http://www.ohchr.org/EN/Countries/Pages/HumanRightsintheWorld.aspx.
Appendix
3.1. Introduction.
3.1.1. Purpose. A code of ethics serves as a boundary within which employees, directors
and stakeholders (where applicable) of a company should operate. It serves as guide line for
a company's employees when making day to day business decisions, raising and maintaining
ethical awareness, company's expectations and ethical stance.
“The Group's philosophy is to conduct it's affairs with uncompromising honesty, integrity,
diligence and professionalism and to be recognised for these qualities by all its
stakeholders”(Mackintosh, 2011)
The MTN group encourages employees to rely on their personal ethics over and above the
Groups ethics code when making business decisions stating;
“Do unto others as you would have them do unto you.” ~ Confucius
3.1.2. Policy. The code of ethics policy is endorsed by Company's Board of Directors and is
based on the fundamental belief that business should be conducted honestly, fairly and
legally. (Mackintosh, 2011) . The Group expects its employees, directors and stakeholders to
practice the highest ethics standards and nothing less.
3.1.3. Understanding the Code. Compliance with the Code by employees, directors and
stakeholders is compulsory throughout the group. If anyone is suspected to be in breach of
the Code, the matter should be escalated and will be dealt with as set out in Contravention
of the Code section.
3.2. Compliance with the laws and regulations. The MTN Group does not condone any
unethical or illegal business operations such as; fraud, money laundering, bribery etc.
3.3. Conflict of interest. Owing to relationships that employees and directors might have
with the outside world a conflict of interest might arise. Any action, obligation or interest
that might cause an employee, director or stakeholder of MTN Group to act in a way that
does not put the best interest of the company first is a conflict of interest.
“A conflict could arise where an employee, a member of an employee's family or a business
with which the employee of family is associated obtains a gain, advantage or profit by virtue
of the employee's position with the Group, or knowledge gained through that position”
(Mackintosh, 2011)
3.3.1. Outside activities, employment and directorships. Employees are encouraged
to partake in activities outside the Group provided that those activities are not in conflict
with the group's activities. Employees' private activities should not be so demanding on
their energy, time and attention to an extent that their contribution to the MTN Group
suffers.
Outside employment might not be taken before prior approval by management.
3.3.2. Relationship with clients, customers and suppliers. Employees are expected to
be independent and are seen as independent from all organisations that have contractual
business obligations with the MTN Group. They may neither invest nor acquire financial
interest in such companies before approval by an Executive Director is given. If such
relationships arise they should not influence the employee's business decision making
process and being dutiful towards the Group. When dealing with clients, customers and
suppliers Group employees should:

Never accept or pay any bribes to suppliers, protect the suppliers data and consider
creditors financial situation whenever requesting any payment extension.

Keep business and personal life separate.
3.3.3. Gifts, Hospitality and favours. Gifts, hospitality and favours could be perceived to
influence the employees' judgement in relations to business transactions hence employees
should neither give nor accept gifts, hospitality and favours from organisations that have
business contracts with the MTN Group with the following exceptions;

Employees may accept advertising matter of limited commercial value.

Employees may give or accept occasional business entertainment and hospitality
such as free tickets. Local hospitality getaways with prior consent from a superior,
the CEO need to approve oversees hospitality.

Gifts above R1 000 should be declared to superior and company secretary, and no
gifts above R 5 000 should be accepted.

Cellular devices and related accessories up to the value of R10 000. The Groups
employee may supply the Groups/subsidiaries branded products on a limited basis.
(Mackintosh, 2011)
Employees should neither offer personal favours nor preferential treatment to customers or
suppliers representatives that place some obligation to the recipient. Investments
All employers are permitted to invest provided their investments are not in conflict with the
Groups interest and all sensitive information should be kept private and confidential. The
ethics of employees that make investment decisions on behalf of the Group are governed by
the Companies Act, Insider Trading, SEC Regulation Panel and other regulatory bodies,
industry associations and management. Employees are not to act injudiciously and
unethically owing to the pressures placed on them by shareholders unrealistic expectations.
3.4. Employment equity.
“The company strongly rejects notions of 'window dressing' or tokenism and believes it is in
the best interest of the business, the individual employees and peers to know that
employment in the Group is on merit, rather than simply an individual's race or other
criterion unrelated to their capacity to do the job” (Mackintosh, 2011)
The company supports BEE and the advancement of blacks and females in managerial
positions throughout the Group. All employees have the right to work in a discrimination
free environment. All employees may continue to work for the Group irrespective of their
illness or disabilities provided that the quality of their work is maintained and they are not a
health hazard to their colleagues as well as themselves.
3.5. Environmental responsibility. All MTN Group operations that pose a real safety and
health hazard are to be reported by employees as set out in the Contravention of the Code
of Ethics. The Group is committed to developing policies addressing operations that impact
the environment negatively through measures such as; pollution control, waste
management and rehabilitation activities.
3.6. Political support. Employees' political affiliations are private and the Group respects
political activity and supports it as long as it does not cause any workplace disruptions and
industrial unrest.
3.7. Group's funds and property. The Groups funds, property, goods or services shall not
be used for any activity other than its normal business function, special authorisation is
necessary when a need arises. Group funds can be spent by an employee given 'good
judgement' is used and the usage such expenditure should generate value on behalf of the
Group. Speculation using financial derivatives is not permitted; the use of such instruments
should be for risk mitigation only, within detailed parameters of the MTN Group risk
management policies. All employees should report fraudulent and inappropriate usage of
funds as set out in the Contravention of the Code.
3.8. Group's records. Employees responsible for the handling of financial records should
adhere to ethical accounting practices. The Group does not permit omission of revenues,
expenses, assets and/or liabilities from financial records.
3.9. Dealing with outside persons and organizations. Communication with the outside
world should be prompt, courteous and accurate. Complaints are dealt with using
established internal protocol. All as a general rule the Group's senior management should
deal with the Group's position on public policy or industry issues. Employees should not
speak on behalf of the Group unless their views are ones shared by the Group and it's the
Groups desire to make those views public. The CEO or Group's Secretary should be
consulted first before an employee may engage a media official. When employees comment
on matters not involving the MTN Group they should separate their personal roles from the
Group position.
The MTN Group obligations to the society are;

To uplift the communities in which it operates, within its means

Respect the law, rights and dignity of others

Pay all taxes and other duties as the required by law
3.10. Privacy and confidentiality. It's the employees' responsibility to safeguard the
Group's or Customer's confidential and private information. Divulging such information
without following the proper procedures is not permitted.
3.11. Contravention of the Code.
“As contravention of the code is a serious matter, it may result in disciplinary action,
including the termination of employment. Certain breaches of the Code could also result in
civil or criminal proceeding” (Mackintosh, 2011)
All suspected and actual contraventions of the Code are to be reported to management,
Human Resource practitioner or commercial legal service. All incidences will be handled
with confidentiality.