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VEON Ltd.

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FY2020 Annual Report · VEON Ltd.
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Annual Report 2020 

VEON Ltd. 

Claude Debussylaan 88, 

1082 MD Amsterdam

The Financial Statements are
approved by the Audit Committee
on behalf of the Board 
on March 15, 2021 

 
TABLE OF CONTENTS

Director's Report............................................................................................................................................
Information on the Company...........................................................................................................................................

Directors and Senior Management and Employees........................................................................................................

Major Shareholders and Related Party Transactions......................................................................................................

How We Manage Risks...................................................................................................................................................

Risk factors......................................................................................................................................................................

Operating and Financial Review and Prospects..............................................................................................................

Additional Information......................................................................................................................................................

Quantitative and Qualitative Disclosures about Market Risks.........................................................................................

Declarations.....................................................................................................................................................................
Consolidated Financial Statements..............................................................................................................
Company Financial Statements....................................................................................................................
Other Information...........................................................................................................................................
Independent Auditor’s Report.......................................................................................................................

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Directors’ Report

INFORMATION ON THE COMPANY

Overview

VEON is a leading global provider of connectivity and internet services. Present in some of the world’s most dynamic 
markets, VEON provides more than 210 million customers with voice, fixed broadband, data and digital services. VEON currently 
offers  services  to  customers  in  9  countries:  Russia,  Ukraine,  Pakistan,  Kazakhstan,  Algeria,  Uzbekistan,  Bangladesh,  
Kyrgyzstan  and  Georgia.  VEON’s  reportable  segments  currently  consist  of  the  following  seven  segments:  Russia,  Pakistan, 
Algeria,  Bangladesh,  Ukraine,  Uzbekistan  and  Kazakhstan.  We  provide  services  under  the  “Beeline,”  “Kyivstar,”  “banglalink,” 
“Jazz” and “Djezzy” brands. As of December 31, 2020, we had 43,639 employees. For a breakdown of total revenue by category 
of  activity  and  geographic  segments  for  each  of  the  last  three  financial  years,  see  —  Operating  and  Financial  Review  and 
Prospects.

 In September 2019, we announced a new strategy framework at the Group level including a commitment to boost long-
term growth beyond traditional connectivity services. The strategy framework set out how VEON plans to drive value from three 
business  pillars:  its  fundamental  mobile  and  fixed  line  connectivity  services  and  the  drive  of  4G  adoption;  a  portfolio  of  new 
services  built  around  digital  technologies  with  the  active  involvement  of  big  data  and  artificial  intelligence;  and  future 
assets which seeks to identify, acquire and develop ‘’know-how” and technologies that open up adjacent growth opportunities.

As  part  of  our  initiative  to  digitize  our  core  telecommunications  business,  ensuring  we  address  4G  penetration  levels 
across  the  group  is  vital  as  4G  services  remain  a  core  enabler  of  our  digital  strategy.  We  intend  to  continue  focusing  on 
increasing  our  capital  investment  efficiency,  including  with  respect  to  our  IT,  network,  and  distribution  costs.  We  have  secured 
network  sharing  agreements  and  intend  to  maintain  our  focus  on  achieving  an  asset-light  business  model  in  certain  markets, 
where we own only the core assets needed to operate our business. For further information on our capital expenditures, see  — 
Operating and Financial Review and Prospects — Liquidity and Capital Resources — Future Liquidity and Capital Requirements. 
We anticipate that we will finance the investments with operational cash flow, cash on our balance sheet and external financing.  
For more information on our recent developments, see  — Operating and Financial Review and Prospects — Key Developments 
During 2020.

VEON  Ltd.  is  an  exempted  company  limited  by  shares  registered  under  the  Companies  Act  1981  of  Bermuda,  as 
amended  (the  “Companies  Act”),  on  June  5,  2009,  and  our  registered  office  is  located  at  Victoria  Place,  31  Victoria  Street, 
Hamilton HM 10, Bermuda. Our headquarters are located at Claude Debussylaan 88, 1082 MD, Amsterdam, the Netherlands. 
Our  telephone  number  is  +31  20  797  7200.  VEON  Ltd.  is  registered  with  the  Dutch  Trade  Register  (registration  number 
34374835) as a company formally registered abroad (formeel buitenlandse kapitaalvennootschap), as this term is referred to in 
the Dutch Companies Formally Registered Abroad Act (Wet op  de formeel buitenlandse  vennootschappen), which means  that 
we are deemed a Dutch resident company for tax purposes in accordance with applicable Dutch tax regulations. Our website is 
www.veon.com. The information presented on our website is not part of this Annual Report.

Our legal representative in the United States is Puglisi & Associates, 850 Library Ave, Suite 204, Newark, DE 19711 (+1 
(302) 738 6680). Our agent for service of process in the United States is CT Corporation, 11 Eighth Avenue, New York, NY 10011 
(+1 (212) 894 8400). In addition, the SEC maintains a website that contains reports, proxy and information statements, and other 
information regarding issuers that file electronically with the SEC, which can be accessed over the internet at http://www.sec.gov.

History

Our predecessor PJSC VimpelCom (formerly OJSC “VimpelCom”) was founded in 1992. In 1996, VimpelCom listed on 
the  New York  Stock  Exchange,  where  it  remained  listed  until  2013  when  VimpelCom  moved  its  listing  to  the  NASDAQ  Global 
Select Market. In March 2017, VimpelCom rebranded to VEON and on April 4, 2017, VEON began trading its ordinary shares on 
Euronext Amsterdam.

In  the  early  2000s,  we  began  an  expansion  into  the  Commonwealth  of  Independent  States  (CIS)  by  acquiring  local 
operators or entering into joint ventures with local partners, including, but not limited to, in Kazakhstan (2004), Ukraine (2005), 
Uzbekistan  (2006), Armenia  (2006)  and  Georgia  (2006).  In  2009  and  2010,  PJSC  VimpelCom  and  Ukrainian  mobile  operator, 
Kyivstar,  combined,  and  we  subsequently  established  our  headquarters  in  Amsterdam.  Our  expansion  efforts  have  included 
transactions involving operations outside of CIS. In 2011, we completed the acquisition of Wind Telecom S.p.A., an international 
provider of mobile and fixed-line telecommunications and internet services with operations in Italy, through Wind Telecom, and in 
Algeria, Bangladesh and Pakistan, through GTH (previously known as Orascom Telecom Holding S.A.E.).

In  November  2016,  the  group  combined  its  Italian  mobile  telecommunications  business  with  that  of  CK  Hutchison 
Holdings Ltd. in a joint venture company named Wind Tre. In July 2018, the group announced the sale of its 50% stake in Wind 
Tre  to  CK  Hutchison  Holdings  Ltd.  which  was  completed  in  September  2018.  In  July  2019,  VEON  Holdings  B.V.  launched  a 
mandatory tender offer (“MTO”) to purchase the shares of GTH, a subsidiary of VEON which consolidates the group’s operations 
in Algeria, Bangladesh and Pakistan. At the close of the MTO in August 2019, VEON held approximately 98.24% of  GTH’s total 
outstanding  shares.  VEON  subsequently  embarked  on  a  comprehensive  restructuring  of  GTH,  including  a  successful  offer  to 
acquire substantially all of GTH’s operating assets in Algeria, Pakistan and Bangladesh following the delisting of GTH from the 
Egyptian Exchange in September 2019.  In late 2020, we sold our operating subsidiary in Armenia. 

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Recent Developments

COVID-19 

The  global  outbreak  of  COVID-19  and  associated  containment  and  mitigation  measures  implemented  worldwide  have  had  a 
sustained impact on our operations and financial performance.

The  second  quarter  saw  the  full  impact  on  our  operations  of  the  lockdowns  imposed  across  our  markets  in  response  to 
COVID-19. This resulted in material disruption to our retail operations following store closures, impacting gross connections and 
airtime sales. Restrictions on travel resulted in a significant decline in roaming revenues and the loss of migrant customers from 
our subscriber base, particularly in Russia. 

Although VEON’s operations remained impacted by lockdown measures throughout the second half of the year, all operations 
saw a  recovery in the performance as our local businesses continue building resilience to the restrictions related to COVID-19. 
Demand for our data services remains strong, enabling us to continue to grow our data revenues. We also experienced a shift in 
data traffic from mobile to fixed networks as lockdowns encouraged remote working and home schooling alongside a greater use 
of devices through our domestic broadband services.

An  increase  in  demand  for  hard  currencies,  in  part  due  to  COVID-19,  resulted  in  the  devaluation  of  exchange  rates  in  the 
countries in which VEON operates. As such, during the year ended December 31, 2020, the book value of assets and liabilities 
of  our  foreign  operations,  in  U.S.  dollar  terms,  decreased  significantly,  with  a  corresponding  loss  of  US$623  million  recorded 
against the foreign currency translation reserve in Other Comprehensive Income.

Our management has taken appropriate measures to keep our personnel safe and secure. As of the date of these financial 
statements, other than as described above, we have not observed any particular material adverse impacts to our business, 
financial condition, and results of operations. The group liquidity is sufficient to fund the business operations for at least another 
12 months. 

Partnership with MasterCard

In May 2020, VEON announced a partnership between JazzCash and payment technology leader Mastercard that strengthens 
the payments ecosystem for merchants and customers in Pakistan. More than 7 million customers and merchants use JazzCash 
every  month,  making  it  Pakistan’s  leading  digital  wallet.  The  partnership  with  Mastercard  allows  merchants  to  accept  digital 
payments from customers, digitize their supply chain, and move to cashless operations. In a first for Pakistan, merchants and 
consumers  who  sign  up  for  JazzCash  wallet  will  be  able  to  benefit  from  a  wide  range  of  Mastercard’s  digital  solutions  and 
capabilities to pay for orders and services via all digital channels as well as make online payments in a fast, safe and convenient 
manner. JazzCash customers will also have access to Mastercard’s virtual and branded debit cards that can be used in 55,000 
points of sale and ATMs in Pakistan, in addition to JazzCash merchants and e-commerce sites.

Exercise of put option for 15% stake in Pakistan Operations 

In September 2020, the Dhabi Group exercised its put option to sell us its 15% shareholding in Pakistan Mobile Communications 
Limited  ("PMCL"),  the  operating  company  of  Pakistan’s  leading  mobile  operator,  Jazz.  VEON  updated  the  fair  value  of  its  put 
option liability following the completion of an independent valuation process which determined a fair value for the shareholding of 
US$273  million.  Completion  of  the  transfer  remains  subject  to  the  conclusion  of  the  contractual  transfer  mechanics  with  the 
Dhabi Group. Once completed, VEON will indirectly own 100% of PMCL. 

Beeline Kazakhstan signed Network Sharing Partnership 

In October 2020, VEON announced that its operating company in Kazakhstan, which provides services under the Beeline brand, 
entered into a network sharing partnership that unites the nation’s three mobile telecom providers in the delivery of high-speed 
internet to rural communities. The agreement brings Beeline together with Kcell and Tele2 in support of the nation’s 250+ project, 
which  aims  to  extend  high-speed  internet  to  all  villages  with  a  population  of  250  or  more.  Once  complete,  the  project  will  see 
almost 1,000 rural settlements with a combined population of 600,000 offered 3G and 4G connections by all three operators.

The  250+  initiative,  the  infrastructure  deployment  for  which  started  immediately,  enables  rural  residents  to  receive  mobile 
services on competitive terms and select a service provider of their choice. In turn, each mobile operator will enjoy equal access 
to the shared network.

VEON acquired strategic stake in ShopUp in Bangladesh

In October 2020, VEON joined Sequoia Capital India and Flourish Ventures as investors in ShopUp, Bangladesh’s leading full-
stack B2B commerce platform for small businesses, becoming ShopUp’s first strategic corporate investor.

The investment of approximately US$8 million, in exchange for a 13.5% stake, is expected to enable VEON to support ShopUp’s 
fast-growing  digital  ecosystem  for  micro,  small  and  medium-sized  enterprises,  which  form  a  vital  backbone  of  Bangladesh’s 
economy, as well as provide opportunities for developing mobile financial services for ShopUp’s users.

5

Agreement concluded for the sale of Armenian operations 

In  October  2020,  VEON  concluded  an  agreement  for  the  sale  of  CJSC  “VEON  Armenia”,  VEON’s  operating  subsidiary  in 
Armenia,  to  Team  LLC  for  a  consideration  of  US$51  million.  Accordingly  the  net  carrying  value  of  assets  amounting  US$33 
million  were  de-recognized  along  with  reclassification  of  cumulative  foreign  currency  translation  reserve  of  US$96  million    to 
profit and loss, resulting in the net loss of US$78 million.

Beeline Russia completed coverage of all Moscow metro stations with 4G and expanded 4G coverage in Moscow

In  December  2020,  VEON  announced  that  Beeline  Russia  achieved  100%  4G  coverage  and  enabled  its  customers  to  access 
high-speed  internet  at  all  stations  of  the  Moscow  metro,  as  well  as  in  most  of  the  adjacent  tunnels.  The  milestone  reflects 
Beeline’s ongoing efforts to improve the quality of 4G connectivity and offers Beeline customers the ability to stay in touch, listen 
to music and stream content in good quality whilst underground.

In January 2021, VEON announced that Beeline Russia completed a large-scale project to improve the quality and availability of 
mobile internet in Moscow. The project included the redistribution of the 2100 frequency range from 3G to 4G and an expansion 
in the frequency range used in the 4G network from 30 to 45 MHz. This has enabled an increase in the average speed of mobile 
internet by up to 30%, with peak speeds now reaching up to 350 Mbit/sec.

Financing activities  

In January 2020, VEON Holdings B.V. ("VEON Holdings") issued US$300 million in  senior unsecured notes due in 2025, to be 
consolidated  and  form  a  single  series  with  the  US$700  million  4.00%  senior  notes  due  in  2025  issued  by  VEON  Holdings  in 
October 2019. VEON Holdings used the net proceeds of the tap issuance to refinance certain existing outstanding debt, address 
upcoming debt maturities and for general corporate purposes. 

In April 2020, VEON Holdings announced the establishment of a US$ 6.5 billion (or the equivalent thereof in other currencies) 
Global Medium Term Note program for the issuance of bonds (the "MTN Program"). In connection with the establishment of the 
MTN  Program,  VEON  prepared  a  base  offering  memorandum,  which  was  approved  by  the  Luxembourg  Stock  Exchange,  in 
order  to  enable  bonds  issued  under  the  MTN  Program  to  be  admitted  to  listing  on  the  Official  List  of  the  Luxembourg  Stock 
Exchange and to trading on the Euro MTF market of the Luxembourg Stock Exchange. In June, September and November 2020, 
VEON Holdings issued senior unsecured notes of RUB20 billion (US$288 million), RUB10 billion (US$135 million) and US$1.25 
billion,  respectively,  under  the  MTN  Program,  maturing  in  June  2025,  September  2025  and  November  2027,  respectively. The 
use  of  proceeds  of  the  Notes  is  being  used  to  finance  certain  investments  in  subsidiaries,  to  refinance  certain  outstanding 
indebtedness of the Issuer, and for general corporate purposes. 

In  April  2020,  Banglalink  extended  the  maturity  of  its  US$300  million  syndicated  loan  by  an  additional  two  years  to  2022. 
Following  this  extension,  VEON,  via  a  wholly-owned  subsidiary,  acquired  the  loan  from  the  original  lenders,  leading  to  an 
effective extinguishment of this debt for the VEON Group. 

In  June  2020,  VEON  entered  into  a  new  RUB  100  billion  (approximately  US$1.5  billion)  bilateral  term  loan  agreement  with 
Sberbank. The loan was used to refinance and extend the maturity of the existing loan between Sberbank and VEON Holdings, 
as well as to provide additional funds for general corporate purposes.

In July 2020, VEON refinanced its existing RUB 30 billion (approximately US$422 million) bilateral term loan agreement with VTB 
Bank. This refinancing extended the maturity and reduced the cost of the existing loan between VTB Bank and VEON.

In December 2020, VEON completed the optional early redemption of all of its outstanding US$600 million 3.95% Senior Notes 
due  June  2021  (the  "2021  Notes")  pursuant  to  Condition  5.3  of  the  2021  Notes.  The  2021  Notes  were  redeemed  in  full  at  a 
redemption price equal to 101.00% of the principal amount thereof, plus accrued and unpaid interest and additional amounts due 
thereon. 

In  December  2020,  VEON’s  operating  company  in  Ukraine,  Kyivstar,  signed  three  bilateral  unsecured  loan  agreements  with 
Raiffeisen  Bank  Aval  Joint  Stock  Company  ("Raiffeisen"),  Joint  Stock  Company  Alfa-Bank  ("Alfa-Bank")  and  Joint  Stock 
Company OTP Bank ("OTP"), for an aggregate amount of UAH 4.1 billion (approximately US$146 million). The loan agreement 
with Raiffeisen has a 5-year term, and the loan agreements with Alfa-Bank and OTP have a 3-year term. 

Similarly, VEON’s subsidiary in Kazakhstan, KaR-Tel, has signed a bilateral unsecured loan agreement with Forte Bank JSC for 
KZT 10 billion (approximately US$25 million), which has a 3-year term. Both Kyivstar and KaR-Tel will continue to monitor the 
local debt markets for further borrowing opportunities, in line with VEON’s strategy to improve its capital structure via long-term 
borrowings in local currencies.

Changes to Board of Directors and Senior Management 

On February 13, 2020, VEON announced the appointment of Sergi Herrero and Kaan Terzioğlu as co-Chief Executive Officers, 
effective  from  March  1,  2020.  Ursula  Burns,  who  was  appointed  as  Chairman  in  July  2017  and  CEO  in  December  2018,  
remained as VEON’s Chairman before stepping down on June 1, 2020. Gennady Gazin was appointed as Chairman of VEON on 
1 June 2020.  

One  of  the  co-CEOs  chairs  each  VEON  local  board,  with  the  exception  of Algeria. The  role  of  the  boards  is  to  foster  growth, 
monitor progress and oversee operations in each of VEON’s operating companies.

6

On  April  3,  2020,  VEON  announced  the  appointment  of  Alexander  Torbakhov  as  Chief  Executive  Officer  of  Beeline  Russia, 
effective from April 6, following Vasyl Latsanych stepping down from the role earlier in the year.

On April 6, 2020, VEON announced the appointment of Serkan Okandan as Group Chief Financial Officer (CFO), effective from 
May 1, 2020.

On April 28, 2020, VEON announced that Erwan Gelebart has been appointed as CEO for JazzCash effective May 18, 2020.

On  June  1,  2020  VEON  announced  the  results  of  the  elections  conducted  at  its  Annual  General  Meeting  of  Shareholders. 
Shareholders  elected  five  new  members  to  the  company’s  board  of  directors,  Hans  Holger Albrecht,  Mariano  De  Beer,  Peter 
Derby, Amos  Genish  and  Stephen  Pusey,  as  well  as  seven  previously  serving  directors:  Osama  Bedier,  Mikhail  M.  Fridman, 
Gennady Gazin, Andrei Gusev, Gunnar Holt, Robert Jan van de Kraats and Alexander Pertsovsky.

Following the election of the directors, Gennady Gazin was appointed as Chairman of VEON’s board of directors, effective June 
1, 2020.

VEON appointed Yaroslav Glazunov and Leonid Boguslavsky on October 28, 2020 and January 15, 2021, respectively, to the 
company’s board of directors.  Mr. Glazunov is a managing partner at Spencer Stuart International based in Moscow and has 
been  in  the  global  leadership  advisory  business  for  20  years,  focusing  on  CEO  succession,  efficiency  and  performance.  Mr. 
Boguslavsky  is  the  founder  of  RTP  Global,  an  early-stage  venture  capital  firm  with  a  strong  track  record  of  investing  in 
technology, and is considered a pioneer of IT and internet tech investment.

VEON Co-CEO Kaan Terzioğlu Elected to Serve on GSMA Board of Directors

On November 16, 2020, VEON announced that Kaan Terzioğlu was elected to the Board of Directors of the GSMA, the mobile 
industry’s leading global organization that brings together more than 750 operators and nearly 400 ecosystem companies. Kaan 
Terzioğlu’s  appointment  was  confirmed  among  those  of  26  industry  leaders  elected  to  the  GSMA’s  Board  for  a  two-year  term, 
each of whom will serve the mobile industry’s leading global body from January 2021 to December 2022.

Appointment of Chief Internal Audit and Compliance Officer

In October 2020, Joop Brakenhoff was appointed to the position of Chief Internal Audit & Compliance Officer. He reports to the 
co-CEOs and also has a reporting line to the Chairman of the Audit & Risk Committee. 

VEON enters into a US$1,250 million multi-currency revolving credit facility agreement

In March 2021, VEON entered into a new multi-currency revolving credit facility agreement (the "RCF") of US$1,250 million.  The 
RCF replaces the revolving credit facility signed in February 2017, which is now cancelled. The RCF has an initial tenor of three 
years, with the company having the right to request two one-year extensions, subject to lender consent. International banks from 
Asia, Europe and the US have committed to the RCF. The new RCF caters for USD LIBOR cessation with the secured overnight 
financing  rate  (SOFR)  administered  by  the  Federal  Reserve  Bank  of  New  York  agreed  as  the  replacement  risk  free  rate  with 
credit  adjustment  spreads  agreed  for  interest  periods  with  a  one  month,  three  month  and  six  month  tenor.  SOFR  will  apply  to 
interest  periods  commencing  on  and  from  October  31,  2021  (or  earlier  if  USD  LIBOR  is  no  longer  published  or  ceases  to  be 
representative prior to that date). The company will have the option to make each drawdown in either U.S. dollars or euro. 

VEON subsidiary Banglalink successfully acquires 9.4MHz in spectrum auction 

In March 2021, Banglalink, the Company's wholly-owned subsidiary in Bangladesh, acquired 4.4MHz spectrum in the 1800MHz 
band  and  5MHz  spectrum  in  2100MHz  band  following  successful  bids  at  an  auction  held  by  the  BTRC.  The  newly  acquired 
spectrum  will  see  Banglalink  increase  its  total  spectrum  holding  from 30.6MHz  to  40MHz.  Banglalink  will  invest  approximately 
BDT 10 billion (US$115) to purchase the spectrum.

Appointment of CEO of Beeline Uzbekistan

In March 2021, we announced the appointment of Andrzej Malinowski to the vacant position of CEO of Beeline Uzbekistan, with 
effect from March 15, 2021.  Mr. Malinowski joins from Beeline Georgia, where he has held the position of CEO.  Lasha Tabidze 
has been appointed as Mr. Malinowski’s successor at Beeline Georgia, who previously held the joint position of Chief Operating 
Officer  and  Chief  Commercial  Officer  of  Beeline  Georgia.    A  candidate  for  the  Beeline  Uzbekistan  role  had  been  previously 
announced but Beeline Uzbekistan was unable to finalize the employment of this candidate. 

Shareholders trading on NASDAQ no longer subject to annual depository fee 

From January 1, 2021 holders of VEON American Depositary Shares ("ADSs") trading on NASDAQ will no longer be subject to 
any cash dividend fee or depository service fee of any kind. ADS holders will continue to be subject to the normal issuance and 
cancellation fees.

No final dividend declared by the VEON for FY2020

The VEON Group will not be paying a dividend for FY2020.

7

Business overview

Business Units and Reportable Segments 

VEON  Ltd.  is  the  holding  company  for  a  number  of  operating  subsidiaries  and  holding  companies  in  various 
jurisdictions.    We  currently  operate  and  manage  VEON  on  a  geographical  basis.  These  segments  are  based  on  the  different 
economic  environments  and  varied  stages  of  development  across  the  geographical  markets  we  serve,  each  of  which  requires 
different investment and marketing strategies. 

Our  reportable  segments  currently  consist  of  the  following  seven  segments:  Russia,  representing  our  “cornerstone” 
market;  Pakistan,  Ukraine,  Uzbekistan  and  Kazakhstan,  representing  our  “growth  engines”;  and  Algeria  and  Bangladesh, 
representing  our  “frontier  markets”.  We  also  present  our  results  of  operations  for  “Other  frontier  markets”  as  well  as  “HQ  and 
eliminations”  separately,  although  these  are  not  reportable  segments.  “Other  frontier  markets”  represents  our  operations  in 
Kyrgyzstan, Armenia  and  Georgia.  “HQ  and  eliminations”  represents  transactions  related  to  management  activities  within  the 
group in Amsterdam, London and Luxembourg and costs relating to centrally managed operations and reconciles the results of 
our reportable segments and our total revenue and Adjusted EBITDA.

See  — Operating and Financial Review and Prospects — Reportable Segments and Note 2 - Segment information to 

our Audited Consolidated Financial Statements for further details.

Subsidiaries

The  table  below  sets  forth  our  significant  subsidiaries  as  of  December  31,  2020.  The  equity  interest  presented 
represents our ownership interest, direct and indirect. Our percentage ownership interest is identical to our voting power for each 
of the subsidiaries listed below.

Name of significant subsidiary

VEON Amsterdam B.V.

VEON Holdings B.V.

PJSC VimpelCom

JSC “Kyivstar”

LLP “KaR-Tel”

LLC “Unitel”

LLC “VEON Georgia”

LLC “Sky Mobile”

VEON Luxembourg Holdings S.à r.l.

VEON Luxembourg Finance Holdings S.à r.l.

VEON Luxembourg Finance S.A.

Global Telecom Holding S.A.E

Omnium Telecom Algérie S.p.A.*

Optimum Telecom Algeria S.p.A.*

Pakistan Mobile Communications Limited

Banglalink Digital Communications Limited

Country of 
incorporation

Nature of 
subsidiary

Percentage of 
ownership 
interest

Netherlands

Netherlands

Russia

Ukraine

Kazakhstan

Uzbekistan

Georgia

Kyrgyzstan

Luxembourg

Luxembourg

Luxembourg

Egypt

Algeria

Algeria

Pakistan

Bangladesh

Holding

Holding

Operating

Operating

Operating

Operating

Operating

Operating

Holding

Holding

Holding

Holding

Holding

Operating

Operating

Operating

 100.0 %

 100.0 %

 100.0 %

 100.0 %

 75.0 %

 100.0 %

 80.0 %

 50.1 %

 100.0 %

 100.0 %

 100.0 %

 99.6 %

 45.4 %

 45.4 %

 85.0 %

 100.0 %

* The Group has concluded that it controls Omnium Telecom Algérie S.p.A and Optimum Telecom Algeria S.p.A, See Significant Accounting Judgments in Note 13 of 
the Audited Consolidated Financial Statements for further details. 

8

VEON, through its operating companies, provides customers with mobile and fixed-line telecommunications services in 

certain markets, which are described more fully below.  

Our mobile and fixed-line businesses are dependent on interconnection services. The table below presents certain of 
the  primary  interconnection  agreements  that  we  have  with  mobile  and  fixed-line  operators  in  Russia,  Pakistan,  Algeria, 
Bangladesh, Ukraine, Uzbekistan and Kazakhstan: 

Russia

Pakistan

Algeria

Bangladesh

Ukraine

Uzbekistan

We have interconnection agreements with mobile and fixed-line operators in Russia. During 2020, we had the following 
MTRs in Russia: average cost per minute of national traffic at 0.9483 RUB (US$ 0.0131) and average price per minute 
of national traffic at 0.9827 RUB (US$ 0.0136), which were broadly stable as compared to average cost per minute at 
0.9480 RUB (US$ 0.0147) and average price per minute of national traffic at 0.9861 RUB (US$ 0.0152) in 2019 and 
average cost per minute at 0.9258 RUB (US$ 0.0148) and average price per minute of national traffic at 0.9750 RUB 
(US$ 0.0156) in 2018.

In  the  territories  of  Pakistan  and  Azad  Jammu  and  Kashmir  (“AJK”)  and  Gilgit-Baltistan,  we  have  several 
interconnection  agreements  with  mobile  and  fixed-line  operators.  Our  MTRs  in  2018  and  2019,  were  at  PKR  0.9 
(US$0.00739) and PKR 0.8 (US$0.0053), respectively, and in 2020 it was PKR 0.70 (US$0.00452). 

We  have  interconnection  agreements  with  mobile,  VoIP  and  fixed-line  operators.  For  the  2016-2017  period,  the 
evolution  of  MTRs  was  favorable  to  our  business  despite  an  asymmetry  with  our  competitors.  For  the  2017-2018 
period, our MTR remained stable and the asymmetry was reduced both in scope (with one competitor instead of two 
benefitting from the asymmetry) and in value (the gap between MTRs was reduced).  In the reference interconnection 
offer approved for the 2018-2019 period, Autorité de Régulation de la Poste et des Communications Electroniques the 
(ARPCE) imposed symmetrical MTRs for all three operators  for both voice and SMS (respectively DZD 0.95 for voice 
and DZD 1.5 for SMS). In the  previous reference interconnect offer (2019-2020), the ARPCE returned to asymmetry 
for voice MTR (DZD 0.95, DZD 0.74, and DZD 0.67 for Ooredoo, Mobilis, and DJEZZY, respectively) while maintaining 
symmetry for SMS (DZD 1.5 ).  In the last reference interconnection offer (2020-2021), symmetry was again applied for 
both voice (DZD 0.68 /min) and SMS (DZD 1.5).

We  have  interconnection  agreements  with  interconnection  exchange  (ICX)  operators,  international  gateway  (IGW) 
operators,  mobile  operators,  internet  protocol  telephony  service  providers  (IPTSPs)  and  fixed-line  operators.  The 
international  termination  rate  was  changed  with  effect  from  February  14,  2020,  following  which  the  minimum 
termination  rates  became  US$  0.006/min.  Henceforth,  IGW  operators  share  22.5%  of  international  call  termination 
revenue with mobile operators based on the minimum international call termination rate.  The domestic termination rate 
was changed, with effect from August 14, 2018, to BDT 0.14/min or US$0.0017/min (terminating mobile operator gets 
BDT 0.10 (US$0.0012) and ICX gets BDT 0.04 (US$0.0005).

We  have  interconnection  agreements  with  various  mobile  and  fixed-line  operators.  As  of  December  31,  2020,  in 
Ukraine, the  effective MTR was UAH 0.12/min (US$0.0043) as well as effective IMTR equaled US$ 0.048/min. 

We have interconnection agreements with various mobile and fixed-line operators. On September 5, 2017, the State 
Committee  of  Uzbekistan  on  Privatization,  Demonopolization  and  Development  of  Competition  (“State  Committee  of 
Uzbekistan”)  issued  an  injunction  requiring  Unitel  LLC  to  implement  equal  mobile  termination  rates  for  all  national 
operators.    Unitel  LLC  unsuccessfully  challenged  this  injunction  in  Uzbek  Courts.  Our  MTR  for  2020  was  UZS  0.05/
minute as established by the court decision.

Kazakhstan

We  have  interconnection  agreements  with  mobile  and  fixed  operators.  Our  MTR  for  2020  for  local  mobile  operators 
was 5.60 KZT/min.($0.0132, inclusive of VAT) and for fixed operators was 14.80 KZT/min ($0.0351, inclusive of VAT).

9

Description of Our Mobile Telecommunications Business

The table below presents the primary mobile telecommunications services we offer to our customers and a breakdown of prepaid 
and postpaid subscriptions as of December 31, 2020.

Mobile Service Description

Russia

Pakistan

Algeria

Bangladesh

Ukraine

Uzbekistan Kazakhstan Others(3)

Value added and call completion 

services (1)   

National and international roaming 

services(2)   

Wireless Internet access   

Mobile financial services

Mobile bundles   

_______________

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes(4)

Yes(5)

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No/Yes(7)

Yes(6)

(1) 
content delivery channels.  

Value added services include messaging services, content/infotainment services, data access services, location based services, media, and 

(2) 

Access to both national and international roaming services allows our customers and customers of other mobile operators to receive and make 

international, local and long-distance calls while outside of their home network.  

(3) 

(4) 

(5) 

(6) 

(7) 

For a description of the mobile services we offer in Kyrgyzstan and Georgia, see “—Mobile Business in Others.”  

Includes 4G 

Includes Smart Money (payment method for services via mobile phone) 

Reflects mobile bundles provided in Kyrgyzstan. 

Reflects services offered in Kyrgyzstan.

10

 
Mobile Business in Russia  

In  Russia,  through  our  operating  company  PJSC  VimpelCom  and  our  “Beeline”  brand,  we  primarily  offer  mobile 
telecommunications  services  to  our  customers  under  two  types  of  payment  plans:  postpaid  plans  and  prepaid  plans.  As  of 
December 31, 2020, approximately 87.9% of our customers in Russia were on prepaid plans. 

The table below presents a description of the primary mobile telecommunications services we offer in Russia. 

• airtime charges from mobile postpaid and prepaid customers, including monthly contract fees for a predefined amount of 

voice traffic and roaming fees for airtime charges when customers travel abroad

Voice

• GPRS/EDGE; 3G/HSPA; 4G/LTE; special wireless “Plug&Play” USB modems

Internet and Data Access

Roaming

• active roaming agreements with 706 GSM networks in 214 countries

• GPRS roaming with 606 networks in 189 countries

• 4G/LTE roaming with 325 networks in 133 countries 

• roaming agreements generally state that the host operator bills PJSC VimpelCom for roaming services; PJSC VimpelCom 

pays these charges and then bills the customer for these services on a monthly basis

VAS

• caller-ID; voicemail; call forwarding; conference calling; missed call notification (via text); call blocking and call waiting

Messaging
• SMS (consumer and corporate); MMS and voice messaging (allows customers to send pictures, audio and video to mobile 

phones and to e-mails); mobile instant messaging

Content/infotainment
• voice services (including referral services); content downloadable to telephone (including music, pictures, games and video); 
RBT; mobile cloud solutions; geo-positioning and compass service for fleet and assets management; and M2M control center 
solution for all M2M/IoT verticals, Smart TV services, including Beeline TV

• Mobile payment; banking card; trusted payment; loans repayments; remittances; banks notification; and mobile insurance

The table below presents a description of business licenses relevant to our mobile business in Russia. Unless noted otherwise, 
we plan to apply for renewal of these licenses prior to their expiration.

Mobile financial services

Services

License

Expiration

Super-regional GSM (GSM900, GSM1800, 
GSM900/1800, UMTS 900 and 4G/LTE 1800 
standards)

Moscow, Central and Central Black 
Earth, North Caucasus, North-West, 
Siberia, Ural and Volga

September 2022- April 2023 (various dates)

GSM(1) (GSM900, GSM1800, GSM900/1800 and 4G/
LTE 1800 standards)

Regions  in  the  Far  East  super-region 
of Russia

2021 - 2025 (various dates)

3G(2) (UMTS/LTE)

4G(3) (LTE)

4G/LTE 2600

Orenburg region

June 2025

Irkutsk region

Nationwide(4)

Nationwide(4)

32 districts of Russia

2021 (various dates)

May 2022

July 2022

April 2026

(1) 

In total, our GSM licenses cover approximately 97% of Russia’s population.

(2)  PJSC VimpelCom holds one of three 3G licenses in Russia.

(3) 

In  July  2012,  PJSC  VimpelCom  was  awarded  a  mobile  license,  a  data  transmission  license,  a  voice  transmission  license  and  a  telematic  license  for  the 
provision of 4G/LTE services in Russia. These licenses allow PJSC VimpelCom to provide services using radio-electronic devices in Russia via networks that 
use 4G/LTE standard equipment within any of the following frequency bands: 735-742.5/776-783.5 MHz; 813.5-821/854.5-862 MHz; and 2550-2560/2670-2680 
MHz. Certain channels allocated to us in accordance with the licenses have restrictions on their use. To remove restrictions, we have to perform organizational 
technical measure field tests. The rollout of the 4G/LTE network is using a phased approach based on a pre-defined schedule pursuant to the requirements of 
the license.

(4)  This includes 83 regions of Russia, except for Republic of Crimea and Sevastopol.

11

PJSC VimpelCom must pay an annual fee for the use of radio frequency spectrum. These fees were RUB 3,952 million and RUB 3,946 million 
for the years ended December 31, 2020 and 2019, respectively. Under Federal Law No. 126 FZ “On Communication” and license terms, PJSC 
VimpelCom  is  required  to  make  universal  service  fund  contributions  in  the  amount  equal  to  1.2%  of  corporate  revenues  from  provided 
communications services.  Universal service fund contributions were RUB 2,152 million and RUB 2,345 million for the years ended December 
31, 2020 and 2019, respectively.  PJSC VimpelCom is also subject to certain other license fees on a case-by-case basis.

LICENSE FEES

Mobile bundles 

In 2020, we have kept our focus on product lines from a customer needs perspective, simplifying offers and maintaining 
competitive prices in combination with transparent conditions. In October 2020, a new product “Svyaz Z” was launched. There is 
no similar product in the market and the offering is based on conscious consumption – packages of internet, minutes and SMS 
are unlimited; there is no monthly subscription fee; and customers determine the level of internet, minutes and SMS service and 
related options they will consume. The tariff plan is managed within the MyBeeline app. We also continued to attract customers 
to our shared bundle product and сonvergence offers. 

Distribution

In 2020, we sought to optimize the number of our stores by closing unprofitable locations.  Compared to December 31, 
2019,  as  of  December  31,  2020  the  number  of  owned  retail  monobrand  stores  was  2,284  compared  to  2,849;  the  number  of 
franchise stores was 1,666 compared to 1,678; the number of “Know How” stores was 94 compared to 134; and the total number 
of  owned  retail  monobrand  stores  was  4,044  stores  compared  to  4,661.    We  continued  on  the  same  course  as  in  2019  to 
increase the efficiency of retail stores and have closed a total of 872 stores over the last two years, which include own offices 
and franchise. We have no immediate plans to close further retail stores and expect the rising trend of online sales to positively 
affect the overall market and enable a more balanced and cost-efficient distribution footprint with fewer retail points in the future. 

In  2020,  we  maintained  high  availability  of  live  agents  at  call  centers,  simplified  a  number  of  service  procedures  and 
business  processes,  and  endeavored  to  improve  overall  customer  care,  operational  efficiency  and  customer  experience.      In 
addition, several initiatives have been launched to continue the transition of our customer care functions from traditional voice 
channels to digitalized text and self-service channels.  Notably, we have launched a project focused on dynamic Interactive Voice 
Response (IVR) FTTB structures where these structures have been built according to the principles of simplifying communication 
by text, rejecting unpopular and ineffective parts, checking customer data and offering only relevant services.  We also launched 
Digital Code, an identification method by which a client receives a one-time password to perform a service operation.  More than 
500 clients connected using Digital Code in December 2020 and January 2021. Furthermore, our mobile self-service application 
for iOS and Android was downloaded approximately 16.2 million times in 2020, and the monthly active base of the MyBeeline 
platform reached 11.5 million active customers per month as of December 2020. We continued to develop ChatBot, a software 
robot  that  converses  in  natural  language  and  provides  necessary  information  and  answers  client  questions  as  a  call  center 
operator in our mobile application and website.

Competition 

The  following  table  shows  our  and  our  primary  mobile  competitors’  respective  customer  numbers  in  Russia  as  of 

December 31, 2020: 

Operator

MTS   

MegaFon

PJSC VimpelCom   

Tele2   

Source: Omdia.

Customers in Russia  
(in millions)

78.0

75.8

49.9

45.9

According  to  Omdia,  there  were  approximately  249.6  million  mobile  customers  in  Russia  as  of  December  31,  2020, 
compared to 253.5 million mobile customers as of December 31, 2019, representing a mobile penetration rate of approximately 
174.7%, compared to approximately 177.2% as of December 31, 2019.

12

Mobile Business in Pakistan  

In Pakistan, customers continued to migrate to 4G/LTE following its launch in 2017. We operate in Pakistan through our 
operating company, PMCL and our brand, “Jazz,” which is the historic Mobilink brand together with the merged Warid brand. In 
2020, PMCL provided 3G services in over 300 towns and cities and 4G/LTE services in 243 cities.  

In  Pakistan,  we  offer  our  customers  mobile  telecommunications  services  under  postpaid  and  prepaid  plans.  As  of  

December 31, 2020, approximately 97.1% of our customers in Pakistan were on prepaid plans. 

The table below presents the primary mobile telecommunications services we offer in Pakistan. 

Voice

• airtime charges from mobile postpaid and prepaid customers, including monthly contract fees for a predefined amount of voice traffic and 

roaming fees for airtime charges when customers travel abroad

• GPRS, EDGE, 3G and 4G/LTE

Internet and data access

Roaming

• active roaming agreements with 319 GSM networks in 148 countries

• GPRS roaming with 246 networks in 116 countries

• LTE roaming through 55 networks in 40 countries

• CAMEL roaming through 125 networks in 70 countries

•

roaming agreements generally state that the host operator bills PMCL for the roaming services; PMCL pays these charges and then bills the 
customer for these services on a monthly basis

• caller-ID; voicemail; call forwarding; missed call alert; credit balance; balance share; conference calling; call blocking and call waiting

Messaging

• SMS, MMS (which allows customers to send pictures, audio and video to mobile phones and to e-mail), and mobile instant messaging

VAS

• ecosystem of digital services: mobile TV, music and live audio streaming, video streaming, mobile magazine, sports (including cricket), mega 

deals, games 

Content/infotainment

• mobile payment; banking card; trusted payment; banks notification; and mobile insurance

Mobile financial services(1)

(1)  Mobilink Microfinance Bank Limited (“Mobilink Bank”), our wholly owned subsidiary, carries on a microfinance banking business and provides certain MFS, DFS 
and traditional banking services (including the granting of microfinance loans, provision of credit, payment and transfer services and a variety of other banking 
services)  in Pakistan under license granted by the State Bank of Pakistan and is subject to regulation by the State Bank of Pakistan.  In partnership with Jazz, 
Mobilink Bank offers mobile wallets and payment services under the brand “JazzCash”. 

The table below presents a description of business licenses relevant to our mobile business in Pakistan. Unless noted 

otherwise, we plan to apply for renewal of these licenses prior to their expiration.

Services

License(1)(3)

Expiration

2G(4)

3G

4G/LTE (NGMS)

Nationwide

Nationwide

Nationwide

Nationwide

Nationwide

2022
2019 (2)
2029

2032
2019 (2)

(1)  Warid (now merged with Jazz) acquired a 15-year technology neutral license in 2004 for US$291 million. US$145.5 million was paid upfront with the remainder 
paid  in  ten  equal  annual  installments  starting  with  a  four-year  grace  period,  with  the  last  payment  made  May  2018.   The  same  2G  license  was  amended  in 
December  2014  by  the  Pakistan  Telecommunication  Authority  (“PTA”)  to  allow  Warid  to  provide  4G/LTE  services  in  Pakistan.  Additionally,  the  National 
Accountability Bureau is currently conducting an investigation into certain former PTA and other officials, and has requested information from Jazz concerning 
Warid’s 2014 license amendment while the investigation is ongoing. 

(2)  The ex-Warid license renewal was due in May 2019. Pursuant to directions from the Islamabad High Court, the PTA issued a license renewal decision on July 
22, 2019 requiring payment of US$40 million per MHz for 900 MHz spectrum and US$29.5 million per MHz for 1800 MHz spectrum, equating to an aggregate 
price of approximately US$450 million (excluding applicable taxes of approximately 13%). On August 17, 2019, Jazz appealed the PTA’s order to the Islamabad 
High  Court.  On  August  21,  2019,  the  Islamabad  High  Court  suspended  the  PTA’s  order  pending  the  outcome  of  the  appeal  and  subject  to  Jazz  making 
payment in the form of security (under protest) as per the options given in the PTA’s order. In September 2019 and May 2020, Jazz deposited approximately 
US$225  million  and  US$58  million,  respectively,  in  order  to  maintain  its  appeal  in  the  Islamabad  High  Court  regarding  the  PTA’s  underlying  decision  on  the 

13

license  renewal.  There  were  no  specific  terms  and  conditions  attached  to  the  deposit.  The  most  recent  hearing  on  this  matter  was  concluded  before  the 
Islamabad High Court on March 1, 2021 and a judgment is now pending.

