Vimpelcom Deferred Prosecution Agreement

VimpelCom admitted that it had falsified its books and recordings and tried to conceal the bribes. It recorded payments as equity transactions, advisory contracts and returnee transactions. In an agreement on deferred lawsuits, VimpelCom agreed to maintain an independent corporate monitor for at least three years. It also agreed to put in place “strict internal controls”. . . . and fully cooperate with the division`s ongoing investigations, including the investigation of individuals,” the DOJ said. In addition, VimpelCom admitted to falsifying its books and records and attempting to conceal and conceal the corruption system by classifying payments as equity transactions, advisory and refusal agreements, and returnee transactions. VimpelCom also failed to implement and implement adequate internal accounting controls, allowing bribes to be done without detection or correction. In addition, when the Board of Directors consulted an FCPA legal opinion on the assessment of corruption risks related to transactions, VimpelCom`s management withheld crucial information from external lawyers who conducted the audit, which limited the scope of the FCPA`s opinions and rendered them worthless.

Instead of implementing and imposing a strong anti-corruption ethic, some VimpelCom executives have sought ways to deny the company`s illegality while knowingly pursuing corrupt business transactions. With the completion of the DPA, the U.S. Department of Justice asked the U.S. District Court for the Southern District of New York to dismiss the charges deferred by the DPA. VimpelCom has entered into an agreement with the U.S. Securities and Exchange Commission (SEC) and the Openbaar Ministrie (OM) in a corresponding proceeding. Under the terms of its resolution with the SEC, VimpelCom has agreed to a total realization of $375 million in profits and interest in damages to be shared between the SEC and OM. VimpelCom agreed to amend OM by $230 million for a total fine of $460,326,398.40 and a total solution amount of more than $835 million. The ministry agreed to offset the penalty paid to OM as part of its agreement with the company.

The SEC agreed to credit the forfeiture paid to the department under its agreement with the company. Thus, the total amount of criminal and regulatory penalties paid by VimpelCom in the United States and the Netherlands will amount to $795,326,398.40, making it one of the largest global foreign bribery decisions of all time. This press release contains “forward-looking statements” as defined in the amended Section 27A of the U.S. Securities Act of 1933 and Section 21E of the U.S. Securities Exchange Act of 1934, as amended. Forward-looking statements are not historical facts and are inherently subject to risks and uncertainties, many of which cannot accurately predict VEON and some of which do NOT even anticipate, including the expected termination of deferred royalties by DPA. The forward-looking statements contained in this press release speak only as of the date of this press release. .

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