Conflict of Interest Questionnaire & Declaration

VEON’s core values include truthfulness and collaboration. Accordingly, employees must act in the VEON's
best interests and refrain from making decisions that benefit personal interests over VEON's interests or divide
loyalties between personal and professional obligations.

Conflicts of interest exist when personal interests or loyalties interfere or appear to interfere with the ability to
perform one's professional responsibilities and duties effectively and without bias. Conflicts of interest are not
always obvious, and sometimes people wrongly think that a conflict will not affect their decisions or
performance. Conflicts of interest harm collaboration, competitiveness, and the commitment to customers, who
trust VEON to operate in a clean, transparent manner. Even the appearance of conflicts can damage our
relationships internally among employees and externally with customers, regulators, and business partners.

In an effort to better identify actual and potential conflicts of interests, all candidates for key leadership positions
must complete the following questionnaire and declare to its accuracy and return the document to Human
Resources.

CANDIDATE DETAILS
BUSINESS N/A
NAME:
UNIT
TELEPHONE #: OPCO N/A
EMAIL N/A
FUNCTION:
ADDRESS:
QUESTIONNAIRE

1. Have you ever been employed by a VEON Group company?

Please circle: Yes or No
If yes, please describe by providing the (a) name of the former employer, (b) location, (c) position held,
(d) dates of service in each position (MM/YYYY), and (e) circumstances of your departure.

2. Are you subject to any contractual or statutory restrictions prohibiting you being employed by
the VEON Group (for example, a “non-competition clause”)?
Please circle: Yes or No
If yes, please describe by providing (a) the month and year (MM/YYYY) you became bound by the
restriction, (b) the month and year (MM/YYYY) the restriction ends, and (c) the reasons why you are
subject to the restriction.

3. Are you or have you been employed by a VEON Group competitor?

Please circle: Yes or No
If yes, please describe by providing the (a) name of the former employer, (b) location, (c) position held,
and (d) dates of service in each position (MM/YYYY).

4. Do any of your relatives1 currently work for the VEON Group?

Please circle: Yes or No
If yes, please describe by providing the (a) name of the individual, (b) location, and (c) position.

1 The term “relatives” includes by marriage, law or blood: spouse, significant other, domestic partner, co-habitor, mother,
father, grandfather, grandmother, brother, sister, daughter, son, stepmother, stepfather, stepson, stepdaughter, uncle, aunt,
niece, nephew, first cousin, and the spouse, co-habitor, significant other, or domestic partner of any of the above.
 5. Have you or any of your immediate family members2 founded a for-profit or not-
for-profit entity?
Please circle: Yes or No
If yes, please describe by providing the (a) name of the founder, (b) entity name, (c) entity
purpose, (d) location, and (e ) whether you/your immediate family member is active in the entity, and, if
not, when activity ended (MM/YYYY).

6. Do you have any additional or part time jobs, or are you involved in any other entrepreneurial,
business or consultancy activity?
Please circle: Yes or No
If yes, please describe by providing the (a) name of the entity/activity; (b) your role, (c) number of hours
dedicated per week to it; and (d) whether it (i) is in the technology/telecommunications industry or (ii)
provides goods or services to VEON.

7. Do you or your immediate family member hold any Significant Financial Interests 3? If yes,
please describe:
Please circle: Yes or No
If yes, please describe by indicating (a) how much of the stock, (b) whether you/your immediate family
member have or share discretionary authority over decisions made by that business, and (c) whether the
investment represents more than 5% of your/your immediate family member's total assets.

8. Do you hold any public, business, or charitable positions?

Please circle: Yes or No
If yes, please describe by indicating (a) the name of the entity/activity, (b) your role, (c) number of hours
dedicated per week to it, and (d) a brief description of the organization's purpose.

9. Are you currently, or have you been within the last five years, a government official4?
Please circle: Yes or No
If yes, please describe by indicating (a) your roles, (b) the name of the government entity with which you
were affiliated, (c) date of departure, and (d) whether you believe the entity regulates or may influence
VEON.

2 The term “immediate family member” includes by marriage, law or blood: spouse, significant other, domestic partner, co-
habitor, mother, father, brother, sister, daughter, or son.

3 A “Significant Financial Interest” exists if: (1) the individual, individually or together with his or her immediate family,
directly or indirectly, (i) owns more than 2% of the stock of a business, or (ii) has or shares discretionary authority over
decisions made by that business; or (2) the investment represents more than 5% of an employee’s total assets. Significant
Financial Interest’s do not include small investments in stocks of publicly-held companies.
4 The term “government official” includes:
 Any elected or appointed official (whether in the executive, legislative or judicial branches of government) of a
local, state, provincial, regional or national government (or any department or agency of those types of government
bodies);
 Any government employee, part-time government worker, unpaid government worker, or anyone “acting in an
official capacity” (that is, acting under a delegation of authority from a government to carry out government
responsibilities);
 Any political party, party official, or candidate for political office;
 Any official or employee of a public international organization such as the World Bank or United Nations, or any
department or agency of those types of organizations;
 Any official, representative, or employee of a company that is under even partial ownership or control by a
government. This means that all employees of government-owned companies and instrumentalities are officials for
purposes of this policy, even if the companies are operated like privately-owned corporations
10. Are you or do you desire to be a candidate for political office?
Please circle: Yes or No
If yes, please identify the (a) office, (b) date (MM/YYYY) of election, and (c) number of
hours dedicated per week to it.

11. Are any of your immediate family members or close personal friends government officials?
Please circle: Yes or No
If yes, please describe by indicating (a) their roles, (b) the names of the government entities with which
they are affiliated, and (c) whether you believe the entity regulates or may influence VEON

12. Do you have any other potential or apparent conflicts of interest that you would like to disclose?
Please circle: Yes or No
If yes, please describe:

13. Have you ever been sued, charged with a criminal or administrative offence, or subject to a
corporate investigation or disciplinary process?
Please circle: Yes or No
If yes, please describe the (a) suit, charge, or investigatory or disciplinary process, (b) resolution,
including sanction, if any, (c) suing party, charging agency, or corporate entity, (d) location, and (e) date
(MM/YYYY).

For those countries where the data protection or privacy laws require, the following statement should
be added to the form and signed by the employee:

I, [Candidate Name], identification number _____________, hereby consent to record and process
my personal data by the [name of OpCo or BU] of VEON Ltd and to give access to such personal
data to the external auditor and to the Compliance Office of VEON Ltd., located at 88, Claude
Debussylaan, Amsterdam, 1082 MD, the Netherlands, for the purposes of compliance with the Key
Leadership Position Questionnaire and Declaration.

Signature: Date: ______________________________

______________________________