(3) 

(4) 

In addition, PMCL and its subsidiaries have other licenses, including LDI, WLL, TTP, local loop licenses, licenses to provide non-voice communication services, 
and licenses to provide class VAS in Pakistan, AJK and Gilgit-Baltistan. The licensees must also pay annual fees (0.5%) to the PTA and make universal service 
fund contributions (1.5%) and/or research and development fund contributions (0.5%), as applicable, in a total amount equal to a percentage of the licensees’ 
annual gross revenues (less certain allowed deductions) for such services.

In 2007, PMCL renewed its 2G license for a further term of 15 years. As of December 31, 2020, PMCL had paid its outstanding balance of US$14.5 million to 
the  PTA  for  the  renewal  of  its  2G  license  (paid  on  December  5,  2019). This  amount  had  been  payable  in  yearly  installments  of  US$14.5  million,  payable  in 
December of each year, until December 2019. PMCL has two 15-year licenses for provision of cellular mobile 2G services in AJK and Gilgit-Baltistan.

LICENSE FEES
Under the terms of its 2G, 3G and 4G/LTE licenses, as well as its license for services in AJK and Gilgit-Baltistan, PMCL must pay annual fees 
to  the  PTA  and  make  universal  service  fund  contributions  and/or  research  and  development  fund  contributions,  as  applicable  (not  all  of  the 
foregoing are applicable to all licenses), in a total amount equal to 2.5% of PMCL’s annual gross revenues (less certain allowed deductions) for 
such services, in addition to spectrum administrative fees. 

PMCL’s total license fees (annual license fees plus revenue sharing) in Pakistan (excluding the yearly installments noted above) were US$23.7 
million,  US$24.7  million  and  US$26.9  million  for  the  years  ended  December  31,  2020,  2019  and  2018,  respectively.  PMCL’s  total  spectrum 
administrative  fee  payments,  including  for  Warid’s  spectrum,  were  US$2.1  million,  US$1.6  million  and  US$1.9  million  for  the  years  ended 
December 31, 2020, 2019 and 2018, respectively.

Mobile bundles

We continue to focus on a technology agnostic mobile internet portfolio, meaning same pricing across 2G, 3G and 4G/
LTE  technologies.  n  Pakistan,  we  offer  a  portfolio  of  tariffs  and  products  designed  to  cater  to  the  needs  of  specific  market 
segments,  including  mass-market  customers,  youth  customers,  personal  contract  customers,  SOHOs  (with  one  to  three 
employees), SMEs (with four to 249 employees) and enterprises (with more than 249 employees). We offer corporate customers 
several  postpaid  plan  bundles,  which  include  on-net  minutes,  variable  discounts  for  closed  user  groups  and  follow-up  minutes 
based on bundle commitment. We also offer dedicated account management to large corporates and 24x7 business helpline for 
support.  

Distribution

As of December 31, 2020, our sales channels in Pakistan included one company store, 21 business centers, a direct 
sales  force  of  183  employees  looking  after  indirect  sales  channels,  407  exclusive  franchise  stores  currently  active  and  over 
200,000 non-exclusive third-party retailers. For top-up, we offer prepaid scratch cards and electronic recharge options, which are 
distributed  through  the  same  channels.  Jazz  brand  SIMs  are  sold  through  more  than  43,101  retailers,  supported  by  biometric 
verification devices.

Competition

The following table shows our and our competitors’ respective customer numbers in Pakistan as of December 31, 2020: 

Operator

PMCL (“Jazz”)   
Telenor Pakistan   
Zong   
Ufone   

Source: The Pakistan Telecommunications Authority.

Customers in 
Pakistan 
(in millions)
66.4
47.6
38.6
23.1

According to the PTA, there were approximately 175.6 million mobile customers in Pakistan as of December 31, 2020, 
compared  to  165.4  million  mobile  customers  in  Pakistan  as  of  December  31,  2019,  representing    a  mobile  penetration  rate  of 
approximately 82.3% compared to 78.2% as of December 31, 2019.

14

Mobile Business in Algeria 

We  operate  in Algeria  through  our  operating  company,  Optimum,  and  our  brand,  “Djezzy.”  Optimum  provides  4G/LTE 
services in Algeria in 45 of 48 provinces across the country, including Algiers, and the largest provinces in terms of population.  In 
Algeria,  we  generally  offer  our  customers  mobile  telecommunications  services  under  prepaid  and  postpaid  plans.  As  of 
December 31, 2020, prepaid, postpaid and hybrid (a monthly fee with recharge possibility) represented approximately 86%, 3% 
and 11%, respectively, of the revenue generated by all our customers in Algeria. 

With  respect  to  ownership  of  Omnium  Telecom  Algérie  S.p.A.  (“OTA”),  GTH  holds  a  controlling  interest  of  45.57% 
directly and indirectly through Oratel International Inc. Limited and Moga Holding Limited. The Algerian National Investment Fund 
holds 51% directly in OTA and a local minority shareholder, Cevital S.p.A., holds directly the remaining 3.43%. The establishment 
of this partnership in January 2015 strengthened OTA’s position and prospects, with greater opportunities for our operations in 
Algeria.  VEON  Ltd.  exercises  operational  control  over  OTA  and,  as  a  result,  fully  consolidates  OTA,  which  holds  99.99%  of 
Optimum.  In  2015,  the  operating  company  in  Algeria  changed  from  OTA  to  Optimum.  Historical  references  to  our  operating 
company in Algeria have therefore been retained as OTA throughout this Annual Report.

The table below presents the primary mobile telecommunications services we offer in Algeria. 

• airtime charges from mobile postpaid and prepaid customers, including monthly contract fees for a predefined amount of voice traffic and 

roaming fees for airtime charges when customers travel abroad

Voice

Internet and data access

• GPRS, EDGE, 3G and 4G/LTE technology

• data services available via pay-per-use and via a bundle

• active roaming agreements with 466 GSM networks in 158 countries

Roaming

• GPRS roaming with 331 networks in 119 countries

• 3G roaming with 271 networks in 112 countries

• 4G/LTE roaming with 93 networks in 47 countries

• GPRS, EDGE, 3G and 4G/LTE technology

•

roaming  agreements  generally  state  that  the  host  operator  bills  OTA  for  roaming  services;  OTA  pays  these  charges  and  then  bills  the 
customer for these services on a monthly basis

• caller-ID; call forwarding; conference calling; call blocking; call waiting; beep call; verso+; collect SMS; VMS vocal message service; A2P; 

and short code third party services

• SMS, MMS (which allows customers to send pictures, audio and video to mobile phones and to e-mail), and mobile instant messaging

Messaging

VAS

• mobile message notification service offering packages with various types of content (sports, news, food, culture) (SMS SCOOP); ring back 

tunes (RBT); co-branding with VTC service app (Yassir); game portal; QUIZ game (Instawin)

Content/infotainment

• peer-to-peer credit transfer and credit loan

Mobile financial services

15

The table below presents a description of business licenses relevant to our mobile business in Algeria. Unless noted otherwise, 
we plan to apply for renewal of these licenses prior to their expiration.

Services
2G(1)
VSAT(2)
3G(3)
4G/LTE(4)

License
Nationwide
Nationwide
Nationwide
Nationwide

Expiration
2021
2024
2028
2031

(1) 

(2) 

(3) 

In 2001, OTA was awarded a 15-year license to operate a 2G telecommunications network for an aggregate fee of approximately US$737 million. The license 
expired in 2016 and was renewed for a five-year period at no additional cost (Decree 17-195 of June 11, 2017). 

In 2003, OTA acquired a VSAT data-voice license for an aggregate fee of US$2.05 million and renewed the license in 2014 for an additional period of five years, 
at no additional cost.  This license expired in April 2019, and, a new license agreement was signed in September 2019 between Optimum, ARPCE and MPT, 
with publication of the executive decree finalizing the renewal on March 31, 2020. 

In 2013, OTA was awarded a 15-year license to operate a 3G telecommunications network for an aggregate fee of approximately US$38 million, which was paid 
in  full  in  2013.  Under  the  terms  of  its  3G  license,  OTA  is  required  to  pay  an  additional  annual  revenue  sharing  fee  of  1%  based  on  3G  revenues  less 
interconnection costs. 

(4)  Under  the  terms  of  its  4G/LTE  license,  Optimum  is  required  to  pay  an  additional  annual  revenue  sharing  fee  of  1%  based  on  4G/LTE  revenues  less 

interconnection costs.

LICENSE FEES
Under the terms of its 2G, 3G, 4G/LTE and VSAT licenses, OTA is required to pay contributions for the universal service and environmental 
protection  fund  (3%  of  revenues);  management  of  the  numbering  plan  (0.2%  of  revenues  less  interconnection  costs);  research,  training  and 
standardization (0.3% of revenues less interconnection costs); license fees for 3G and 4G licenses (1% of revenue less interconnection costs; 
and a new tax (0.5% of revenues excluding VSAT) introduced in the 2018 Finance Law.

OTA’s total license fees in Algeria were US$59.9 million, US$65.1 million, and US$62.6 million for the years ended December 31, 2020, 2019 
and  2018,  respectively,  of  which  US$28.0  million,  US$27.8  million,  and  US$28.1  million,  respectively,  was  related  to  spectrum  charges,  and 
US$31.9 million, US$37.3 million(1), and US$34.5 million, respectively, was related mainly to contributions made to the Universal Services of 
Telecommunications fund and to the number plan management over the same periods.

(1)   Reflects a change of the universal services tax calculation rule, from a calculation base of 3% of total revenue less interconnection cost to a calculation base of 

3% of total revenue, with retroactivity in 2018 (with an impact of US$2.2 million reported in 2019). 

Distribution 

As of December 31, 2020, we sell our mobile telecommunications services through our 87,429 shops, via both direct 
and indirect channels, of which 111 were monobrand shops rented, equipped, staffed and managed by Optimum and equipped 
with IT material and sales applications. Our seven exclusive national distributors cover all 48 wilayas (provinces) of Algeria and 
are  distributing  our  products  through  over  87,318  points  of  sale,  of  which  all  are  authorized  to  sell  airtime  and  15,809  are 
authorized to sell SIMs. As of December 31, 2020, we also had a pool of more than 87 agents in a call centers directly managed 
by Optimum providing customer care services, including retention, troubleshooting and handling of complaints. 

Competition 

Growth  in Algeria’s  mobile  market  is  expected  to  slow,  and  attention  is  expected  to  shift  to  maintaining  or  improving 

ARPU, supported by data revenue growth after the commercial launch of 4G/LTE networks.

The following table shows our and our competitors’ respective customer numbers in Algeria as of December 31, 2020:

Operator

Mobilis   

Optimum (“Djezzy”)   

Ooredoo   

Source: Omdia.

Customers in 
Algeria 
(in millions)

18.7

14.1

12.3

According  to  Omdia,  there  were  approximately  45.2  million  mobile  customers  in  Algeria  as  of  December  31,  2020, 
compared to 45.7 million mobile customers as of December 31, 2019, representing a mobile penetration rate of approximately 
105.1%, compared to 107.8% as of December 31, 2019.

16

Mobile Business in Bangladesh 

We  operate  through  our  operating  company,  Banglalink  Digital  Communications  Limited  (“BDCL”)  with  our  brand 
“banglalink” in Bangladesh. On February 19, 2018, BDCL acquired a 4G/LTE license for US$1.2 million in order to launch a high-
speed data network. Following the rollout of 4G/LTE network, BDCL’s data customers as well as data usage have grown rapidly, 
which contributed to an increase in BDCL’s data revenue and ARPU. 

The telecommunications market in Bangladesh is largely comprised of prepaid customers. As of December 31, 2020, 

approximately 94% of our customers were on prepaid plans.

The table below presents the primary mobile telecommunications services we offer in Bangladesh.

• voice telephony to postpaid and prepaid customers through voice packs and mixed bundles

Voice

• GPRS, EDGE, 3G and 4G/LTE technology

• data services provided via pay-per-use and via bundles

Internet and data access

Roaming

• active roaming agreements with 400 GSM networks in 145 countries

• GPRS roaming with 301 networks in 115 countries

• maritime roaming and in-flight roaming

•

roaming agreements generally state that the host operator bills BDCL for roaming services; BDCL pays these charges and subsequently bills 
the customer for these services on a monthly basis

VAS

• call forwarding; conference calling; call blocking; call waiting; caller line identification presentation; call me back; and voicemail missed call 

alert

• SMS, MMS (which allows customers to send pictures, audio and video to mobile phones and to e-mail) and mobile instant messaging

• news alert service; sports related content; job alerts; music streaming; mobile TV; content download; religious content; and RBT

Content/infotainment

Messaging

• SMS and data network is provided to Bangladesh Post Office for their Mobile Money Order service

Mobile financial services

The  table  below  presents  a  description  of  business  licenses  relevant  to  our  mobile  business  in  Bangladesh.  Unless 

noted otherwise, we plan to apply for renewal of these licenses prior to their expiration.

Services
2G(1)
3G(2)
4G/LTE(3)

License
Nationwide
Nationwide
Nationwide

Expiration
2026
2028
2033

(1) 

(2) 

In November 1996, BDCL was awarded a 15-year GSM license to establish, operate and maintain a digital mobile telephone network to provide 2G services 
throughout Bangladesh. The license was renewed in November 2011 for a further 15-year term.

In  September  19,  2013,  following  a  competitive  auction  process,  BDCL  was  awarded  a  15-year  license  to  use  5  MHz  of  technology  neutral  spectrum  in 
2100MHz  band  and  was  also  awarded  a  3G  license,  for  which  it  paid  a  total  cost  of  BDT  8,677.4  million  (inclusive  of  5%  VAT),  including  both  a  license 
acquisition fee and a spectrum assignment fee. 

(3)  On February 19, 2018, BDCL acquired a 4G/LTE license for US$1.2 million. BDCL also acquired the right to use 10.6 MHz technology neutral of spectrum in 
1800  MHz  (5.6)  and  2100  MHz  (5)  for  US$323  million  including  VAT  (33.34%  of  the  fee  has  been  considered  as  tariff  value  for  15%  VAT).  Banglalink  also 
converted 15MHz of existing 2G spectrum for US$37.01 million.

17

LICENSE FEES

Under the terms of its 2G, 3G and 4G/LTE mobile licenses, BDCL is required to pay to the Bangladesh Telecommunication 
Regulatory Commission (i) an annual license fee of BDT 50.0 million (US$0.6 million as of December 31, 2019) for each mobile 
license; (ii) 5.5% of BDCL’s annual audited gross revenue, as adjusted pursuant to the applicable guidelines; and (iii) 1% of its 
annual audited gross revenue (payable to Bangladesh’s social obligation fund), as adjusted pursuant to the applicable 
guidelines. The annual license fees are payable in advance of each year, and the annual revenue sharing fees are each 
payable on a quarterly basis and reconciled at the end of each year.

BDCL’s total license fees (annual license fees plus revenue sharing) in Bangladesh were equivalent to US$ 36.8 million, 
US$36.9 million, and US$34.7 million for the years ended December 31, 2020, 2019, and 2018, respectively.  In addition to 
license fees, BDCL pays annual spectrum charges to the BTRC, calculated according to the size of BDCL’s network, its 
frequencies, the number of its customers and its bandwidth. The annual spectrum charges are payable on a quarterly basis and 
reconciled at the end of each year. 

BDCL’s annual spectrum charges were equivalent to US$10.3 million, US$11.8 million, and US$11.8  million for the years 
ended December 31, 2020, 2019, and 2018, respectively.

Distribution

As of December 31, 2020, our sales and distribution channels in Bangladesh included 85 monobrand stores, a direct 
sales  force  of  58  enterprise  sales  managers  and  165  zonal  sales  managers  (for  mass  market  retail  sales),  54,026  retail  SIM 
outlets, 275,047 top-up selling outlets, online sales channels, and 4,340 key retail outlets. We provide a top-up service through 
mobile financial services, ATMs, recharge kiosks, international top-up services, SMS top-up and the banglalink online recharge 
system.  We provide customer support through our contact center, which operates 24 hours a day and seven days a week. The 
contact center caters to a number of after-sales services to all customer segments with a special focus on a “self-care” app to 
empower  customers  and  avoid  customer  reliance  on  call  center  agents.    In  order  to  stimulate  data  usage  and  smartphone 
penetration, we offer banglalink branded internet through reverse-bundle model via device partners’ channels. 

Competition 

The  mobile  telecommunications  market  in  Bangladesh  is  highly  competitive.  The  following  table  shows  our  and  our 

competitors’ respective customer numbers in Bangladesh as of December 31, 2020.

Operator

Grameenphone   

Robi Axiata

BDCL (“banglalink”)   

Teletalk   

Source: Bangladesh Telecommunication Regulatory Commission.

Customers in 
Bangladesh 
(in millions)

79.0

50.9

35.3

4.9

According  to  the  Bangladesh  Telecommunication  Regulatory  Commission,  the  top  three  mobile  operators, 
Grameenphone, Robi Axiata and Banglalink, collectively held approximately 97.1% of the mobile market which consisted of 
approximately  170.1  million  customers  as  of  December  31,  2020,  compared  to  165.6  million  customers  as 
of  .December  31,  2019.  According  to  Omdia,  as  of  December  31,  2020,  a  mobile  penetration  rate  comprised  approximately 
98.3% compared to 97.2% as of December 31, 2019 

18

Mobile Business in Ukraine 

We  operate  in  Ukraine  with  our  operating  company  “Kyivstar”  JSC  and  our  brand,  “Kyivstar.”  The  Ukrainian  mobile 
market operates on a 2G, 3G and 4G/LTE basis. As of December 31, 2020, approximately 85% of our customers in Ukraine were 
on prepaid plans. Kyivstar secured 4G/LTE licenses and spectrum in two separate transactions in 2018.

The table below presents the primary mobile telecommunications services we offer in Ukraine. 

Voice
• airtime  charges  from  mobile  postpaid  and  prepaid  customers,  including  monthly  contract  fees  for  a  predefined  amount  of 

voice traffic and roaming fees for airtime charges when customers travel abroad

• GPRS/EDGE, 3G and 4G/LTE

Internet and data access

Roaming

• active roaming agreements for 495 networks in 189 countries
• GPRS roaming on 432 networks in 167 countries
• 3G roaming on 319 networks in 133 countries
• 4G/LTE roaming on 100 networks in 67 countries

Messaging

• SMS;voice messaging and SMS services (including information services such as news, weather, entertainment chats and 

friend finder)

Content/infotainment
• voice services (including referral services); content downloadable to telephone (including music, pictures, games and video); 

mobile TV and RBT

Mobile financial services
• mobile payment; banking card; trusted payment; banks notification; mobile insurance; and Smart Money (payment method 

for services via mobile phone)

The table below presents a description of business licenses relevant to our mobile business in Ukraine. Unless noted 

otherwise, we plan to apply for renewal of these licenses prior to their expiration.

Services
GSM900 and GSM1800(1)
3G(2)
4G/LTE(3)
4G/LTE(3)
4G/LTE(5)

License

Nationwide

Nationwide

Nationwide

Nationwide

Expiration

October 5, 2026(4)

April 1, 2030

July 1, 2033 (1800 MHz)

January 31, 2033 (2600 MHz)

25 Regions (excl. Crimea & Sevastopol)

July 1, 2040 (900 MHz)

(1)  Licenses were received on October 5, 2011 for a term of 15 years each.

(2)  The  license  was  issued  on April  1,  2015  for  a  term  of  15  years.  Services  provided  in  the  2100  MHz  band.    We  have  also  obtained  a  range  of  national  and 
regional radio frequency licenses for the use of radio frequency resources in the referred standards and in specified standards— radio-relay and WiMax. Our 
network coverage is (except the Anti-Terrorist Operation zone where Kyivstar is not able to use and control its network): 91.46% of the 2G network; 18.7% of the 
3G network; 9,864 localities covered by 2G network; and 25,484 localities covered by 3G network.

(3)  Kyivstar secured 4G/LTE licenses and spectrum in two separate transactions in 2018.  Following the auction held on January 31, 2018, Kyivstar acquired 15 
MHz (paired) of contiguous frequency in the 2600 MHz band for UAH 0.9 billion (approximately US$32 million).  In addition, on March 6, 2018, Kyivstar secured 
the following spectrum through auction in the 1800MHz band: 25MHz (paired) for UAH 1.325 billion (approximately US$47 million) and two lots of 5MHz (paired) 
for UAH 1.512 billion (approximately US$54 million).

(4) 

 The date is valid for licenses to provide telecommunications services. Due to the changes to legislation that came into force on December 24, 2019, extensions 
and renewals of these licenses will not be required in future. 

(5)  The licenses for the radio frequency resource in 900 MHz re-issued (1 July 2020) as part of a government project on 900 MHz redistribution and refarming as a 
way to introduce 4G (LTE) into 900 MHz. As a result of this project, Kyivstar returned 12.5 MHz and received back on average across the country 11.9 MHz, out 
of which 6.2 MHz was provided with technological neutrality license conditions.

In 2020, Kyivstar PJSC made spectrum and license payments as follows: annual fee for the use of radio frequency spectrum - UAH 976 
million (paid to the State Budget); EMC and monitoring - UAH 255.2 million (paid to Ukrainian State Center of Radio Frequencies); and an 
extension of existing licenses and acquisition of new licenses including within the framework of refarming project for implementation of  
LTE-900 (13 licenses in all) on use of radio frequency spectrum - UAH 350,5 million (paid to the State Budget).

LICENSE FEES

19

Mobile bundles 

Kyivstar offers bundles including combinations of voice, SMS, mobile data and OTT services. 

Distribution

Kyivstar’s strategy is to maintain a leadership position by using the following distribution channels: distributors (37% of 

all connections), local chains (14%), national chains (8%), monobrand stores (23%), direct sales (12%) and active sales (7%).

Competition 

The  following  table  shows  our  and  our  primary  mobile  competitors’  respective  customer  numbers  in  Ukraine  as  of 

December 31, 2020: 

Operator

Kyivstar   

“VF Ukraine” JSC   

“lifecell” LLC   

Source: Omdia

Customers 
(in millions)

25.9

19.6

8.0

Kyivstar  competes  primarily  with  “VF  Ukraine”  JSC,  operating  under  the  Vodafone  brand,  which  is  100%  owned  by 
Bakcell  LLC  (NEQSOL  Holding  international  group  of  companies)  and  operates  a  GSM900/1800  and  an  LTE  1800/2600/900 
network in Ukraine. Kyivstar also competes with “lifecell” LLC, which is 100% owned by Turkcell, as well as with Trimob LLC, a 
100% affiliate company of Ukrtelecom to provide services under a 3G license, and with other small CDMA operators. 

According  to  Omdia,  as  of  December  31,  2020,  there  were  approximately  54.8  million  customers  in  Ukraine, 
representing a mobile penetration rate of approximately 125.4% compared to 55.0 million customers and a mobile penetration 
rate of 125.3% as of December 31, 2019.

20

Mobile Business in Uzbekistan  

In  Uzbekistan,  we  operate  through  our  operating  company,  LLC  “Unitel,”  and  our  brand,  “Beeline.”  We  offer  our 
customers  mobile  telecommunications  services  under  postpaid  and  prepaid  plans.  As  of  December  31,  2020,  approximately 
97.0% of our customers in Uzbekistan were on prepaid plans.  

Our 3G/HSPA services were commercially launched in 2008, and the majority of the network was constructed in 2010. 

Our 4G/LTE services were commercially launched in 2014. Unitel was the first mobile operator to provide 4G/LTE services. 

The table below presents the primary mobile telecommunications services we offer in Uzbekistan.

• airtime  charges  from  mobile  postpaid  and  prepaid  customers,  including  monthly  contract  fees  for  a  predefined  amount  of 

voice traffic and roaming fees for airtime charges when customers travel abroad

• GSM service is provided in 2G and 3G networks; call duration for one session is limited to 40 minutes

Voice

• GPRS/EDGE/3G/4G/LTE networks 

Internet and data access

Roaming

• active roaming agreements with 492 GSM networks in 186 countries

• GPRS roaming with 399 networks in 163 countries

• CAMEL roaming through 302 networks in 125 countries

• roaming agreements generally state that the host operator bills us for roaming services; we pay these charges and then bill the customer 

for these services on a monthly basis

• caller-ID; voicemail; call forwarding; conference calling; call blocking; and call waiting
• the process of implementation of two-step verification for VAS subscriptions (the “double yes” program) began in December 2020 and is 

part of the transparency policy for all of Beeline users

VAS

• SMS and voice messaging

Messaging

Content/infotainment

• Beeline  Games  (more  than  1000  mobile  games),  Beeline  Press  (more  than  200  periodicals),  and  partnership  project  with  Bookmate 
(online service for books and audiobooks); Beeline Club 2.0 (loyalty program available via app, online, USSD. universal virtual discount 
and cashback card); virtual cashback; and My Beeline app

• proprietary  payment  system  “Beepul”  (including  card-to-card  transfer);  bank  card  payments;  trusted  payment;  and  M-

Mobile financial services

The  table  below  presents  a  description  of  business  licenses  relevant  to  our  mobile  business  in  Uzbekistan.  Unless 

noted otherwise, we plan to apply for renewal of these licenses prior to their expiration.

Services
GSM900/1800(1)
3G(1)
4G/LTE(1)
International Communication Services 
License

Data Transfer

License

Nationwide

Nationwide

Nationwide

Nationwide

Nationwide

Inter-city communication services license 

Nationwide

Expiration

August 7, 2031

August 7, 2031

August 7, 2031

2026
Unlimited/Unlimited(2)
2026

TV broadcasting

Nationwide

2023

(1)  Requires annual license fee payments.

(2)  License for exploitation of the data transfer network does not have a fixed term, and the license for design, construction and service provision of data transfer 

network was renewed in June 2020 with an unlimited term.

In 2020, Unitel LLC made payments for spectrum and licenses with the following split: the annual fee for use of radio frequency spectrum 
in the total amount of US$6,062,848 and renewal of existing licenses (7 licenses in total) in the total amount of US$2,992,720 paid to the 
state budget of Ministry for Development of Information Technologies and Communications.

LICENSE FEES

21

Mobile bundles 

We  offer  bundled  tariff  plans,  which  may  differ  by  types  or  volume  of  traffic,  duration  (daily,  weekly,  fortnightly,  and 
monthly),  and  region  or  charge  type.  Currently,  we  provide  data  only  bundles  consisting  of  different  types  of  traffic  volume, 
charge and duration and integrated bundles consisting of traditional voice with SMS and data traffic, including digital services. 

Distribution 

In  Uzbekistan,  we  offer  a  portfolio  of  tariffs  and  products  for  the  prepaid  system  designed  to  cater  to  the  needs  of 
specific market segments, including mass-market customers, youth customers and high value contract customers. Further, we 
have  the  following  four  segments  in  our  postpaid  system:  large  accounts,  business  to  government,  SME  and  SOHO.  As  of 
December  31,  2020,  our  sales  channels  in  Uzbekistan  include  28  owned  offices,  562  exclusive  stores  and  1,934  multibrand 
stores.

Competition  

The  following  table  shows  our  and  our  primary  mobile  competitors’  respective  customers  in  Uzbekistan  as  of 

December 31, 2020: 

Operator

LLC “Unitel”   

Ucell   

UzMobile  (Uzbektelecom) 

UMS   

Perfectum   

Source: Omdia

Customers 
(in millions)

6.8

5.0

4.2

2.8

0.4

According to Omdia, as of December 31, 2020, there were approximately 19.2 million mobile customers in Uzbekistan, 
representing a mobile penetration rate of approximately 60.4% compared to 22.6 million customers and a mobile penetration rate 
of 72.0% as of December 31, 2019.

22

Mobile Business in Kazakhstan 

In Kazakhstan, we operate as Beeline Kazakhstan, the country’s largest independent mobile operator.  As of December 

31, 2020, approximately 93.6% of our customers in Kazakhstan were on prepaid plans.

The table below presents the primary mobile telecommunications services we offer in Kazakhstan.

• Standard voice services
• Prepaid and postpaid airtime charges from customers, including weekly and monthly contract fees for a predefined amount 

of voice traffic and roaming fees for airtime usage when customers travel abroad

Voice

• 3G and 4G/LTE service
• technology neutral licenses

Internet and data access

Roaming

• Voice roaming with 571 networks in 195 countries

• 4G/LTE roaming with 251 networks in 94 countries

• GPRS roaming with 486 networks in 156 countries

• CAMEL roaming through 423 networks in 167 countries

• roaming agreements generally state that the host operator bills us for roaming services; we pay these charges and then 

bill the customer for these services on a monthly basis

• caller-ID; voicemail; call forwarding; call blocking; trusted payment; mobile transfer (transferring funds from the balance of 

VAS

one subscriber to the balance of another)

• SMS; display of Beeline account balance information

Messaging

Content/infotainment
• Brand Content (including Yandex, ZVOOQ, Book.beeline.kz, Viktorina, RingBack Tone (RBT), Press, SeZim, Beeline.Music, 

NoStress, MySafety, Traditional, Engster, Fitness)

• SMS inform, free phone (Voice CPA)

Mobile financial services
• mobile payments (including Kazeuromobile and Woopay payment organizations
• mobile transfers (including Sim2Sim, Sim2Card, Sim2IBAN, Sim2ATM, Sim2post)
• bank card payments
• trusted payment
• Google DCB

The table below presents a description of business licenses relevant to our mobile business in Kazakhstan. 

Licenses (as of December 31, 2020)

Expiration

Mobile services (GSM900/1800, UMTS/WCDMA2100, 4G/
LTE800/1800)

Unlimited term

•

•

•

License received on August 24, 1998.

KaR-Tel has permission to use of spectrum in 800 MHz, 900 MHz, 1800 MHz and 2100 MHz for mobile services and in 2.5-2.6 GHz, 3.3-3.5 GHz,  and 

5,5 GHz for wireless access to internet (WLL).

Upfront payments in US$ are: 800 MHz (US$62,691,378) in 2016, 900 MHz (US$67,500,000) in 1998, 1800 MHz (US$10,958,904) for 4G in 2016, 2G 

(US$20,783,107) in 2008, and 2100 MHz (US$34,106,412) in 2010.

LICENSE FEES
Under the Kazakhstan tax code, in 2020 KaR-Tel was required to pay: (i) an annual fee for the use of radio frequency spectrum 
amounting to KZT 5,948,967,486 for mobile and KZT 193,909,866 for a wireless local loop (WLL); and (ii) a mobile services 
provision payment amounting to 1.3992% of corporate revenues from provided communications services, which totaled KZT 
1,998,605,531.

23

Mobile bundles  

Our  suite  of  integrated  bundles  is  designed  for  active  internet-users.    We  focus  on  data  services,  such  as  unlimited 
access to popular resources: social networks, instant messaging and video hosting. Our tariffs include many useful functions for 
free: exchange of minutes to GB and vice versa, the ability to share the rest of the packages with friends and family. We have 
added free access to mobile TV with popular movies and TV series to all tariffs. Our family option allows customers to join 
groups of up to 5 people and economize. In 2021, we will continue to develop internet services and mobile gaming. We will 
release  a  tariff  constructor,  where  customers  can  customize  a  tariff  according  to  their  needs.  All  bundles  work  with  a  mixed 
payment  system:  they  automatically  switch  to  daily  payment  if  the  current  balance  is  insufficient  for  full  payment.  The 
penetration of bundles into the active base is 87.5%. 

Distribution 

We  distribute  our  products  in  the  countries  in  Kazakhstan  through  owned  monobranded  stores,  franchises  and  other 
distribution channels.  As of December 31, 2020, we had 69 total stores in Kazakhstan (including 9,000 other points of sale and 
466 electronics stores). 

Competition   

The following table shows our and our primary mobile competitors’ respective customers in Kazakhstan as of December 

31, 2020:

Operator
Beeline Kazakhstan
Kcell
Tele2/Altel

Customers 
(in millions)
9.54
8.01
6.7

Source: Ministry of National Economy of the Republic of Kazakhstan, Statistics Committee, Agency for strategic planning and reforms of the Republic of 

Kazakhstan, Beeline Kazakhstan data and Kcell Q4 2020 public disclosure.  

According to Ministry of National Economy of the Republic of Kazakhstan, Statistics Committee and other data sources noted 
above, as of December 31, 2020, there were approximately 24.3 million mobile customers in Kazakhstan, representing a mobile 
penetration rate of approximately 129.0% compared to 25.7 million customers and a mobile penetration rate of 138% in 2019.

24

Mobile Business in Others  

In the countries in our “Others” category, we generally offer our customers mobile telecommunications services under 

prepaid and postpaid plans. 

The “Others” category represents our operations in Kyrgyzstan and Georgia.  For information on reportable segments, 

see — Operating and Financial Review and Prospects — Reportable Segments. 

As of December 31, 2020, we had the following percentages of prepaid and postpaid customers: 

Payment Plan

Kyrgyzstan

Prepaid

Postpaid

Standard voice services

94.9%

5.1%

Voice

Georgia

100%

—

Prepaid and postpaid airtime charges from customers, including weekly and monthly contract fees for a predefined amount 
of voice traffic and roaming fees for airtime usage when customers travel abroad.

3G and 4G/LTE services in each of Kyrgyzstan and Georgia

technology neutral licenses in each of Kyrgyzstan and Georgia

Roaming

Internet and Data Access

•

•

•

•

Kyrgyzstan

Georgia

Voice: 434 networks in 130 countries

GPRS: 279 networks in 102 countries

4G/LTE:108 networks in 58 countries 

CAMEL: 210 networks in 88 countries

Voice: 242 networks in 93 countries

GPRS: 218 networks in 83 countries

CAMEL: 171 networks in 67 countries

•

roaming agreements generally state that the host operator bills for roaming services; we pay these charges and then bill 
the customer for these services (in some cases on a monthly basis)

caller-ID; voicemail; call forwarding; conference calling; call blocking and call waiting

SMS, MMS, voice messaging and mobile instant messaging

Messaging

Content/infotainment

VAS

SMS  CPA,  Voice  CPA,  RBT,  voice  services  (including  referral  services),  content  downloadable  to  telephone  (including 
music, pictures, games and video); access to radio or television broadcasting online or via mobile app

balance transfer, trusted payment, mobile wallet

Mobile financial services

•

•

•

•

25

The  table  below  presents  a  description  of  business  licenses  relevant  to  our  mobile  business  in  Others.  Unless  noted 

otherwise, we plan to apply for renewal of these licenses prior to their expiration. 

Country

Licenses (as of December 31, 2020)

Expiration

Kyrgyzstan Radio spectrum of 2600 MHz for the certain territory of Kyrgyzstan  
(technology neutral) 2530-2550MHz/2650-2670MHz

February 2030

Radio spectrum of 800 MHz for the entire territory of Kyrgyzstan 
(technology neutral) 796-801MHz/837-842MHz

September 2025

Radio spectrum of 800 MHz for the entire territory of Kyrgyzstan 
(technology neutral) 791-796MHz/832-837MHz

Radio spectrum of 900 MHz, 1800 MHz and 2100 MHz for the entire 
territory of Kyrgyzstan (technology neutral)

National license for electric communication service activity

National license for base station transmission

National license for services on data traffic

Radio spectrum for one site (transmission)

Georgia

GSM1800 10 MHz frequency

GSM900 5.49 MHz frequency

LTE 800 10 MHz frequency

10 MHz 3G frequency

Wireless internet services 

December 2026

October 2024

Unlimited term

December 2024

Unlimited term

May 2023

February 2030

February 2030

February 2030

December 2031

We have promotional zero-zones for major local and international social networks in each of these countries to lower 
the  entry  barrier  for  new  data  users  and  stimulate  consumption  for  existing  ones.  We  also  focus  on  smartphone  penetration 
growth in each of these countries as the major source of effective demand for our mobile internet services. 

Distribution 

We distribute our products in the countries in our “Others” category through owned monobranded stores, franchises and 
other distribution channels. As of December 31, 2020, we had 76 stores in Kyrgyzstan (including 5969 other points of sale)  and 
28 stores in Georgia.

Mobile customers and mobile penetration rate

The table below presents our total number of customers and the total mobile penetration rate for all operators in each of 

the countries in our “Others” category as of December 31, 2020 and December 31, 2019.

Kyrgyzstan
Georgia

2020
(millions of customers)
2.5
1.3

Mobile Penetration

123.6%
116%

2019
(millions of customers)
2.6
1.3

Mobile Penetration

124.7%
134.8%

Source: Omdia; and the Georgian National Communications Commission.

26

Description of Our Fixed-line Telecommunications 

In Russia, Ukraine and Uzbekistan, we offer voice, data and internet services to corporations, operators and consumers 
using  a  metropolitan  overlay  network  in  major  cities  and  fixed-line  telecommunications  using  inter-city  fiber  optic  and  satellite-
based networks. In Kazakhstan, we offer a range of fixed-line business services for B2O, B2B and B2C segments. In Pakistan, 
we offer internet and value-added services over a wide range of access media, covering major cities of Pakistan. We do not offer 
fixed-line telecommunications services in Algeria, Bangladesh, Kyrgyzstan or Georgia.

Fixed-line Business in Russia  

The table below presents a description of the fixed-line telecommunications services we offer in Russia.

Services

• network access and hardware and software solutions, including configuration and maintenance, SaaS and an integrated 

managed service 

• local access services by connecting the customers’ premises to our own fiber network, international and domestic long-

distance services and VSAT services to customers located in remote areas

• internet access to both corporate and consumer customers through backbone networks and private line channels

• IP address services, the ability to rent leased channels with different high-speed capacities and remote access to corporate 

information, databases and applications. 

• managed Wi-Fi networks based on IEEE 802.11b/g/n/ac wireless technology

• virtual PSTN number, xDSL services, session initiation protocol (SIP) connection, financial information services, data center 

services, such as co-location, web hosting, audio conference and domain registration services

• IPTV services (1.88 million customers), virtual PBX, certain Microsoft Office packages (including SaaS), web-

videoconferencing services and sale, rental and technical support for telecommunications equipment

• Pay TV (cable TV) (21,842 customers)

•  OTT TV (TVE)

• FMC product services (1,534,131 customers)

• carrier and operator services, including voice, internet and data transmission over our own networks and roaming services

• MPLS-based IP VPN, local, domestic and international private lines, equipment and equipment maintenance (under 

interconnection agreements with international global data network operators

• high-speed domestic and international channels to international and Russian operators to sell excess backbone network 

capacity

• all major population centers

Coverage

40 regions of Russia (189 cities covered by FTTB network), including FVNO projects (10 cities)

Operations

• operate a number of competitive local exchange carriers that operate fully digital overlay networks in a number of major 

Russian cities

• FTTB and FMC

• large multinational corporate groups 

• government clients

• SMEs

• high-end residential buildings in major cities 

Customers

27

Distribution  

We utilize a direct sales force in Moscow, operating both with fixed-line and mobile corporate customers and supported 
by  specialists  in  technical  sales  support,  marketing,  customer  service  and  end-user  training.  In  addition,  we  employ  a  team  of 
regional sales managers and a dedicated sales force in each of our regional branch offices, as well as having sales incentive 
plans with our regional partners.  

Competition  

Our  fixed-line  telecommunications  business  marketed  as  “Beeline  Business”  faces  significant  competition  from  other 
service  providers  and  competes  principally  on  the  basis  of  convergent  services  and  bundles,  installation  time,  network  quality, 
geographical network reach, customer service, range of services offered and price. The table below presents our competitors in 
the voice services, data services and fixed-line broadband markets in Russia.

• Rostelecom

• Rostelecom

Voice Services

• TransTelecom

Data Services

• TransTelecom

Fixed-line Broadband

• Rostelecom
• MTS and its subsidiaries

• Akado
• ER-Telecom

• OJSC “Multiregional TransitTelecom”

• MegaFon

• NetbyNet

In terms of end-user internet penetration, the consumer internet access business in Russia is saturated and end-user 
internet penetration is high. Competition for customers in Russia is intense, with internet providers utilizing new marketing efforts 
(for example, aggressive price promotions) in order to retain existing customers and attract new ones. We expect competition to 
increase  in  the  future  due  to  wider  market  penetration,  consolidation  of  the  industry,  the  growth  of  current  operators  and  the 
appearance of new technologies, products and services.  

28

Licenses 

The  table  below  presents  a  description  of  business  licenses  relevant  to  our  fixed-line  business  in  Russia  and  which 

expire in 2021. Unless noted otherwise, we plan to apply for renewal of these licenses prior to their expiration. 

Services

Local Communications Services

Leased 
Services

Communications 

Circuits 

Local Communication Services

Intra-zone Communication Services

Telematic Services

License
Moscow
Yekaterinburg
Khabarovsk
Krasnodar
St. Petersburg
Moscow
Nizhny Novgorod
Khabarovsk
Novosibirsk
Rostov
Krasnodar
Moscow
St. Petersburg
Krasnodar
Moscow
St. Petersburg
Yekaterinburg
Nizhny Novgorod
Khabarovsk
Novosibirsk
Rostov
Krasnodar
Yekaterinburg
Nizhny Novgorod

Khabarovsk

Novosibirsk

Rostov

Moscow

Expiration
August 30, 2021
February 16, 2026
October 31, 2021
October 1, 2021
June 8, 2021; July 5, 2021; October 4, 2021 
July 5, 2021; November 9, 2021 
July 5, 2021
July 5, 2021
July 5, 2021
July 5, 2021
July 5, 2021
September 21, 2021
September 21, 2021
February 16, 2026, December 12, 2021
October 24, 2021
October 24, 2021
February 16, 2026
February 16, 2026
February 16, 2026
February 16, 2026
February 16, 2026
May 06, 2021; September 14, 2021; November 17, 2021
May 6, 2021
May 6, 2021

May 6, 2021

May 6, 2021

May 6, 2021

April 26, 2021; May 06, 2021; November 21, 2021

Data Transmission Services License

St. Petersburg

May 06, 2021; November 21, 2021

Krasnodar

Moscow

September 14, 2021

March 15 2026; April 26, 2026

Communications Services for the Purposes Krasnodar

August 27, 2021

29

Fixed-line Business in Pakistan  

The table below presents a description of the fixed-line telecommunications services we offer in Pakistan.

Services

• data, voice and VAS services over a wide range of access media, covering more than 225 locations, including all  the major 
• data services being provided to the enterprise customers include: dedicated internet access, VPN (virtual private networking), 

cities

leased lines & fixed telephony

• domestic and international leased lines, domestic and international MPLS, and IP transit services through our access 

network1

• high-speed internet access (including fiber optic lines)
• telephony
• telephone communication services, based on modern digital fiber optic network
• dedicated lines of data transmission
• dedicated line access and fixed-line mobile convergence

Coverage

• wired and wireless access services include FTTx, PMP (point to multipoint), point-to-point radios, VSAT and Microwave links 

connecting more than 225 locations across Pakistan

• long-haul fiber optic network covers more than 10,000 kilometers and, supplemented by wired and wireless networks

Customers

Operations

• enterprise customers
• domestic and international carriers
• corporate and individual business customers

Distribution  

We  utilize  a  direct  sales  force  in  Pakistan  for  enterprise  customers.  This  dedicated  sales  force  has  three  channels 
dedicated to SMEs, large/key accounts and business-to-government. These channels are led by individual channel heads who 
further  employ  a  team  of  regional  sales  managers  in  different  regions,  which  are  further  supported  by  a  sales  force,  including 
team leads and key account managers. There is also a centralized telesales executive team led by a manager who upsells through targeted 
campaigns.

Competition 

In  Pakistan,  our  fixed-line  business  faces  significant  competition  from  other  providers  of  fixed-line  corporate  services, 
carrier and operator services and consumer internet services. The table below presents our competitors in the internet services, 
carrier and operator services and fixed-line broadband markets in Pakistan.

• PTCL
• Wateen

• PTCL
• Wateen

Internet Services

• Transworld

• Cybernet

Carrier and Operator Services

• Transworld
• Telenor Pakistan

Fixed-line Broadband

• Pakistan Telecommunication Company 

Limited, or “PTCL”

• Multinet
• Wateen

• Cybernet
• Nexlinx
• Nayatel

• World Call
• Multinet

• World Call

• Supernet

30

Licenses 

The  table  below  presents  a  description  of  business  licenses  relevant  to  our  fixed-line  business  in  Pakistan.    Unless 

noted otherwise, we plan to apply for renewal of these licenses prior to their expiration.

Services

License

Expiration

Long Distance & International (“LDI”)

Nationwide and International

Local Loop (“LL”) (fixed line and/or 
wireless local loop with limited mobility)

Regional

Telecom Tower Provider (“TTP”)

Nationwide

2024

2024

2032

Fixed-line Business in Ukraine 

The table below presents a description of the fixed-line telecommunications services we offer in Ukraine.

Services

• data

• broadband services

• corporate internet access

• Fixed-line: VPN services, data center, contact center, voice, fixed-line telephony and a number of VAS

• Internet access services: ADSL, symmetrical and Ethernet interfaces at speeds ranging from 256 kilobytes per second to 10 

gigabytes per second

• FMC

• FTTB services tariffs for fixed-line broadband internet access targeted at different customer segments

Coverage

• provided services in 125 cities in Ukraine (excluding cities in Crimea and the ATO zone)

• engaged in a project to install FTTB for fixed-line broadband services in approximately 42,779 residential buildings in 125 

cities, providing over 59,288 access points

Our joint carrier and operator services division in Ukraine provides local, international and intercity long- distance voice 
traffic transmission services to Ukrainian fixed-line and mobile operators on the basis of our proprietary domestic long-distance/
ILD  network,  as  well  as  IP  transit  and  data  transmission  services  through  our  own  domestic  and  international  fiber  optic 
backbone and IP/MPLS data transmission network. We derive most of our carrier and operator services revenue in Ukraine from 
voice call termination services to our own mobile network and voice transit to other local and international destinations.  

Distribution  

Our company emphasizes high customer service quality and reliability for its corporate large accounts while at the same 
time focusing on the development of its SME offerings. We sell to corporate customers through a direct sales force and various 
alternative distribution channels such as IT servicing organizations and business center owners, and to SME customers through 
dealerships, direct sales, own retail and agent networks. We use a customized pricing model for large accounts which includes 
service or tariff discounts, volume discounts, progressive discount schemes and volume lock pricing. We use standardized and 
campaign-based pricing for SME customers. Our residential marketing strategy is focused on attracting new customers. We offer 
several tariff plans, each one targeted at a different type of customer. 

Competition  

There is a high level of competition with more than 2000 internet service providers in Ukraine. According to NCCIR, the 
National Regulatory Authority, as of September 30, 2020, Kyivstar leads the fixed broadband market with 1.1 million customers, 
which corresponds to 15.3% market share.

31

• Ukrtelecom

• Data Group

• Farlep-Invest (Vega)

Voice Services(1), Data Services(2) and Voice Services

• Ukrtelecom

• Volia

Top 5 ISPs (market share)(3)

Retail Internet Services

•

•

Kyivstar (15.3%)

Freenet (2.1%)

•

•

Ukrtelecom (14.8%)

Data Group (2.1%)

(1)   Voice services market for business customers only.    

(2)   Data services for corporate market only. 

(3)   Source: National Regulatory Authority - NCCIR

Licenses 

•

Volia (9.4%)

Following recent legislative changes, including the changes to the Law “On Telecommunications” made in 2019 by the 
Ukrainian  Parliament,  state  licensing  of  fixed-line  telecommunications  services  is  now  abolished.    Accordingly,  our  fixed-line 
business in Ukraine no longer requires licensing in order to operate.  Licensing of radio frequency resource (RFR) use remains 
unchanged.

Fixed-line Business in Uzbekistan 

The table below presents a description of the fixed-line telecommunications services we offer in Uzbekistan. 

Services(1)
• fixed-line services, such as network access

• internet and hardware and software solutions, including configuration and maintenance

• high-speed internet access (including fiber optic lines and xDSL)

• telephony

• long distance and international long-distance telephony on prepaid cards

• telephone communication services, through our copper cable network and our modern digital fiber optic network

• dedicated lines of data transmission

• dedicated line access and fixed-line mobile convergence

Distribution 

One of our priorities in Uzbekistan is the development of information and communications technology, which supports 
economic  development  in  Uzbekistan.  Our  strategy  includes  maintaining  our  current  market  position  by  retaining  our  large 
corporate client customer base.  

Competition 

There is a high level of competition in the capital city of Tashkent, but the fixed-line internet market in most of the other 

regions remains undeveloped. The table below presents our competitors in the fixed-line services market in Uzbekistan.

Fixed-line Services

• Uztelecom

• East Telecom

• Sarkor Telecom

Licenses 

• Sharq Telecom

• TPS

• EVO

The  table  below  presents  a  description  of  business  licenses  relevant  to  our  fixed-line  business  in  Uzbekistan.  Unless 

noted otherwise, we plan to apply for renewal of these licenses prior to their expiration.

Services

Fixed-line

Data

Long-distance

International

Expiration

2021

2021

2029

2029

License

Nationwide

Nationwide

Nationwide

Nationwide

32

Fixed-line Business in Kazakhstan  

The table below presents a description of the fixed-line telecommunications services we offer in Kazakhstan.

Services
• high-speed internet access
• local, long distance and international voice services over IP
• local, intercity and international leased channels and IP VPN services
• cloud services, BeeTV, Internet of things (IoT)
• integrated corporate networks (including integrated network voice, data and other services)
• FMC product, including mobile bundles and video content from Amediateka and IVI, and additional sim-cards for family
• ADSL, FTTB, Wi-Fi, WiMax, VSAT, GPON, WTTX

Distribution   

We  are  focusing  on  customer  base  and  revenue  growth,  which  we  aim  to  promote  by  expanding  our  transport 
infrastructure, developing unique products, strengthening our position in the market and enhancing our sales efforts and data 
services, and Fixed Virtual Network Operator (FVNO) activity. 

Competition 

The table below presents our competitors in the fixed-line telecommunications services market in Kazakhstan. 

Internet, Data Transmission and Traffic Termination Services

• Kazakhtelecom

• KazTransCom
• Alma TV

Licenses 

• TransTelecom (owned by Kazakhstan Temir Zholy, the 

national railway company)

• Astel (a leader in the provision of satellite services)

The table below presents a description of business licenses relevant to our fixed-line business in Kazakhstan. Unless 

noted otherwise, we plan to apply for renewal of these licenses prior to their expiration.

Services
Long-distance and International Nationwide

License

Expiration
Unlimited

33

Regulatory 

The  voice,  data  and  connectivity  services  we  provide  may  also  expose  us  to  sanctions  and  embargo  laws  and 
regulations of the United States, the United Nations, the European Union, the United Kingdom and the jurisdictions in which we 
operate.   In addition, as a global telecommunications company, we have roaming and interconnect arrangements with mobile 
and  fixed-line  operators  located  in  the  majority  of  countries  throughout  the  world,  including  in  countries  that  are  the  target  of 
certain  sanctions  restrictions.  For  a  discussion  of  the  sanctions  regimes  we  are  subject  to,  including  the  risks  related  to  such 
exposure,  see  Item  3.D.  Risk  Factors  -  Geopolitical  Risks  -  "  Violations  of  and  changes  to  applicable  sanctions  and  embargo 
laws may harm our business”.

Seasonality 

Our  mobile  telecommunications  business  is  subject  to  certain  seasonal  effects.  Generally,  revenue  from  our  contract 
and  prepaid  tariff  plans  tends  to  increase  during  the  December  holiday  season,  and  then  decrease  in  January  and  February. 
Mobile revenue is also higher in the summer months, when roaming revenue increases significantly as customers tend to travel 
more during these months. Guest roaming revenue on our networks also tends to increase in the summer period. 

Our fixed-line telecommunications business is also subject to certain seasonal effects. Among the influencing factors is 
the  number  of  working  days  in  a  given  period,  as  well  as  periods  of  vacations.  Generally,  our  revenue  from  our  fixed-line 
telecommunications business is lower when there are fewer working days in a period or a greater number of customers are on 
vacation, such as during the December holiday season and in the summer months.

In 2020, these trends were less pronounced due to the outbreak of COVID-19 and the associated lockdown restrictions 
imposed by governments across the world. Roaming revenues were significantly lower as compared to normal years, while we 
saw  a  pick-up  in  usage  of  our  fixed-line  services  due  to  work-from-home  conditions  and  travel  restrictions.  However,  going 
forward we expect the seasonal trends described above to continue.

Information Technology  

We devote considerable resources to the maintenance, development and improvement of our IT systems. As part of our 
continuous  IT  innovation  process,  we  engage  with  third  parties  in  order  to  develop  and  implement  IT  technologies  across  our 
infrastructure.  In  June  2016  in  partnership  with  Ericsson,  we  entered  into  a  technology  infrastructure  agreement  which  was 
subsequently amended in July 2017 and February 2019. Under the current agreement, which reflects a reduction in scope from 
the  prior  agreements,  Ericsson  will  upgrade  our  core  IT  systems  with  new  digital  business  support  systems  (DBSS)  using 
software  from  Ericsson  and  will  manage  the  new  systems  under  the  managed  services  agreement.  The  new  Ericsson  DBSS 
system has already been launched in four of our operations: Georgia, Algeria, Kyrgyzstan and Bangladesh. 

We are also in the process of implementing our cyber security strategy, which we believe will enable us to better identify 
potential  threats  that  may  impact  our  business  and,  consequently,  may  aid  us  in  the  implementation  of  the  required  security 
measures to address such threats.

Intellectual Property 

We  rely  on  a  combination  of  trademarks,  service  marks  and  domain  name  registrations,  copyright  protection  and 
contractual  restrictions  to  establish  and  protect  our  technologies,  brand  name,  logos,  marketing  designs  and  internet  domain 
names.  We  have  registered  and  applied  to  register  certain  trademarks  and  service  marks  in  connection  with  our 
telecommunications and digital businesses in accordance with the laws of our operating companies. Our registered trademarks 
and service marks include our brand name, logos and certain advertising features. Our copyrights and know-how are principally 
in the area of computer software for service applications developed in connection with our mobile and fixed-line network platform, 
our  internet  platforms  and  non-connectivity  service  offerings  and  for  the  language  and  designs  we  use  in  marketing  and 
advertising  our  communication  services.  For  a  discussion  of  the  risks  associated  with  new  technology,  see  Risk  Factors  — 
Operational Risks — “Our intellectual property rights are costly and difficult to protect, and we cannot guarantee that the steps 
we  have  taken  to  protect  our  intellectual  property  rights  will  be  adequate”  and  —  Regulatory,  Compliance  and  Legal  Risks  — 
“New intellectual property laws or regulations may require us to invest substantial resources in compliance or may be unclear.” 

34

Property, Plants and Equipment

Buildings

The buildings housing our offices in Amsterdam and London are leased. Our global headquarters activities are hosted in 
Amsterdam,  and  we  have  subleased  a  portion  of  our Amsterdam  office  as  of  February  2020.  Our  London  office  at  15  Bonhill 
Street  has  been  fully  subleased  since  January  2019,  and  our  London-based  staff  now  utilize  a  space  located  at  13  Hannover 
Square,  London  W1S  1HN.  Our  subsidiaries,  including  those  in  Russia,  Pakistan,  and  Ukraine,  both  own  and  lease  property 
used for a variety of functions, including administrative offices, technical centers, data centers, warehouses, operating facilities, 
main switches for our networks and IT centers.  We also own office buildings in some of our regional license areas and lease 
space on an as-needed basis.

Telecommunications Equipment and Operations  

The primary elements of our material tangible fixed assets are our networks. 

Mobile network infrastructure 

Our  mobile  networks,  which  use  mainly  Ericsson,  ZTE,  Huawei,  Nokia,  and  Cisco  equipment,  are  integrated  wireless 
networks  of  radio  base  station  equipment,  circuit  and  packet  core  equipment  and  digital  wireless  switches  connected  by  fixed 
microwave  transmission  links,  fiber  optic  cable  links  and  leased  lines.  We  select  suppliers  based  mainly  on  compliance  with 
technical and functional requirements and total cost. 

We enter into agreements for the location of base stations in the form of either leases or cooperation agreements that 
provide us with the use of certain spaces for our base stations and equipment. Under these leases or cooperation agreements, 
we typically have the right to use such property to place our towers and equipment shelters. We are also party to certain network 
managed services agreements to maintain our networks and infrastructure. 

We  also  enter  into  agreements  with  other  operators  for  radio  network  sharing,  where  we  either  share  the  passive 
equipment,  physical  site  and  towers  or  combine  the  operation  of  the  radio  equipment  with  other  operators.  Network  sharing 
brings not only substantial savings on site rentals and maintenance costs but also on investments in equipment for the rollout of 
new  base  stations.  In  Russia,  we  have  agreements  with  MTS  and  MegaFon  in  different  regions  and  for  different  technology 
combinations, respectively.  

Fixed-lined infrastructure 

Our  infrastructure  in  Russia,  Pakistan,  Ukraine,  Uzbekistan  and  Kazakhstan,  where  we  provide  fixed-line  services, 
supports  our  mobile  businesses  as  well  as  our  fixed-line  businesses.  Our  infrastructure  in  these  markets  include:  a  transport 
network designed and continually developed to carry voice, data and internet traffic of mobile network, FTTB and our fixed-line 
customers using fiber optics and microwave links; and a transport network based on our optical cable network utilizing DWDM, 
SDH and IP/MPLS equipment with all DWDM and SDH optical networks being fully ring-protected (except for secondary towns).

For  more  information  on  our  property,  plants  and  equipment,  see Note  11  —  Property  and  Equipment  to  our Audited 

Consolidated Financial Statements.

35

Corporate Social Responsibility

The  Group  Chief  Strategy  Officer  oversees  the  corporate  responsibility  program  and  function,  and  the  corporate 

responsibility team confers with our management in connection with executing its duties.

We  have  a  long-term  corporate  responsibility  strategy,  consisting  of  two  main  elements:  maintaining  the  trust  of  our 
stakeholders  by  behaving  in  a  responsible  and  sustainable  manner,  reflected  in  our  “license  to  operate”  initiatives,  and  by 
creating shared value in our communities through our products and services, reflected in our “license to grow” initiatives. We are 
committed  to  investing  in  the  markets  in  which  we  operate  and  continue  to  seek  opportunities  to  leverage  our  technology, 
commercial expertise and the commitment of our employees for the betterment of our communities. 

Our group Sustainability Report and group Integrated Annual Report meet Global Reporting Initiative standards at the 
“core” level, follow the guidance in the AA1000 Accountability Principles Standard and are influenced by International Integrated 
Reporting Council guidance. 

The group Sustainability Report and the group Integrated Annual Report have obtained a “limited” level of assurance in various 
“subject matters” to meet the requirements of the International Standard on Assurance Engagements (ISAE) 3000 (revised). For 
the AA1000 Principles, our assurance engagement was planned and performed to meet the requirements of a Type 1 “moderate 
level” of assurance as defined by AA1000 Assurance Standard (AA1000AS) 2008. 

As part of our reporting cycle, we assess the effectiveness of our corporate responsibility strategy and revise it when 

needed. 

Our  approach  to  the  identification,  management  and  evaluation  of  corporate  responsibility  is  guided  by  three  main 

principles:  

•

Stakeholders:  By  engaging  with  our  stakeholders,  we  understand  their  concerns  and  expectations,  and  we  follow  a 
number of stakeholder-defined standards and guidelines;  

• Materiality: Using pre-defined criteria, we prioritize by assessing individual opportunities against our strategy and their 

importance to our stakeholders; and  

•

Accountability:  We  are  accountable  to  our  stakeholders  through  the  publication  of  our  Integrated Annual  Report.  We 
also share periodic updates with internal stakeholders, including members of management, to inform them  about  key 
corporate responsibility-related developments and our corporate responsibility performance. 

In  November  2019,  we  were  recognized  as  among  the  most  transparent  companies  in  the  Netherlands  by  the  Dutch 
Transparency Benchmark (Transparantiebenchmark). More than 480 of the largest companies in the Netherlands were assessed 
for the Dutch Transparency Benchmark by the Dutch Ministry of Economic Affairs and Climate Policy, and VEON improved its 
ranking from 449 in 2011 to 32 in 2019. Furthermore, among technology-focused companies in the Netherlands, VEON ranked 
fourth.

We are committed to mitigating the Group’s carbon footprint and the rollout network energy-efficiency measures, which 
will contribute to a low-carbon economy, as well as offer us the potential to reduce our operating costs over time. We continue to 
upgrade  existing  diesel-  and  petrol-powered  units  with  more  energy-efficient,  hybrid  and  renewable-energy-powered  network 
equipment and, where practical, increase the number of Base Transceiver Stations (BTS) situated outside to reduce the energy 
use  involved  in  keeping  them  cool.  In  some  markets  we  share  tower  capacity  with  other  operators,  which  has  had  a  direct 
positive impact on our energy consumption and our environmental footprint. We keep abreast of local environmental legislation 
and strive to reduce the environmental impact of our operations through responsible use of natural resources and by reducing 
waste and emissions.

VEON’s carbon dioxide (CO2) emissions decreased from 0.24 tonnes per terabyte in 2019 to 0.1 tonnes in 2020, a 58% 
decrease.  The decrease was largely a result of a significant increase in data traffic carried across our networks during 2020 due 
to COVID-19 lockdowns, with the increased data load requiring a lesser increase in energy.

Our  operating  companies  continued  to  developing  innovative  solutions  to  reduce  energy  intensity,  such  as  powering 
telephone exchange stations on solar energy, installing state-of the-art on-grid photovoltaic systems and carrying out trainings on 
renewable energy solutions to ensure stakeholders are aware of its carbon- and cost-saving benefits. Across our organization, 
we continued working on reducing the carbon footprint of our offices, with initiatives ranging from switching to LED lighting.

36

DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES

Directors and Senior Management 

As  of  March  1,  2021,  our  directors,  their  respective  ages,  positions,  dates  of  appointment  and  assessment  of 

independence were as follows:

Name

Age

Position

First Appointed

Independent

Gennady Gazin

Hans Holger Albrecht

Osama Bedier

Leonid Boguslavsky

Peter Derby

Mikhail M. Fridman

Amos Genish

Yaroslav Glazunov

Andrei Gusev

Gunnar Holt

Robert Jan van de Kraats

Alexander Pertsovsky

Steve Pusey

56

57

45

69

60

56

60

41

48

66

60

52

59

Chairman of Board of Directors

2020 (as Chairman); 
2015 (as member)

Director

Director

Director

Director

Director

Director

Alternate Director (Alexander Pertsovsky)

Director

Director

Director

Director

Director

2020

2018

2021

2020

2010

2020

2020

2014

2015

2018

2018

2020

x

x

x

x

x

x

x

x

x

The board of directors consists of twelve members, nine of whom we deem to be independent.  In analyzing 
the  independence  of  the  members  of  the  board  of  directors  for  this  purpose,  we  are  guided  by  the  NASDAQ  listing  rules,  the 
rules promulgated by the SEC and the Dutch Corporate Governance Code, as if those rules applied to us.  

All  members  of  the  board  of  directors  are  elected  by  our  shareholders  through  a  cumulative  voting  process. 
Nominations to the board of directors are managed by its nominating and corporate governance committee, which is led by Peter 
Derby,  whom  we  deem  to  be  an  independent  member  of  the  board  of  directors.  The  nominating  and  corporate  governance 
committee  looks  to  ensure  that  the  membership  of  the  board  of  directors  consists  of  individuals  with  sufficiently  diverse  and 
independent  backgrounds. All  members  of  the  board  of  directors  possess  relevant  industry  experience  and  have  additionally 
been selected to provide the requisite experience required of the committees of our board of directors.

The members of our current board of directors, with the exception of Mr. Glazunov and Mr. Boguslavsky, were elected 
at the June 1, 2020 annual general meeting of shareholders in accordance with our bye-laws.  Mr. Glazunov was appointed as 
an alternate director for Alexander Pertsovsky on October 27, 2020. Mr. Boguslavsky was appointed as a director on January 15, 
2021 to fill the casual vacancy created when Mariano de Beer stepped down in December 2020.  All members of our board of 
directors, including Mr. Glazunov and Mr. Boguslavsky, will serve until the next annual general meeting, unless any members are 
removed from office or their offices are vacated in accordance with our bye-laws. Alternate directors will be summoned to act as 
regular directors in a temporary or permanent manner in case of absence, vacancy or demise. 

On July 30, 2018, we amended and restated our bye-laws to, among other things, eliminate our two-tier board structure.  

As a result, we have a board of directors and a management advisory committee known as the group executive committee.  

Our bye-laws empower the board of directors to direct the management of the business and affairs of the group, and 
require that the board of directors approves important matters including, among others, the annual budget and audited accounts, 
organizational or reporting changes to the management structure, significant transactions and changes to share capital or other 
significant actions. Additionally, under Bermuda law, the board of directors has the right to require that any matter come to the 
board of directors for approval and any member of the board of directors may bring forward an item for the agenda of the board 
of directors, which helps to ensure that the board of directors provides appropriate oversight over group matters. 

The  group  executive  committee  is  currently  comprised  of  VEON  Ltd.’s  co-Chief  Executive  Officers,  Group  Chief 
Financial Officer, Group General Counsel, Group Chief Internal Audit & Compliance Officer, and the Chief Strategy Officer.  The 
group executive committee is focused on the management of the business affairs of VEON Ltd. and its subsidiaries as a whole, 
including  execution  of  the  group’s  competitive  strategy,  driving  financial  performance  and  overseeing  and  coordinating  group-
wide initiatives.  On an annual basis, our group executive committee, audit and risk committee and board of directors define our 
risk profile for the categories of risk we encounter in operating our business, which are then integrated into our business through 
global policies and procedures. 

37

 
As  of  March  1,  2021,  the  members  of  our  group  executive  committee,  their  respective  ages,  positions  and  dates  of 

appointment were as follows: 

Name

Kaan Terzioğlu

Sergi Herrero

Serkan Okandan

Scott Dresser
Alex Kazbegi(1)

Joop Brakenhoff

Age

52

38

50

53

58

55

Position

First Appointed

Group Chief Executive Officer

March 2020 (as co-CEO)

Group Chief Executive Officer

March 2020 (as co-CEO)

Group Chief Financial Officer

May 2020

Group General Counsel

Group Chief Strategy Officer

Group Chief Internal Audit & 
Compliance Officer

September 2014

February 2019

July 2020

(1) Alex Kazbegi will be stepping down from his role as Group Chief Strategy Officer effective March 31, 2021.  His replacement 
will be announced in due course.

 Board of Directors  

Gennady  Gazin  (Chairman  of  Board  of  Directors)  has  served  as  the  Chairman  of  the  VEON  Ltd.  Board  of  directors 
since  June  2020  and  a  director  of  the  company  since  June  2015  and  we  deem  Mr.  Gazin  to  be  an  independent  director.  Mr. 
Gazin is a member of VEON Ltd.’s nominating and corporate governance committee and its finance committee.  Mr. Gazin has 
served as an Affiliate Partner at Lindsay Goldberg, a New York based private equity firm, since 2015;  Chairman of the Board at 
Genesis Philanthropy Group since 2014; and a member of the advisory board of LetterOne Technology LLP since 2015 and DVO 
Private  Equity  since  2018.  From  2007  to  2012,  Mr.  Gazin  served  as  CEO  of  EastOne,  an  international  investment  advisory 
group. Prior to EastOne, Mr. Gazin worked at McKinsey & Company’s New York and Moscow offices for 14 years, during which 
time  he  was  an  active  member  of  the  Telecommunications  practice  and  also  served  as  the  Senior  Partner  responsible  for 
McKinsey’s  CIS  practice.  Mr.  Gazin  started  his  professional  career  as  a  systems  and  telecommunications  engineer  at  Bell 
Communications  Research/Tellcordia  and  General  Dynamics  in  the  USA.  Mr.  Gazin  received  a  bachelor’s  degree  in  Electrical 
Engineering from Cornell University in 1987, a master’s degree in Electrical Engineering from Stanford University in 1988 and an 
M.B.A. from the Wharton School of Business at the University of Pennsylvania in 1993. 

Hans Holger Albrecht (Director) has been a director of VEON Ltd. since June 2020 and we deem Mr. Albrecht to be an 
independent director.   Mr. Albrecht is a member of VEON Ltd.’s compensation and talent committee and digital committee.  He 
has served as the Chairman of the supervisory board of Scout24 AG, a publicly listed operator of online marketplaces in several 
industries, since 2018. In addition, Mr. Albrecht has served as a member of the boards of directors of Norwegian mobile network 
operator Ice Group AS since 2015 and German cable provider Tele Columbus AG since 2019. Mr. Albrecht has also served as a 
member  of  the  digital  advisory  board  of  German  retail  bank  Deutsche  Postbank  since  2016.  Mr. Albrecht  has  been  the  Chief 
Executive  Officer  of  Deezer  Group  since  2015,  a  French  online  music  streaming  service.  Mr. Albrecht  was  the  President  and 
Chief  Executive  Officer  of  Millicom  International  Cellular  S.A.,  a  telecom  and  media  group  offering  digital  services  to  over  50 
million customers in Africa and Latin America, from 2012-2015, and Modern Times Group MTG AB, a publicly traded Swedish 
digital entertainment company, from 1998 to 2012. Mr. Albrecht holds a doctorate from Ruhr-Universitat Bochum in Germany and 
a master of law from the University of Freiburg.

Osama  Bedier  (Director)  has  been  a  director  of  VEON  Ltd.  since  July  2018  and  we  deem  Mr.  Bedier  to  be  an 
independent director.  Mr. Bedier is a member of VEON Ltd.’s digital committee.  Mr. Bedier is the founder of Poynt, a credit card 
processing  terminal  developed  and  marketed  for  small  businesses,  which  was  acquired  by  GoDaddy  in  February  2021.  Mr. 
Bedier now leads the Commerce Division of GoDaddy.  Mr. Bedier also serves on the Board of RS2.  Prior to founding Poynt, Mr. 
Bedier  served  as  the  Vice  President  of  Payments  at  Google  from  2011  to  2013,  where  he  created  Google  Wallet.    Prior  to 
Google, Mr. Bedier spent nine years running product and engineering at PayPal.  He has also held engineering leadership roles 
at eBay, Gateway Computers and AT&T Wireless.

Leonid Boguslavsky (Director) has been a director of VEON Ltd. since January 2021 and we deem Mr. Boguslavsky 
to  be  an  independent  director.    Mr.  Boguslavsky  is  a  member  of  VEON  Ltd.’s  digital  committee.    Mr.  Boguslavsky  is  an 
entrepreneur,  scientist  and  venture  capitalist  and  founder  of  RTP  Global  (formerly  known  as  ru-Net),  which  since  2000  has 
focused  on  investments  in  early-stage  start-ups  across  the  globe.    He  was  a  managing  partner  at  PricewaterhouseCoopers 
(PwC) from 1997 to 2001.  Mr. Boguslavsky has served as a Member of the Board of Directors of JSC “AC Rus Media” since 
2019;  Member  of  the  Board  of  Directors  of  Sberbank  PJSC  since  2017;  Member  of  the  Board  of  Directors  of  Super  League 
Holdings  Pte.  LTD  (Singapore)  since  2016;  and  Chairman  of  the  Board  of  Ivi.ru  LLC  since  2012.    Mr.  Boguslavsky  graduated 
from the Moscow Institute of Transport Engineering (MIIT) in 1973, majoring in Computer Science and Applied Mathematics.

Peter Derby (Director) has been a director of VEON Ltd. since June 2020 and we deem Mr. Derby to be an 

independent director. Mr. Derby is serving as the chairman of VEON Ltd.’s nominating and corporate governance committee and 
as a member of the audit and risk committee.  He currently serves as Managing Partner of investment management company, 
Concinnity Advisors LP, which he founded in 2007. From 2018 to 2011, Mr. Derby was a portfolio manager at Diamondback 
Advisors NY, LLC. From 2003 to 2005, Mr. Derby served as the Managing Executive for Operations and Management for the 
U.S. SEC. In 1989, he participated in the founding of DialogBank, the first private Russian bank to receive an international 
banking license, where he served as Chairman of the Board from 1997 to 1998 and as President and CEO from 1991 to 1997. 

38

Mr. Derby also founded the first Russian investment firm in 1991, Troika Dialog. He began his career in banking and finance with 
roles at Chase Manhattan Bank and later at National Westminster Bank. Mr. Derby received a bachelor’s degree in accounting, 
finance and international finance from New York University in 1983. 

Mikhail M. Fridman (Director) has been a director of VEON Ltd. since April 2010 and we deem Mr. Fridman to be a 
non-independent director. Mr. Fridman was a member of the board of directors of OJSC VimpelCom from July 2001 until April 
2010. He currently serves as the Chairman of the Supervisory Board of the Alfa Group Consortium and a member of the board of 
directors of JSC Alfa-Bank since 1994, ABH Holdings S.A. since 2015, LetterOne Holdings SA since 2013, LetterOne Investment 
Holdings SA since 2015 and LetterOne Core Investments SARL since 2019. Mr. Fridman also has served as a member of the 
Supervisory Board of X5 RETAIL GROUP N.V. since 2006.  He is a member of the Public Chamber of the Russian Federation. 
From 1986 until 1988, Mr. Fridman served as an engineer at Elektrostal Metallurgical Works. Mr. Fridman graduated with honors 
from  the  Faculty  of  Non-Ferrous  Metals  of  the  Moscow  Institute  of  Steel  and  Alloys  in  1986  and  in  1989,  together  with  his 
partners, founded the Alfa Group Consortium. 

Amos  Genish  (Director)  has  served  as  a  director  of  VEON  Ltd.  since  June  2020  and  we  deem  Mr.  Genish  to  be  an 
independent director.  Mr. Genish is serving as chairman of VEON Ltd.’s  telecommunications committee and is a member of its 
digital committee. currently serves on the board of representatives of music video and entertainment services distributor VEVO 
LLC, and has served as Chairman of the Board of Israeli on-demand mobility company Gett since 2019. He has also served as 
the Senior Partner and the Head of Digital Retail at Brazilian investment bank BTG Pactual since 2019. Previously, Mr. Genish 
served on the board of directors of the Brazilian publicly listed bank Itau Unibanco Holding S.A. from 2017 to 2019. Mr. Genish 
also served as the Chief Executive Officer of Telecom Italia from 2017 to 2018, the Chief Convergence Officer of French mass 
media conglomerate Vivendi in 2017, and the Chief Executive Officer of the Vivo division of telecommunications group Telefonica 
Brasil  from  2015  to  2016.  Mr.  Genish  co-founded  and  served  as  the  Chief  Executive  Officer  of  Brazilian  telecommunications 
company Global Village Telecom from 1999 to 2015. He started his career at KPMG in Israel. Mr. Genish received a bachelor’s 
degree in accounting and economics from Tel Aviv University in 1986. 

Yaroslav Glazunov (Alternate Director for Alexander Pertsovsky) has been a director of VEON Ltd. since October 2020 
and  we  deem  Mr.  Glazunov  to  be  a  non-independent  director.    Mr.  Glazunov  is  serving  as  chairman  of  VEON  Ltd.’s 
compensation  and  talent  committee  and  is  a  member  of  its  nominating  and  corporate  governance  committee.    Mr.  Glazunov 
joined Korn Ferry in January 2021 as a senior client partner.  Prior to joining Korn Ferry, Mr. Glazunov was a managing partner at 
Spencer Stuart International and a partner at Heidrick & Struggles in Moscow.  Mr. Glazunov has been in the leadership advisory 
global  business  for  20  years  focusing  on  CEO  succession,  efficiency  and  performance  and  has  worked  with  corporate  boards 
and founders of companies in Europe, India and Russia.  He holds a master's degree in management from Plekhanov University. 
He  previously  completed  a  leadership  program  at  INSEAD  in  Fontainebleau,  France,  and  an  executive  program  at  Singularity 
University in Silicon Valley, California.

Andrei  Gusev  (Director)  has  been  a  director  of  VEON  Ltd.  since April  2014  and  we  deem  Mr.  Gusev  to  be  a  non-
independent director. Mr. Gusev is serving as chairman of VEON Ltd.’s finance committee and as a member of its nominating 
and corporate governance committee. Mr. Gusev is a senior partner at LetterOne Technology (UK) LLP, joining in 2014, and was 
a managing director at Altimo from 2013 to 2014. Mr. Gusev was Chief Executive Officer of X5 Retail Group N.V. from 2011 to 
2012 and prior to that, from 2006 to 2010, served as its Director of Business Development and M&A. From 2001 to 2005, Mr. 
Gusev served as Managing Director of the Alfa Group with overall responsibility for investment planning. Prior to that, Mr. Gusev 
worked at Bain & Company and Deloitte Consulting. Mr. Gusev received an M.B.A. from the Wharton School at the University of 
Pennsylvania  in  2000  and  a  diploma  with  honors  from  the  Department  of  Applied  Mathematics  and  Computer  Science  at 
Lomonosov Moscow State University in 1994.

Gunnar Holt (Director) has been a director of VEON Ltd. since June 2015 and we deem Mr. Holt to be an independent 
director.  Mr.  Holt  is  serving  as  a  member  of  VEON  Ltd.’s  audit  and  risk  committee,  finance  committee  and  compensation  and 
talent  committee.  Mr.  Holt  was  a  Senior Advisor  at  Telenor ASA  from  2006  to  2017  and  previously  served  as  Group  Finance 
Director. From 1995 to 1999, he worked at Aker ASA and Aker RGI ASA, serving as Executive Vice President and CFO. From 
1986 to 1995, he held various leadership positions in the Aker Group, including Deputy President of Norwegian Contractors AS, 
Executive  Vice  President  and  Chief  Financial  Officer  of Aker  Oil  and  Gas Technology AS,  President  of Aker  Eiendom AS,  and 
Finance and Accounting Director of Aker Norcem AS. From 1978 to 1986, he served as Executive Officer and Special Advisor in 
the  Norwegian  Ministry  of  Petroleum  and  Energy.  Mr.  Holt  holds  a  Doctor  of  Business  Administration  degree  and  Advanced 
Postgraduate Diploma in Management Consultancy from Henley Management College, Brunel University, in the United Kingdom; 
an  M.B.A.  from  the  University  of  Queensland  in Australia,  and  an  M.B.A.  in  finance  from  the  University  of  Wisconsin.  He  also 
received a Diplomøkonom from The Norwegian School of Management. Mr. Holt has served on a number of corporate boards. 

39

Mr. Robert Jan van de Kraats (Director) RA (Chartered Accountant) has been a director of VEON Ltd. since July 2018 
and we deem Mr. Jan van de Kraats to be an independent director.  On February 16, 2021, Mr. Jan van de Kraats was appointed 
as director liaison for matters related to investor relations.  He serves as the chairman of VEON Ltd.’s audit and risk committee.  
He was appointed as Chairman of the Board of TMF Group, a global provider of payroll, accounting, corporate secretarial and 
alternative  investment  services  earlier  this  year.  He  has  served  as  a  non-executive  director  /  supervisory  board  director  with 
Royal  Schiphol  NV,  an  aviation  company  majority  held  by  the  Dutch  state,  since  2015  and  OCI  NV,  a  fertilizer  and  chemicals 
company,  since  2014.  In  addition,  he  has  served  as  an  advisor  to  the  Dutch  Authority  for  the  Financial  Markets  (AFM)  and 
privately held retailer SuitSupply. He previously served as the Chief Financial Officer and a member of the Executive Board of 
Randstad  Holding  NV  from  2001  to  2018,  serving  as  the  Vice  Chairman  of  the  Executive  Board  from  2006  to  2018,  and  was 
responsible for finance, information technology, shared service centers, merger and investor relations business functions. During 
his tenure at Randstad he also served as COO and was operationally responsible for businesses located in Japan, India, China, 
Nordics, Argentina and Chile. He also previously served as a member of the Commission on Dutch Corporate Governance from 
2013  to  2017,  which  designed  a  new  corporate  governance  code  for  the  Netherlands.  He  was  a  member  of  the  supervisory 
boards of bank and insurance provider SNS Reaal from 2006 to 2013, financial services provider SRLEV NV, and information 
and  telecommunication  services  provider  Ordina  NV  from  2004  to  2012.  In  addition,  he  served  on  the  management  board  of 
Dutch  credit  insurance  company  NCM  Holding  NV  (now  Atradius)  from  1999  to  2001  as  Chief  Financial  Officer  and  Chief 
Operating Officer for a business line. He began his career in 1979 with Deloitte Dijker van Dien (now part of PwC). In 2007, he 
founded  the  Barcode  for  Life  Foundation,  an  organization  that  supports  research  into  DNA  analysis  in  order  to  improve  the 
treatment of cancer. 

Mr. Alexander Pertsovsky (Director) has been a director of VEON Ltd. since July 2018 and we deem Mr. Pertsovsky 
to be a non-independent director. Mr. Pertsovsky is serving as a member of VEON Ltd.’s compensation and talent committee. Mr. 
Pertsovsky joined LetterOne Technology in London on January 1, 2018 from Bank of America Merrill Lynch, where he serves as 
Vice Chairman since November 2020 and served as Managing Partner until October 2020. At Bank of America Merrill Lynch, Mr. 
Pertsovsky  served  as  the  Country  Executive  for  Russia  &  CIS  since  February  2013.  Prior  to  that,  Mr.  Pertsovsky  was  at 
Renaissance Capital, which he joined in 2002 and oversaw the institutional securities business and our activities in Russia. He 
became  Chief  Executive  Officer  of  Renaissance  Capital  in  2007.  Mr.  Pertsovsky  holds  an  MS  degree  in Applied  Mathematics 
from the Moscow Institute of Radio, Engineering and Automation. He also received an M.B.A. from Columbia University in 2002.

Steve  Pusey  (Director)  has  been  a  director  of  VEON  Ltd.  since  June  2020  and  we  deem  Mr.  Pusey  to  be  an 
independent  director.    He  serves  as  a  member  of  VEON  Ltd.’s  telecommunications  committee.  Mr.  Pusey  has  served  on  the 
boards  of  directors  of  publicly  listed  British  multinational  energy  and  services  company  Centrica  PLC  and  publicly  listed  US 
cybersecurity  company  FireEye,  Inc.  since  2015.  In  addition,  Mr.  Pusey  has  also  served  on  the  board  of  directors  of  digital 
product  engineering  services  provider  GlobalLogic,  Inc,  since  2016,  Accedian  Networks,  Inc.,  a  US  developer  of  network 
communication and application monitoring software and hardware, since 2017 and Canadian middleware manufacturer Solace 
Systems, Inc. since 2018. Mr. Pusey has served as a senior adviser to Bridge Growth Partners, an American private equity fund 
that invests in technology and financial services companies, since 2017. Mr. Pusey previously served on the board of directors of 
British global semiconductor and software design company ARM Holdings PLC from 2015 to 2016. In addition, Mr. Pusey served 
as  the  Group  Chief  Technology  Officer  of  Vodafone  Group  PLC  from  2006  to  2015.  Mr.  Pusey  held  positions  of  increasing 
seniority at Nortel Networks from 1982 to 2006, culminating in his appointment as President, Europe of Nortel Networks UK Ltd. 
in 2005. Mr. Pusey began his career as an apprentice at British Telecom Plc in 1977.

Group executive committee

Kaan  Terzioğlu  has  served  as  Group  co-Chief  Executive  Officer  since  March  2020.  Previously,  he  served  as  a  joint 
Chief Operating Officer of VEON Ltd. since November 2019, and as a member of the VEON Ltd. Board of Directors from June 
2019 until November 2019.  Mr. Terzioğlu was Turkcell’s Chief Executive Officer from April 2015 until March 2019.  Mr. Terzioğlu 
is  the  recipient  of  the  global  2019  Outstanding  Contribution  Award  to  Mobile  Industry  from  the  GSMA.  He  has  served  as  a 
member of the Board of Directors of Digicel since July 2019, a Caribbean and Pacific telecommunications operator, since July 
2019, and is currently on the board of the GSMA Foundation focusing on “Mobile Communications for Development” as well as 
several  international  institutions  and  organizations.  He  served  on  the  GMSA  board,  the  leading  international  mobile 
communication  organization,  for  three  consecutive  terms  and  on  the  advisory  board  of  the  World  Economic  Forum  Center  for 
Fourth Industrial Revolution. Mr. Terzioğlu also served as a board member for “Turkey’s Car” Initiative and was the chairman of 
the Mobile Telecommunications Operators Association (m-TOD).  From 2012 to 2015, Mr. Terzioğlu served as a member of the 
board of directors at Akbank, Aksigorta A.Ş., Teknosa Iç ve Diş Ticaret A.Ş. and Carrefoura A.Ş.  From 1999 to 2012, he held 
global managerial roles at Cisco offices located in Brussels, London and San Jose. Mr. Terzioğlu began his professional life at 
Arthur Andersen Turkey, and later undertook several roles on information technologies at Arthur Andersen from 1990 to 1998 in 
the  United  States,  Belgium  and  Turkey.  Mr.  Terzioğlu  graduated  from  the  Department  of  Business Administration  at  Boğaziçi 
University. 

40

Sergi  Herrero  has  served  as  Group  co-Chief  Executive  Officer  since  March  2020.  Previously  he  served  as  Chief 
Operating Officer of VEON Ventures since September 2019. Prior to joining VEON, Mr. Herrero was Facebook’s Global Director 
of Payments and Commerce Partnerships where he has overseen the launch and growth of payment and commerce capabilities 
for Messenger, WhatsApp and Instagram. He also led the deployment of Charitable Giving, the scaling and optimization of the 
Facebook Ads  payments  business  and  drove  the  expansion  of  the  platform's  global  marketplace.  Before  joining  Facebook  in 
2014,  he  held  several  senior  roles  in  technology,  banking  and  consulting.    Mr.  Herrero  was  awarded  an  MSc  in 
Telecommunications  Management  from  Spain's  Ramon  Llull  University,  in  addition  to  an  earlier  undergraduate  degree  in 
Electrical Engineering. 

Serkan  Okandan  has  served  as  VEON’s  Group  Chief  Financial  Officer  since  May  2020.  Prior  to  joining  VEON,  Mr. 
Okandan had been Group CFO at the Etisalat Group since 2012, and prior to joining Etisalat Group, was Group CFO at Turkcell.  
During  his  twenty  years  at  the  Etisalat  Group  and Turkcell,  telecommunications  providers  in  the  Middle  East,  Eastern  Europe, 
Asia  and Africa,  he  held  senior  management  and  board  positions  of  subsidiaries  in  Ukraine  and  Pakistan.    Mr.  Okandan  is  a 
graduate of the Faculty of Economics and Administrative Sciences at Bosphorus University in Istanbul, Turkey.

Scott Dresser has served as VEON’s General Counsel since September 2014. Prior to joining VEON, Mr. Dresser was 
most recently Vice President of Global Strategic Initiatives at BirdLife International, a global conservation organization. Between 
2006  and  2012,  Mr.  Dresser  was  with  Virgin  Media  in  the  UK,  including  serving  as  General  Counsel,  where  he  led  its  legal 
department  and  acted  as  principal  liaison  with  Virgin  Media’s  Board  of  Directors,  as  well  as  being  a  member  of  its  Executive 
Management Team. He also previously held positions in the United States at White Mountains RE Group (which is the operating 
company  of  White  Mountains  Insurance  Group  Ltd),  in  the  role  of  Senior  Vice  President  and Associate  General  Counsel  from 
2005  to  2006.  From  2002  to  2005,  he  served  as  Senior  Advisor  for  Legal  and  Financial  Affairs  for  the  International  Global 
Conservation Fund (an international environmental conservation organization), and prior to that, he was an attorney at Morgan, 
Lewis  &  Bockius  LLP  and  at  Lord  Day  &  Lord,  Barrett  Smith.  Mr.  Dresser  studied  at  Vanderbilt  University  School  of  Law  and 
University of New Hampshire.  He is currently a member of the Bar in New York and Connecticut where he was admitted in 1993. 
Mr. Dresser is on the advisory board of BirdLife International.    

Alex Kazbegi has served as VEON’s Chief Strategy Officer of VEON since February 2019.  He will be stepping down 
from this role effective March 31, 2021.  Prior to joining VEON, Mr. Kazbegi was Head of Research and was an equity analyst for 
Renaissance Capital since 2002.  From 1995 to 2002, Mr. Kazbegi was an equity research analyst for Salomon Brothers (now 
Citi). Mr. Kazbegi received an MA from Tbilisi State University, Physics Faculty in 1984, and a PhD in Physics from Tbilisi State 
University  (in  a  joint  degree  program  with  Moscow  State  University)  in  1993.  Mr.  Kazbegi  obtained  an  MBA  from  Tulane 
University in 1995. 

Joop Brakenhoff Joop Brakenhoff has served as VEON’s Group Chief Internal Audit & Compliance Officer since July 
2020.    Mr.  Brakenhoff  joined  VEON  in  January  2019  and,  until  assuming  his  current  role,  served  as  VEON’s  Head  of  Internal 
Audit.  Prior to joining VEON,  he was head of Global Audit at Heineken International from 2010 to 2018.  From 2002 to 2010, Mr. 
Brakenhoff  held  senior  audit  roles  at  Royal Ahold,  prior  to  which  he  was  Chief  Financial  Officer  of  Burg  Industries  B.V.    Mr. 
Brakenhoff started his career at KPMG in 1985 where he worked for nine years in a variety of audit roles.  Mr. Brakenhoff is a 
graduate of NIVRA Amsterdam and is a certified public accountant (CPA). 

41

Compensation

In order to ensure alignment with the long-term interests of the company’s shareholders, the compensation and talent 
committee  periodically  evaluates  the  compensation  of  the  company’s  board  of  directors  directors  taking  into  account  the 
competitive  landscape,  the  compensation  of  directors  at  other  comparable  companies  and  recommendations  regarding  best 
practices.  Following  review  by  the  nominating  and  corporate  governance  committee,  both  the  compensation  and  talent 
committee  and  the  nominating  and  corporate  governance  committee  make  recommendations  to  the  board  of  directors  on 
compensation of the board of directors. 

We  incurred  remuneration  expense  in  respect  of  our  directors  and  senior  managers  in  an  aggregate  amount  of 
approximately  US$40  million  for  services  provided  during  2020.  For  more  information  regarding  our  director  and  senior 
management compensation, see Note 21 — Related Parties to our Audited Consolidated Financial Statements.

To  stimulate  and  reward  leadership  efforts  that  result  in  sustainable  success,  value  growth  cash-based  multi-year 
incentive plan (“Incentive  Plans”) were designed for members of our recognized leadership community. The participants in the 
Incentive Plans may receive cash payouts after the end of each relevant award performance period. 

Vesting is based on the attainment of certain Key Performance Indicators (“KPIs”), such as absolute share price, total return per 
share or value growth of certain VEON businesses.  Options may be exercised by the participant at any time during  a  defined 
exercise period, subject to the Company’s insider trading policy. 

The Company’s Short Term Incentive (“STI”) Scheme provides cash pay-outs to participating employees based on the 
achievement of established KPIs over the period of one calendar year. KPIs are set every year at the beginning of the year and 
evaluated in the first quarter of the next year. The KPIs are partially based on the financial and operational results (such as total 
operating  revenue,  EBITDA  and  equity  free  cash  flow)  of  the  Company,  or  the  affiliated  entity  employing  the  employee,  and 
partially based on individual targets that are agreed upon with the participant at the start of the performance period based on his 
or her specific role and activities. The weight of each KPI is decided on an individual basis. 

Pay-out of the STI award is scheduled in March of the year following the assessment year and is subject to continued 
active employment during the year of assessment (except in limited “good leaver” circumstances in which case there is a pro-
rata reduction) and is also subject to a pro-rata reduction if the participant commenced employment after the start of the year of 
assessment. Pay-out of the STI award is dependent upon final approval by the compensation and talent committee.

Pursuant  to  our  bye-laws,  we  indemnify  and  hold  harmless  our  directors  and  senior  managers  from  and  against  all 
actions, costs, charges, liabilities, losses, damages and expenses in connection with any act done, concurred in or omitted in the 
execution of our business, or their duty, or supposed duty, or in their respective offices or trusts, to the extent authorized by law. 
We  may  also  advance  moneys  to  our  directors  and  officers  for  costs,  charges  and  expenses  incurred  by  any  of  them  in 
defending any civil or criminal proceedings. The foregoing indemnity will not apply (and any funds advanced will be required to 
be repaid) with respect to a director or officer if any allegation of fraud or dishonesty is proved against such director or officer. We 
have also entered into separate indemnification agreements with our directors and senior managers pursuant to which we have 
agreed to indemnify each of them within substantially the same scope as provided in the bye-laws. 

We  have obtained insurance on behalf of  our  senior  managers and directors for liability arising out of their  actions  in 

their capacity as a senior manager or director. 

We do not have any pension, retirement or similar benefit plans available to our directors or senior managers.

42

Board Practices

VEON Ltd. is governed by our board of directors, currently consisting of twelve directors. Our bye-laws provide that our 
board of directors consists of at least seven and no more than thirteen directors, as determined by the board of directors and 
subject to approval by a majority of the shareholders voting in person or by proxy at a general meeting. We have not entered into 
any service contracts with any of our current directors providing for benefits upon termination of service.  

The board of directors has delegated to the co-CEOs the power to manage the business and affairs of the company, 
subject  to  certain  material  business  decisions  reserved  for  the  board  of  directors  or  shareholders,  within  the  framework  of  our 
new governance model announced in the third quarter of 2020.  The co-CEOs and their leadership team manage and operate 
the  company  on  a  day-to-day  basis.    The  board  of  directors  may  appoint  such  other  senior  executives  as  the  board  may 
determine.

Under  the  new  governance  model,  our  board  of  directors  and  the  co-CEOs  have  delegated  to  each  VEON  operating 
company considerable authority to operate their businesses.  A Group Authority Matrix and updated policy framework has also 
been  implemented,  establishing  clear  decision  making  parameters  and  other  requirements.    Specifically,  each  operating 
company is accountable for operating its own business subject to oversight by their respective operating company boards and 
our board of directors; and they are also obligated to operate in accordance with Group policy and controls framework.  The new 
governance model forms the cornerstone of governance and delegation of authority across the Group.  

The board of directors has established a number of committees to support it in fulfilling its oversight and governance 
duties. These charters set out the purpose, membership, meeting requirement, authorities and responsibilities of the committees.

On  an  annual  basis,  our  group  executive  committee,  audit  and  risk  committee  and  board  of  directors  define  our  risk 
profile  for  the  categories  of  risk  we  encounter  in  operating  our  business,  which  are  then  integrated  into  our  business  through 
global policies and procedures.

In  the  composition  of  our  board  of  directors  and  senior  executives,  we  are  committed  to  diversity  of  nationality,  age, 
education, gender and professional background.  In March 2021, we implemented a diversity and inclusion policy to formalize 
our commitment to diversity and inclusion at the board of directors’ level and throughout the organization.

Committees of the Board of Directors

The committees of our board of directors consist of: an audit and risk committee, a compensation and talent committee, 
a  finance  committee,  a  nominating  and  corporate  governance  committee,  a  telecommunications  committee  and  a  digital 
committee.  Our board of directors and committees meet at least quarterly. In 2020, our board of directors met 11 times, the audit 
and risk committee met 8 times, the compensation and talent committee met 11 times, the finance committee met 14 times, the 
nominating and corporate governance committee met 6 times, and telecommunications committee met 7 times, and the digital 
committee met 3 times. Each director who served on our board of directors during 2020 attended at least 94% of the meetings of 
the board of directors and committees on which he or she served that were held during his or her tenure on our board. 

Audit and risk committee 

The  charter  of  our  audit  and  risk  committee  provides  that  each  committee  member  is  required  to  satisfy  the 
requirements of Rule 10A-3 under the Exchange Act and the rules and regulations thereunder as in effect from time to time. The 
audit  and  risk  committee  is  primarily  responsible  for  the  following:  the  integrity  of  the  company’s  financial  statements  and  its 
financial  reporting  to  any  governmental  or  regulatory  body  and  the  public;  the  company’s  audit  process;  the  qualifications, 
engagement, compensation, independence and performance of the company’s independent auditors, their conduct of the annual 
audit  of  the  company’s  financial  statements  and  their  engagement  to  provide  any  other  services;  VEON  Ltd.’s  process  for 
monitoring compliance with legal and regulatory requirements as well as the company’s corporate compliance codes and related 
guidelines, including the Code of Conduct; the company’s systems of enterprise risk management and internal controls; and the 
company’s compliance program. The current members of our audit and risk committee, Robert Jan van de Kraats (chairman), 
Gunnar Holt and Peter Derby, are expected to serve until our next annual general meeting. 

Compensation and talent committee 

Our compensation and talent committee is responsible for assisting and advising the board of directors in discharging 
its responsibilities with respect to overseeing the performance, selection and compensation of the CEO and all other individuals 
whose  appointment,  reappointment  or  early  termination  of  employment  require  Board  approval  under  the  company’s  bye-laws 
(including the members of the company’s group executive committee and the chief executive officers of  the company’s operating 
subsidiaries).    Our  compensation  and  talent  committee  also  has  overall  responsibility  for  approving  and  evaluating  company’s 
director, executive and employee compensation and benefit plans. The committee advises the board of directors in relation to the 
company’s  overall  culture  and  values  program,  including  by  periodically  assessing  the  substance  and  effectiveness  of  the 
program  and  considering  overall  employee  feedback  and  other  measurements  of  effectiveness.  In  addition,  the  committee 
periodically evaluates the compensation of directors of the company (including the annual board retainer fee, any equity-related 
compensation or incentive plan participation and fees for service on the committees of the board of directors), taking into account 
the competitive landscape, the compensation of directors at other comparable companies and recommendations regarding best 

43

practices. The committee formulates recommendations to the board of directors regarding such director compensation and any 
adjustments in compensation and/or incentives that the committee considers appropriate. Such recommendations are reviewed 
by  the  nominating  and  corporate  governance  committee  of  the  board  of  directors,  and  both  committees  jointly  deliver  to  the 
board  such  recommendations  for  consideration  and  approval.  Finally,  the  compensation  and  talent  committee  evaluates  the 
company’s programs, priorities, and progress for recruiting, staffing, developing talent, motivating and retaining competent CEO 
and  senior  executives  (and  potential  successors)  for  present  and  future  company  needs,  including  succession  planning.    The 
current  members  of  our  compensation  and  talent  committee,  Yaroslav  Glazunov  (chairman),  Gunnar  Holt  and  Hans  Holger 
Albrecht, are expected to serve until our next annual general meeting.

Finance committee 

Our finance committee is responsible for assisting and advising the board of directors in discharging its responsibilities 
with respect to its oversight of the business plan of the company, management of the capital structure of the company and its 
subsidiaries and the execution of certain material transactions. In doing so, the committee reviews with company management 
and gives advice or makes recommendations to the board of directors in relation to mergers and acquisitions transactions and 
divestitures, financing transactions, the incurrence of indebtedness, finance policies, dividends, material litigation, arbitration or 
other  proceedings,  and  certain  material  and  outside  of  the  ordinary  course  business  contracts.  The  current  members  of  our 
finance  committee,  Andrei  Gusev  (chairman),  Gennady  Gazin  and  Gunnar  Holt,  are  expected  to  serve  until  our  next  annual 
general meeting. 

Nominating and corporate governance committee 

Our  nominating  and  corporate  governance  committee  is  responsible  for  identifying  and  recommending  to  the  board 
individuals  qualified  to  serve  as  members  of  the  board  of  directors,  making  recommendations  to  the  board  of  directors 
concerning committee structure, membership and operations, developing, advising the board of directors on the adoption of and 
periodically  reviewing  a  set  of  corporate  governance  practices  applicable  to  the  conduct  of  the  company’s  business,  and 
periodically  conducting  an  evaluation  of  the  board  of  directors  and  its  committees.  In  addition,  the  committee  reviews 
recommendations  of  the  compensation  and  talent  committee  of  the  board  of  directors  regarding  adjustments  in  director 
compensation,  and  both  committees  jointly  deliver  to  the  board  of  directors  such  recommendations  for  consideration  and 
approval.  The  current  members  of  our  nominating  and  corporate  governance  committee,  Peter  Derby  (chairman),  Gennady 
Gazin and Yaroslav Glazunov, are expected to serve until our next annual general meeting.

Telecommunications committee

Our  telecommunications  committee  is  responsible  for  oversight  of  the  operations  and  business  strategy  of  the 
company’s telecommunications business, including the operational and technological capabilities associated with that strategy.  
The  current  members  of  our  telecommunications  committee,  Amos  Genish  (chairman),  Andrei  Gusev  and  Steve  Pusey,  are 
expected to serve until our next annual general meeting.

Digital committee 

Our digital committee is responsible for advising on, and overseeing, the development of the company’s digital strategy 
and digital initiatives.  The current members of our digital committee, Hans Holger Albrecht (chairman), Osama Bedier, Leonid 
Boguslavsky and Amos Genish, are expected to serve until our next annual general meeting.

44

Employees

The following chart sets forth the number of our employees as of December 31, 2020, 2019 and 2018, respectively: 

As of December 31,

Russia

Pakistan

Algeria

Bangladesh

Ukraine

Uzbekistan
Kazakhstan(1)
HQ

Others

Total

2020

26,453

4,539

2,747

1,137

3,628

1,604

2,521

187

824

2019

28,003

4,325

2,781

1,200

3,527

1,594

2,142

286

2,634

43,639

46,492

2018

28,570 

4,424

2,866 

1,120 

2,754

1,563 

—

507 

4,328 

46,132

(1)  The number of employees in Kazakhstan for the year ended December 31, 2018 was included in “Others.”  

Subsequently, Kazakhstan became a reportable segment and so for the years ended December 31, 2020 and 2019, the total 
number of employees in Kazakhstan is reported separately..

From time to time, we also employ external staff, who fulfill a position at the company for a temporary period. We do not 

consider these employees to constitute a significant percentage of our employee totals and have not included them above. 

The following chart sets forth the number of our employees as of December 31, 2020, according to geographic location 

and our estimates of main categories of activities:

Category of activity(1)
Executive and senior management

Engineering, construction and 
information technology

Sales, marketing and other 
commercial operations

Finance, administration and legal

Customer service

Procurement and logistics

Other support functions

Russia

Pakistan 

Algeria Bangladesh Ukraine Uzbekistan Kazakhstan

As of December 31, 2020

20   

21   

12   

8   

15   

2,393   

785   

764   

352   

1,354   

  15,131   

2,734   

1,182   

1,961   

5,253   

660   

1,035   

514   

253   

70   

162   

356   

335   

67   

31   

552   

124   

35   

25   

41   

902   

430   

760   

65   

102   

21 

420 

383 

132 

367 

32 

249 

12

1,161 

935

218

83

46

66

Total

  26,453   

4,539   

2,747   

1,137   

3,628   

1,604   

2,521 

(1)  A breakdown of employees by category of activity is not available for our HQ segment and our “Others” category.

A joint works council has been established at our Amsterdam headquarters, and it has consultation or approval rights in 
relation  to  a  limited  number  of  decisions  affecting  our  employees  working  at  this  location.  For  VEON  Wholesale  Services  BV 
(“VWS”), a separate works council was established and addresses management decisions that may affect the VWS workforce. 
The  works  councils  may  utilize  legal  remedies  that  can  impact  the  timing  of  implementation  of  decisions  at  our  Amsterdam 
headquarters or within VWS that are subject to consultation or approval by the works councils.

Our  employees  are  represented  by  unions  or  operate  collective  bargaining  arrangements  in Algeria,  Kyrgyzstan  and 
Ukraine. We consider relations with our employees to be generally good. In February 2016, BDCL experienced labor disruptions 
in connection with the implementation of our announced performance transformation program. Such disruptions have not had a 
significant impact on our operations. An application for the registration of a union within BDCL was rejected by the government 
authorities and subsequent litigation is ongoing. A consequent notification was made by UNI Global Union to the Dutch NCP and 
the NCP has issued a final statement. For a discussion of risks related to labor matters, see — Other Risks — “Our business 
may be adversely impacted by work stoppages and other labor matters.” 

45

 
 
 
 
 
 
 
Share Ownership

To  our  knowledge,  as  of  March  1,  2021  other  than  Mikhail  Fridman,  none  of  our  directors  or  senior  managers 
beneficially owned more than 1.0% of any class of our capital stock. To our knowledge, Mr. Fridman has an indirect economic 
benefit in our shares held for the account of L1T VIP Holdings S.à r.l. (“L1T VIP Holdings”) and, thus, may be considered under 
the  definition  of  “beneficial  owner”  for  purposes  of  this  Annual  Report  only,  as  a  beneficial  owner  of  the  shares  held  for  the 
account of L1T VIP Holdings. See — Major Shareholders And Related Party Transactions — Major Shareholders.

To our knowledge, as of March 1, 2021, Kaan Terzioğlu owned 600,000 of our ADSs.

To  our  knowledge,  as  of  March  1,  2021,  none  of  the  other  board  of  director  members  held  any  Common  Shares  or 
ADSs.  To  our  knowledge,  as  of  March  1,  2021,  none  of  our  directors  or  senior  managers  held  any  options  to  acquire  the 
company’s common shares. 

For more information regarding share ownership, including a description of applicable stock-based plans and options, 

see Note 21 — Related Parties to our Audited Consolidated Financial Statements.

46

MAJOR SHAREHOLDERS AND RELATED PARTY TRANSACTIONS

Major Shareholders

The following table sets forth information with respect to the beneficial ownership of VEON Ltd. as of March 1, 2021, by 
each person who is known by us to beneficially own 5.0% or more of our issued and outstanding shares. As of March 1, 2021, 
we  had  1,756,731,135  issued  and  outstanding  common  shares.  None  of  our  shareholders  has  different  voting  rights.  For  a 
discussion of certain risks associated with our major shareholders, see — Risk Factors —  Other Risks — “A disposition by our 
largest shareholder of its stake in VEON Ltd. or a change in control of VEON Ltd. could harm our business.” 

Name
L1T VIP Holdings S.à r.l.(1)
Stichting Administratiekantoor Mobile Telecommunications 
Investor (2)

Number of VEON Ltd. 
Common Shares
840,625,001

Percent of VEON Ltd. 
Issued and Outstanding 
Shares
47.85

145,947,562

8.31

(1) 

(2) 

As reported on Schedule 13D, Amendment No. 20, filed on September 13, 2019, by L1T VIP Holdings S.à r.l. (“L1T”), 
Letterone Core Investments S.à r.l. (“LCIS”) and Letterone Investment Holdings S.A. (“LetterOne”) with the SEC, L1T is 
the direct beneficial owner of 840,625,001 common shares. LCIS is the sole shareholder of L1T, and LetterOne is the 
sole shareholder of LCIS and, in such capacity, each of L1T, LCIS and LetterOne may be deemed to be the beneficial 
owner of the 840,625,001 common shares held for the account of L1T. Each of L1T, LCIS and LetterOne is a 
Luxembourg company, with its principal business to function as a holding company.

As reported on Schedule 13G, filed on April 1, 2016, by Stichting with the SEC, Stichting is the direct beneficial owner of 
145,947,562 of VEON Ltd.’s common shares. LetterOne is the holder of the depositary receipts issued by Stichting and 
is therefore entitled to the economic benefits (dividend payments, other distributions and sale proceeds) of such 
depositary receipts and, indirectly, of the 145,947,562 common shares represented by the depositary receipts. 
According to the conditions of administration entered into between Stichting and LetterOne (“Conditions of 
Administration”) in connection with the transfer of 145,947,562 ADSs from LetterOne to Stichting on March 29, 2016, 
Stichting has the power to vote and direct the voting of, and the power to dispose and direct the disposition of, the 
ADSs, in its sole discretion, in accordance with the Conditions of Administration and Stichting’s articles of association. 
Stichting is a foundation incorporated under the laws of the Netherlands. The common shares held by Stichting 
represent approximately 8.31% of VEON Ltd.’s issued and outstanding shares.

Based on a review of our register of members maintained in Bermuda, as of March 1, 2021, a total of 1,228,276,403 
common shares representing approximately 69.92% of VEON Ltd.’s issued and outstanding shares were held of record by BNY 
(Nominees) Limited in the United Kingdom as custodian of The Bank of New York Mellon for the purposes of our ADS program 
and a total of 515,226,176 common shares representing approximately 29.33% of VEON Ltd.’s issued and outstanding shares 
were  held  of  record  by  Nederlands  Centraal  Instituut  Voor  Giraal  Effectenverkeer  B.V.  and  where  ING  Bank  N.V.  is  acting  as 
custodian  of The  Bank  of  New York  Mellon,  for  the  purposes  of  our ADS  program,  and  a  total  of  13,228,556  common  shares 
representing approximately 0.75% of VEON Ltd.’s issued and outstanding shares were held of record by Nederlands Centraal 
Instituut Voor Giraal Effectenverkeer B.V., for the purposes of our common shares listed and tradable on Euronext Amsterdam. 
As  of  March  1,  2021,  21  record  holders  of  VEON  Ltd.’s  ADRs,  holding  an  aggregate  of  758,028,329  common  shares 
(representing  approximately  43.15%  of  VEON  Ltd.’s  issued  and  outstanding  shares),  were  listed  as  having  addresses  in  the 
United States.

Changes in Percentage Ownership by Major Shareholders

As  reported  on  Schedule  13D, Amendment  43,  filed  on  November  25,  2019  by  Telenor  East  Holding  II AS,  Telenor 
Mobile Holding AS and Telenor ASA with the SEC, on November 22, 2019, Telenor East Holding sold 156,703,840 of VEON Ltd. 
common stock, in the form of ADSs, at a price per share of US$2.31, representing all of Telenor East Holding’s remaining interest 
in  VEON  Ltd.  The  sale  resulted  in  net  proceeds  to  Telenor  East  Holding  of  approximately  US$362  million.  This  transaction 
represented  approximately  8.9%  of  the  total  outstanding  common  stock  and  Telenor  East  Holding’s  final  exit  from  VEON  Ltd. 
Please also see Schedule 13D, Amendment 38, filed on April 12, 2017 by Telenor East Holding II AS, Telenor Mobile Holding AS 
and Telenor ASA with the SEC, reporting a sale by Telenor East Holding II AS of 70,000,000 of ADSs in VEON Ltd. pursuant to 
an underwritten offering and Schedule 13D, Amendment 40, filed on September 25, 2017 by Telenor East Holding II AS, Telenor 
Mobile Holding AS, and Telenor ASA with the SEC, reporting a sale by Telenor East Holding II AS of 90,000,000 ADSs in VEON 
Ltd. pursuant to an underwritten offering.

47

Related Party Transactions

In addition to the transactions described below, VEON Ltd. has also entered into transactions with related parties as part of its 
day to day operations. These mainly relate to ordinary course telecommunications operations, such as interconnection, roaming, 
retail and management advisory services, as well as development of new products and services. Their terms vary according to 
the nature of the services provided thereunder. VEON Ltd. and certain of its subsidiaries may, from time to time, also enter into 
general services agreements relating to the conduct of business and financing transactions within the VEON group.

For  more  information  on  our  related  party  transactions,  see  Note  21  —  Related  Parties  to  our Audited  Consolidated 

Financial Statements. 

Registration Rights Agreements 

The Registration Rights Agreement, as amended, between VEON Ltd., Telenor East and certain of its affiliates, Altimo 
Holdings  &  Investments  Ltd.  and Altimo  Coöperatief  U.A.  requires  us  to  use  our  best  efforts  to  effect  a  registration  under  the 
Securities Act, if requested by one of the shareholders party to the Registration Rights Agreement, of our securities held by such 
party in order to facilitate the sale and distribution of such securities. Pursuant to the Registration Rights Agreement, we have 
filed a registration statement on Form F-3 with the SEC using a “shelf” registration process. 

Separately, in connection with the issuance of US$1,000,000,000 in aggregate principal amount of 0.25% exchangeable 
bonds due 2019, exchangeable for VEON Ltd. ADSs (the “Telenor Exchangeable Bond”) by Telenor East Holding II AS, VEON 
Ltd. entered into a registration rights agreement, dated September 21, 2016 (the “New Registration Rights Agreement”) for the 
benefit  of  holders  of  the  Telenor  Exchangeable  Bonds.  Following  Telenor’s  divestment  of  its  interest  in  VEON  Ltd.  ADSs  in 
November 2019, the New Registration Rights Agreement is no longer effective.  

Major Shareholders and their Affiliates 

LetterOne 

From December 2010 until March 2018, VEON Ltd. was a party to a General Services Agreement with L1HS Corporate 
Advisor  Limited,  part  of  the  LetterOne  Group,  under  which  L1HS  Corporate  Advisor  Limited  rendered  to  VEON  Ltd.  and  its 
affiliates  services  related  to  telecommunications  operations,  including  management  advisory  services,  training,  technical 
assistance and network maintenance, industry information research and consulting, implementation support for special projects 
and  other  services  as  mutually  agreed  by  L1HS  Corporate Advisor  Limited  and  VEON  Ltd.  VEON  Ltd.  paid  L1HS  Corporate 
Advisor Limited annually US$1.5 million for the services.  The agreement was terminated on December 12, 2017 with effect from 
March 12, 2018. 

From  August  2013  until  March  2018,  VEON  was  also  party  to  a  Consultancy  Deed  with  L1HS  Corporate  Advisor 
Limited, under which L1HS Corporate Advisor Limited provided additional consultancy services to VEON Ltd. for which VEON 
Ltd. paid US$3.5 million annually. The agreement was terminated on December 12, 2017 with effect from March 12, 2018.

Board of Directors

Compensation paid to the board of directors is disclosed in — Directors and Senior Management — Compensation.

Mikhail  M.  Fridman,  a  director  of  VEON  Ltd.,  serves  as  Chairman  of  the  Supervisory  Board  of  the  Alfa  Group 
Consortium  and  has  been  a  member  of  the  board  of  directors  of  JSC Alfa-Bank  since  1994.    In  March  2020,  VEON  Holdings 
B.V., an indirect wholly-owned subsidiary of VEON Ltd., increased the size of its existing facility with JSC Alfa-Bank to RUB 30 
billion (US$406 million as of December 31, 2020). The outstanding amount under the facility, originally entered into in 2017, was 
RUB 17.5 billion (US$304 million) as of December 31, 2017, RUB 17.5 billion (US$252 million) as of December 31, 2018, and 
RUB 17.5 billion (US$283 million) as of December 31, 2019.

In June, September and November 2020, VEON Holdings B.V. issued senior unsecured notes of RUB20 billion (US$288 million), 
RUB10 billion (US$135 million) and US$1.25 billion, respectively, under the MTN Program, maturing in June 2025, September 
2025 and November 2027, respectively.  The Alfa Group participated in the aforementioned June issuance as an underwriter.

In  December  2020,  VEON’s  operating  company  in  Ukraine,  Kyivstar,  signed  a  bilateral  unsecured  3-year  term  loan 
agreement  with  Joint  Stock  Company  Alfa-Bank  for  UAH  1,700  million,  of  which  UAH  1,480  million  (US$52  million)  was 
outstanding at December 31, 2020.

The Alfa Group also participates in our US$1.25 billion RCF, which we entered into on March 9, 2021, following their 

purchase of a 10% interest in the syndication.

In January 2021, the company entered into an agreement with Alexander Pertsovsky, former member of the board of 
directors, under which he will provide certain consulting and advisory services relating to strategic transactions in Russia. Under 
the agreement, Mr. Pertsovsky receives a fixed annual fee of €240,000 in compensation for his services, as well as the potential 
for  a  discretionary  success  fee  (subject  to  approval  by  our  board  of  directors).  The  initial  term  of  the  agreement  is  one  year, 
though either party may terminate the agreement for any reason upon 30 days written notice.

Except as specified above, during 2020 and through the date of this Annual Report, none of our board of directors have 

been involved in any material related party transactions with us.

48

HOW WE MANAGE RISKS

VEON has adopted the relevant criteria from the Committee of Sponsoring Organizations of the Treadway Commission (COSO) 
and Enterprise Risk Management (ERM) – Integrated Framework (2017) as the foundation of our enterprise risk management 
approach. Through VEON’s ERM framework, our management aims to identify, assess, adequately manage, monitor and report 
risks  that  could  jeopardize  the  achievement  of  our  strategic  objectives.  A  unified  and  consistent  ERM  framework  is  used 
throughout the organization.

Strengthening our risk culture: three lines of defense

The ‘three lines of defense’ approach provides a simple and effective way to enhance communications around risk management, 
governance and control by clarifying roles and responsibilities. VEON has adopted this model to provide reasonable assurance 
that risks to achieving important objectives are identified and mitigated. 

First line of defense

VEON recognizes that the first line of defense consists of the business  who own and are responsible and accountable 
for  directly  assessing,  controlling  and  mitigating  risks.  Since  2016,  targeted  communication  campaigns  have  been  launched 
globally to foster risk and control awareness across the Group.

To  embed  a  culture  aligned  to  our  risk  appetite  and  individual  responsibilities  in  relation  to  risk  management  we 
embarked on a programme in 2019 which continued throughout 2020. This programme involved, an awareness campaign using 
sport, games and the idea of teamwork to highlight the importance of every individual’s contribution to effective risk management 
and a strong control environment was launched to reinforce accountability and ownership for risk management and the internal 
control environment.

Second line of defense

The  second  line  of  defense  monitors  and  facilitates  the  implementation  of  effective  risk  management  practices  and 
internal controls by the first line. The second line comprises Group Internal Control, Group Enterprise Risk Management, Group 
Ethics and Compliance and  Group Legal, amongst other Group functions. The second line supports the business functions in 
identifying what could go wrong and provides the methods, tools and guidance necessary to support the first line in managing 
their risks.

Third line of defense

The  Group  Internal  Audit  team  comprises  the  third  line  of  defense  and  is  responsible  for  providing  independent 
assurance  to  senior  management  on  the  effectiveness  of  the  first  and  second  lines  of  defense. The  function  conducts  ad  hoc 
financial, information technology, strategic and operational audits and special investigations. Throughout, Internal Audit conducts 
its activities in a manner based on a continuous evaluation of perceived business risks.

To  ensure  strong  oversight  of  and  alignment  between  the  three  lines  of  defense,  we  established  our  each  OpCo  has 
established a Business Risk Committee and an OpCo Board. Each OpCos BRC,  is chaired by the Group Chief Financial Officer, 
his nominee or the Group Chief Internal Audit & Compliance Officer.  The purpose of each OpCo Business Risk Committee is to 
consider  the  overall  risk  profile  of  the  Group  and  ensure  risk  informed  decision  making.  The  BRC  oversees  and  aligns  the 
activities  of  the  Group’s  various  risk  and  assurance  functions  to  coordinate  and  manage  actions  efficiently  across  the  Group. 
Each of the OpCos are managed by way of OpCo Boards which comprises of the respective OpCo CEO and management team 
with  the  oversight  by  their  respective  Board  of  Directors.  Each  OpCo’s  overall  risk  profile  is  presented  to  its  OpCo  Board 
regularly and at least once per quarter (accompanied by recommendations of its OpCo Business Risk Committee). This program 
is continuously monitored by OpCo management and the OpCo Boards, and tested by both OpCo and Group Internal Audit, with 
the  Group  Audit  &  Risk  Committee  providing  ultimate  oversight,  with  each  OpCo  Business  Risk  Committee  providing  active 
monitoring and engagement with the OpCos on all enterprise risks, control, compliance and assurance matters.

49

Defining our risk appetite

Defining  our  risk  appetite  in  line  with  the  COSO  Framework,  the  VEON  Enterprise  Risk  Management  (ERM)  Framework 
categorises risk into four risk categories: Strategic, Operational, Financial and Compliance.

Our risk appetite is defined for each of the four risk categories by considering our business objectives, as well as potential threats 
to achieving these. On an annual basis, the VEON appetite statements for each category of risk are revised and approved by the 
VEON  Executive  Committee  and  presented  to  the Audit  and  Risk  Committee.  These  statements,  are  then  integrated  into  the 
business through our global policies and procedures and our risk management cycle.

Risk Appetite Table

Risk Management in Execution

Effective risk management requires a continuous and iterative process and involves the following five steps:

1. Clarify objectives and identify risks:

VEON’s strategy is developed with a comprehensive understanding of the strategic and inherent risks involved in doing 
business. We consider the potential effects of the business context on risk profile as well as possible ways of mitigating the risks 
we are exposed to.

2. Assess and prioritize risks:

Risks  identified  as  relevant  for  VEON  are  assessed  in  order  to  understand  the  severity  of  each  risk  to  the  ability  to 
execute on VEON’s strategy and business objectives. The severity of risk is assessed at multiple levels of the business as it may 
not be the same across divisions, functions, and operating companies.

3. Respond to risk:

The  assessed  severity  of  the  risk  is  utilized  by  management  to  determine  an  appropriate  risk  response  (Take,  Treat, 

Transfer or Terminate) which may include implementing mitigations, taking into account the risk appetite.

50

4. Monitor, report and escalate:

VEON’s  Group  Co-CEOs  and  Senior  Management  review  significant  risks  assessed  and  prioritized  based  on  the 
Group’s ERM framework. The Top Group risks are also reported to VEON’s Board of Directors, in particular with the Audit and 
Risk Committee (at least on a quarterly basis), to evaluate material Group risks.

VEON’s  management  also  monitors  and  evaluates  risk  through  our  Group  Risk  Ethics  and  Assurance  Committee 
(REAC),  which  is  chaired  by  the  Group  Chief  Financial  Officer  and  includes  the  Group  Directors  of  each  of  the  assurance 
departments. Group REAC oversees and aligns the activities of the Group’s various risk and assurance functions to coordinate 
and manage actions efficiently across the Group, which include:

a. Advising  senior  management  on  matters  concerning  the  risk,  ethics  and  compliance,  including  an  overall  risk  and 

assurance vision and strategy.

b. Overseeing activities to develop and maintain a fit-for-purpose risk and assurance programme.

c. Engaging with VEON’s senior management on important developments in the context of risk, ethics and compliance..

The  Board  of  Directors  maintains  a  number  of  committees,  including  the Audit  and  Risk  Committee,  which  expressly 

refers to its role in overseeing VEON’s ERM framework in its charter.

5. Assure:

On a quarterly basis, through the management certification process, local CEO and CFOs certify significant risks have 
been considered and appropriate measures have been taken to manage the identified risks in accordance with the Group’s ERM 
policies and procedures.

Control framework 

VEON is publicly traded on a U.S. stock exchange and registered with the U.S. Securities and Exchange Commission. Thus, it 
must  comply  with  Sarbanes  Oxley  Act  (“SOX”).  SOX  Section  404  requires  that  management  perform  an  assessment  of  the 
Internal Controls over Financial Reporting (“ICFR”) to confirm both the design and operational effectiveness of the controls. 

Our  internal  control  system  is  designed  to  provide  reasonable  assurance  regarding  the  reliability  of  financial  reporting  and  the 
preparation  and  fair  presentation  of  VEON  Ltd.’s  published  consolidated  financial  statements  under  generally  accepted 
accounting principles. The VEON ICFR Framework incorporates risk assessment as part of our scoping process, an assessment 
of  the  design  effectiveness  of  the  required  controls,  testing  of  the  operating  effectiveness  of  the  key  control  activities  and 
monitoring of our financial reporting at entity-wide and functional levels. VEON has established uniform governance, policies and 
control  standards  that  apply  to  controlled  subsidiaries.  Our  ICFR  testing  results  are  reported  into  our  Board  of  Management, 
Group Risk, Ethics, and Assurance Committee (REAC), local Business & Risk Committee (BRC), local VEON Boards and our 
Audit  and  Risk  Committee  at  least  on  a  quarterly  basis  as  part  of  our  assurance  model.  For  a  more  detailed  overview  of  the 
Governance changes in 2020 see Director's Report section in these Financial statements.

Local management is responsible for business operations of our subsidiaries, including risk mitigation and compliance 
with laws, regulations and internal requirements. We have created uniform governance and control standards for all our levels of 
operations. The standards apply to all our subsidiaries with the same expectation: that they conduct business in accordance with 
ethical  principles,  internal  policies  and  procedures,  and  applicable  laws  and  regulations. The  standards  are  intended  to  define 
and guide conduct with respect to relevant compliance and ethics principles and rules, and to create awareness about when and 
where  to  ask  for  advice  or  report  a  compliance  or  ethics  concern,  which  includes  the  use  of  VEON’s  SpeakUp  channels. The 
principles  apply  to  all  VEON  employees  in  all  operating  businesses  and  headquarters.  Employees  receive  annual  Code  of 
Conduct  ("Code")  training,  which  includes  certification  to  comply  with  the  Code.  Our  group-wide  Code  applies  to  all  VEON 
employees,  officers  and  directors,  including  its  principal  executive  officer,  principal  financial  officer,  and  principal  accounting 
officer or controller. Our Code is available on our website at http://www.veon.com (information appearing on the website is not 
incorporated by reference into this Annual Report.

A  Group Authority  Matrix  has  been  established  and  was  updated  in  2020,  to  ensure  that  all  expenditures  and  decisions  are 
approved by the appropriate levels of management, with more significant decisions requiring approval from senior management 
at the Group level. 

We have a Group-wide, quarterly management certification process in place, which requires the CEO and CFO at each of our 
reporting entities to certify compliance with the uniform governance and control standards established in VEON, including: 

•

•

•

•

•

Compliance with our Code of Conduct and related Group policies and procedure 

Compliance with local laws and regulations 

Compliance with the VEON Accounting Manual 

Compliance with VEON’s principles, procedures and policies on ethics and compliance, fraud prevention and detection, 
accounting and internal control standards, and disclosure requirements 

Internal disclosure obligations 

• Material  weaknesses  and/or  deficiencies,  if  applicable,  in  design  and  operation  of  internal  controls  over  financial 

reporting have been reported

51

Key risks table for VEON and example of mitigation and 2020 developments

Below is a summary of the key risks we face in operating our business and a discussion of certain mitigation efforts associated 
with  these  risks.    For  a  more  detailed  discussion  of  the  risks  and  uncertainties  relating  to  our  business,  see  the  Risk  Factors 
Section of this Annual Report. The risks listed may not be exhaustive, and additional risks and uncertainties not presently known 
to VEON or that it currently deems immaterial, may also have or develop a material adverse effect on its business, operations, 
financial condition or performance, or other interests. 

Prioritization  of  Strategic,  Operational  and  Financial  risks  are  is  based  on  EBITDA  business  impact’s  thresholds  and 
likelihood scales from 1 to 5. Once the identified risks are assessed and prioritized based on the above scales, the risk response 
strategy (take, treat, terminate, transfer) is decided and mitigating action plans are defined and/or updated, the outcome of the 
risk assessment information is captured in our Global GRC Tool. The risk response strategy is determined based on the business 
context, risk appetite, severity and prioritization.  Further the risk response must also consider the anticipated costs and benefits 
commensurate  with  the  severity  and  prioritization  of  the  risk  and  address  any  obligations  and  expectations  (e.g.  industry 
standards, shareholder expectations, etc.). 

Prioritization  of  some  compliance  risks  such  as  Non-compliance  to  Anti-bribery  and  corruption  laws,  and  Non-
compliance to International Sanction and export laws and regulations is performed qualitatively, due to their nature, based 
on  external  factors  sourced  from  independent  non-governmental  reports  (where  possible)  and  Internal  factors  sourced  from 
VEON’s business processes by the Local Ethics and Compliance and Legal teams.  

The  sequence  in  which  the  risks  and  mitigating  actions  are  presented  below  are  not  intended  to  be  in  any  order  of  severity, 
chance or materiality. Legend (qualitatively assessed of net risk i.e. considering mitigating actions): 

Risk increased: é	Risk decreased: ê	Risk stable: = 

52

Risk

1.     Market

Our business is subject to a variety of 
market-related risks across our 
geographies. These include:

ê Foreign exchange-related risks since 
a significant proportion of our costs and 
liabilities are in US dollars and Russian 
rubles whereas our revenues are in a 
variety of local currencies. 

ê	Competition since we operate in 
highly competitive markets which may 
impact our ability to attract and retain 
customers and achieve our financial 
targets.

ê Keeping pace with technology since 
our future success will depend on our 
ability to keep pace with investments in 
current technologies and technological 
changes in our industry and deploying 
networks and services that these 
enable.

'=  Macroeconomic developments given 
that we operate in a variety of markets 
that may be subject to adverse 
economic, political and regulatory 
factors which may impact the operating 
environment for our services.

é	Implications of the COVID-19 
pandemic, or those relating to similar 
public health developments, which may 
impact our operations and those of our 
customers and suppliers, as well as the 
economies in which we operate.

 Examples of how we mitigate

Some examples of 2020 developments

During 2020  the Company used 
foreign exchange forwards to mitigate 
foreign currency translation risk 
related to the Company’s net 
investment in its Russian operating 
company.
In April 2020, the Company 
established a USD 6.5 billion 
Medium-Term Note (MTN) 
programme that has since allowed us 
to increase the proportion of our 
Russian ruble-denominated 
borrowings to better match the ruble 
contribution to our revenues.

• We  continued to adapt our marketing 
strategies to local market conditions, 
notably in Russia where we simplified 
our product offers and maintained 
competitive prices in combination with 
increasing the transparency of our 
content policies conditions. 

• We continued to attract customers to 
our shared bundle product and 
convergence offers while deploying 
high-speed 4G networks across our 
markets to enhance the experience of 
our customers, 

•

• We now have the capacity to launch 
4G services in each of our operating 
markets. We have also acquired new 
spectrum to boost our network 
capacity, enhance spectral efficiency 
and enable the launch of new Radio 
Access Networks Technologies. 
The second quarter 2020 saw the full 
impact on our operations of the 
lockdowns imposed across our 
markets in response to COVID-19. 
Throughout the second half of the 
year, all operations saw a recovery in 
the performance as our local 
businesses continue building 
resilience to the restrictions related to 
COVID-19. Our management has 
taken appropriate measures to keep 
our personnel safe and secure. We 
have not observed any particular 
material adverse impacts to our 
business, financial condition, and 
results of operations, other than as 
described elsewhere in this report, 
and Group liquidity is sufficient to 
fund the business operations for at 
least another 12 months.

•

The Company hedges part of its 
exposure to fluctuations on the 
translation into US dollars of the 
revenues of its foreign operations by 
holding borrowings in foreign 
currencies and by the use of foreign 
exchange swaps and forwards. 
• We are monitoring and responding 

•

•

to technology developments and 
competitor activity that could have 
an impact on us achieving our goals.

• We continue to engage in dialogue 
with local industry regulators to 
ensure we understand the 
requirements and challenges of local 
markets and adapt our services 
accordingly.

• We are continuing to assess and 
take what we believe are the 
necessary steps to ensure the 
continuity of our operations and the 
safety of our employees during the 
COVID-19 pandemic 

53

Examples of how we mitigate

Some examples of 2020 developments

•

•

•

•

The Company assessed the 
concentration of risk with respect to 
refinancing its debt and concluded it 
to be low based on liquidity in the 
markets the Company has access to, 
and its recent history of refinancing.

Under its MTN programme, the 
Company took advantage of 
favorable capital market conditions 
three times during 2020 to refinance 
over USD 1.6 billion worth of debt at 
lower coupons and longer maturities.

loan 

agreements 

The  Company  signed  three  bilateral 
in 
unsecured 
Ukraine  for  an  aggregate  amount  of 
around  USD  146  million. 
It  also 
signed  a  bilateral  unsecured  loan 
agreement  worth  approximately  USD 
25 million in Kazakhstan.

The  Company  additionally  entered 
into  entered  into  new  bilateral  loan 
agreements  in  Russia  worth  around 
USD  1.9  billion,  which 
together 
extend  the  maturity  and  reduced  the 
borrowing  costs  of 
local 
facilities. 

these 

Risk

2.     Liquidity & Capital

Our business requires considerable 
financial capital in order to invest in the 
growth opportunities we identify. This 
requires us to manage a number of 
risks relating to capital and liquidity. 
These include:

= Liquidity risk  since as a holding 
company, VEON Ltd. depends on the 
performance of its subsidiaries and 
their ability to pay dividends, and may 
therefore be affected by changes in 
exchange controls and currency 
restrictions in the countries in which its 
subsidiaries operate

= Banking and Financial Counterparty 
risk given that the Banking systems in 
many countries in which we operate 
remain underdeveloped and there are a 
limited number of creditworthy banks in 
these countries with which we can 
conduct business, and currency control 
requirements restrict activities in certain 
markets in which we have operations.

= Debt service risks given that 
substantial amounts of indebtedness 
and higher Debt service obligations 
could materially impact our cash flow 
and affect our ability to raise additional 
capital.

•

= Access to capital since a significant 
rise in our indebtedness would imply 
higher Debt service obligations, which 
may not be fully covered by our cash 
flow and could hinder our ability to 
Access capital markets on acceptable 
terms.

• We have a centralized treasury 

function whose job is to manage 
liquidity and funding requirements as 
well as our exposure to financial and 
market risks

•

•

The Company monitors its risk to a 
shortage of funds using a recurring 
liquidity planning tool. The Company’s 
objective is to maintain a balance 
between continuity of funding and 
flexibility through the use of bonds, 
bank overdrafts, bank loans and 
lease contracts. 

The Company’s policy is to create a 
balanced debt maturity profile and to 
use market opportunities to extend 
the maturity and reduce the cost of its 
borrowings  as they arise.

• We adopt a prudent approach to 

managing our balance sheet leverage 
increasing the level of our local 
currency borrowing and maintain 
borrowing headroom in our revolving 
credit facilities

The primary objective of the 
Company’s capital management is to 
ensure that it maintains healthy 
capital ratios, so as to secure access 
to debt and capital markets at all 
times and maximize shareholder 
value. The Company manages its 
capital structure and makes 
adjustments to it in light of changes in 
economic conditions.

54

 
Risk

Examples of how we mitigate

Some examples of 2020 developments

·         We remain committed to simplifying 
our business structure, which extends to 
our local partnerships. 

·         We monitor and log our network 
and systems, and keep raising our 
employees’ security awareness through 
training, and  

operate a structured vulnerability scanning 
process within our security operations 
centers. 

·         We maintain good bilateral 
relationships with the regulatory 
authorities in our operating markets in 
order to help us understand and adapt to 
their concerns and needs with respect to 
local regulation. 

·         We conduct risk-based due 
diligence on our business partners and 
mitigate apparent risks through 
contractual requirements, representations, 
indemnities, warranties, etc.

·         We regularly monitor the media 
presence and reputations or our partners 
and respond accordingly

·         We reduce our reliance on single 
vendors to the extent possible.

·         Our new Governance, Risk and 
Compliance (“GRC”) framework sets out 
polices for key operational activities, 
detailing the minimum standards to which 
each OpCo must comply in areas such as 
employee behavior, financial conduct, 
procedures for Group contracting, 
cybersecurity and data privacy. These 
policies form part of the charter of our 
various Business Risk committees, People 
Committees and our OpCo Boards, setting 
common boundaries for behavior whilst 
encouraging freedom to operate within 
these to maximize business opportunity.

·         In May 2020, VEON announced a 
partnership between JazzCash and 
payment technology leader Mastercard 
that strengthens the payments ecosystem 
for merchants and customers in Pakistan.  
The partnership with Mastercard allows 
merchants to accept digital payments from 
customers, digitize their supply chain, and 
move to cashless operations. JazzCash 
customers will also have access to 
Mastercard’s virtual and branded debit 
cards that can be used in 55,000 points of 
sale and ATMs in Pakistan, in addition to 
JazzCash merchants and e-commerce 
sites.

·         In September 2020 the Dhabi 
Group exercised its put option to sell 
VEON its 15% shareholding in Pakistan 
Mobile Communications Limited 
("PMCL"), the operating company of 
Pakistan’s leading mobile operator, Jazz.  
Once completed, VEON will own 100% of 
PMCL.

·         We are enhancing our cyber 
security strategy,with a greater emphasis 
on local identification and response to 
cyber threats,  which we believe will 
enable us to better identify potential 
threats that may impact our business and, 
consequently, aid us in the implementation 
of the required security measures to 
address such threats. 

·         As part of our initiative to digitize 
our core telecommunications business, we 
intend to continue focusing on increasing 
our capital investment efficiency, including 
with respect to our IT, network, and 
distribution costs. We have secured 
network sharing agreements and intend to 
maintain our focus on achieving an asset-
light business model in certain markets, 
where we own only the core assets 
needed to operate our business.

3.     Operational
Ours is a complex business operating 
across ten markets at various levels of 
development and each with a variety of 
opportunities and challenges. These 
give rise to operational risks, which 
include:

= Challenges in local implementation of 
our strategic initiatives, which could be 
affected by a variety of unforeseen 
issues, including (but not limited to) 
technological limitations, regulatory 
constraints and insufficient customer 
engagement.

= Partnership risks given that we 
participate in strategic partnerships and 
joint ventures in a number of our 
markets, agreements around which 
may affect our ability to execute on our 
strategy and, where the consent of our 
partners is required, to withdraw funds 
and dividends from these entities. 
Partnerships could also give rise to 
reputational and indirect regulatory 
risks with respect to the behaviors and 
actions of our partners, as well as risks 
surrounding losing a partner with 
important insights in the local market.

é Cyber-attacks and denials of service, 
to which telecoms providers are 
vulnerable given the open nature of 
their networks and services, which 
could result in financial, reputational 
and legal harm to our business should 
these succeed in disrupting our 
services and result in the leakage of 
customer data or of our intellectual 
property.

= Supply chain risks since we depend 
on third parties for certain services and 
products important to our business and 
there may be unexpected disruptions to 
Supply chains due to a variety of 
factors, including regulatory (e.g. trade 
restrictions), natural disasters, war, 
pandemics and similar unforeseen 
events.

= Spectrum and license rights given 
that the success of our operations 
depends on acquiring and maintaining 
Spectrum and licenses in each of our 
markets, most of which are granted for 
specified terms with no assurance that 
they will be renewed once expired, or 
at what price.

= Interconnection agreements with 
other operators upon which the 
economic viability of our operations 
depend. a significant rise in these 
costs, or a decrease in the 
Interconnection rates we earn, could 
impact the Financial performance of 
our business, as could adverse local 
regulation of Mobile Termination rates 
(MTRs), which govern the rates at 
which carriers compensate each other 
for carrying calls that originate on one 
another’s networks.

55

Examples of how we mitigate

Some examples of 2020 developments

·         Our Ethics & Compliance and Legal 
teams maintain oversight and expertise 
from HQ and rely on dedicated local 
teams with knowledge of  the legal and 
regulatory requirements of each of our 
operating markets and supplement with 
external counsel when required. 

·         We maintain a privacy program that 
includes data privacy controls such as 
privacy assessments, data breach 
response processes and individual rights 
processes, to ensure we comply with EU 
and local data privacy laws for the 
collection and processing of personal data 
for our services, human resource 
management and compliance processes. 

·         We maintain appropriate know-
your-customer (KYC) and anti-money 
laundering (AML) controls across our DFS 
products and services as required by local 
rules and international best practices. 

·         We operate a policy of diverse 
sourcing with respect to equipment 
suppliers to ensure that we are not overly 
reliant on any single vendor should a 
supply disruption arise, including as a 
consequence of the imposition of 
sanctions and export controls laws.

·         A new governance model was 
introduced in the third-quarter of 2020, at 
the Group level,which sets the functional 
requirements, reporting standards and 
expected behaviors for OpCo 
Management. This defines clear 
objectives, roles and responsibilities, 
maintain minimum requirements in 
accordance with our GRC framework, and 
promotes transparent discussions about 
strategy, operations and business 
dilemmas. 

·        Alongside our OpCo Business Risk 
Committees (BRCs), we believe these 
new arrangements ensure Group 
management is now much closer to our 
OpCo managers and key risks they face, 
and reinforces effective, informed decision 
making by the local OpCo Boards and 
VEON’s Board where appropriate.

·         With respect to sanctions and 
export controls, in May and August 2019, 
and August 2020, the U.S. Department of 
Commerce, Bureau of Industry and 
Security (“BIS”) added Huawei 
Technologies Company Ltd. and 152 of its 
affiliates (collectively, “Huawei”) to its 
“Entity List”, which prohibits companies 
globally from directly or indirectly 
exporting, reexporting or in-country 
transferring goods, software, and 
technology that is subject to the EAR to 
Huawei and from procuring such items 
from Huawei when they have reason to 
know of any underlying U.S. export control 
violations in connection with those items. 

Risk

4.     Legal 

Our business is subject to a variety of 
laws and regulations, including:

= Unethical or inappropriate behavior, 
which could result in fraud or a breach 
of regulation or legislation and could, in 
turn, expose VEON to significant 
penalties, criminal prosecution and 
damage to our brand and reputation.

= regulation & compliance risks given 
that we operate in a highly regulated 
industry, operate in uncertain regulatory 
environments and are subject to a large 
number of laws and regulations, which 
change from time to time, vary between 
jurisdictions and can attract 
considerable costs with respect to 
regulatory compliance.

=  Unpredictable tax claims, decisions, 
audits & systems which could give rise 
to significant uncertainties and risks 
that could complicate our tax planning 
and business decisions.

= Data privacy since we collect and 
process customer personal Data , we 
are subject to an increasing amount of 
Data privacy laws and regulations. in 
some cases these laws and regulations 
also bring restrictions on cross border 
transfers of personal Data and 
surveillance related requirements to 
store Data and contents of 
communication for minimum periods. 
the costs and operating consequences 
of these laws and regulations may 
affect the performance of our business.

= Money Laundering rules which 
require anti-Money Laundering (AML) 
and counter-terrorism financing (CTF) 
systems and controls due to our 
expansion of digital Financial services 
(DFS) offerings beyond our core 
telecommunications services.

ê Sanctions and export controls risks 
since we may be subject to, depending 
on the transaction or business dealing, 
laws and regulations prescribed by 
various jurisdictions, including the 
United States, the United Kingdom and 
the European Union.  Applicable 
requirements remain subject to change 
and may impact our ability to conduct 
business in certain countries and with 
certain parties with which we have 
services, supply or other business 
arrangements.

56

Risk

Examples of how we mitigate

Some examples of 2020 developments

·         We operate a policy of diverse 
sourcing with respect to equipment 
suppliers to ensure that we are not overly 
reliant on any single vendor should a 
supply disruption arise, including as a 
consequence of the imposition of 
sanctions and export controls laws.

·         We manage a diverse portfolio of 
emerging markets businesses, which 
helps ensure that in the event of a market 
underperforming for whatever reason its 
impact on the financial and operating 
performance of the Group as a whole is 
limited.

·         We act as long-term investors in the 
network infrastructure of our operating 
markets and ensure that our networks are 
adequately served, including through the 
provision of off-grid power where 
necessary. By helping to generate 
economic activity and prosperity within the 
communities we serve, we believe our 
operations can act as a positive catalyst 
for the broader development of the nations 
that host us.

·         In October 2020, VEON concluded 
an agreement for the sale of VEON’s 
operating subsidiary in Armenia. The sale 
of the Armenian operations is in line with 
VEON’s ambition to simplify the Group’s 
structure and enhance its operational 
focus on markets with attractive long-term 
growth opportunities.

·         With respect to infrastructure risks, 
on December 30, 2020, the Russian 
government decree “On licensing of 
activities in the field of communication 
services” introduced a new license 
requirements to ensure the 
implementation of requirements related to 
the stability, security and integrity of the 
internet. The new provisions came into 
force on January 1, 2021. The 
implementation and support of measures 
to comply with the legislation may lead to 
substantial investments in the future.

5.     Geographical and Political

Our geographic footprint subjects us to 
a variety of political factors and 
uncertainties which could have a 
bearing on our business operations.  
These include:

ê Sanction and export controls risks 
since we may be subject to, depending 
on the transaction or business dealing, 
laws and regulations prescribed by 
various jurisdictions, including the 
United States, the United Kingdom and 
the European Union. Applicable 
requirements remain subject to  change 
and may impact our ability to conduct 
business in certain countries and with 
certain parties with which we have 
services, supply or other business 
arrangements.

= Emerging markets-related risks given 
that nine of our nine operating markets 
are in the developing world and are 
subject to a varying degree of political, 
economic and legal variability around 
issues such as foreign exchange policy, 
capital controls and rules on foreign 
investment.

= Infrastructure risks given that the 
physical Infrastructure in some of our 
markets is in poor condition and may 
require significant investment by local 
governments or additional expenditures 
by us in order to sustain our operations 
and services.

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Risk Factors

The risks and uncertainties described below are not the only ones we face. Any of the following risks could materially 

and adversely affect our business, financial condition or results of operations. Additional risks and uncertainties not currently 
known to us or those we currently view to be immaterial may also materially and adversely affect our business, financial 
condition or results of operations. In addition, you should consider the interrelationship and compounding effects of two or more 
risks occurring simultaneously.

The following summarizes the principal risks that could adversely affect our business, operations and financial results. 
Before purchasing our American Depositary Shares (“ADSs”), you should carefully consider all of the information set forth in this 
Annual  Report  including,  but  not  limited  to,  these  risks.  In  addition  to  those  risk  factors,  there  may  be  additional  risks  and 
uncertainties of which management is not aware or focused on or that management currently deems immaterial. Our business, 
financial condition or results of operations or prospects could be materially adversely affected by any of these risks, causing the 
trading price of our securities to decline and you to lose all or part of your investment.

•

•

•

•

•

•

•

•

•

•

risks relating to changes in political, economic and social conditions in each of the countries in which we operate and 
where laws are applicable to us (including as a result of armed conflict) such as any harm, reputational or otherwise, 
that  may  arise  due  to  changing  social  norms,  our  business  involvement  in  a  particular  jurisdiction  or  an  otherwise 
unforeseen development in science or technology; 

in each of the countries in which we operate and where laws are applicable to us, risks relating to legislation, regulation, 
taxation and currency, including costs of compliance, currency and exchange controls, currency fluctuations, and abrupt 
changes to laws, regulations, decrees and decisions governing the telecommunications industry and taxation, laws on 
foreign  investment,  anti-corruption  and  anti-terror  laws,  economic  sanctions,  data  privacy,  anti-money  laundering, 
antitrust, national security and lawful interception and their official interpretation by governmental and other regulatory 
bodies and courts;

risks  related  to  the  impact  of  export  controls,  sanctions,  international  trade  regulation,  customs  and  technology 
regulation,  on  our  ability,  and  the  ability  of  important  third-party  suppliers  to  procure  goods,  software  or  technology 
necessary to provide services to our customers, particularly services related to the production and delivery of supplies, 
support services, software, and equipment sourced from these suppliers – for example, between April and July 2018, 
the  U.S.  Department  of  Commerce,  Bureau  of  Industry  and  Security  (“BIS”)  imposed  a  Denial  Order  against  ZTE 
Corporation (“ZTE”) under the Export Administration Regulations (“EAR”) which prohibited transactions with ZTE during 
this time that involved goods, software or technology subject to the EAR and could have led to service degradation and 
disruption  in  certain  markets,  and  in  May  and  August  2019,  and  August  2020,  BIS  added  Huawei  Technologies 
Company Ltd. and 152 of its affiliates (collectively, “Huawei”) to its “Entity List”, which prohibits companies globally from 
directly or indirectly exporting, reexporting or in-country transferring goods, software, and technology that is subject to 
the EAR to Huawei and from procuring such items from Huawei when they have reason to know of any underlying U.S. 
export control violations in connection with those items;

risks related to the ongoing COVID-19 pandemic, such as adverse impacts on our financial performance resulting from 
lockdown  restrictions,  changes  in  customer  trends  and  the  broader  macroeconomic  impact  of  the  pandemic  on  our 
countries of operation; 

risks  relating  to  a  failure  to  meet  expectations  regarding  various  strategic  initiatives,  including,  but  not  limited  to, 
changes  to  our  portfolio  of  operating  companies,  product  and  technology  offerings,  development  of  networks  and 
customer services;

risks related to solvency and other cash flow issues, including our ability to raise the necessary additional capital and 
incur additional indebtedness, the ability of our subsidiaries to make dividend payments, our ability to develop additional 
sources of revenue and unforeseen disruptions in our revenue streams;

risks  that  the  adjudications  by  the  various  regulatory  agencies  or  other  parties  with  whom  we  are  involved  in  legal 
challenges, license and regulatory disputes, tax disputes or appeals may not result in a final resolution in our favor or 
that we are unsuccessful in our defense of material litigation claims or are unable to settle such claims; 

risks  relating  to  our  company  and  its  operations  in  each  of  the  countries  in  which  we  operate  and  where  laws  are 
applicable  to  us,  including  demand  for  and  market  acceptance  of  our  products  and  services,  regulatory  uncertainty 
regarding our licenses, frequency allocations and numbering capacity, constraints on our spectrum capacity, access to 
additional  bands  of  spectrum  required  to  meet  demand  for  existing  products  and  service  offerings  or  additional 
spectrum  required  from  new  products  and  services  and  new  technologies,    availability  of  line  capacity,  fiber  capacity, 
international  gateway  access,  intellectual  property  rights  protection,  labor  issues,  interconnection  agreements, 
equipment failures and competitive product and pricing pressures;

risks related to developments from competition, unforeseen or otherwise, in each of the countries in which we operate 
and where laws are applicable to us, including our ability to keep pace with technological changes and evolving industry 
standards;

risks related to the activities of our strategic shareholders, lenders, employees, joint venture partners, representatives, 
agents, suppliers, customers and other third parties;

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•

•

•

risks associated with our existing and future transactions, including with respect to realizing the expected synergies of 
closed  transactions,  satisfying  closing  conditions  for  new  transactions,  obtaining  regulatory  approvals,  implementing 
remedies, and assuming related liabilities;

risks  associated  with  data  protection,  data  breaches,  cyber-attacks  or  systems  and  network  disruptions,  or  the 
perception of such attacks or failures in each of the countries in which we operate, including the costs associated with 
such events and the reputational harm that could arise therefrom;

risks related to the ownership of our ADSs, including those associated with VEON Ltd.’s status as a Bermuda company 
and a foreign private issuer; and

other risks and uncertainties as set forth in Item 3D. Risk Factors.

For a more complete discussion of the material risks facing our business, see below.

Market Risks

We are exposed to foreign currency exchange loss and currency fluctuation and translation risks. 

A  significant  amount  of  our  costs,  expenditures  and  liabilities,  including  capital  expenditures  and  borrowings,  is 
denominated in U.S. dollars and Russian rubles, while a proportion of our revenue is denominated in currencies other than U.S. 
dollars and Russian rubles. Thus, declining values of local currencies against the U.S. dollar could make it more difficult for us to 
repay  or  refinance  our  debt,  make  dividend  payments,  comply  with  covenants  under  our  debt  agreements  or  purchase 
equipment or services denominated in U.S. dollars, and may also impact our ability to support one jurisdiction with reserves from 
another  jurisdiction.  For  example,  the  values  of  the  Russian, Algerian,  Ukrainian,  Uzbek,  Pakistani,  Bangladeshi  and  Kazakh 
currencies have experienced significant volatility in recent years in response to certain political and economic issues, and may 
continue to decline.

Our  existing  and  future  hedging  strategies  may  not  adequately  protect  us  from  exchange  rate  risks.  Our  operating 
metrics, debt coverage metrics, as well as the value of our investments in U.S. dollar terms have been negatively impacted in 
recent  years  by  foreign  currency  transactions  and  translations.  Such  future  currency  fluctuations  and  volatility  may  result  in 
additional losses or otherwise negatively impact our results of operations despite our ongoing efforts to better match the currency 
mix of our debt and derivatives with the currencies of our operations.

Our hedging strategies may further prove ineffective if, for example, exchange rates fluctuate in response to legislative 
or  regulatory  action  by  a  government  with  respect  to  its  currency,  which  could  lead  to  adverse  developments  that  harm  our 
business, financial condition, results of operations or prospects. In addition, the countries in which we operate have historically 
experienced periods of high levels of inflation, including certain cases of hyperinflation. Our profit margins could be harmed if we 
are unable to sufficiently increase our prices to offset any significant future increase in the inflation rate, which may be difficult 
with our mass market and price-sensitive customer base. For more information about foreign currency translation and associated 
risks, see    — Operating and Financial Review and Prospects,  — Quantitative and Qualitative Disclosures About Market Risk 
and Note 17 — Financial Risk Management to our Audited Consolidated Financial Statements.

We may be unable to develop additional revenue market share in markets where the potential for additional growth of 
our customer base is limited and customers may demand new services, technologies and increased access, which may 
require significant capital expenditures. 

Increasing competition, market saturation and technological development have led to the increased importance of data 
services  and  access  to  next  generation  technologies  such  as  4G/LTE  in  the  markets  in  which  we  operate,  including  Russia, 
Commonwealth of Independent States (“CIS”) countries, Pakistan and Bangladesh and the provision of such technologies and 
services  requires  significant  capital  investment  in  spectrum  and  network  presenting  a  risk  that  we  cannot  keep  up  with  the 
demands  of  our  customers.  The  mobile  markets  in  Russia, Algeria,  Ukraine,  Kazakhstan,  Kyrgyzstan  and  Georgia  have  each 
reached mobile penetration rates exceeding 100%, according to Omdia and publicly available government sources. As a result, 
we have become increasingly focused on revenue market share growth in each of these markets. The key components of this 
strategy are to increase data usage and improve customer loyalty. However, we cannot guarantee that these initiatives will be 
successful, particularly in markets where the potential for additional growth of our customer base is limited.  Failure to develop 
additional  revenue  market  share  could  materially  harm  our  business,  financial  condition,  results  of  operations,  cash  flows  or 
prospects. For more information on the competition we face in our markets, see “— We operate in highly competitive markets, 
which we expect to only become more competitive, and as a result may have difficulty expanding our customer base or retaining 
existing customers.”  For more information on our growth strategy, see   — Information on the Company. 

Our revenue is often unpredictable, and our revenue sources are short-term in nature.

Our primary source of revenue comes from prepaid mobile customers whom we do not require to enter into long-term 
contracts.  Therefore,  we  cannot  be  certain  these  customers  will  continue  to  use  our  services  in  the  future.  Revenue  from 
postpaid mobile customers represents a small percentage of our total operating revenue and the contracts that are required to be 
signed by such customers can be canceled with limited advance notice and without significant penalty. Because we incur costs 
based on our expectations of future revenue, the sudden loss of a large number of customers or a failure to accurately predict 
revenue could harm our business, financial condition, results of operations, cash flows or prospects. For example, following the 
outbreak  of  COVID-19  and  lockdown  restrictions  imposed  across  our  countries  of  operations,  our  revenue  projections  were 

59

frustrated as material disruption to our retail operations resulted in store closures, impacting gross connections and airtime sales. 
Restrictions on travel resulted in a significant decline in roaming revenues and the loss of migrant customers from our subscriber 
base,  particularly  in  Russia.  The  impact  of  such  was  only  partially  offset  by  increases  in  fixed  line  revenue,  as  lockdowns 
encouraged home working and schooling. For a description of the key trends and developments with respect to our business, 
including  further  discussion  of  the  impact  of  COVID-19  on  our  operations  and  financial  performance,  see    —  Operating  and 
Financial Review and Prospects — Key Developments During 2020.

We operate in highly competitive markets, which we expect only to become more competitive, and as a result may have 
difficulty expanding our customer base or retaining existing customers. 

The  markets  in  which  we  operate  are  highly  competitive  in  nature,  and  we  expect  that  competition  will  continue  to 
increase. Our financial performance has been and will continue to be significantly determined by our success in adding, retaining 
and  engaging  our  customers.  As  penetration  rates  increase  in  the  markets  in  which  we  operate,  we  may  have  difficulty 
expanding our customer base. If customers find our connectivity and internet services not to be valuable, reliable or trustworthy 
or otherwise believe competitors in our markets can offer better services, we may have difficulty retaining customers. In addition, 
as new players enter our markets or existing competitors combine operations, maintaining our market positions will become even 
more difficult. For more information on the competition in our markets, see — Business Overview.

Each  of  the  items  discussed  immediately  below  regarding  increased  competition  could  materially  harm  our  business, 

financial condition, results of operations, cash flows or prospects:

•

•

•

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•

•

•

•

•

•

•

•

•

•

we cannot assure you that our revenue will grow in the future, as competition puts pressure on prices; 

with  the  increasing  pace  of  technological  developments,  including  new  digital  technologies  and  regulatory  changes 
impacting our industry, we cannot predict with certainty future business drivers and we cannot assure you that we will 
adapt to these changes at a competitive pace; 

we may be forced to utilize more aggressive marketing schemes to retain existing customers and attract new ones that 
may include lower tariffs, handset subsidies or increased dealer commissions; 

in  more  mature  or  saturated  markets,  there  are  limits  on  the  extent  to  which  we  can  continue  to  grow  our  customer 
base, and the continued growth of our business and results of operations will depend, in part, on our ability to extract 
greater revenue from our existing customers, including through the expansion of data services and the introduction of 
next generation technologies, which may prove difficult to accomplish;  

we  may  be  unable  to  deliver  better  customer  experience  relative  to  our  competitors  or  our  competitors  may  reach 
customers more effectively through better use of digital and physical distribution channels, which may negatively impact 
our revenue and market share; 

as  we  expand  the  scope  of  our  services,  such  as  new  networks,  fixed-line  residential  and  commercial  broadband, 
Mobile  Financial  Services  ("MFS")  and  Digital  Financial  Services  ("DFS")  offerings,  streaming  content  and  other 
services, we may encounter a greater number of competitors that provide similar services; 

the liberalization of the regulations in certain markets in which we operate could greatly increase competition; 

competitors  may  operate  more  cost-effectively  or  have  other  competitive  advantages  such  as  greater  financial 
resources,  market  presence  and  network  coverage,  stronger  brand  name  recognition,  higher  customer  loyalty  and 
goodwill, and more control over domestic transmission lines; 

competitors,  particularly  current  and  former  state-controlled  telecommunications  service  providers,  may  receive 
preferential treatment from the regulatory authorities and benefit from the resources of their shareholders; 

current or future relationships among our competitors and third parties may restrict our access to critical systems and 
resources; 

new competitors or alliances among competitors could rapidly acquire significant market share, and we may not be able 
to form similar relationships to capitalize on such opportunities; 

reduced  demand  for  our  core  services  of  voice,  messaging  and  data  and  the  development  of  services  by  application 
developers (commonly referred to as OTT players) could significantly impact our future profitability; 

competition from OTT players offering similar functionality to us may increase, including digital providers offering VOIP 
calling, internet messaging and other digital services which compete with our telecommunications services; further our 
competitors may partner with such OTT players to provide integrated customer experiences, and we may be unable to 
implement offers, products and technology to compete with the offerings of our telecommunications competitors or to  
support our commercial partnerships; and 

our existing service offerings could become disadvantaged as compared to those offered by competitors who can offer 
bundled combinations of fixed-line, broadband, public Wi-Fi, TV and mobile.

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We  may  be  unable  to  keep  pace  with  technological  changes  and  evolving  industry  standards,  which  could  harm  our 
competitive position and, in turn, materially harm our business. 

The  telecommunications  industry  is  characterized  by  rapidly  evolving  technology,  industry  standards  and  service 
demands, which may vary by country or geographic region. Accordingly, our future success will depend on our ability to adapt to 
the  changing  technological  landscape  and  the  regulation  of  standards  utilizing  these  technologies.  It  is  possible  that  the 
technologies or equipment we utilize today will become obsolete or subject to competition from new technologies in the future for 
which we may be unable to obtain the appropriate license in a timely manner or at all. We may not be able to meet all of these 
challenges in a timely and cost-effective manner. 

For  example,  with  respect  to  our  mobile  services,  while  we  continue  deploying  mobile  networks  such  as  4G/LTE,  in 
some  markets  the  industry  is  already  well  advanced  in  planning  for  the  future  deployment  of  5G,  which  is  expected  to  drive 
continued  demand  for  data  in  the  future.    If  our  licenses  and  spectrum  are  not  appropriate  or  sufficient  to  address  changing 
technology,  we  may  require  additional  or  supplemental  licenses  and  spectrum  to  implement  5G  technology  or  to  upgrade  our 
existing 2G, 3G and 4G/LTE networks to remain competitive, and we may be unable to acquire such licenses and spectrum on 
reasonable terms or at all. We may need to incur significant capital expenditures to acquire licenses, spectrum or infrastructure 
to  offer  new  services  to  our  customers  or  improve  our  current  services.    In  particular,  the  introduction  of  5G  services  into  our 
markets may draw additional entrants and require infrastructure capital expenditures for providers seeking to gain or maintain a 
competitive advantage.  As new technologies are developed or upgraded, such as advanced 5G systems and next generation 
technologies, our equipment may need to be replaced or upgraded or we may need to rebuild our mobile network, in whole or in 
part. Technological change is also impacting the capabilities of the equipment our customers use, such as mobile handsets, and 
potential  changes  in  this  area  may  impact  demand  for  our  services  in  the  future.  Implementing  new  technologies  requires 
substantial investment. However, there can be no guarantee that we will generate our expected return on any such investments. 

If we experience substantial problems keeping pace with technological changes and evolving industry standards, it may 
impair  our  success  with  the  provision  of  related  services,  increase  our  costs  or  delay  or  decrease  revenue  and  profits  and 
therefore hinder recovery of any significant capital investments in such services, as well as our growth.

The international economic environment could cause our business to decline. 

Our  operations  are  subject  to  macro-economic  and  political  risks  that  are  outside  of  our  control.  The  current  macro-
economic  environment  is  volatile,  and  recent  levels  of  instability  in  global  markets  has  contributed  to  the  challenging  global 
economic environment in which we operate.  As future developments are dependent upon a number of political and economic 
factors, we cannot accurately predict how long challenging conditions will exist or the extent to which the markets in which we 
operate  may  deteriorate.  Unfavorable  economic  conditions  may  impact  a  significant  number  of  our  current  and  potential 
customers’  spending  patterns,  in  terms  of  both  the  products  they  subscribe  for  and  usage  levels. As  a  result,  it  may  be  more 
difficult for us to attract new customers, more likely that customers will downgrade or disconnect their services and more difficult 
for  us  to  maintain  ARPUs  at  existing  levels.  A  difficult  international  economic  environment  and  any  future  downturns  in  the 
economies  of  markets  in  which  we  operate  or  may  operate  in  the  future,  or  such  downturns  in  the  international  economic 
environment  in  general  could  also  increase  our  costs  (for  example,  by  precipitating  higher  levels  of  taxation),  prevent  us  from 
executing  our  strategies,  hurt  our  liquidity,  or  impair  our  ability  to  take  advantage  of  future  opportunities,  to  respond  to 
competitive pressures, to refinance existing indebtedness or to meet unexpected financial requirements, all of which could harm 
our business, financial condition, results of operations, cash flows or prospects.

Our  financial  performance  may  be  affected  by  ongoing  issues  in  the  European  Union  relating  to  risks  of  deflation, 
sovereign debt levels, the suitability and stability of the euro, including the withdrawal of the United Kingdom from the European 
Union.  Our  financial  performance  may  be  affected  by  ongoing  issues  in  the  European  Union  relating  to  risks  of  deflation, 
sovereign debt levels, the suitability and stability of the euro, including the withdrawal of the United Kingdom from the European 
Union following the expiry of the transition period on December 31, 2020.

As  a  result  of  the  coronavirus  or  other  similar  outbreaks  or  adverse  public  health  developments,  our  operations,  and 
those  of  our  customers  and  suppliers,  may  experience  delays  or  disruptions,  such  as  difficulty  obtaining  components  and 
temporary suspension of operations. In addition, our financial condition and results of operations could be adversely affected to 
the extent that coronavirus or any other epidemic or outbreak harms the economies in which we operate. Any of the foregoing 
could materially and adversely affect our business, financial condition, results of operations, share price and cost of capital.

Our  financial  performance  has  also  been  affected  since  the  COVID-19  outbreak  and  the  restrictions  imposed  by 
governments across our countries of operation.  Following the introduction of lockdown measures, we saw a significant impact 
on roaming revenues which largely disappeared in the second quarter of 2020, while the travel restrictions further saw a market 
reduction in the migrant workforce which is traditionally a source of  a large subscriber base in Russia.  Network traffic patterns 
were also impacted as people worked from home, and this required some adjustments to our network deployment plans.  As a 
result of the continued outbreak of COVID-19 and restrictions imposed in our countries of operation, or other similar outbreaks or 
adverse  public  health  developments,  our  operations,  and  those  of  our  customers  and  suppliers,  may  experience  delays  or 
disruptions,  such  as  difficulty  obtaining  components  and  temporary  suspension  of  operations,  and  our  financial  condition  and 
results of operations could be adversely affected.

International economic sanctions and export controls may also adversely affect our ability to operate. In anticipation of 
the United Kingdom leaving the European Union, the United Kingdom created a new sanctions enforcement agency, the Office of 
Financial Sanctions Implementation (“OFSI”). In October 2019, OFSI announced a fine against a telecommunications carrier for 

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violations of U.K. sanctions. Also, in the U.S., Congress enacted the Export Controls Act of 2018 (“ECA”) which aims to enhance 
protection of U.S. technology resources by imposing greater restrictions on the transfer to non-U.S. individuals and companies, 
particularly  through  exports  to  China,  of  certain  key  foundational  and  emerging  technologies  and  cyber-security  considered 
critical to U.S. national security. In recent months, the Department of Commerce has also broadened the scope of U.S. export 
controls  measures  to  protect  a  wider  range  of  national  security  interests,  including  telecommunications  technology,  against 
perceived challenges presented by China.

In  Russia,  the  impact  of  economic  sanctions  and  the  significant  devaluation  of  the  Russian  ruble  have  negatively 
impacted the Russian economy and economic outlook, and may also negatively impact our ability to raise external financing. Our 
operations may also be adversely affected by potential future sanctions by the United States targeting Russia, fueled by broader 
foreign  policy  considerations.  Throughout  2020,  the  United  States  launched  stronger  sanctions  against  Russia  designed  to 
address increased tensions in foreign conflicts (e.g., in Syria and Venezuela), proliferation of chemical and biological weapons, 
tensions related to alleged election interference and Russia’s impact on European energy security. The United States included 
sanctions from the Protecting Europe’s Energy Security Act of 2019 in the 2020 National Defense Authorization Act (“NDAA”), 
which threatens asset freezes against companies involved in building the Russian natural gas pipelines to Europe: North Stream 
2 and TurkStream. In addition, the U.S. Congress has considered passing new laws that would impose sanctions on a range of 
Russian  persons  and  entities,  including  banks,  energy  companies,  defense  companies  and  entities  in  the  intelligence  sector, 
state-owned enterprises, Russian energy projects and sovereign debt, oligarchs, and senior government officials. We could be 
materially  adversely  impacted  by  the  imposition  of  further  sanctions.  Further  confrontation  in  Ukraine  and  any  escalation  of 
tensions  between  Russia  and  the  United  States  and/or  the  European  Union  related  to  the  imposition  of  further  sanctions,  or 
continued  uncertainty  regarding  the  scope  thereof,  could  have  a  prolonged  adverse  impact  on  the  Russian  economy.  These 
impacts  could  be  more  severe  than  those  experienced  to  date.  In  particular,  should  either  the  United  States  or  the  European 
Union  expand  their  respective  sanctions  to  include  our  suppliers  or  other  counterparties,  such  an  expansion  could  result  in 
substantial legal and other compliance costs and risks on our business operations and could have a material adverse impact on 
our  business,  financial  condition,  results  of  operations  or  prospects.  If  further  restrictions  are  levied  on  Russian  banks,  our 
existing  and  future  Russian  ruble  loans  could  be  blocked  both  in  relation  to  our  ability  to  draw  them  and  our  ability  to  service 
them and may require a change in our repayment terms. The sanctions imposed by the United States and the European Union in 
connection  with  the  Ukraine  crisis  so  far  have  had  an  adverse  effect  on  the  Russian  economy. Tensions  between  Russia,  the 
European Union and the United States have further increased recently, and there can be no assurance that the governments of 
the  European  Union  and  United  States  or  other  countries  will  not  impose  further  sanctions  on  Russia.  For  more  on  sanctions 
affecting Russia and how they may affect our operations, see Geopolitical Risks - “Our operations may be adversely affected by 
ongoing developments in Russia and Ukraine” and Exhibit 99.2 - Regulation of Telecommunications - Sanctions Regimes. 

Deterioration  of  macro-economic  conditions  in  the  countries  in  which  we  operate  may  also  have  certain  accounting 
ramifications. A significant difference between the actual performance of our operating companies and the forecasted projections 
for  revenue, Adjusted  EBITDA  or  CAPEX  could  require  us  to  write  down  the  value  of  the  goodwill,  particularly  in  Russia  and 
Algeria  which  have  significant  goodwill  balances.  In  addition,  the  possible  consequences  of  a  financial  and  economic  crisis 
related to, in particular, customer behavior, the reactions of our competitors in terms of offers and pricing or their responses to 
new entrants, regulatory adjustments in relation to reductions in consumer prices and our ability to adjust costs and investments 
in keeping with possible changes in revenue, may also adversely affect our forecasts and lead to a write-down of tangible and 
intangible assets, including goodwill. Also, significant adverse developments in our share price, and the resulting decrease in our 
market capitalization may also adversely impact our accounting presentation and lead to a write-down to our goodwill balances. 

A write-down recorded for tangible and intangible assets resulting in a lowering of their book values could impact certain 
covenants and provisions under our debt agreements, which could result in a deterioration of our financial condition, results of 
operations or cash flows. 

For further information on the impairment of tangible and intangible assets and recoverable amounts (particularly key 
assumptions  and  sensitivities),  see  Note  10  -  Impairment  of  Assets  to  our Audited  Consolidated  Financial  Statements.  For  a 
discussion of the risks associated with the markets where we operate, see Geopolitical Risks - “Investors in emerging markets, 
where  our  operations  are  located,  are  subject  to  greater  risks  than  investors  in  more  developed  markets,  including  significant 
political, legal and economic risks as well as risks related to fluctuations in the global economy.”

Liquidity and Capital Risks

Substantial amounts of indebtedness and debt service obligations could materially decrease our cash flow, adversely 
affect our business and financial condition and prevent us from raising additional capital.

We have substantial amounts of indebtedness and debt service obligations. As of December 31, 2020, the outstanding 
principal amount of our external debt for bonds, bank loans, and other borrowings amounted to approximately US$7.7 billion. In 
addition  to  these  borrowings,  we  also  have  lease  liabilities  amounting  to  US$1.9  billion.  For  more  information  regarding  our 
outstanding indebtedness and debt agreements, see  — Operating and Financial Review and Prospects — Liquidity and Capital 
Resources — Indebtedness.

Agreements under which we borrow funds contain obligations, which include covenants or provisions that impose on us 
certain  operating  and  financial  restrictions.  Some  of  these  covenants  relate  to  our  financial  performance  or  financial  condition, 
including  balance  sheet  solvency,  such  as  levels  or  ratios  of  earnings,  debt,  equity  and  assets  and  may  prevent  us  or  our 
subsidiaries from incurring additional debt. Failure to comply with these covenants or provisions may result in a default, which 
could increase the cost of securing additional capital, lead to accelerated repayment of our indebtedness or result in the loss of 

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any  assets  that  secure  the  defaulted  indebtedness  or  to  which  our  creditors  otherwise  have  recourse.  Such  a  default  or 
acceleration  of  the  obligations  under  one  or  more  of  these  agreements  (including  as  a  result  of  cross-default  or  cross-
acceleration) could have a material adverse effect on our business, financial condition, results of operations or prospects, and in 
particular on our liquidity and our shareholders’ equity. In addition, covenants in our debt agreements could restrict our liquidity 
and our ability to expand or finance our future operations. For  a discussion of agreements under which we borrow  funds, see 
Note 15 — Investments, Debt and Derivatives to our Audited Consolidated Financial Statements. 

Aside  from  the  risk  of  default,  given  our  substantial  amounts  of  indebtedness  and  the  limits  imposed  by  our  debt 
obligations, our business could suffer significant negative consequences such as the need to dedicate a substantial portion of 
our cash flows from operations to repayment of our debt, thereby reducing funds available for paying dividends, working capital, 
capital  expenditures,  acquisitions,  joint  ventures  and  other  purposes  necessary  for  us  to  maintain  our  competitive  position, 
flexibility and resiliency in the face of general adverse economic or industry conditions.

We  may  not  be  able  to  raise  additional  capital,  or  we  may  only  be  able  to  raise  additional  capital  at  significantly 
increased costs.

We  may  need  to  raise  additional  capital  in  the  future,  including  through  debt  financing.  If  we  incur  additional 
indebtedness, the risks that we now face related to our indebtedness and debt service obligations could increase. Specifically, 
we may not be able to generate enough cash to pay the principal, interest and other amounts due under our indebtedness or we 
may not be able to borrow money within local or international markets on acceptable terms, or at all. We may also be impacted 
by conditions or local legal requirements in local or international markets that make it difficult to raise capital, refinance existing 
debt or to service existing indebtedness. As more of our debt is denominated in local currencies, it may become more difficult to 
support one jurisdiction with reserves from another jurisdiction.  

Our ability to raise additional capital, and the cost of raising additional capital, may also be affected by any downgrade 
of  our  credit  ratings,  which  may  happen  for  reasons  outside  our  control  and  could  materially  harm  our  business,  financial 
condition, results of operations and prospects. In addition, economic sanctions which may be imposed in the future by the United 
States, the United Nations, the European Union, or other countries or organizations, including in connection with developments 
in  Russia  and  Ukraine,  may  also  negatively  affect  our  existing  financing  and  our  ability  to  service  it  and  our  ability  to  secure 
future  external  financing,  particularly  if  the  sanctions  are  broadened.  Furthermore,  the  announced  restrictions  on  use  of  and 
future  elimination  of  the  LIBOR  benchmark,  expected  from  June  2023  for  U.S.  dollar  LIBOR  and  December  2021  for  other 
currencies, or any other benchmark, changes in the manner of administration of any benchmark, or actions by regulators or law 
enforcement agencies could result in changes to the manner in which EURIBOR or LIBOR is determined, which could require an 
adjustment to the terms and conditions, or result in other consequences, in respect of any of our current or future debt linked to 
such benchmark.

If we are unable to raise additional capital in the market in which we want to raise it, or at all, or if the cost of raising 
additional capital significantly increases, we may be unable to make necessary or desired capital expenditures, take advantage 
of investment opportunities, refinance existing indebtedness or meet unexpected financial requirements, and our growth strategy 
and liquidity may be negatively affected. This could cause us to be unable to repay indebtedness as it comes due, to delay or 
abandon  anticipated  expenditures  and  investments  or  otherwise  limit  operations,  which  could  materially  harm  our  business, 
financial condition, results of operations or prospects.

A change in control of VEON Ltd. could harm our financial condition and business. 

Our financing agreements across the VEON group generally have “change of control” provisions that may require us to 
make  a  prepayment  if  a  person  or  group  of  persons  (with  limited  exclusions)  directly  or  indirectly  acquire  beneficial  or  legal 
ownership of or control over more than 50.0% of our share capital or the ability to appoint a majority of directors to our board. If 
such a change of control provision is triggered and we fail to agree necessary amendments to our bond or loan documentation 
and  then  fail  to  make  any  required  prepayment,  it  could  trigger  cross-default  or  cross-acceleration  provisions  of  our  other 
financing  agreements,  which  could  lead  to  our  obligations  being  declared  immediately  due  and  payable. A  change  of  control 
could also impact other contracts and relationships with third parties and may require a renegotiation or reorganization of certain 
contracts or undertakings. This could harm our business, financial condition, results of operations, cash flows or prospects.

Operational Risks

Our  strategic  initiatives  may  not  be  successfully  implemented  and  the  benefits  we  expect  to  achieve  may  not  be 
realized. 

We continue to transform our business with the aim of improving our operations across all markets in which we operate. 
This transformation is working to expand our growth opportunities beyond traditional voice and access data provision into new 
digitally-enabled  services.  We  are  also  developing  new  IT  capabilities,  including  local  platforms  that  enable  our  customers  to 
manage  their  accounts  and  services  independently  (“self-care”),  digital  applications  (e.g.  TV,  music,  financial  services),  billing 
systems,  customer  relationship  management  systems,  enterprise  resource  management  systems,  human  capital  management 
systems  and  enterprise  performance  management  systems;  and  reducing  and  simplifying  our  IT  cost  base.  There  can  be  no 
assurance  that  this  strategy  will  generate  the  results  we  expect.  We  may  experience  implementation  issues  due  to  a  lack  of 
coordination  or  cooperation  with  our  operating  companies  or  third  parties,  significant  change  in  key  personnel  or  otherwise 
encounter  unforeseen  issues,  such  as  technological  limitations,  regulatory  constraints  or  lack  of  customer  engagement,  which 
could  frustrate  our  expectations  regarding  cost-optimization  and  process  redesign  or  otherwise  delay  or  hinder  execution  of 

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these initiatives. As a result, these directional improvements may not be successful, which could adversely affect our business, 
financial condition, results of operations, cash flows or prospects.

As a holding company, VEON Ltd. depends on the performance of its subsidiaries and their ability to pay dividends or 
make  other  transfers  to  VEON  Ltd.  and  may  therefore  be  affected  by  a  variety  of  local  legal  or  regulatory  changes, 
including changes in exchange controls and currency restrictions in the countries in which its subsidiaries operate. 

VEON  Ltd.  is  a  holding  company  and  does  not  conduct  any  revenue-generating  business  operations  of  its  own.  Its 
principal assets are the direct and indirect equity interests it owns in its operating subsidiaries, and thus VEON Ltd. depends on 
cash  dividends,  distributions,  loans  or  other  transfers  received  from  its  subsidiaries  to  make  dividend  payments  to  its 
shareholders and service interest and principal payments in respect of its indebtedness, including holders of ADSs and ordinary 
shares,  and  to  meet  other  obligations.  The  ability  of  its  subsidiaries  to  pay  dividends  and  make  other  transfers  to  VEON  Ltd. 
depends on the success of their businesses and is not guaranteed. 

VEON Ltd.’s subsidiaries are separate and distinct legal entities. Any right that VEON Ltd. has to receive any assets of, 
or distributions from, any subsidiary upon its bankruptcy, dissolution, liquidation or reorganization, or to realize proceeds from the 
sale  of  the  assets  of  any  subsidiary,  may  be  junior  to  the  claims  of  that  subsidiary’s  creditors,  including  trade  creditors. 
Furthermore,  our  ability  to  withdraw  funds  and  dividends  from  our  subsidiaries  and  operating  companies  may  depend  on  the 
consent of our strategic partners where applicable. 

The ability of VEON Ltd.’s subsidiaries to pay dividends and make payments or loans to VEON Ltd., and to guarantee 
the VEON group’s debt, will depend on their operating results and may be restricted by applicable corporate, tax and other laws 
and regulations, including restrictions on dividends, limitations on repatriation of cash and earnings and on the making of loans 
and  repayment  of  debts,  monetary  transfer  restrictions,  covenants  in  debt  agreements,  and  foreign  currency  exchange  and 
related  restrictions  in  certain  agreements  or  certain  jurisdictions  in  which  VEON  Ltd.’s  subsidiaries  operate  or  both.  For  more 
information on the legal and regulatory risks associated with our markets, see Regulatory, Compliance and Legal Risks — “We 
operate in uncertain judicial and regulatory environments.” 

For more information on the restrictions on dividend payments, see Geopolitical Risks — “The banking systems in many 
countries in which we operate remain underdeveloped, there are a limited number of creditworthy banks in these countries with 
which  we  can  conduct  business  and  currency  control  requirements  restrict  activities  in  certain  markets  in  which  we  have 
operations.”  

Initiatives to merge with or acquire other companies or businesses, divest our companies, businesses or assets or to 
otherwise  invest  in  or  form  strategic  partnerships  with  third  parties  may  divert  management  attention  and  resources 
away  from  our  underlying  business  operations,  and  such  efforts  may  not  yield  the  benefits  that  were  expected,  or 
subject us to additional liabilities and higher costs from integration efforts or otherwise.  

We  seek  from  time  to  time  to  merge  with  or  acquire  other  companies  or  businesses,  divest  our  companies  or 
businesses or form strategic partnerships through investments, the formation of joint ventures or otherwise, for various strategic 
reasons,  including  to:  simplify  our  corporate  structure;  pursue  optimal  competitive  positions  in  markets  in  which  we  have 
operations; divest certain operations, business lines or assets, including infrastructure assets; acquire more frequency spectrum; 
acquire  new  technologies  and  service  capabilities;  share  our  networks  or  infrastructure;  add  new  customers;  increase  market 
penetration; expand into new or enhance “non-telecommunications” services such as digital financial services, banking or digital 
content; and expand into new markets. 

Our  ability  to  implement  successful  mergers,  acquisitions,  strategic  partnerships  or  investments  depends  upon  our 
ability  to  identify,  evaluate,  negotiate  the  terms  of,  complete  and  integrate  suitable  businesses  and  to  obtain  any  necessary 
financing and the prior approval of any relevant regulatory bodies. These efforts could divert the attention of our management 
and  key  personnel  from  our  underlying  business  operations.  Following  any  such  merger,  acquisition,  strategic  partnerships  or 
investment  or  failure  of  any  such  transaction  to  materialize  (including  any  such  failure  caused  by  regulatory  or  third-party 
challenges), we may experience:

•

•

•

•

•

•

•

difficulties in realizing expected synergies and investment returns from acquired companies, joint ventures, investments 
or other forms of strategic partnerships;

unsuccessful integration of personnel, products, property and technologies into our existing business;

higher  or  unforeseen  costs  of  integration  or  capital  expenditures  (including  the  time  and  resources  of  our  personnel 
required to successfully integrate any combined businesses); 

difficulties  relating  to  the  acquired  or  formed  companies’  or  our  partnerships’  compliance  with  telecommunications  or 
other  regulatory  licenses  and  permissions,  compliance  with  laws,  regulations  and  contractual  obligations,  ability  to 
obtain  and  maintain  favorable  interconnect  terms,  frequencies  and  numbering  capacity  and  ability  to  protect  our 
intellectual property; 

adverse market reactions stemming from competitive and other pressures; 

difficulties in retaining key employees of the merged or acquired business or strategic partnerships who are necessary 
to manage the relevant businesses; 

difficulties in maintaining uniform standards, controls, procedures and policies throughout our businesses; 

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•

•

•

•

risks related to loss of full control of a merged business, or not having the ability to adequately control and manage an 
acquired business, strategic partnership or investment;   

risks  that  different  geographic  regions  present,  such  as  currency  exchange  risks,  competition,  regulatory,  political, 
economic and social developments, which may, among other things, restrict our ability to successfully capitalize on our 
acquisition, merger, joint venture or investment; 

adverse customer reaction to the business acquisition or combination; and 

increased  liability  and  exposure  to  contingencies  that  we  did  not  contemplate  at  the  time  of  the  merger,  acquisition, 
strategic partnership or investment, including tax liabilities. 

In  addition,  a  merger,  acquisition,  strategic  partnership  or  investment  could  materially  impair  our  operating  results  by 
causing us to incur debt or requiring us to amortize merger or acquisition expenses and merged or acquired assets. We may not 
be  able  to  assess  ongoing  profitability  and  identify  all  actual  or  potential  liabilities  or  issues  of  a  business  prior  to  a  merger, 
acquisition,  strategic  partnership  or  investment.  If  we  merge  with,  acquire,  form  strategic  partnerships  with,  or  invest  in 
businesses  or  assets  and  it  results  in  assuming  unforeseen  liabilities  or  we  have  not  obtained  contractual  protections  or  such 
protection  is  not  available,  our  business,  financial  condition,  results  of  operations,  cash  flows  or  prospects  could  be  adversely 
affected. As we investigate industry consolidation, our risks may increase. Our integration and consolidation of such businesses 
may  also  lead  to  changes  in  our  operational  efficiencies  or  structure.  For  more  information  about  our  recent  transactions,  see 
Note 9 - Significant Transactions to our Audited Consolidated Financial Statements. 

From  time  to  time,  we  may  seek  to  divest  some  of  our  businesses,  including  divestitures  of  operations  in  certain 
markets,  infrastructure  or  business  lines,  but  such  divestitures  may  take  longer  than  anticipated  or  may  not  happen  at  all.    If 
these  or  other  divestitures  do  not  occur,  close  later  than  expected  or  do  not  deliver  expected  benefits,  this  may  result  in 
decreased  cash  proceeds  to  the  group  and  continued  operations  of  non-core  businesses  that  divert  the  attention  of  our 
management.    Our  success  with  any  divestiture  is  dependent  on  effectively  and  efficiently  separating  the  divested  asset  or 
business and reducing or eliminating associated overhead costs which may prove difficult or costly for us. There could also be 
transitional  or  business  continuity  risks  or  both  associated  with  these  divestitures  that  may  impact  our  service  levels  and 
business  targets.  Further,  in  some  cases,  we  may  agree  to  indemnify  acquiring  parties  for  certain  liabilities  arising  from  our 
former  businesses.    Failure  to  successfully  implement  or  complete  a  divestiture  could  materially  harm  our  business,  financial 
condition, results of operations, cash flows or prospects.

Our strategic partnerships and relationships carry inherent business risks. 

We  participate  in  strategic  partnerships  and  joint  ventures  in  a  number  of  countries,  including  in  Pakistan  (Pakistan 
Mobile  Communications  Limited,  "PMCL"),  Kazakhstan  (KaR-Tel  LLP  and  TNS-Plus  LLP),  Algeria  (Omnium  Telecom  Algérie 
S.p.A.,  "OTA"),  Uzbekistan  (Joint  Venture  Buzton  LLC),  Kyrgyzstan  (“Sky  Mobile”  LLC  and  Terra  LLC),  Georgia  (“VEON 
Georgia” LLC) and Singapore (a minority holding in Shopup Pte. Ltd.). In addition, in Algeria, our local partner is a government 
institution, which could increase our exposure to the risks discussed in — Geopolitical Risks.

We do not always have a controlling stake in our affiliated companies and even when we do, our actions with respect to 
these  affiliated  companies  may  be  restricted  to  some  degree  by  shareholders’  agreements  entered  into  with  our  strategic 
partners. In addition, our ability to withdraw funds and dividends from these entities may depend on the consent of partners. If 
disagreements  develop  with  our  partners,  or  any  existing  disagreements  are  exacerbated,  our  business,  financial  condition, 
results of operations, cash flows or prospects may be harmed. 

For example, in Algeria, our partner can acquire the shares held by GTH at fair market value in various circumstances 
(including,  generally,  change  in  VEON’s  indirect  control  of  OTA,  insolvency  of  GTH  or  VEON  or  material  breach  of  the 
shareholders’  agreement  by  GTH),  as  well  as  under  call  option  arrangements  exercisable  solely  at  its  discretion  between 
October 1, 2021 and December 31, 2021.  Concurrently, GTH has a right to require our partner in Algeria to acquire its shares in 
various circumstances (including, generally, change of control of the Algerian National Investment Fund, material breach of the 
shareholders’  agreement  by  the Algerian  National  Investment  Fund,  loss  of  VEON’s  ability  to  consolidate  OTA,  the  taking  of 
certain  actions  in  Algeria  against  GTH  or  OTA,  failure  by  OTA  to  pay  a  minimum  dividend  or  imposition  of  certain  tax 
assessments),  as  well  as  under  put  option  arrangements  exercisable  solely  at  its  discretion  between  July  1,  2021  and 
September 30, 2021.  In September 2020, in Pakistan, our partner the Dhabi Group, exercised its put option to sell us, at fair 
value (based on a mechanism established under the applicable shareholders’ agreement), its 15% shareholding in PMCL, the 
operating  company  of  our  subsidiary  Jazz.    Completion  of  the  transfer  remains  subject  to  the  conclusion  of  the  contractual 
transfer mechanics with the Dhabi Group, and once completed, VEON will indirectly own 100% of PMCL.

If one of our strategic partners becomes subject to investigation, sanctions or liability, or does not act in accordance with 
our  standards,  we  might  be  adversely  affected.  Furthermore,  strategic  partnerships  in  emerging  markets  are  accompanied  by 
risks inherent to those markets, such as an increased possibility of a partner defaulting on obligations or losing a partner with 
important insights in that region.

If  any  of  the  above  circumstances  occur,  or  we  otherwise  determine  that  a  partnership  or  joint  venture  is  no  longer 
yielding the benefits we expect to achieve, we may decide to unwind such initiative, which may result in significant transaction 
costs or an inferior outcome than was expected when we entered into such partnership or joint venture.

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We  depend  on  third  parties  for  certain  services  and  equipment,  infrastructure  and  other  products  important  to  our 
business. 

We  rely  on  third  parties  to  provide  services  and  products  important  for  our  operations.  We  currently  purchase  the 
majority of our network-related equipment from a core number of suppliers, principally Ericsson, Huawei, Nokia, Cisco and ZTE. 
The  successful  build-out  and  operation  of  our  networks  depends  heavily  on  obtaining  adequate  supplies  of  core  and 
transmission telecommunications equipment, fiber, switching equipment, radio access network solutions, base stations and other 
services and products on a timely basis. From time to time, we have experienced delays in receiving equipment, installation of 
equipment,  and  maintenance  services.  Delivery  of  equipment  can  be  delayed  by  new  and  existing  telecommunications 
regulations, customs regulations and governmental investigations or enforcement actions.  Our vendors’ ability to deliver on key 
network and IT projects can be affected by global events such as pandemics, as we saw in the recent COVID-19 pandemic, by 
trade tensions and new regulations.

Our  business  could  be  materially  impacted  by  disruptions  to  our  core  suppliers’  businesses  or  supply  chains,  due  to 
developments  such  as  significant  geopolitical  events,  changes  in  law  or  regulation,  public  health  issues  (such  as  the 
coronavirus),  and  export  and  re-export  restrictions  that  affect  our  and  our  suppliers’  ability  to  procure  goods,  software  or 
technology necessary for the service, production and satisfactory delivery of the supplies, support services, and equipment that 
we source from them. For example, in May and August 2019, the U.S. Department of Commerce added Huawei and 114 of its 
affiliates  to  its  “Entity  List”,  prohibiting  companies  globally  from  directly  or  indirectly  exporting,  re-exporting  or  transferring  (in-
country) all items subject to the EAR to Huawei and procuring items from Huawei when they know or have reason to know that 
the items were originally procured by Huawei in violation of the EAR.  Further restrictions adopted by the United States, or any 
other  applicable  jurisdiction,  on  Huawei  could  potentially  have  a  material  adverse  impact  on  our  operations  in  certain  markets 
where we are reliant on Huawei equipment or services. Specifically, any restriction on Huawei’s ability to deliver equipment or 
services,  or  on  our  ability  to  receive  such  equipment  or  services,  could  adversely  impact  our  business,  the  operation  of  our 
networks and our ability to comply with the terms of our operating licenses and local laws and regulations.

We have and may continue to outsource all or a portion of construction, maintenance services, IT infrastructure hosting 
and network capabilities in certain markets in which we operate. For example, our digital stacks and data management platforms 
are  dependent  on  third  parties.  We  have  also  partially  implemented  outsourcing  initiatives  in  a  number  of  markets  including 
Russia and Kazakhstan. For more information on such initiatives, see - Property, Plants and Equipment. Our business could be 
materially  harmed  if  our  agreements  with  third  parties  were  to  terminate,  if  our  partners  experience  certain  negative 
developments (financial, legal, regulatory or otherwise), or a dispute between us and such parties occurs, causing the parties to 
no  longer  be  able  to  deliver  the  required  services  on  a  timely  basis  or  at  all  or  otherwise  fulfill  their  obligations  under  our 
agreements with them. If such events occur, we may attempt to renegotiate the terms of such agreements with the third parties. 
For  example,  in  February  2019,  we  entered  into  a  revised  agreement  with  Ericsson  to  upgrade  core  IT  systems  in  several 
countries  with  new  digital  business  support  systems  (DBSS).  For  more  information  on  this  revised  agreement,  see  -  Business 
Overview  -  Information  Technology.  There  can  be  no  assurance  that  the  terms  of  such  amended  agreements  will  be  more 
favorable to us than those of the original agreements. For more information, see — Property, Plants and Equipment. As a result, 
the implementation of such initiatives, including our digital stacks and data management platforms, is dependent on third parties. 

We  also  depend  on  third  parties,  including  software  providers  and  service  providers,  for  our  day-to-day  business 
operations. For example, we rely on roaming partners to provide services to our customers while they are outside the countries 
in  which  we  operate  and  on  interconnect  providers  to  complete  calls  that  originate  on  our  networks  but  terminate  outside  our 
networks, or that originate outside our networks and terminate on our networks. Certain roaming partners have been targeted by 
sanctions restrictions which has led us to change or terminate certain roaming relationships. We also rely on handset providers 
to provide the equipment used on our networks. Many of our mobile products and services are sold to customers through third 
party  channels.  These  third-party  retailers,  agents  and  dealers  that  we  use  to  distribute  and  sell  products  are  not  under  our 
control and may stop distributing or selling our products at any time or may more actively promote the products and services of 
our competitors. Should this occur with particularly important retailers, agents or dealers, we may face difficulty in finding new 
retailers, sales agents or dealers that can generate the same level of revenue. Any negative developments regarding the third 
parties  on  which  we  depend  could  materially  harm  our  business,  financial  condition,  results  of  operations,  cash  flows  or 
prospects.

The  telecommunications  industry  is  highly  capital  intensive  and  requires  substantial  and  ongoing  expenditures  of 
capital. 

The telecommunications industry is highly capital intensive. Our success depends to a significant degree on our ability 
to keep pace with new developments in technology, to develop and market innovative products and to update our facilities and 
process  technology,  which  will  require  additional  capital  expenditures  in  the  future.  The  amount  and  timing  of  our  capital 
requirements  will  depend  on  many  factors,  including  acceptance  of  and  demand  for  our  products  and  services,  the  extent  to 
which we invest in new technology and research and development projects, the status and timing of competitive developments, 
and certain regulatory requirements. 

Although we regularly consider and take measures to improve our capital efficiency, including selling capital intensive 
segments of our business and entering into managed services and network sharing agreements with respect to towers and other 
assets,  our  levels  of  capital  expenditure  will  remain  significant.  If  we  do  not  have  sufficient  resources  from  our  operations  to 
finance  necessary  capital  expenditures,  we  may  be  required  to  raise  additional  debt  or  equity  financing,  which  may  not  be 
available when needed or on terms favorable to us or at all. If we are unable to obtain adequate funds on acceptable terms, or at 

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all,  we  may  be  unable  to  develop  or  enhance  our  products,  take  advantage  of  future  opportunities  or  respond  to  competitive 
pressures,  which  could  harm  our  business,  financial  condition,  results  of  operations,  cash  flows  or  prospects.  For  more 
information  on  our  future  liquidity  needs,  see  —  Operating  and  Financial  Review  and  Prospects  —  Liquidity  and  Capital 
Resources — Future Liquidity and Capital Requirements.

Cyber-attacks  and  other  cybersecurity  threats  may  lead  to  compromised  or  inaccessible  telecommunications,  digital 
and  financial  services  and/or  leaks  or  unauthorized  processing  of  confidential  information,  and  perceptions  of  such 
threats may cause customers to lose confidence in our services. 

Each  of  our  subsidiaries  is  responsible  for  managing  cybersecurity  risks  locally,  including  all  operational  preventive, 
detective  and  response  capabilities,  and  as  a  group  our  operations  and  business  continuity  depend  on  how  well  these 
subsidiaries  collectively  protect  and  maintain  our  network  equipment,  information  technology  (“IT”)  systems  and  other  assets. 
Due to the nature of the services we offer across our geographical footprint, we are exposed to cybersecurity threats that could 
negatively  impact  our  business  activities  through  service  degradation,  alteration  or  disruption,  including  a  risk  of  unauthorized 
access to our systems, networks and data by third parties, whether private or state-sponsored, utilizing unidentified existing or 
new weaknesses, flaws or backdoors into network or IT systems. Cybersecurity threats could also lead to the compromise of our 
physical  assets  dedicated  to  processing  or  storing  customer  and  employee  information,  financial  data  and  strategic  business 
information, exposing this information to possible leakage, unauthorized dissemination and loss of confidentiality. These events 
could result in reputational harm, lawsuits against us by customers, employees or other third parties, violations of data protection 
and telecommunications laws, adverse actions by telecommunications regulators and other authorities, an inability to operate our 
digital  services  or  our  wireless  or  fixed-line  networks,  loss  of  revenue  from  business  interruption,  loss  of  market  share  or 
significant  additional  costs.  In  addition,  the  potential  liabilities  associated  with  these  events  could  exceed  the  cyber  insurance 
coverage  we  maintain  and  certain  violations  of  data  protection  and  telecommunications  laws  (including  as  a  result  of  data 
leakage)  are  administrative  or  criminal  offenses  in  some  countries,  and  can  result  in  suspension  of  operating  licenses, 
imprisonment or fines for the entity and/or the individuals involved. 

Although we devote significant resources to the development and improvement of our IT and security systems, we are 
and  will  continue  to  remain  vulnerable  to  cyber-attacks  and  other  cybersecurity  threats  that  could  lead  to  compromised  or 
inaccessible  telecommunications,  digital  and  financial  services  and/or  leaks  or  unauthorized  processing  of  confidential 
information, including customer information. Our systems are vulnerable to harmful viruses and the spread of malicious software 
that could compromise the confidentiality, integrity or availability of technology assets. In addition, unauthorized users or hackers 
may  access  and  process  the  customer  and  business  information  we  hold,  or  authorized  users  may  improperly  process  such 
data. Such risks are inherent in our business operations and we will never be able to fully insulate ourselves from these risks.  
Our systems will remain vulnerable to attacks by third parties who are able to thwart the safeguards we have in place with tactics 
that are unforeseen or prove to be too sophisticated.  Moreover, we may experience cyber-attacks and IT and network failures 
and outrages due to factors under our control, such as malfunction of technology assets or services caused by obsolescence, 
wear  or  defects  in  design  or  manufacturing,  faults  during  standard  or  extraordinary  maintenance  procedures,  unforeseen 
absence of key personnel, and the inability to protect our systems from phishing attacks.

From time to time, we have experienced cyber-attacks of varying degrees to gain access to our computer systems and 
networks. As of the date of this Annual Report on Form 20-F, we have suffered various cybersecurity incidents, which targeted 
our internal infrastructure but were contained by our response teams and generated limited or negligible impacts. In addition, we 
have  identified  unauthorized  access  to  some  of  our  network  systems,  possibly  with  the  intention  to  capture  information  or 
manipulate  the  communications.  Although  we  found  no  evidence  that  any  such  capture  or  manipulation  was  performed,  we 
cannot guarantee that they did not take place, that all such attempts will be successfully thwarted in the future or that the impact 
of such attempts, if successful, would not be material to our business. There is also a possibility that we are not currently aware 
of certain undisclosed vulnerabilities in our IT systems and other assets. In such an event, hackers or other cybercrime groups 
(whether private or state-sponsored) may exploit such vulnerabilities, weaknesses or unidentified backdoors (including previously 
unidentified designed weaknesses embedded into network or IT equipment allowing access by private or government actors) or 
may be able to cause harm more quickly than we are able to mitigate (zero-day exploits). 

Our business is also subject to disruption by computer malware or other technical or operational issues. Although our 
subsidiaries  have  implemented  cyber-security  strategies  for  mitigating  these  risks,  we  cannot  be  sure  that  our  network  and 
information technology systems will not be subject to such issues, or, if they are, that we will be able to maintain the integrity of 
our  customers’  and  employees’  data  or  that  malware  or  other  technical  or  operational  issues  will  not  disrupt  our  network  or 
systems and cause significant harm to our operations. For example, in recent years, we have experienced infections by malware, 
advanced  persistent  threats,  and  network  service  interruptions  during  installations  of  new  software.  In  some  regions,  our 
equipment for the provision of mobile services resides in a limited number of locations or buildings. Disruption to the security or 
operation  of  these  locations  or  buildings  could  result  in  disruption  of  our  mobile  services  in  those  regions.  Moreover,  the 
implementation of our transformation strategies may result in under-investments or failures in internal business processes, which 
may in turn result in greater vulnerability to technical or operational issues, including harm from failure to detect malware. 

If our services are affected by such attacks and malware and this degrades our services, our products and services may 
be perceived as being vulnerable to cyber risk and the integrity of our data protection systems may be questioned. As a result, 
users and customers may curtail or stop using our products and services, and we may incur litigation exposure, regulatory fines, 
penalties, reimbursement or other compensatory costs.

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Our  equipment  and  systems  are  subject  to  disruption  and  failure  for  various  reasons  which  could  cause  us  to  lose 
customers, limit our growth, violate our licenses or reduce the confidence of our customers in our ability to securely 
hold their personal data. 

Our business depends on providing customers with reliability, capacity and security. Our technological infrastructure is 
vulnerable  to  damage  or  disruptions  from  other  events,  including  natural  disasters,  military  conflicts,  power  outages,  terrorist 
acts,  riots,  government  shutdown  orders,  changes  in  government  regulation,  equipment  or  system  failures  or  an  inability  to 
access or operate such equipment or systems, human error or intentional wrongdoings, such as breaches of our network, cyber-
attacks  or  any  other  types  of  information  technology  security  threats.  For  example,  we  may  experience  network  or  technology 
failures  or  a  leak  or  unauthorized  processing  of  confidential  customer  data  if  our  technology  assets  are  altered,  damaged, 
destroyed or misused, by employees, third parties or users, either intentionally or due to human error. In addition, as we operate 
in countries which may have an increased threat of terrorism and military conflict, incidents on or near our premises, equipment 
or  points  of  sale  could  result  in  causalities,  property  damage,  business  interruption,  legal  liability  and  damage  to  our  brand  or 
reputation. 

Interruptions of services could harm our reputation and reduce the confidence of our customers to hold their personal 
data, and consequently impair our ability to obtain and retain customers and could lead to a violation of the terms of our licenses, 
each of which could materially harm our business. In addition, the potential liabilities associated with these events could exceed 
the business interruption insurance we maintain. 

Our  ability  to  profitably  provide  telecommunications  services  depends  in  part  on  the  terms  of  our  interconnection 
agreements and access to third-party owned infrastructure and networks. 

Our ability to secure and maintain interconnection agreements with other wireless and local, domestic and international 
fixed-line operators and, upon access to infrastructure, networks and connections that are owned or controlled by third parties 
and governments, on cost-effective terms is critical to the economic viability of our operations. The countries in which we operate 
have a limited number of international cable connections providing access to internet, data service and call interconnection and 
such international connections may be controlled by national governments that may seek to control or restrict access from time 
to  time  or  impose  conditions  on  pricing  and  availability  which  may  impact  our  access  and  the  competitiveness  of  our  pricing.  
Outages, disconnections or restrictions, including governmental, to access affecting these international connections can have a 
significant impact on our ability to offer services and data connectivity to our customers.  Interconnection is required to complete 
calls that originate on our respective networks but terminate outside our respective networks, or that originate from outside our 
respective networks and terminate on our respective networks. In certain jurisdictions in which we operate, the relevant regulator 
sets mobile termination rates (“MTRs”). If any such regulator sets MTRs that are lower for us than the MTRs of our competitors, 
our interconnection costs may be higher and our interconnection revenues may be lower, relative to our competitors. Moreover, 
even in cases of equal MTRs on the market for all players, the lowered MTR significantly impacts our revenues on a particular 
market.  A  significant  increase  in  our  interconnection  costs,  or  decrease  in  our  interconnection  rates,  as  a  result  of  new 
regulations, commercial decisions by other fixed-line operators, increased inflation rates in the countries in which we operate or a 
lack  of  available  line  capacity  for  interconnection  could  harm  our  ability  to  provide  services,  which  could  in  turn  harm  our 
business,  financial  condition,  results  of  operations,  cash  flows  or  prospects.  For  more  information  on  our  interconnection 
agreements, see — Business Overview.

Our intellectual property rights are costly and difficult to protect, and we cannot guarantee that the steps we have taken 
to protect our intellectual property rights will be adequate. 

We  regard  our  copyrights,  service  marks,  trademarks,  trade  names,  trade  secrets,  know-how  and  similar  intellectual 
property,  including  our  rights  to  certain  domain  names,  as  important  to  our  continued  success.  For  example,  our  widely 
recognized logos, such as “VEON”, “Beeline” (Russia, Kazakhstan, Uzbekistan, Georgia and Kyrgyzstan), “Kyivstar” (Ukraine), 
“Jazz” (Pakistan), “Djezzy” (Algeria) and “banglalink” (Bangladesh), have played an important role in building brand awareness 
for our services and products. We rely upon trademark and copyright law, trade secret protection and confidentiality or license 
agreements with our employees, customers, partners and others to protect our proprietary rights. However, intellectual property 
rights are especially difficult to protect in many of the markets in which we operate. In these markets, the regulatory agencies 
charged to protect intellectual property rights are inadequately funded, legislation is underdeveloped, piracy is commonplace and 
enforcement of court decisions is difficult. 

We are in the process of registering, and maintaining and defending the registration of, the VEON name and logo as 
trademarks  in  the  jurisdictions  in  which  we  operate  and  other  key  territories,  along  with  our  other  key  trademarks  and 
tradenames,  logos  and  designs.  As  of  the  date  of  this  Annual  Report,  we  have  achieved  registration  of  the  VEON  name  in 
thirteen of the seventeen jurisdictions sought (although in only certain classes in the European Union), with the remaining four 
pending.  With  respect  to  the  logo,  we  have  achieved  registration  in  thirteen  of  the  seventeen  jurisdictions  sought  (although  in 
only certain classes in the European Union and Bermuda), with the remaining four pending. The timeline and process required to 
obtain trademark registration can vary widely between jurisdictions.

As we continue our investment into a growing ecosystem of local digital services, we will need to ensure that we have 
adequate legal rights to the ownership or use of necessary source code, content, and other intellectual property rights associated 
with our systems, products and services. For example, a number of platforms and non-connectivity services offered by VEON 
and its operating companies are developed using source code created in conjunction with third parties. We rely on a combination 
of contractual provisions and intellectual property law to protect our proprietary technology and software, access to and use of 
source code and other necessary intellectual property. Third parties may infringe or misappropriate our intellectual property. As 

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the number of convergent product offerings, such as JazzCash or Beeline TV, and overlapping product functions increase, the 
possibility of intellectual property infringement claims against us may increase. Any such litigation may result in substantial costs 
and diversion of resources, and adverse litigation outcomes could harm our business, financial condition, results of operations, 
cash flows or prospects. We may have to litigate to enforce and protect our copyrights, trademarks, trade names, trade secrets 
and know-how or to determine their scope, validity or enforceability. In that event, we may be required to incur significant costs, 
and our efforts may not prove successful. The inability to secure or protect our intellectual property assets could have a material 
adverse effect on our business and our ability to compete. 

In  addition,  new  intellectual  property  laws  or  regulations  may  require  us  to  invest  substantial  resources  or  may  be 
unclear. Current and new intellectual property laws may affect the ability of companies, including us, to protect their innovations 
and defend against claims of intellectual property rights infringement. The costs of compliance with these laws and regulations 
are high and are likely to increase in the future.  Claims have been, or may be threatened and/or filed against us for intellectual 
property infringement based on the nature and content in our products and services, or content generated by our users. 

Current and new intellectual property laws may affect the ability of companies, including us, to effectively protect their 
innovations and defend against claims of intellectual property rights infringement. The costs of compliance with these laws and 
regulations are high and are likely to increase in the future.  Claims have been, or may be threatened and/or filed against us for 
intellectual  property  infringement  based  on  the  nature  and  content  in  our  products  and  services,  or  content  generated  by  our 
users. 

We  depend  on  our  senior  management  and  highly  skilled  personnel,  and,  if  we  are  unable  to  retain  or  motivate  key 
personnel,  hire  qualified  personnel,  or  implement  our  strategic  goals  or  corporate  culture  through  our  personnel,  we 
may not be able to maintain our competitive position or to implement our business strategy.  

Our performance and ability to maintain our competitive position and to implement our business strategy is dependent 
in certain important respects on our global senior management team, highly skilled personnel and their level of continuity. In the 
markets in which we operate, competition for qualified personnel with relevant expertise is intense. There is sometimes limited 
availability of individuals with the requisite knowledge of the telecommunications and the digital services industries, the relevant 
experience and, in the case of expatriates, the ability or willingness to accept work assignments in certain of the jurisdictions in 
which we operate. We have experienced in recent years, and may continue to experience, certain changes in key management. 

The  loss  of  any  key  personnel  or  an  inability  to  attract,  train,  retain  and  motivate  qualified  members  of  senior 
management or highly skilled personnel could have an adverse impact on our ability to compete and to implement new business 
models and could harm our business, financial condition, results of operations, cash flows or prospects. In addition, we may not 
succeed  in  instilling  our  corporate  culture  and  values  in  new  or  existing  employees,  which  could  delay  or  hamper  the 
implementation of our strategic priorities, or our compensation schemes may not always be successful in attracting new qualified 
employees and retaining and motivating our existing employees. 

Our success is also dependent on our personnel’s ability to adapt to rapidly changing environments and to perform in 
pace with continuous innovations and industry developments.  We also may, from time to time, make adjustments or changes to 
our operating and governance model and there is a risk in such instances that our personnel and the overall organization may 
not  effectively  adapt.   Although  we  devote  significant  attention  to  recruiting  and  training,  there  can  be  no  assurance  that  our 
existing personnel will successfully be able to adapt to and support our strategic priorities. There is also a possibility that we are 
unable to attract qualified individuals with the requisite skills to implement our digital initiatives or other business strategies.

We  face  uncertainty  regarding  our  frequency  allocations  and  may  experience  limited  spectrum  capacity  for  providing 
wireless  services,  and  are  subject  to  risk  that  government  action  results  in  requiring  us  to  transfer  our  existing 
spectrum allocations. 

To  establish  and  commercially  launch  mobile  and  fixed  wireless  telecommunications  networks,  we  need  to  receive 
frequency allocations for bandwidths within the frequency bands in the regions in which we operate. The availability of spectrum 
is limited, closely regulated and can be expensive, and we may not be able to obtain it from the regulator or third parties at all or 
at a price that we deem to be commercially acceptable given competitive conditions or without the imposition of certain service 
obligations, which could be burdensome. There are a limited number of frequencies available for mobile operators in each of the 
regions in which we operate or hold licenses to operate. We are dependent on access to adequate frequency allocation in each 
such  market  in  order  to  maintain  and  expand  our  customer  base.  In  the  past,  we  have  experienced  difficulties  in  obtaining 
adequate frequency allocation in some of the markets in which we operate.  For instance, in Russia, we have previously been 
unable to obtain frequency allocations in an assigned frequency band for LTE network development and, in Bangladesh, while 
we are currently one of the largest operators, we until recently held a disproportionately small amount of the frequency spectrum.  
In addition, frequency allocations may be issued for periods that are shorter than the terms of our licenses, and such allocations 
may not be renewed in a timely manner, or at all.    

We  are  also  subject  to  the  risk  that  government  action  impairs  our  frequency  allocations  or  spectrum  capacity.  For 
example,  in  2017,  the  government  of  Uzbekistan  published  a  decision  ordering  the  equitable  reallocation  amongst  all 
telecommunications  providers  in  the  market,  which  has  affected  approximately  half  of  the  900  MHz  and  1800  MHz  radio 
frequencies of our Uzbek subsidiary, Unitel LLC. The decision, which also granted tech neutrality in the 900 MHz and 1800 MHz 
bands, came into force on March 31, 2018. In addition, the Ministry of Digital Development, Communications and Mass Media of 
the Russian Federation (formerly, the Ministry of Telecom and Mass Communications of the Russian Federation) has published a 
number of regulations regarding frequency allocation, consolidation and conversation, and increase of spectrum fees.  

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We may also be subject to increases in fee payments for frequency allocations under the terms of some of our licenses 
or to obtain new licenses. 

Legislation in many countries in which we operate, including Russia and Pakistan, requires that we make payments for 
frequency spectrum usage. As a whole, the fees for all available frequency assignments, as well as allotted frequency bands for 
different  mobile  communications  technologies,  have  been  significant.    For  example,  in  Pakistan,  the  PTA  issued  a  license 
renewal decision on July 22, 2019 requiring payment of an aggregate price of approximately US$450 million, a price which we 
are currently disputing in the Islamabad High Court, where the most recent hearing on this matter was concluded on March 1, 
2021  and  a  judgment  is  now  pending.  Any  significant  increase  in  the  fees  payable  for  the  frequencies  that  we  use  or  for 
additional  frequencies  that  we  need  could  have  a  negative  effect  on  our  financial  results.  We  expect  that  the  fees  we  pay  for 
radio-frequency  spectrum,  including  radio-frequency  spectrum  renewals,  could  substantially  increase  in  some  or  all  of  the 
countries in which we operate, and any such increase could harm our business, financial condition, results of operations, cash 
flows or prospects.

If our frequency allocations are limited, we are unable to renew our frequency allocations or obtain new frequencies to 
allow  us  to  provide  mobile  or  fixed  wireless  services  on  a  commercially  feasible  basis,  our  network  capacity  and  our  ability  to 
provide these services would be constrained and our ability to expand would be limited, which could harm our business, financial 
condition, results of operations, cash flows or prospects. 

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Regulatory, Compliance and Legal Risks

We operate in uncertain judicial and regulatory environments, which may result in unanticipated outcomes that harm 
our business. 

In  many  of  the  emerging  market  countries  where  we  operate,  the  application  of  the  laws  and  regulations  of  any 

particular country is frequently unclear and may result in unpredictable outcomes, including:

•

•

•

restrictions  or  delays  in  obtaining  additional  numbering  capacity,  receiving  new  licenses  and  frequencies,  receiving 
regulatory  approvals  for  rolling  out  our  networks  in  the  regions  for  which  we  have  licenses,  receiving  regulatory 
approvals for the use of changes to our frequency, receiving regulatory approvals of our tariffs plans and importing and 
certifying our equipment; 

significant additional costs, including fines and penalties, operational burdens and other difficulties associated with not 
complying in a timely manner, or at all, with new or existing legislation or the terms of any notices or warnings received 
from the telecommunications and other regulatory authorities; and 

adverse  rulings  or  audit  findings  by  courts  or  government  authorities  resulting  from  a  change  in  interpretation  or 
inconsistent application of existing law, 

each  of  which  may  cause  delays  in  implementing  our  strategies  and  business  plans  and  create  a  more  challenging  operating 
environment.    If  we  are  found  to  be  involved  in  practices  that  do  not  comply  with  applicable  laws  or  regulations,  we  may  be 
exposed  to  significant  fines,  the  risk  of  prosecution  or  the  suspension  or  loss  of  our  licenses,  frequency  allocations, 
authorizations  or  various  permissions,  any  of  which  could  harm  our  business,  financial  condition,  results  of  operations,  cash 
flows or prospects. 

New or proposed changes to laws or new interpretations of existing laws in the markets in which we operate may harm 
our business. 

We are subject to a variety of national and local laws and regulations in the countries in which we do business. These 
laws  and  regulations  apply  to  many  aspects  of  our  business.  Violations  of  applicable  laws  or  regulations  could  damage  our 
reputation  or  result  in  regulatory  or  private  actions  with  substantial  penalties  or  damages,  including  the  revocation  of    our 
licenses.  In  addition,  any  significant  changes  in  such  laws  or  regulations  or  their  interpretation,  or  the  introduction  of  higher 
standards, additional obligations or more stringent laws or regulations, including revision in regulations for license and frequency 
allocation and changes in foreign policy or trade restrictions and regulations (such as those resulting from recent tariff disputes 
between the United States and China) could have an adverse impact on our business, financial condition, results of operations 
and prospects. 

For  example,  in  some  of  the  markets  in  which  we  operate,  SIM  verification  and  re-verification  initiatives  have  been 
implemented.  In  Pakistan,  our  subsidiary  was  required  to  re-verify  more  than  38  million  SIM  cards  in  2016,  with  operators 
blocking all SIM cards that could not be verified. This resulted in a loss of approximately 13% of its customer base. In addition, 
the Pakistan Prevention of Electronic Crimes Act of 2016 introduced sentencing and heavy fines for certain traditional marketing 
activities,  thus  directly  impacting  how  we  conduct  our  business.  Similar  actions  may  be  contemplated  or  introduced  in  other 
markets in which we operate. In addition to customer losses, such requirements can result in claims from legitimate customers 
who  are  incorrectly  blocked,  fines,  license  suspensions  and  other  liabilities  for  failure  to  comply  with  the  requirements. To  the 
extent re-verification and/or new verification requirements are imposed in the jurisdictions in which we operate, it could have an 
adverse impact on our business, financial condition, results of operations and prospects.

Many jurisdictions in which we operate have seen the adoption of data localization and protection laws that prohibit the 
collection  of  certain  personal  data  through  servers  located  outside  of  the  respective  jurisdictions.  For  example,  in  Russia, 
telecommunications operators are required to provide information to Russian investigative authorities and gradually install pre-
approved equipment to ensure storage of metadata for three years and contents of communications for six months pursuant to 
Federal Law No 374-FZ (commonly referred to as the Yarovaya laws). Violation of these laws by an operator may result in fines, 
suspension of activities or license revocation. For more information on the Yarovaya laws, see “Anti-terror legislation passed in 
Russia and other jurisdictions could result in additional operating costs and capital expenditures and may harm our business.” 

In some jurisdictions in which we operate legislation is being implemented to establish a legal framework for preventing 
cyber-attacks and protecting critical information infrastructure. For example, Russian telecommunications operators are obliged 
to  take  various  measures  to  protect  their  information  infrastructure,  provide  reliable  data  transmission  channels  and  inform 
government agencies and partners about incidents on critical information infrastructure. In addition, Federal Law No. 90-FZ “On 
certain  amendments  to  the  Federal  Law  ‘On  communications’  and  Federal  Law  ‘On  information,  information  technologies  and 
information protection’” (commonly referred to as the RuNet law) was adopted in Russia in 2019. The RuNet law is aimed at the 
development of an autonomous system that can support the operation of the internet in Russia in the event of disconnection from 
the global network and allow the Russian government to centralize, control and restrict data traffic in case of certain emergencies 
as may be determined by the Russian authorities. The provisions of the RuNet law impose a number of obligations that aim to 
ensure the centralization and control over data traffic on a broad range of persons. Telecommunications operators, including us, 
are  required  to,  among  other  things,  install  counter-threat  equipment  to  be  provided  by  the  Russian  authorities,  participate  in 
trainings  and  file  certain  notifications  to  the  Russian  authorities.  We  are  in  the  process  of  ensuring  compliance  with  these 
requirements. However, the application of the RuNet law may, among other things, reduce the data transfer speed significantly, 
adversely affect the functioning of our infrastructure and business operations, restrict the use of or result in interruption of certain 

71

services,  and  trigger  material  costs.    Most  of  the  provisions  of  the  RuNet  law  and  subordinate  legislation  entered  into  force 
between  November  1,  2019  and  May  11,  2020.  On  December  30,  2020,  the  Russian  government  decree  “On  licensing  of 
activities  in  the  field  of  communication  services”  introduced  a  new  license  requirement:  ensuring  the  implementation  of 
requirements related to the stability, security and integrity of the internet. The new provisions came into force on January 1, 2021. 
The implementation and support of measures to comply with the legislation may lead to substantial investments.

We are, and may in the future be, involved in, associated with, or otherwise subject to legal liability in connection with 
disputes and litigation with regulators, competitors and third parties. 

We are party to a number of lawsuits and other legal, regulatory or antitrust proceedings and commercial disputes, the 
final outcome of which is uncertain. Litigation and regulatory proceedings are inherently unpredictable. An adverse outcome in, or 
any disposition of, these or other proceedings, including any that may be asserted in the future, could harm our reputation and 
have an adverse impact on our business, financial condition, results of operations, cash flows or prospects. For more information 
on these disputes, see Note 7 - Provisions and Contingent Liabilities to our Audited Consolidated Financial Statements. 

In addition, we currently host and provide a wide variety of services and products that enable users to engage in various 
online activities. The law relating to the liability of providers of these online services and products for the activities of their users is 
still  unsettled  in  some  jurisdictions.  Claims  may  be  threatened  or  brought  against  us  for  defamation,  negligence,  breaches  of 
contract, copyright or trademark infringement, unfair competition, tort, including personal injury, fraud, or other grounds based on 
the nature and content of information that we use and store. In addition, we may be subject to domestic or international actions 
alleging  that  certain  content  we  have  generated,  user-generated  content  or  third-party  content  that  we  have  made  available 
within our services violates applicable law. 

We may also be subject to claims concerning certain third-party products, services or content we provide by virtue of 
our involvement in marketing, branding, broadcasting, or providing access to them, even if we do not ourselves host, operate, 
provide,  or  provide  access  to,  these  products,  services  or  content.  Defense  of  any  such  actions  could  be  costly  and  involve 
significant time and attention of our management and other resources, may result in monetary liabilities or penalties, and may 
require us to change our business in an adverse manner.

We  may  not  be  able  to  detect  and  prevent  fraud  or  other  misconduct  by  our  employees,  joint  venture  partners,  non-
controlled subsidiaries, representatives, agents, suppliers, customers or other third parties.

We may be exposed to fraud or other misconduct committed by our employees, joint venture partners, representatives, 
agents, suppliers, customers or other third parties undertaking actions on our behalf that could subject us to litigation, financial 
losses and fines or penalties imposed by governmental authorities, and affect our reputation. Such misconduct could include, but 
is  not  limited  to,  misappropriating  funds,  conducting  transactions  that  are  outside  of  authorized  limits,  engaging  in 
misrepresentation or fraudulent, deceptive or otherwise improper activities, including activities in exchange for personal benefit or 
gain or activities that otherwise do not complying with applicable laws or our internal policies and procedures. The risk of fraud or 
other misconduct could increase as we expand certain areas of our business. 

We  regularly  review  and  update  our  policies  and  procedures  and  internal  controls,  which  are  designed  to  provide 
reasonable  assurance  that  we  and  our  employees  comply  with  applicable  laws  and  our  internal  policies.  VEON  Ltd.  issued  a 
Business  Partner  Code  of  Conduct  that  we  expect  our  representatives,  agents,  suppliers  and  other  third  parties  to  follow.  In 
addition, we conduct risk-based training for our employees.  However, are no guarantees that such policies, procedures, internal 
controls  and  training  will,  at  all  times,  prevent  or  detect  misconduct  and  protect  us  from  liability  arising  from  actions  of  our 
employees, representatives, agents, suppliers, customers or other third parties. 

In  addition  to  legal  and  financial  liability,  our  reputation  may  be  adversely  impacted  by  association,  action  or  inaction 
that  is  perceived  by  stakeholders  or  customers  to  be  inappropriate  or  unethical  and  not  in  keeping  with  the  group’s  stated 
purposes and values. Reputational risk may arise in many different ways, including, but not limited to any real or perceived:

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failure to act in good faith and in accordance with the group’s values, Code of Conduct, other policies, procedures, and 
internal standards; 

failure to comply with applicable laws or regulations or association, real or perceived, with illegal activity; 

failure in corporate governance, management or systems; 

association with controversial practices, customers, transactions, projects, countries or governments; 

association with controversial business decisions, including but not limited to, those relating to existing or new products, 
delivery  channels,  promotions/advertising,  acquisitions,  representation,  sourcing/supply  chain  relationships,  locations, 
or treatment of financial transactions; or 

association with poor employment or human rights practices.

Our Mobile Financial Services (“MFS”) and Digital Financial Services (“DFS”) offerings are complex and increase our 
exposure to fraud, money laundering, reputational and regulatory risk. 

MFS  and  DFS  offerings  are  complex  and  subject  to  regulatory  requirements  which  can  be  different  from  regulatory 
requirements  of  a  telecommunications  business. They  may  involve  cash  handling  or  other  value  transfers,  exposing  us  to  risk 

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that  our  customers  or  business  partners  engage  in  fraudulent  activities,  money  laundering  or  terrorism  financing.  Violations  of 
anti-money  laundering  and  counter-terrorist  financing  laws,  know-your-customer  rules,  and  customer  name  screening  and 
monitoring  requirements  or  other  regulations  applicable  to  our  MFS/DFS  offerings  could  have  material  adverse  effects  on  our 
financial  condition  and  results  of  operations  and  result  in  legal  and  financial  liability  or  reputational  damage.  The  regulations 
governing these services are evolving and, as they develop, regulations could become more onerous, impose additional controls, 
reporting or disclosure obligations, or limit our flexibility to rapidly deploy new products, which may limit our ability to provide our 
services efficiently or in the way originally envisioned. 

In  addition,  because  our  MFS  and  DFS  offerings  require  us  to  process  personal  data  (such  as,  consumer  names, 
addresses,  credit  and  debit  card  numbers  and  bank  account  details),  we  must  comply  with  strict  data  privacy  and  consumer 
protection laws. For more information on risks associated with possible unauthorized disclosure of such personal data, see - “We 
collect  and  process  sensitive  customer  data,  and  are  therefore  subject  to  an  increasing  amount  of  data  privacy  laws  and 
regulations  that  may  require  us  to  incur  substantial  costs  and  implement  certain  changes  to  our  business  practices  that  may 
adversely affect our results of operations.”  

Our  MFS  and  DFS  businesses  also  require  us  to  maintain  availability  of  our  systems  and  platforms,  and  failure  to 
maintain  agreed  levels  of  service  availability  or  to  reliably  process  our  customers’  transactions  due  to  performance, 
administrative or technical issues, system interruptions or other failures could result in a loss of revenue, violation of certain local 
banking  regulations,  payment  of  contractual  or  consequential  damages,  reputational  harm,  additional  operating  expenses  to 
remediate any failures, or exposure to other losses and liabilities.

Mobilink  Microfinance  Bank  Limited,  a  wholly  owned  subsidiary  of  the  company,  carries  on  a  microfinance  banking 
business and provides certain MFS, DFS and traditional banking services in Pakistan under license granted by the State Bank of 
Pakistan  and  is  subject  to  regulation  by  the  State  Bank  of  Pakistan.    State  Bank  regulations  and  banking  laws  are  subject  to 
change  from  time  to  time,  including  with  respect  to  capitalization  requirements  and  we  may  be  required  to  increase  the 
capitalization of Mobilink Bank from time to time and may be required to inject funds to cover any losses that the bank suffers.  
Mobilink Bank’s activities may expose it or the group to a risk of liability under banking and financial services compliance laws, 
including, for example, anti-money laundering and counter-terrorist financing regulations. 

Our majority stake in an Egyptian company may expose us to legal and political risk and reputational harm.

Our  subsidiary  in  Egypt,  Global  Telecom  Holding  S.A.E.  (“GTH”),  is  an  Egyptian  private  company  and  is  therefore 

subject to corresponding laws and regulations. 

GTH is the holding company for our assets in Algeria. We have experienced and expect to continue to experience the 
risk  of  unpredictable  and  adverse  government  action  stemming  from  the  political  and  economic  conditions  in  Egypt  and  the 
inconsistent  and  unpredictable  application  of  laws  and  regulations.  Furthermore,  although  GTH  entered  into  a  tax  settlement 
agreement with the Egyptian tax authorities for certain historic periods, GTH may in the future be subject to significant unfounded 
or unfair tax claims for other tax periods, or under existing or new Egyptian tax law.  For more information on tax claims of the 
Egyptian authorities, see Note 7 — Provisions and Contingent Liabilities to our Audited Consolidated Financial Statements. 

We  operate  in  a  highly  regulated  industry  and  are  subject  to  a  large  variety  of  laws  and  extensive  regulatory 
requirements. 

As a global telecommunications company, we are subject to different and occasionally conflicting laws and regulations 
in  each  of  and  between  the  jurisdictions  in  which  we  operate.  Mobile,  internet,  fixed-line,  voice,  content  and  data  markets 
generally are subject to extensive regulatory requirements, including strict licensing regimes, as well as antitrust and consumer 
protection regulations. Regulations may be especially strict in those countries in which we are considered to hold a significant 
market position (Ukraine, Pakistan and Uzbekistan), a dominant market position (Russia and Kazakhstan) or are considered a 
dominant  company  (Kyrgyzstan).  The  applicable  rules  are  generally  subject  to  different  interpretations  and  the  relevant 
authorities may challenge the positions that we take. As we expand certain areas of our business and provide new services, such 
as MFS, DFS, banking, digital content, other non-connectivity services, or value-added and internet-based services, we may be 
subject  to  additional  laws  and  regulations.  For  more  on  risks  related  to  MFS  and  DFS,  see  -  "Our  Mobile  Financial  Services 
("MFS") and Digital Financial Services ("DFS") offerings are complex and increase our exposure to fraud, money laundering and 
reputational  risk."    Regulatory  compliance  may  be  costly  and  involve  a  significant  expenditure  of  resources,  thus  negatively 
affecting our financial condition and results of operations. 

Certain regulations may require us to reduce retail prices, roaming prices or mobile and/or fixed-line termination rates, 
require  us  to  offer  access  to  our  network  to  other  operators,  or  result  in  the  imposition  of  fines  if  we  fail  to  fulfill  our  service 
commitments. In some countries, we are required to obtain approval for offers and advertising campaigns, which can delay our 
marketing campaigns and require restructuring of business initiatives. We may also be required to obtain approvals for certain 
acquisitions, reorganizations or other transactions, and failure to obtain such approvals may impede or harm our business and 
our ability to adjust our operations or acquire or divest of businesses or assets. Laws and regulations in some jurisdictions oblige 
us  to  install  surveillance,  interception  and  data  retention  equipment  to  ensure  that  our  networks  are  capable  of  allowing  the 
government to monitor data and voice traffic on our networks.  The nature of our business also subjects us to certain regulations 
regarding open internet access or net neutrality. 

Regulatory requirements impact our business operations and may affect our financial performance. We face regulatory 
risks and costs in each of the markets in which we operate and may be subject to additional regulations in future. Any failure on 
our  part  to  comply  with  these  laws  and  regulations  can  result  in  negative  publicity,  diversion  of  management  time  and  effort, 

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increased competitive and pricing pressure on our operations, significant liabilities, third party civil claims and other penalties or 
otherwise harm our business, financial condition, results of operations, cash flows or prospects.  

We are subject to anti-corruption laws in multiple jurisdictions. 

We  operate  in  countries  which  pose  elevated  risks  of  corruption  and  are  subject  to  a  number  of  anti-corruption  laws, 
including the US Foreign Corrupt Practices Act (“FCPA”), the UK Bribery Act, the anti-corruption provisions of the Dutch Criminal 
Code  in  the  Netherlands  and  local  laws  in  the  jurisdictions  in  which  we  operate.  An  investigation  into  allegations  of  non-
compliance or a finding of non-compliance with anti-corruption laws or other laws governing the conduct of business may subject 
us to administrative and other financial costs, reputational damage, criminal or civil penalties or other remedial measures, which 
could  harm  our  business,  financial  condition,  results  of  operations,  cash  flows  or  prospects.  Anti-corruption  laws  generally 
prohibit companies and their intermediaries from promising, offering or giving a financial or other things of value or advantage to 
someone  for  the  purpose  of  improperly  influencing  a  matter  or  obtaining  or  retaining  business  or  rewarding  improper  conduct. 
The FCPA further requires US issuers to maintain accurate books and records and a system of sufficient internal controls. We 
regularly review and update our policies and procedures and internal controls to provide reasonable assurance that we and our 
personnel comply with the anti-corruption laws to which we are subject, although we cannot guarantee that these efforts will be 
successful. 

We  maintain  a  Business  Partner  Code  of  Conduct  and  attempt  to  obtain  assurances  from  distributors  and  other 
intermediaries, through contractual and other legal obligations, that they also will comply with anti-corruption laws applicable to 
them and to us. However, these efforts to secure legal commitments are not always successful. There are inherent limitations to 
the effectiveness of any policies, procedures and internal controls, including the possibility of human error and the circumvention 
or  overriding  of  the  policies,  procedures  and  internal  controls. There  can  be  no  assurance  that  such  policies  or  procedures  or 
internal controls will work effectively at all times or protect us against liability under anti-corruption or other laws for actions taken 
by our personnel, distributors and other intermediaries with respect to our business or any businesses that we may acquire. Our 
Business Partner Code of Conduct is available on our website at http://www.veon.com (information appearing on the website is 
not incorporated by reference into this Annual Report

In addition, as previously disclosed, the Deferred Prosecution Agreement (“DPA”) that VEON entered into with the U.S. 
Department of Justice (“DOJ”) on February 18, 2016 has concluded and the criminal charges that had been deferred by the DPA 
have been dismissed. Since concluding the DPA, we have provided, and may in the future provide, updates on certain internal 
investigations related to potential misconduct to the U.S. authorities. In the event that any of these matters lead to governmental 
investigations or proceedings, it could have a material adverse impact on our business and results of operations.

Anti-terror legislation passed in Russia and other jurisdictions could result in additional operating costs and capital 
expenditures.

Federal  Law  No  374-FZ  (the  “Yarovaya  law”)  amended  anti-terrorism  legislation  and  imposed  certain  obligations  on 
communication  providers,  including  a  requirement  to  store  information  evidencing  receipt,  transmission,  delivery  and/or 
processing of voice data, text messages, pictures, sounds, videos or meta-data reflecting these communications for a period of 
three years and a requirement to store the contents of such communications for a period of up to six months. This requirement 
came into force on July 1, 2018 for voice traffic and on October 1, 2018 for data traffic. In addition, the Yarovaya law requires 
communication providers to supply information to investigation and prosecution authorities about users and any other information 
“which  is  necessary  for  these  authorities  to  achieve  their  statutory  goals”  including  any  information  and  codes  necessary  to 
decode  the  information.  Furthermore,  under  other  local  Russian  law,  operators  are  required  to  block  services  for  users  whose 
personal data does not correspond to the data registered and stored by the operator. Failure to comply with this law may lead to 
administrative fines and could impact the effectiveness of our licenses. The implementation and support of measures to comply 
with  the  legislation  led  to  substantial  investments  for  the  design  of  our  IT  systems  in  Russia  and  the  purchase  of  specialized 
equipment and tools. The Russian authorities require, among other things, the use of specific storage equipment (such as data 
storage,  interception  devices,  fiberoptic  cables  and  technical  platforms).  We  estimate  that  total  Yarovaya  law-related 
expenditures  will  be  RUB  45  billion  (US$609  million)  over  five  years  starting  from  2018.  Although  the  Yarovaya-law-related 
investment plans are progressing in alignment with legal requirements, it is possible that in the future the Russian Government 
will  adopt  additional  requirements  in  this  area  which  will  lead  to  additional  expenditures  or  otherwise  necessitate  additional 
investments to be compliant. 

Similar legislation has been implemented, or is being contemplated, in other markets in which we operate. Compliance 
with  such  measures  may  require  substantial  costs  and  management  resources  and  conflict  with  our  legal  obligations  in  other 
countries.  Failure  to  comply  may  lead  to  administrative  fines,  impair  our  ability  to  operate  or  cause  reputational  damage.  In 
addition, compliance with any such obligations may prompt allegations related to data privacy or human rights concerns, which 
could in turn result in reputational harm or otherwise impact our ability to operate or our results of operations. 

Laws restricting foreign investment could materially harm our business. 

We could be materially harmed by new or existing laws restricting foreign investment. For example, in Russia, there are 
a number of laws regulating foreign investment. Federal Law No. 57-FZ “On the Procedure for Foreign Investments in Business 
Entities of Strategic Importance for National Defense and State Security” (the “Russian Foreign Investment Law”) limits foreign 
investment in companies that are deemed to be strategic. Our Russian subsidiary, PJSC VimpelCom, is deemed to be a strategic 
enterprise  under  the  Russian  Foreign  Investment  Law.  As  a  result,  any  acquisition  by  a  foreign  investor  of  direct  or  indirect 
control over more than 50% of its voting shares, or 25% in the case of a company controlled by a foreign government, requires 

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the  prior  approval  of  the  Government  Commission  on  Control  of  Foreign  Investment  in  the  Russian  Federation.  The  Federal 
Antimonopoly Service of the Russian Federation (the “FAS”) which administers the application of the Russian Foreign Investment 
Law, has in the past challenged acquisitions of our shares by foreign investors. In addition, Federal Law dated July 27, 2006 No. 
149-FZ “On the Information, Information Technology and Protection of Information” affects the provision of audio-visual services 
by  foreign  entities  and  local  companies  with  more  than  20%  of  foreign  investments  or  shares.  Furthermore,  implementing 
regulation  for  Federal  Law  187-FZ  “On  the  security  of  Russia’s  critical  information  infrastructure”  contains  provisions  requiring 
that the subjects of critical information infrastructure make the transition to the preferential use of Russian software by January 1, 
2024 and make the transition to the preferential use of Russian telecommunications equipment and radio-electronic products by 
January 1, 2025, both of which may require substantial investments or materially harm our business. 

In Kazakhstan, according to the national security law, a foreign company or individual cannot directly or indirectly own 
more than a 49% stake in an entity that carries out telecommunications activities as an operator of long-distance or international 
communications or owns fixed communication lines without the consent of the Kazakhstan government.

Such laws may hinder potential business combinations or transactions resulting in a change of control or our ability to 

obtain financing from foreign investors should prior approval be refused, delayed or require foreign investors to comply with 
certain conditions, which could materially harm our business, financial condition, results of operations, cash flows or prospects.

Our  licenses  are  granted  for  specific  periods  and  may  be  suspended,  revoked  or  not  extended  or  replaced  upon 
expiration and we may be fined or penalized for alleged violations of law, regulations or license terms. 

The success of our operations is dependent on the maintenance of our licenses to provide telecommunications services 
in the jurisdictions in which we operate. Most of our licenses are granted for specified terms, and there can be no assurance that 
any license will be renewed upon expiration. Some of our licenses will expire in the near term. For more information about our 
licenses,  including  their  expiration  dates,  see  —  Business  Overview.  These  licenses  and  the  frameworks  governing  their 
renewals  are  subject  to  ongoing  review  by  the  relevant  regulatory  authorities.  If  renewed,  our  licenses  may  contain  additional 
obligations,  including  payment  obligations  (which  may  involve  a  substantial  renewal  or  extension  fee),  or  may  cover  reduced 
service areas or scope of service. Furthermore, the governments in certain jurisdictions in which we operate may hold auctions 
(including auctions of spectrum for the 4G/LTE or more advanced services such as 5G) in the future. If we are unable to maintain 
or obtain licenses for the provision of telecommunications services or more advanced services or if our licenses are not renewed 
or are renewed on less favorable terms, our business and results of operations could be materially harmed.

We  are  required  to  meet  certain  terms  and  conditions  under  our  licenses  (such  as  nationwide  coverage,  quality  of 
service  parameters  and  capital  expenditure,  including  network  build-out  requirements),  including  meeting  certain  conditions 
established by the legislation regulating the communications industry. From time to time, we may be in breach of such terms and 
conditions.  If  we  fail  to  comply  with  the  conditions  of  our  licenses  or  with  the  requirements  established  by  the  legislation 
regulating the communications industry, or if we do not obtain or comply with permits for the operation of our equipment, use of 
frequencies or additional licenses for broadcasting directly or through agreements with broadcasting companies, the applicable 
regulator could decide to levy fines, suspend, terminate or refuse to renew the license or permit. Such regulatory actions could 
adversely impact our ability to carry on our business in the current or planned manner or to carry out divestitures in the relevant 
jurisdictions.

The occurrence of any of these events could materially harm our ability to build out our networks in accordance with our 
plans, our ability to retain and attract customers, our reputation and our business, financial condition, results of operations, cash 
flows or prospects. For more information on our licenses and their related requirements, see - Business Overview. 

It may not be possible for us to procure in a timely manner, or at all, the permissions and registrations required for our 
base stations.

The laws of the countries in which we operate generally prohibit the operation of telecommunications equipment without 
a relevant permit from the appropriate regulatory body. Due to complex regulatory procedures, it is frequently not possible for us 
to procure in a timely manner, or at all, the permissions and registrations required for our base stations, including construction 
permits and registration of our title to land plots underlying our base stations, or to amend or maintain the permissions in a timely 
manner  when  it  is  necessary  to  change  the  location  or  technical  specifications  of  our  base  stations. At  times,  there  can  be  a 
number  of  base  stations  or  other  communications  facilities  and  other  aspects  of  our  networks  for  which  we  are  awaiting  final 
permission  to  operate  for  indeterminate  periods.  This  problem  may  be  exacerbated  if  there  are  delays  in  issuing  necessary 
permits.

We also regularly receive notices from regulatory authorities in countries in which we operate warning us that we are 
not in compliance with aspects of our licenses and permits and requiring us to cure the violations within a certain time period. We 
have closed base stations on several occasions in order to comply with regulations and notices from regulatory authorities. Any 
failure by our company to cure such violations could result in the applicable license being suspended and subsequently revoked 
through court  action. Although we look to take all necessary  steps to comply with any license violations within the  stated time 
periods,  including  by  switching  off  base  stations  that  do  not  have  all  necessary  permits  until  such  permits  are  obtained,  we 
cannot  assure  you  that  our  licenses  or  permits  will  not  be  suspended  or  revoked  in  the  future.  If  we  are  found  to  operate 
telecommunications  equipment  without  an  applicable  license  or  permit,  we  could  experience  a  significant  disruption  in  our 
service or network operation, which could harm our business, financial condition, results of operations, cash flows or prospects.

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We  collect  and  process  personal  data,  and  are  therefore  subject  to  an  increasing  number  of  data  privacy  laws  and 
regulations that may require us to incur substantial costs and implement certain changes to our business practices that 
may adversely affect our results of operations. 

We are subject to various, and at times conflicting, data privacy laws and regulations that apply to the collection, use, 
storage,  disclosure  and  security  of  personal  data  that  identifies  or  may  be  used  to  identify  an  individual,  such  as  names  and 
contact  information,  IP  addresses,  (e-mail)  correspondence,  call  detail  records  and  browsing  history.  Many  countries  have 
additional  laws  that  regulate  the  processing,  retention  and  use  of  communications  data,  including  metadata.  These  laws  and 
regulations are subject to frequent revisions and differing interpretations and are becoming more stringent over time.

In  general,  mobile  operators  are  directly  liable  for  actions  of  third  parties  to  whom  they  forward  personal  data  for 
processing. If severe personal data security breaches are detected, regulatory authorities could sanction our company, including 
suspending our operations for some time and levying fines and penalties. Violation of these laws by an operator may lead to a 
seizure  of  the  operator’s  database  and  equipment,  imposition  of  administrative  sanctions  (including  in  the  form  of  fines, 
suspension of activities or revocation of license) or result in a ban on the processing of personal data by such operator, which, in 
turn,  could  lead  to  the  inability  to  provide  services  to  our  customers.  The  occurrence  of  any  of  the  aforementioned  events, 
individually or in the aggregate, could harm our brand, business, financial condition, results of operations or prospects. 

Many of the jurisdictions in which we operate have laws that restrict cross border data transfers unless certain criteria 
are  met  and/or  are  developing  or  implementing  laws  on  data  localization  requiring  data  to  be  stored  locally.  These  laws  may 
restrict our flexibility to leverage our data and build new, or consolidate existing, technologies, databases and IT systems, limit 
our  ability  to  use  and  share  personal  data,  cause  us  to  incur  costs,  require  us  to  change  our  business  practices  in  a  manner 
adverse to our business or conflict with other laws we are subject to, exposing us to regulatory risk. The stringent cross-border 
transfer rules in certain jurisdictions may also prohibit us from disclosing data to foreign authorities upon their request, which may 
generate a scenario where it is not possible for us to comply with both laws. If so, in addition to the possibility of fines, this could 
result in an order requiring that we change our data practices, which could have an adverse effect on our business and results of 
operations.  We  are  subject  to  a  variety  of  data  protection  regulations.    For  example,  the  European  Union  introduced  a  data 
protection  framework,  the  General  Data  Protection  Regulation  (GDPR),  which  came  into  effect  on  May  25,  2018.  The  GDPR 
implements more stringent operational requirements for processors and controllers of personal data. The GDPR is applicable to 
companies that are established in the European Union, or companies that offer goods and services to, or monitor the behavior 
of, individuals within the European Union. The GDPR is also still applicable for the United Kingdom following its withdrawal from 
the  European  Union  December  31,  2020.  While  we  believe  that  the  processing  of  personal  data  by  only  a  limited  number  of 
entities, including our Amsterdam and London offices and central operating entities within the European Union and the United 
Kingdom,  are  subject  to  GDPR,  our  operations  in  other  markets  may  also  become  subject  to  this  regulation,  under  certain 
circumstances, e.g. if such operations involve the offering of goods or services to, or monitoring the behavior of, individuals in the 
European Union and the United Kingdom.  In addition, in Russia and certain other jurisdictions in our footprint, we are subject to 
certain  data  protection  and  other  laws  and  regulations  that  establish  different  categories  of  information  with  different 
corresponding  levels  of  protection,  permitted  registration,  disclosure  and  required  safeguards.  These  categories  include  state 
secret information and other data, including personal data of our customers and of other persons (such as our employees and 
third-party  supplies  and  other  counter-parties),  privacy  of  communications  and  information  on  rendered  telecommunications 
services.  In  each  case,  the  operators  must  implement  the  required  level  of  data  protection  and  cooperate  with  government 
authorities on law enforcement disclosures for state secrets and personal data of customers. The ability to disclose certain types 
of data to affiliates or governmental authorities may be substantially restricted.

The  laws  and  regulations  regarding  data  privacy  may  become  more  stringent  over  time.    For  example,  the  European 
Commission has also proposed a draft of the new ePrivacy Regulation on January 10, 2017. The current draft of the ePrivacy 
Regulation is going through the EU legislative process and is intended to replace the 2002/58 e-Privacy Directive. When it comes 
into  effect,  it  is  expected  to  regulate  the  processing  of  electronic  communications  data  carried  out  in  connection  with  the 
provision  and  the  use  of  publicly  available  electronic  communications  services  to  users  in  the  European  Union,  regardless  of 
whether  the  processing  itself  takes  place  in  the  European  Union.  Unlike  the  current  ePrivacy  Directive,  the  draft  ePrivacy 
Regulation will likely apply to over-the-top service providers as well as traditional telecommunications service providers (including 
the requirements on data retention and interception and changes to restrictions on the use of traffic and location data). VEON 
entities established in the European Union  which process such electronic communications data are likely to be subject to this 
regime. The current draft of the ePrivacy Regulation also regulates the retention and interception of communications data as well 
as  the  use  of  location  and  traffic  data  for  value  added  services,  imposes  stricter  requirements  on  electronic  marketing,  and 
changes to the requirements for use of tracking technologies like cookies. This could broaden the exposure of our business lines 
based in the European Union to data protection liability, restrict our ability to leverage our data and increase the costs of running 
those businesses. The draft also significantly increases penalties.

Any  failure  or  perceived  failure  by  us  to  comply  with  privacy  or  security  laws,  policies,  legal  obligations  or  industry 
standards may result in governmental enforcement actions and investigations, blockage or limitation of our services, fines and 
penalties.  If  the  third  parties  we  work  with  violate  applicable  laws,  contractual  obligations  or  suffer  a  security  breach,  such 
violations may also put us in breach of our obligations under privacy laws and regulations and/or could in turn have a material 
adverse  effect  on  our  business.  In  addition,  concerns  regarding  our  practices  with  regard  to  the  collection,  use,  disclosure  or 
security of personal information or other privacy-related matters could result in negative publicity and have an adverse effect on 
our reputation and business.

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We could be subject to tax claims and repeated tax audits that could harm our business. 

Tax declarations together with related documentation are subject to review and investigation by a number of authorities 
in many of the jurisdictions in which we operate, which are empowered to impose fines and penalties on taxpayers. Tax audits 
may result in additional costs to our group if the relevant tax authorities conclude that entities of the group did not satisfy their tax 
obligations  in  any  given  year.  Such  audits  may  also  impose  additional  burdens  on  our  group  by  diverting  the  attention  of 
management resources. 

Tax  audits  in  the  countries  in  which  we  operate  are  conducted  regularly,  but  their  outcomes  may  not  be  fair  or 
predictable.  We  have  been  subject  to  substantial  claims  by  tax  authorities  in  Russia,  Algeria,  Egypt,  Pakistan,  Bangladesh, 
Ukraine,  Kazakhstan,  Georgia,  Uzbekistan,  and    Kyrgyzstan.  These  claims  have  resulted,  and  future  claims  may  result,  in 
additional payments, including interest, fines and other penalties, to the tax authorities.  

There can be no assurance that we will prevail in litigation with tax authorities and that the tax authorities will not claim 
that  additional  taxes,  interest,  fines  and  other  penalties  are  owed  by  us  for  prior  or  future  tax  years,  or  that  the  relevant 
governmental  authorities  will  not  decide  to  initiate  a  criminal  investigation  or  prosecution,  or  expand  existing  criminal 
investigations  or  prosecutions,  in  connection  with  claims  by  tax  inspectorates,  including  those  relating  to  individual  employees 
and for prior tax years. In Russia, for example, tax returns remain open and subject to inspection by tax or customs authorities 
for  three  calendar  years  immediately  preceding  the  year  in  which  the  decision  to  conduct  an  audit  is  taken.  Laws  enacted  in 
Russia  in  recent  years  increase  the  likelihood  that  our  tax  returns  that  were  reviewed  by  the  Russian  tax  authorities  could  be 
subject to further review or audit during or beyond the eligible three-year limitation period by a superior Russian tax authority. We 
have  also  been  the  subject  of  repeat  complex  and  thematic  tax  audits  in  Kyrgyzstan,  Russia  and  Pakistan,  which,  in  some 
instances, have resulted in payments made under protest pending legal challenges and/or to avoid the initiation or continuation 
of associated criminal proceedings. The outcome of these audits, including where the relevant tax authorities may conclude that 
we  had  significantly  underpaid  taxes  relating  to  earlier  periods,  could  harm  our  business,  financial  condition,  results  of 
operations, cash flows or prospects.

The adverse or delayed resolution of tax matters could harm our business, financial condition and results of operations. 
For  more  information  regarding  tax  claims  and  tax  provisions  and  liabilities  and  their  effects  on  our  financial  statements,  see 
Note 7 - Provisions and Contingent Liabilities to our Audited Consolidated Financial Statements. 

Changes  in  tax  treaties,  laws,  rules  or  interpretations  could  have  a  material  adverse  effect  on  our  business,  and  the 
unpredictable tax systems in the markets in which we operate give rise to significant uncertainties and risks that could 
complicate our tax planning and business decisions. 

The introduction of new tax laws or the amendment of existing tax laws could have a material adverse impact on our 
business,  financial  performance  and  results  of  operations.  Our  business  decision  take  into  account  certain  taxation  scenarios, 
which could be proven to be untrue in the event of an adverse decisions by tax authorities or changes in tax treaties, laws, rules 
or interpretations.  For example, we are vulnerable to changes in tax laws, regulations and interpretations in the Netherlands, our 
current resident state for tax purposes, including the  enforcement of tax law. Additionally, as European and other tax laws and 
regulations are complex and subject to varying interpretations, we cannot be sure that our interpretations are accurate or that the 
responsible  tax  authority  agrees  with  our  views.  If  our  tax  positions  are  challenged  by  the  tax  authorities,  we  could  incur 
additional  tax  liabilities,  which  could  increase  our  costs  of  operations  and  have  a  material  adverse  effect  on  our  business, 
financial condition or results of operations. The introduction of new tax laws or the amendment of existing tax laws, such as those 
relating to transfer pricing rules or the deduction of interest expenses in the markets in which we operate, may also increase the 
risk of adjustments being made by the tax authorities and, as a result, could have a material adverse impact on our business, 
financial  performance  and  results  of  operations.  For  example,  within  the  Organisation  for  Economic  Co-operation  and 
Development (“OECD”) there is an initiative aimed at avoiding base erosion and profit shifting (“BEPS”) for tax purposes. This 
OECD BEPS project has resulted in further developments in other countries and in particular in the European Union. One of the 
developments  is  the  agreement  on  the  EU Anti-Tax Avoidance  Directive  (“ATAD”). All  EU  Member  States  must  implement  the 
minimum standards as set out in the ATAD. The implementation of these measures against tax avoidance in the legislation of the 
jurisdictions in which we do business could have a material adverse effect on us.   

These considerations are compounded by the fact that the interpretation and enforcement of tax laws in the emerging 
markets in which we operate tend to be unpredictable and give rise to significant uncertainties, which could complicate our tax 
planning  and  business  decisions. Any  additional  tax  liability  imposed  on  us  by  tax  authorities  in  this  manner,  as  well  as  any 
unforeseen changes in applicable tax laws or changes in the tax authorities’ interpretations of the respective double tax treaties 
in  effect,  could  harm  our  future  results  of  operations,  cash  flows  or  the  amounts  of  dividends  available  for  distribution  to 
shareholders in a particular period. For example, Russia has recently initiated renegotiation of certain tax treaties, including the 
treaties  with  Luxembourg  and  the  Netherlands,  the  latter  of  which  is  still  under  negotiation.  In  addition,  in  recent  years,  the 
Russian  tax  authorities  have  aggressively  brought  tax  evasion  claims  relating  to  Russian  companies’  use  of  tax-optimization 
schemes,  and  press  reports  have  speculated  that  these  enforcement  actions  have  been  selective  and  politically  motivated. 
Furthermore,  we  may  be  required  to  accrue  substantial  amounts  for  contingent  tax  liabilities  and  the  amounts  accrued  for  tax 
contingencies  may  not  be  sufficient  to  meet  any  liability  we  may  ultimately  face.  From  time  to  time,  we  may  also  identify  tax 
contingencies for which we have not recorded an accrual. Such unaccrued tax contingencies could materialize and require us to 
pay additional amounts of tax.

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Geopolitical Risks

Investors  in  emerging  markets,  where  our  operations  are  located,  are  subject  to  greater  risks  than  investors  in  more 
developed markets, including significant political, legal and economic risks, as well as risks related to fluctuations in 
the global economy.

Most of our operations are in emerging markets. Investors should fully appreciate the significance of the risks involved 
in investing in an emerging markets company and are urged to consult with their own legal, financial and tax advisors. Emerging 
market governments and judiciaries often exercise broad, unchecked discretion and are susceptible to abuse and corruption and 
rapid reversal of political and economic policies on which we depend. Political and economic relations among the countries in 
which we operate are often complex and have resulted, and may in the future result, in conflicts, which could materially harm our 
business,  financial  condition,  results  of  operations,  cash  flows  or  prospects.  The  economies  of  emerging  markets  are  also 
vulnerable  to  market  downturns  and  economic  slowdowns  elsewhere  in  the  world.  As  has  happened  in  the  past,  financial 
problems  or  an  increase  in  the  perceived  risks  associated  with  investing  in  emerging  economies  could  dampen  foreign 
investment in these markets and materially adversely affect their economies. Turnover of political leaders or parties in emerging 
markets as a result of a scheduled election upon the end of a term of service or in other circumstances may also affect the legal 
and  regulatory  regime  in  those  markets  to  a  greater  extent  than  turnover  in  established  countries. Any  of  these  developments 
could severely limit our access to capital and could materially harm the purchasing power of our customers and, consequently, 
our business. 

Such  events  may  create  uncertain  regulatory  environments,  which  in  turn  could  impact  our  compliance  with  license 
obligations  and  other  regulatory  approvals.  The  nature  of  much  of  the  legislation  in  emerging  markets,  the  lack  of  consensus 
about the scope, content and pace of economic and political reform and the rapid evolution of the legal and regulatory systems in 
emerging  markets  place  the  enforceability  and,  possibly,  the  constitutionality  of  laws  and  regulations  in  doubt  and  result  in 
ambiguities, inconsistencies and anomalies. The legislation often contemplates implementing regulations that have not yet been 
promulgated, leaving substantial gaps in the regulatory infrastructure. Any of these factors could affect our ability to enforce our 
rights under our licenses or our contracts, or to defend our company against claims by other parties. 

Many of the emerging markets in which we operate are susceptible to significant social unrest or military conflicts. The 
local authorities may order our subsidiaries to temporarily shut down their entire network or part or all of our networks may be 
shut down due to actions relating to military conflicts or nationwide strikes. For example, our subsidiary in Pakistan is ordered to 
shut down parts of its mobile network and services from time to time due to the security situation in the country. Governments or 
other factions, including those asserting authority over specific territories in areas of conflict, could make inappropriate use of the 
network,  attempt  to  compel  us  to  operate  our  network  in  conflict  zones  or  disputed  territories  and/or  force  us  to  broadcast 
propaganda  or  illegal  instructions  to  our  customers  or  others  (and  threaten  consequences  for  failure  to  do  so).  Forced 
shutdowns,  inappropriate  use  of  our  network  or  being  compelled  to  operate  our  network  in  conflict  zones  or  broadcast 
propaganda/illegal  instructions  could  materially  harm  our  business,  financial  condition,  results  of  operations,  cash  flows  or 
prospects. 

Social instability in the countries in which we operate, coupled with difficult economic conditions, could lead to increased 
support for centralized authority and a rise in nationalism. These sentiments could lead to restrictions on foreign ownership of 
companies in the telecommunications industry or nationalization, expropriation or other seizure of certain assets or businesses. 
In most of the countries in which we operate, there is relatively little experience in enforcing legislation enacted to protect private 
property against nationalization or expropriation. As a result, we may not be able to obtain proper redress in the courts, and we 
may not receive adequate compensation if in the future the governments decide to nationalize or expropriate some or all of our 
assets.  In addition, ethnic, religious, historical and other divisions have, on occasion, given rise to tensions and, in certain cases, 
military  conflict.  The  spread  of  violence,  or  its  intensification,  could  have  significant  political  consequences,  including  the 
imposition of a state of emergency, which could materially adversely affect the investment environment in the countries in which 
we operate.

Violations of and changes to applicable sanctions and embargo laws may harm our business. 

Authorities  have  imposed  significant  penalties  on  companies  that  fail  to  comply  with  the  requirements  of  applicable 
sanctions  and  embargo  laws  and  regulations.  We  are  subject  to  certain  sanctions  and  embargo  laws  and  regulations  of  the 
United States, the United Nations, the European Union, the United Kingdom and the jurisdictions in which we operate. Sanctions 
and embargo laws and regulations generally establish the scope of their own application, which arise for different reasons and 
can  vary  greatly  by  jurisdiction.  The  scope  of  such  laws  and  regulations  may  be  expanded,  sometimes  without  notice,  in  a 
manner  that  could  materially  adversely  affect  our  business,  financial  condition,  results  of  operations,  cash  flows  or  prospects. 
Additionally,  countries  (such  as  China)  have  also  adopted  sanctions  countermeasures  that  may  impact  our  future  ability  to 
ensure our suppliers’ compliance with these laws.  Notwithstanding our policies and compliance controls, we may be found in the 
future to be in violation of applicable sanctions and embargo laws, particularly as the scope of such laws may be unclear and 
subject to discretionary interpretations by regulators, which may change over time. If we fail to comply with applicable sanctions 
or embargo laws and regulations, we could suffer severe operational, financial or reputational consequences. Moreover, certain 
of our financing arrangements include representations and covenants requiring compliance with or limitation of activities under 
sanctions and embargo laws and regulations of certain additional jurisdictions, the breach of which may trigger defaults or cross-
defaults of mandatory prepayment requirements in the event of a breach thereof. For a discussion of risks related to export and 
re-export  restrictions,  see  Operational  Risks  -  “We  depend  on  third  parties  for  certain  services  and  products  important  to  our 
business.” 

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Our operations may be adversely affected by ongoing developments in Russia and Ukraine. 

The  current  situation  in  Russia  and  Ukraine,  and  the  related  responses  of  the  United  States,  member  states  of  the 
European  Union,  the  European  Union  itself,  the  United  Kingdom  and  certain  other  nations,  have  the  potential  to  materially 
adversely affect our business in Russia and Ukraine where we have significant operations. 

Since  2014,  in  connection  with  the  situation  in  Russia  and  Ukraine,  the  United  States,  the  European  Union,  and  a 
number of other countries have imposed sanctions that block the property of certain designated businesses, organizations and 
individuals, prohibit certain types of transactions with designated businesses operating in certain sectors of the Russian economy 
and restrict investment in and trade with Crimea. Under the U.S. sanctions regime, even non-U.S. persons who engage in certain 
prohibited transactions may be exposed to sanctions, such as the denial of certain privileges, including those relating to financing 
and  contracting  with  U.S.  persons  or  within  the  United  States.  In  addition,  the  United  States  and  the  European  Union  have 
implemented  certain  export  control  restrictions  related  to  Russia’s  energy  sector  and  military  capabilities.  Ukraine  has  also 
enacted  sanctions  with  respect  to  certain  Russian  entities  and  individuals.  Russia  has  responded  to  these  sanctions  with 
countermeasures,  including  sanctions  with  respect  to  certain  Ukrainian  individuals  and  entities,  restricting  imports  of  certain 
goods from the United States, the European Union, Ukraine and other countries, imposing visa bans on certain individuals and 
restricting Russian companies from complying with sanctions imposed by other countries. 

Such  sanctions,  export  controls  and/or  other  measures,  including  sanctions  on  additional  persons  or  businesses 
(including vendors, joint venture and business partners, affiliates and financial institutions), could materially adversely affect our 
business, financial condition, results of operations, cash flows or prospects. Increased tensions between Russia and Ukraine and 
the  continued  imposition  of  sanctions  and  export  controls,  including  prohibitions  and  restrictions  on  conducting  business  with 
certain  individuals  and  entities,  could  have  a  material  adverse  effect  on  our  businesses  in  Ukraine  and  Russia,  which  in  turn 
could harm our business, financial condition, results of operations, cash flows or prospects. 

Our  business  operations  in  Ukraine  have  been  affected  by  the  dispute.    Ukraine  assigned  a  “temporary  occupied 
territories” status to Crimea and a “united forces operation” zone status to certain eastern Ukraine regions which are currently not 
under the Ukrainian government’s full control, and imposed certain restrictions and prohibitions on trade in goods and services in 
such  territories.  Our  Ukrainian  subsidiary,  Kyivstar  JSC  (“Kyivstar”),  shut  down  its  network  in  Crimea  in  2014  as  well  as  its 
network in certain parts of Eastern Ukraine in 2015 and, in each case, has written off the relevant assets. Under the terms of its 
telecommunications  licenses,  Kyivstar  is  obliged  to  provide  services  throughout  Ukraine.  Kyivstar  has  notified  the  regulatory 
authorities  that  Kyivstar  has  stopped  providing  services  in  Crimea  and  certain  parts  of  Eastern  Ukraine  and  has  requested 
clarification from such authorities regarding telecommunications operations in such areas. Since September 2014, legislation has 
been in effect in Ukraine that authorizes the cancellation of telecommunications licenses for sanctioned parties. There can be no 
assurance that the escalation of the current situation will not lead to the cancellation or suspension of, or other actions under, 
certain or all of our Ukrainian telecommunications licenses, or other sanctions. 

Recently,  Russia  and  Ukraine  have  signaled  a  mutual  interest  in  peace  in  eastern  Ukraine.  In  December  2019,  the 
Russian and Ukrainian presidents met in Paris for face-to-face peace talks and committed to a comprehensive cease-fire and a 
release  of  conflict-related  detainees. Although  recent  peace  talks  aim  to  reduce  the  conflict  between  Russia  and  Ukraine,  the 
situation in eastern Ukraine and Crimea remains fragile, and may in the future result in damage or loss of assets, disruption of 
services and regulatory issues which has, and may in the future, adversely impact our group. We are not able to predict further 
developments  on  this  issue,  including  when  these  measures  will  cease  to  be  in  effect.  There  also  may  be  additions  to  the 
designated persons or business lists or other expansions of sanctions by the United States, the European Union, and/or other 
countries that target Russia and restrict dealings related to Crimea in the future. The U.S. government stated in early 2020 that 
Crimea-related sanctions will remain in place until military aggression leading to the loss of civilian lives fully stops in the region. 
It is possible that these sanctions will be in effect for the foreseeable future. The European Union also extended certain sanctions 
related to Russia and Crimea in March 2019, June 2019 and December 2019. If there were an extended continuation or further 
increase in conflict in Crimea or in eastern Ukraine, it could result in further instability and/or worsening of the overall political and 
economic situation in Ukraine, Russia, Europe and/or in the global economy and capital markets generally. This instability could 
harm  our  business,  financial  condition,  results  of  operations,  cash  flows  or  prospects.  We  could  also  be  materially  adversely 
impacted by a decline of the Russian ruble against the U.S. dollar or the euro and the general economic performance of Russia, 
by, for example, the decline of the Russian ruble against the U.S. dollar and euro, investment in Russia or trade with Russian 
companies decreasing substantially and the Russian government experiencing difficulty raising money through the issuance of 
debt in the global capital markets. For a discussion of our foreign currency risk, see Market Risks - “We are exposed to foreign 
currency exchange loss and currency fluctuation and translation risks.” As we derive a significant portion of our revenue from our 
Russian and Ukrainian operations, such developments and measures could have a material adverse impact on our group.

The physical infrastructure in many countries in which we operate is in poor condition and further deterioration in the 
physical infrastructure could harm our business. 

In many countries in which we operate, the physical infrastructure, including transportation networks, power generation 
and  transmission  and  communications  systems,  is  in  poor  condition.  In  some  of  the  countries  in  which  we  operate,  such  as 
Russia,  the  public  switched  telephone  networks  have  reached  capacity  limits  and  need  modernization,  which  may  create 
inconvenience for our customers and will require us to make additional capital expenditures. In addition, some of the markets in 
which  we  operate  are  vulnerable  to  extreme  weather,  the  occurrence  of  which  could  result  in  disruptions  or  damage  to  our 
networks, or to military conflict which could result in damage our physical infrastructure. 

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Continued  growth  in  local,  long  distance  and  international  traffic,  including  that  generated  by  our  customers,  and 
development  in  the  types  of  services  provided  may  require  substantial  investment  in  public  switched  telephone  networks. Any 
efforts  to  modernize  infrastructure  may  result  in  increased  charges  and  tariffs,  potentially  adding  costs  to  our  business.  The 
deterioration  of  the  physical  infrastructure  harms  the  economies  of  these  countries,  disrupts  the  transportation  of  goods  and 
supplies, adds costs to doing business and can interrupt business operations. Further deterioration in the physical infrastructure 
in many of the countries in which we operate could harm our business, financial condition, results of operations, cash flows or 
prospects.

The  banking  systems  in  many  countries  in  which  we  operate  remain  underdeveloped,  there  are  a  limited  number  of 
creditworthy  banks  in  certain  of  these  countries  with  which  we  can  conduct  business,  and  currency  control 
requirements restrict activities in certain markets in which we have operations. 

The banking and other financial systems in many countries in which we operate are less developed or regulated, and 
laws relating to banks and bank accounts are subject to varying interpretations and inconsistent applications. Such banking risk 
cannot be completely eliminated by diversified borrowing and conducting credit analyses. Uncertain banking laws may also limit 
our ability to attract future investment. A banking crisis in any of these countries affecting the capacity for financial institutions to 
lend or fulfill their existing obligations or the bankruptcy or insolvency of the banks from which we receive, or with which we hold, 
our funds could result in the loss of our deposits, the inability to borrow or refinance existing borrowings or otherwise negatively 
affect  our  ability  to  complete  banking  transactions  in  these  countries,  which  could  harm  our  business,  financial  condition  and 
results of operations. 

In  addition,  central  banks  and  governments  in  the  markets  in  which  we  operate  may  restrict  or  prevent  international 
transfers  or  impose  foreign  exchange  controls  or  other  currency  restrictions,  which  could  prevent  us  from  making  payments, 
including the repatriation of dividends and payments to third party suppliers. For more information on currency restrictions, see 
Note 17 — Financial Risk Management — Liquidity Risks — Currency Control Risks. Furthermore, banks have limitations on the 
amounts of loans that they can provide to single borrowers, which could limit the availability of functional currency financing and 
refinancing of existing borrowings in these countries. There can be no assurance that we will be able to obtain approvals under 
the  foregoing  restrictions  or  limitations,  each  of  which  could  harm  our  business,  financial  condition,  cash  flows,  results  of 
operations or prospects.

General Risk Factors

A disposition by our largest shareholder of its stake in VEON Ltd. could harm our business.

We  derive  benefits  and  resources  from  the  participation  of  our  largest  shareholder,  L1T  VIP  Holdings  S.à  r.l. 
(“LetterOne”), in our company such as industry expertise, management oversight and business acumen. Historically, we derived 
the  same  benefits  from  Telenor ASA  (“Telenor”),  until  it  fully  divested    its  interest  in  VEON  Ltd. ADSs  in  November  2019.  For 
additional information on Telenor’s divestment, see - Major Shareholders. Should LetterOne undertake a divestment of its stake, 
we would be deprived of those benefits, which could harm our business, financial condition, results of operations, cash flows or 
prospects. 

Our  largest  shareholder  may  pursue  diverse  development  strategies,  which  may  hinder  our  ability  to  expand  or 
compete in certain regions. 

LetterOne is VEON Ltd.’s largest shareholder, beneficially owning approximately 47.85% of our issued and outstanding 
shares  as  of  March  1,  2021.  In  addition,  LetterOne  is  the  holder  of  the  depositary  receipts  issued  by  Stichting 
Administratiekantoor  Mobile  Telecommunications  Investor  (“Stichting”),  which  represents  an  additional  8.31%  of  VEON  Ltd.’s 
issued and outstanding shares as of March 1, 2021, and is therefore entitled to the economic benefits (dividend payments, other 
distributions and sale proceeds) of such depositary receipts and, indirectly, of the common shares represented by the depositary 
receipts. Stichting, however, has the power to vote and direct the voting of, and the power to dispose and direct the disposition 
of, the ADSs, in its sole discretion, in accordance with the Conditions of Administration and Stichting’s articles of association. For 
more information, see — Major Shareholders.

As a result, LetterOne has some ability to influence the outcome of matters submitted to our shareholders for approval 
and,  through  our  cumulative  voting  procedures,  the  election  of  members  to  our  board  or,  alternatively,  could  enter  into  a 
shareholders’ or similar agreement impacting the composition of our board. A new board could take corporate actions or block 
corporate  decisions  by  VEON  Ltd.  with  respect  to  capital  structure,  financings,  dispositions,  acquisitions  and  commercial 
transactions that might not be in the best interest of the minority shareholders or other security holders. 

At various times our shareholders, including LetterOne, have had different strategies from us and from one another and 
have  engaged  in  litigation  against  our  company  with  respect  to  disagreements  over  strategy.  In  addition,  we  understand  that 
LetterOne has a minority interest in companies that compete with our subsidiary in Ukraine.  

Our business may be adversely impacted by work stoppages and other labor matters.

Although  we  consider  our  relations  with  our  employees  to  be  generally  good,  there  can  be  no  assurance  that  our 
operations  will  not  be  impacted  by  unionization  efforts,  strikes  or  other  types  of  labor  disputes  or  disruptions.  For  instance, 
employee  dissatisfaction  or  labor  disputes  could  result  from  the  implementation  of  internal  operational  and  team  adjustments 
(which have recently included redundancies in our Amsterdam and London offices) necessary to implement our new operating 
model as part of our continued strategy and efforts to further reduce corporate costs. We may also experience strikes or other 

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labor disputes or disruptions in connection with social unrest or political events. For a discussion of our employees represented 
by  works  councils,  unions  or  collective  bargaining  agreements,  see  —  Directors,  Senior  Management  and  Employees  — 
Employees. The ability to work can also be impacted due to natural disasters, civil unrest or security breaches/threats, making 
access  to  work  places  and  management  of  systems  difficult.  Furthermore,  work  stoppages  or  slow-downs  experienced  by  our 
customers or suppliers could result in lower demand for our services and products. In the event that we, or one or more of our 
customers or suppliers, experience a labor dispute or disruption, it could result in increased costs, negative media attention and 
political controversy, and harm our business, financial condition, results of operations, cash flows or prospects. 

Adoption of new accounting standards and regulatory reviews could affect reported results and financial position. 

Our accounting policies and methods are fundamental to how we record and report our financial condition and results of 
operations. Accounting standard-setting bodies, including the International Accounting Standards Board, the U.S. Securities and 
Exchange  Commission  (the  "SEC")  and  the  Dutch  Authority  for  the  Financial  Markets  (the  "AFM"),  may  change  accounting 
regulations  that  govern  the  preparation  and  presentation  of  our  financial  statements,  and  those  who  interpret  the  accounting 
standards, including the SEC, the AFM and our independent registered public accounting firm, may amend or even reverse their 
previous interpretations or positions on how various standards should be applied. Those changes may be difficult to predict and 
could  have  a  significant  impact  on  the  way  we  account  for  certain  operations  and  present  our  financial  position  and  operating 
income.  In  some  instances,  a  modified  standard,  an  outcome  from  a  regulatory  review  or  new  requirement  may  have  to  be 
implemented with retrospective effect, which requires us to restate previous financial statements, or may otherwise impact how 
we prepare and report our financial statements, and may impact our future financial covenants in our debt documents.

For  more  information  on  the  impact  of  IFRS  on  our  Audited  Consolidated  Financial  Statements  and  on  the 
implementation  of  new  standards  and  interpretations  issued,  see    —  Operating  and  Financial  Review  and  Prospects  —  Key 
Developments During  2020  and Note 24 — Significant Accounting Policies to our Audited Consolidated Financial Statements. 

Risks Related to the Ownership of our ADSs

Our ADS price may be volatile, and purchasers of ADSs could incur substantial losses. 

Our ADS  price  may  be  volatile.  The  stock  market  in  general  has  experienced  extreme  volatility  that  has  often  been 
unrelated to the operating performance of particular companies. As a result of this volatility, holders of our ADSs may not be able 
to sell their ADSs at or above the price at which they purchase our ADSs. The market price for our ADSs may be influenced by 
many factors, including:

•

•

•

•

•

•

the success of competitive products or technologies; 

the  issuance  of  new  shares  or  sales  of  shares  by  major  shareholders  or  the  perception  that  such  issuances  or  sales 
could occur; 

regulatory developments in the foreign countries in which we operate; 

developments or disputes concerning licenses or other proprietary rights; 

the recruitment or departure of key personnel; 

quarterly or annual variations in our financial results or those of companies that are perceived to be similar to us; 

• market conditions in the industries in which we compete and issuance of new or changed securities analysts’ reports or 

recommendations; 

•

•

•

the failure of securities analysts to cover our shares or changes in financial estimates by analysts; 

investor perception of our company and of the industry in which we compete; and 

general economic, political and market conditions. 

Various factors may hinder the declaration and payment of dividends. 

The payment of dividends is subject to the discretion of VEON Ltd.’s board and VEON Ltd.’s assets consist primarily of 
investments in its operating subsidiaries. For the financial year ended December 31, 2020, we paid no dividend. Various factors 
may cause the board to determine not to pay dividends or not to increase dividends. Such factors include VEON Ltd.’s financial 
condition, its earnings and equity free cash flow, the movement of the U.S. dollar against VEON’s local currencies, its leverage, 
its capital requirements, contractual restrictions, legal proceedings and other such factors as VEON Ltd.’s board may consider 
relevant.  For  more  information  on  our  policy  regarding  dividends,  see  —  Consolidated  Statements  and  Other  Financial 
Information  —  Policy  on  Dividend  Distributions  and  Operational  Risks  —  “As  a  holding  company,  VEON  Ltd.  depends  on  the 
performance of its subsidiaries and their ability to pay dividends, and may therefore be affected by changes in exchange controls 
and currency restrictions in the countries in which its subsidiaries operate.”

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Holders  of  our  ADSs  may  not  receive  distributions  on  our  common  shares  or  any  value  for  them  if  it  is  illegal  or 
impractical to make them available to them. 

The depositary of our ADSs has agreed to pay holders of our ADSs the cash dividends or other distributions it or the 
custodian  for  our ADSs  receives  on  our  common  shares  or  other  deposited  securities  after  deducting  its  fees  and  expenses. 
Holders of our ADSs will receive these distributions in proportion to the number of our common shares that their ADSs represent. 
However,  the  depositary  is  not  responsible  for  making  such  payments  or  distributions  if  it  is  unlawful  or  impractical  to  make  a 
distribution available to any holders of ADSs. For example, it would be unlawful to make a distribution to a holder of ADSs if such 
distribution  consists  of  securities  that  require  registration  under  the  Securities  Act  but  that  are  not  properly  registered  or 
distributed  pursuant  to  an  applicable  exemption  from  registration.  The  depositary  is  not  responsible  for  making  a  distribution 
available  to  any  holders  of ADSs  if  any  government  approval  or  registration  required  for  such  distribution  cannot  be  obtained 
after reasonable efforts made by the depositary. We have no obligation to take any other action to permit the distribution of our 
ADSs, common shares, rights or anything else to holders of our ADSs. This means that holders of our ADSs may not receive the 
distributions we make on our common shares or any value for them if it is illegal or impractical for us to make them available. 
These restrictions may materially reduce the value of the ADSs.

VEON Ltd. is a Bermuda company governed by Bermuda law, which may affect your rights as a shareholder or holder 
of ADSs, including your ability to enforce civil liabilities under U.S. securities laws. 

VEON  Ltd.  is  a  Bermuda  exempted  company.  As  a  result,  the  rights  of  VEON  Ltd.’s  shareholders  are  governed  by 
Bermuda  law  and  by  VEON  Ltd.’s  bye-laws.  The  rights  of  shareholders  under  Bermuda  law  may  differ  from  the  rights  of 
shareholders of companies incorporated in other jurisdictions. In addition, holders of ADSs do not have the same rights under 
Bermuda law and VEON Ltd.’s bye-laws as registered holders of VEON Ltd.’s common shares.  As substantially all of our assets 
are located outside the United States, it may be difficult for investors to enforce in the United States judgments obtained in U.S. 
courts  against  VEON  or  its  directors  and  executive  officers  based  on  civil  liability  provisions  of  the  U.S.  securities  laws. 
Uncertainty  exists  as  to  whether  courts  in  Bermuda  will  enforce  judgments  obtained  in  other  jurisdictions,  such  as  the  United 
States and the Netherlands, under the securities laws of those jurisdictions, or entertain actions in Bermuda under the securities 
laws of other jurisdictions.

As  a  foreign  private  issuer  within  the  meaning  of  the  Exchange  Act  and  the  rules  of  NASDAQ,  we  are  subject  to 
different  U.S.  securities  laws  and  NASDAQ  governance  standards  than  domestic  U.S.  issuers.  This  may  afford  less 
protection  to  holders  of  our  securities,  and  such  holders  may  not  receive  corporate  and  company  information  and 
disclosure that they are accustomed to receiving or in a manner in which they are accustomed to receiving it. 

As  a  foreign  private  issuer,  the  rules  governing  the  information  that  we  disclose  differ  from  those  governing  U.S. 
corporations pursuant to the Exchange Act. Although we currently report periodic financial results and certain material events, we 
are not required to file quarterly reports on Form 10-Q or provide current reports on Form 8-K disclosing significant events within 
four  business  days  of  their  occurrence.  In  addition,  we  are  exempt  from  the  SEC’s  proxy  rules,  and  proxy  statements  that  we 
distribute will not be subject to review by the SEC. Our exemption from Section 16 rules regarding sales of our shares by insiders 
means that holders of our securities will have less data in this regard than shareholders of U.S. companies that are subject to 
this part of the Exchange Act. As a result, holders of our securities may not have all the data that they are accustomed to having 
when making investment decisions with respect to domestic U.S. public companies. 

While our ADSs are listed on the NASDAQ Global Select Market, as a Bermuda company, we are permitted to follow 
“home country practice” in lieu of certain corporate governance provisions under the NASDAQ listing rules that are applicable to 
a  U.S.  company.    Accordingly,  VEON’s  shareholders  do  not  have  the  same  protections  as  are  afforded  to  shareholders  of 
companies  that  are  subject  to  all  of  NASDAQ’s  corporate  governance  requirements.  The  primary  difference  between  our 
corporate governance practices and the NASDAQ rules relates to NASDAQ listing rule 5605(b)(1), which provides that each U.S. 
company listed on Nasdaq must have a majority of independent directors, as defined in the NASDAQ rules. Bermuda law does 
not require that we have a majority of independent directors and, as a foreign private issuer, we are exempt from complying with 
this NASDAQ requirement.

Holders of ADSs may be restricted in their ability to exercise voting rights and the information provided with respect to 
shareholder meetings. 

Holders of ADSs generally have the right under the deposit agreement to instruct the depositary to exercise the voting 
rights for the equity shares represented by such holders’ ADSs. At our request, the depositary will mail to holders any notice of 
shareholders’ meeting received from us together with information explaining how to instruct the depositary to exercise the voting 
rights of the common shares represented by ADSs. If the depositary timely receives voting instructions from a holder of ADSs, it 
will endeavor to vote the securities represented by the holder’s ADSs in accordance with such voting instructions. However, the 
ability  of  the  depositary  to  carry  out  voting  instructions  may  be  limited  by  practical  and  legal  limitations  and  the  terms  of  the 
common shares on deposit. We cannot assure you that you will receive voting materials in time to enable you to return voting 
instructions to the depositary in a timely manner.

We  may  lose  our  foreign  private  issuer  status  in  the  future,  which  could  result  in  significant  additional  costs  and 
expenses.

We could cease to be considered a foreign private issuer if a majority of our outstanding voting securities are directly or 
indirectly held of record by U.S. residents and we fail to meet additional requirements necessary to avoid loss of foreign private 
issuer  status.    Based  on  a  review  of  our  register  of  members  maintained  in  Bermuda,  as  of  March  1,  2021,  a  total  of 

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1,228,276,403  common  shares  representing  approximately  69.92%  of  VEON  Ltd.’s  issued  and  outstanding  common  shares 
were  held  of  record  by  BNY  (Nominees)  Limited  in  the  United  Kingdom  as  custodian  of The  Bank  of  New York  Mellon  for  the 
purposes of our ADS program and a total of 515,226,176 common shares representing approximately 29.33% of VEON Ltd.’s 
issued and outstanding common shares were held of record by by Nederlands Centraal Instituut Voor Giraal Effectenverkeer B.V. 
in the Netherlands. As of March 1, 2021, 21 record holders of VEON Ltd.’s ADRs, holding an aggregate of 758,028,329 common 
shares (representing approximately 43.15% of VEON Ltd.’s issued and outstanding shares), were listed as having addresses in 
the United States. In the event that we lose our foreign private issuer status, the regulatory and compliance costs to us under 
U.S.  securities  laws  may  be  significantly  higher  than  costs  we  incur  as  a  foreign  private  issuer,  which  could  have  a  material 
adverse effect on our business and financial results.

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OPERATING AND FINANCIAL REVIEW AND PROSPECTS

For discussion related to our financial condition, changes in financial condition, and the results of operations for 2019 
compared  to  2018,  refer  to  Operating  and  Financial  Review  and  Prospects  in  our  Annual  Report    for  the  fiscal  year  ended 
December 31, 2019, which was filed on March 13, 2020.

The  following  discussion  and  analysis  should  be  read  in  conjunction  with  our  Audited  Consolidated  Financial 
Statements  and  the  related  Notes  included  in  this  Annual  Report.  This  discussion  contains  forward-looking  statements  that 
involve risks and uncertainties. Our actual results could differ materially from those anticipated in the forward-looking statements 
as a result of numerous factors, including the risks discussed in — How We Manage Risks — Risk Factors.

OVERVIEW

VEON is a leading global provider of connectivity and internet services, headquartered in Amsterdam. Present in some 
of  the  world’s  most  dynamic  markets,  VEON  provides  more  than  210  million  customers  with  voice,  fixed  broadband,  data  and 
digital  services.  VEON,  through  its  operating  companies,  offers  services  to  customers  in  several  countries:  Russia,  Pakistan, 
Ukraine,  Kazakhstan,  Uzbekistan,  Algeria,  Bangladesh,  Kyrgyzstan  and  Georgia.  We  provide  services  under  the  “Beeline,” 
“Jazz,” “Kyivstar,” “banglalink” and “Djezzy” brands. 

VEON generates revenue from the provision of voice, data  and other telecommunication services through  a  range of 

wireless, fixed and broadband Internet services, as well as selling equipment and accessories.

REPORTABLE SEGMENTS

We  present  our  reportable  segments  based  on  economic  environments  and  stages  of  development  in  different 

geographical areas, requiring different investment and marketing strategies. 

As  of  December  31,  2020,  our  reportable  segments  consist  of  the  following  segments:  Russia,  representing  our 
“cornerstone”  market;  Pakistan,  Ukraine,  Kazakhstan  and  Uzbekistan,  representing  our  “growth  engines”;  and  Algeria  and 
Bangladesh, representing our “frontier markets”. 

We  also  present  our  results  of  operations  for  “Other  frontier  markets”  as  well  as  “HQ  and  eliminations”  separately, 
although  these  are  not  reportable  segments.  “Other  frontier  markets”  represents  our  operations  in  Kyrgyzstan,  Armenia  and 
Georgia. In October 2020, VEON concluded an agreement for the sale of its operating subsidiary in Armenia; refer to Note 9 — 
Significant transactions in our Audited Consolidated Financial Statements attached hereto for further details. 

“HQ  and  eliminations”  represents  transactions  related  to  management  activities  within  the  group  in  Amsterdam,  London  and 
Luxembourg and costs relating to centrally managed operations and reconciles the results of our reportable segments and our 
total revenue and Adjusted EBITDA. 

BASIS OF PRESENTATION OF FINANCIAL RESULTS

Our Audited Consolidated Financial Statements attached hereto have been prepared in accordance with International 
Financial  Reporting  Standards  (“IFRS”)  as  issued  by  the  International Accounting  Standards  Board  and  adopted  by  European 
Union, effective at the time of preparing the consolidated financial statements and applied by VEON. 

RECENT ACCOUNTING PRONOUNCEMENTS

For the description of the recent accounting pronouncements and a discussion of our accounting policies please refer to 

Note 24 — Significant Accounting Policies of our Audited Consolidated Financial Statements attached hereto. 

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KEY DEVELOPMENTS DURING 2020

COVID-19 

The  global  outbreak  of  COVID-19  and  associated  containment  and  mitigation  measures  implemented  worldwide  have  had  a 
sustained impact on our operations and financial performance.

The  second  quarter  saw  the  full  impact  on  our  operations  of  the  lockdowns  imposed  across  our  markets  in  response  to 
COVID-19. This resulted in material disruption to our retail operations following store closures, impacting gross connections and 
airtime sales. Restrictions on travel resulted in a significant decline in roaming revenues and the loss of migrant customers from 
our subscriber base, particularly in Russia. 

Although VEON’s operations remained impacted by lockdown measures throughout the second half of the year, all operations 
saw a  recovery in the performance as our local businesses continue building resilience to the restrictions related to COVID-19. 
Demand for our data services remains strong, enabling us to continue to grow our data revenues. We also experienced a shift in 
data traffic from mobile to fixed networks as lockdowns encouraged remote working and home schooling alongside a greater use 
of devices through our domestic broadband services.

An  increase  in  demand  for  hard  currencies,  in  part  due  to  COVID-19,  resulted  in  the  devaluation  of  exchange  rates  in  the 
countries in which VEON operates. As such, during the year ended December 31, 2020, the book value of assets and liabilities 
of  our  foreign  operations,  in  U.S.  dollar  terms,  decreased  significantly,  with  a  corresponding  loss  of  US$623  million  recorded 
against the foreign currency translation reserve in Other Comprehensive Income.

Our management has taken appropriate measures to keep our personnel safe and secure. As of the date of these financial 
statements, other than as described above, we have not observed any particular material adverse impacts to our business, 
financial condition, and results of operations. The group liquidity is sufficient to fund the business operations for at least another 
12 months.

Partnership with MasterCard

In May 2020, VEON announced a partnership between JazzCash and payment technology leader Mastercard that strengthens 
the payments ecosystem for merchants and customers in Pakistan. More than 7 million customers and merchants use JazzCash 
every  month,  making  it  Pakistan’s  leading  digital  wallet.  The  partnership  with  Mastercard  allows  merchants  to  accept  digital 
payments from customers, digitize their supply chain, and move to cashless operations. In a first for Pakistan, merchants and 
consumers  who  sign  up  for  JazzCash  wallet  will  be  able  to  benefit  from  a  wide  range  of  Mastercard’s  digital  solutions  and 
capabilities to pay for orders and services via all digital channels as well as make online payments in a fast, safe and convenient 
manner. JazzCash customers will also have access to Mastercard’s virtual and branded debit cards that can be used in 55,000 
points of sale and ATMs in Pakistan, in addition to JazzCash merchants and e-commerce sites.

Exercise of put option for 15% stake in Pakistan Operations 

In September 2020, the Dhabi Group exercised its put option to sell us its 15% shareholding in Pakistan Mobile Communications 
Limited  ("PMCL"),  the  operating  company  of  Pakistan’s  leading  mobile  operator,  Jazz.  VEON  updated  the  fair  value  of  its  put 
option liability following the completion of an independent valuation process which determined a fair value for the shareholding of 
US$273  million.  Completion  of  the  transfer  remains  subject  to  the  conclusion  of  the  contractual  transfer  mechanics  with  the 
Dhabi Group. Once completed, VEON will indirectly own 100% of PMCL. 

Beeline Kazakhstan signed Network Sharing Partnership 

In October 2020, VEON announced that its operating company in Kazakhstan, which provides services under the Beeline brand, 
entered into a network sharing partnership that unites the nation’s three mobile telecom providers in the delivery of high-speed 
internet to rural communities. The agreement brings Beeline together with Kcell and Tele2 in support of the nation’s 250+ project, 
which  aims  to  extend  high-speed  internet  to  all  villages  with  a  population  of  250  or  more.  Once  complete,  the  project  will  see 
almost 1,000 rural settlements with a combined population of 600,000 offered 3G and 4G connections by all three operators.

The  250+  initiative,  the  infrastructure  deployment  for  which  started  immediately,  enables  rural  residents  to  receive  mobile 
services on competitive terms and select a service provider of their choice. In turn, each mobile operator will enjoy equal access 
to the shared network.

VEON acquired strategic stake in ShopUp in Bangladesh

In October 2020, VEON joined Sequoia Capital India and Flourish Ventures as investors in ShopUp, Bangladesh’s leading full-
stack B2B commerce platform for small businesses, becoming ShopUp’s first strategic corporate investor.

The investment of approximately US$8 million, in exchange for a 13.5% stake, is expected to enable VEON to support ShopUp’s 
fast-growing  digital  ecosystem  for  micro,  small  and  medium-sized  enterprises,  which  form  a  vital  backbone  of  Bangladesh’s 
economy, as well as provide opportunities for developing mobile financial services for ShopUp’s users.

85

Agreement concluded for the sale of Armenian operations 

In  October  2020,  VEON  concluded  an  agreement  for  the  sale  of  CJSC  “VEON  Armenia”,  VEON’s  operating  subsidiary  in 
Armenia,  to  Team  LLC  for  a  consideration  of  US$51  million.  Accordingly  the  net  carrying  value  of  assets  amounting  US$33 
million  were  de-recognized  along  with  reclassification  of  cumulative  foreign  currency  translation  reserve  of  US$96  million    to 
profit and loss, resulting in the net loss of US$78 million.

Beeline Russia completed coverage of all Moscow metro stations with 4G and expanded 4G coverage in Moscow

In  December  2020,  VEON  announced  that  Beeline  Russia  achieved  100%  4G  coverage  and  enabled  its  customers  to  access 
high-speed  internet  at  all  stations  of  the  Moscow  metro,  as  well  as  in  most  of  the  adjacent  tunnels.  The  milestone  reflects 
Beeline’s ongoing efforts to improve the quality of 4G connectivity and offers Beeline customers the ability to stay in touch, listen 
to music and stream content in good quality whilst underground.

In January 2021, VEON announced that Beeline Russia completed a large-scale project to improve the quality and availability of 
mobile internet in Moscow. The project included the redistribution of the 2100 frequency range from 3G to 4G and an expansion 
in the frequency range used in the 4G network from 30 to 45 MHz. This has enabled an increase in the average speed of mobile 
internet by up to 30%, with peak speeds now reaching up to 350 Mbit/sec.

Financing activities  

In January 2020, VEON Holdings B.V. ("VEON Holdings") issued US$300 million in  senior unsecured notes due in 2025, to be 
consolidated  and  form  a  single  series  with  the  US$700  million  4.00%  senior  notes  due  in  2025  issued  by  VEON  Holdings  in 
October 2019. VEON Holdings used the net proceeds of the tap issuance to refinance certain existing outstanding debt, address 
upcoming debt maturities and for general corporate purposes. 

In April 2020, VEON Holdings announced the establishment of a US$ 6.5 billion (or the equivalent thereof in other currencies) 
Global Medium Term Note program for the issuance of bonds (the "MTN Program"). In connection with the establishment of the 
MTN  Program,  VEON  prepared  a  base  offering  memorandum,  which  was  approved  by  the  Luxembourg  Stock  Exchange,  in 
order  to  enable  bonds  issued  under  the  MTN  Program  to  be  admitted  to  listing  on  the  Official  List  of  the  Luxembourg  Stock 
Exchange and to trading on the Euro MTF market of the Luxembourg Stock Exchange. In June, September and November 2020, 
VEON Holdings issued senior unsecured notes of RUB20 billion (US$288 million), RUB10 billion (US$135 million) and US$1.25 
billion,  respectively,  under  the  MTN  Program,  maturing  in  June  2025,  September  2025  and  November  2027,  respectively. The 
use  of  proceeds  of  the  Notes  is  being  used  to  finance  certain  investments  in  subsidiaries,  to  refinance  certain  outstanding 
indebtedness of the Issuer, and for general corporate purposes. 

In  April  2020,  Banglalink  extended  the  maturity  of  its  US$300  million  syndicated  loan  by  an  additional  two  years  to  2022. 
Following  this  extension,  VEON,  via  a  wholly-owned  subsidiary,  acquired  the  loan  from  the  original  lenders,  leading  to  an 
effective extinguishment of this debt for the VEON Group. 

In  June  2020,  VEON  entered  into  a  new  RUB  100  billion  (approximately  US$1.5  billion)  bilateral  term  loan  agreement  with 
Sberbank. The loan was used to refinance and extend the maturity of the existing loan between Sberbank and VEON Holdings, 
as well as to provide additional funds for general corporate purposes.

In July 2020, VEON refinanced its existing RUB 30 billion (approximately US$422 million) bilateral term loan agreement with VTB 
Bank. This refinancing extended the maturity and reduced the cost of the existing loan between VTB Bank and VEON.

In December 2020, VEON completed the optional early redemption of all of its outstanding US$600 million 3.95% Senior Notes 
due  June  2021  (the  "2021  Notes")  pursuant  to  Condition  5.3  of  the  2021  Notes.  The  2021  Notes  were  redeemed  in  full  at  a 
redemption price equal to 101.00% of the principal amount thereof, plus accrued and unpaid interest and additional amounts due 
thereon. 

In  December  2020,  VEON’s  operating  company  in  Ukraine,  Kyivstar,  signed  three  bilateral  unsecured  loan  agreements  with 
Raiffeisen  Bank  Aval  Joint  Stock  Company  ("Raiffeisen"),  Joint  Stock  Company  Alfa-Bank  ("Alfa-Bank")  and  Joint  Stock 
Company OTP Bank ("OTP"), for an aggregate amount of UAH 4.1 billion (approximately US$146 million). The loan agreement 
with Raiffeisen has a 5-year term, and the loan agreements with Alfa-Bank and OTP have a 3-year term. 

Similarly, VEON’s subsidiary in Kazakhstan, KaR-Tel, has signed a bilateral unsecured loan agreement with Forte Bank JSC for 
KZT 10 billion (approximately US$25 million), which has a 3-year term. Both Kyivstar and KaR-Tel will continue to monitor the 
local debt markets for further borrowing opportunities, in line with VEON’s strategy to improve its capital structure via long-term 
borrowings in local currencies.

Changes to Board of Directors and Senior Management 

On February 13, 2020, VEON announced the appointment of Sergi Herrero and Kaan Terzioğlu as co-Chief Executive Officers, 
effective  from  March  1,  2020.  Ursula  Burns,  who  was  appointed  as  Chairman  in  July  2017  and  CEO  in  December  2018,  
remained as VEON’s Chairman before stepping down on June 1, 2020. Gennady Gazin was appointed as Chairman of VEON on 
1 June 2020.  

One  of  the  co-CEOs  chairs  each  VEON  local  board,  with  the  exception  of Algeria. The  role  of  the  boards  is  to  foster  growth, 
monitor progress and oversee operations in each of VEON’s operating companies.

86

On April 3, 2020, VEON announced the appointment of Alexander Torbakhov as Chief Executive Officer of Beeline Russia, 
effective from April 6, following Vasyl Latsanych stepping down from the role earlier in the year.

On April 6, 2020, VEON announced the appointment of Serkan Okandan as Group Chief Financial Officer (CFO), effective from 
May 1, 2020.

On April 28, 2020, VEON announced that Erwan Gelebart has been appointed as CEO for JazzCash effective May 18, 2020.

On  June  1,  2020  VEON  announced  the  results  of  the  elections  conducted  at  its  Annual  General  Meeting  of  Shareholders. 
Shareholders  elected  five  new  members  to  the  company’s  board  of  directors,  Hans  Holger Albrecht,  Mariano  De  Beer,  Peter 
Derby, Amos  Genish  and  Stephen  Pusey,  as  well  as  seven  previously  serving  directors:  Osama  Bedier,  Mikhail  M.  Fridman, 
Gennady Gazin, Andrei Gusev, Gunnar Holt, Robert Jan van de Kraats and Alexander Pertsovsky.

Following the election of the directors, Gennady Gazin was appointed as Chairman of VEON’s board of directors, effective June 
1, 2020.

VEON appointed Yaroslav Glazunov and Leonid Boguslavsky on October 28, 2020 and January 15, 2021, respectively, to the 
company’s board of directors.  Mr. Glazunov is a managing partner at Spencer Stuart International based in Moscow and has 
been  in  the  global  leadership  advisory  business  for  20  years,  focusing  on  CEO  succession,  efficiency  and  performance.  Mr. 
Boguslavsky  is  the  founder  of  RTP  Global,  an  early-stage  venture  capital  firm  with  a  strong  track  record  of  investing  in 
technology, and is considered a pioneer of IT and internet tech investment.

VEON Co-CEO Kaan Terzioğlu Elected to Serve on GSMA Board of Directors

On November 16, 2020, VEON announced that Kaan Terzioğlu was elected to the Board of Directors of the GSMA, the mobile 
industry’s leading global organization that brings together more than 750 operators and nearly 400 ecosystem companies. Kaan 
Terzioğlu’s  appointment  was  confirmed  among  those  of  26  industry  leaders  elected  to  the  GSMA’s  Board  for  a  two-year  term, 
each of whom will serve the mobile industry’s leading global body from January 2021 to December 2022.

Appointment of Chief Internal Audit and Compliance Officer

In October 2020, Joop Brakenhoff was appointed to the position of Chief Internal Audit & Compliance Officer. He reports to the 
co-CEOs and also has a reporting line to the Chairman of the Audit & Risk Committee. 

RECENT DEVELOPMENTS

VEON enters into a US$1,250 million multi-currency revolving credit facility agreement

In March 2021, VEON entered into a new multi-currency revolving credit facility agreement (the "RCF") of US$1,250 million.  The 
RCF replaces the revolving credit facility signed in February 2017, which is now cancelled. The RCF has an initial tenor of three 
years, with the company having the right to request two one-year extensions, subject to lender consent. International banks from 
Asia, Europe and the US have committed to the RCF. The new RCF caters for USD LIBOR cessation with the secured overnight 
financing  rate  (SOFR)  administered  by  the  Federal  Reserve  Bank  of  New  York  agreed  as  the  replacement  risk  free  rate  with 
credit  adjustment  spreads  agreed  for  interest  periods  with  a  one  month,  three  month  and  six  month  tenor.  SOFR  will  apply  to 
interest  periods  commencing  on  and  from  October  31,  2021  (or  earlier  if  USD  LIBOR  is  no  longer  published  or  ceases  to  be 
representative prior to that date). The company will have the option to make each drawdown in either U.S. dollars or euro. 

VEON subsidiary Banglalink successfully acquires 9.4MHz in spectrum auction 

In March 2021, Banglalink, the Company's wholly-owned subsidiary in Bangladesh, acquired 4.4MHz spectrum in the 1800MHz 
band  and  5MHz  spectrum  in  2100MHz  band  following  successful  bids  at  an  auction  held  by  the  BTRC.  The  newly  acquired 
spectrum  will  see  Banglalink  increase  its  total  spectrum  holding  from 30.6MHz  to  40MHz.  Banglalink  will  invest  approximately 
BDT 10 billion (US$115) to purchase the spectrum.

Appointment of CEO of Beeline Uzbekistan

In March 2021, we announced the appointment of Andrzej Malinowski to the vacant position of CEO of Beeline Uzbekistan, with 
effect from March 15, 2021.  Mr. Malinowski joins from Beeline Georgia, where he has held the position of CEO.  Lasha Tabidze 
has been appointed as Mr. Malinowski’s successor at Beeline Georgia, who previously held the joint position of Chief Operating 
Officer  and  Chief  Commercial  Officer  of  Beeline  Georgia.    A  candidate  for  the  Beeline  Uzbekistan  role  had  been  previously 
announced but Beeline Uzbekistan was unable to finalize the employment of this candidate. 

Shareholders trading on NASDAQ no longer subject to annual depository fee 

From January 1, 2021 holders of VEON American Depositary Shares ("ADSs") trading on NASDAQ will no longer be subject to 
any cash dividend fee or depository service fee of any kind. ADS holders will continue to be subject to the normal issuance and 
cancellation fees.

No final dividend declared by the VEON for FY2020

The VEON Group will not be paying a dividend for FY2020.

87

 
FACTORS AFFECTING COMPARABILITY AND RESULTS OF OPERATIONS

Economic Trends 

As a global telecommunications company with operations in a number of markets, we are affected by a broad range of 
international  economic  developments.  Unfavorable  economic  conditions  may  impact  a  significant  number  of  our  customers, 
including their spending patterns, both in terms of the products they subscribe for and usage levels. As a result, it may be more 
difficult for us to attract new customers, more likely that customers will downgrade or disconnect their services and more difficult 
for us to maintain mobile ARPUs at existing levels. The current difficult economic environment and any future downturns in the 
economies  of  markets  in  which  we  operate  or  may  operate  in  the  future  could  also,  among  other  things,  increase  our  costs, 
prevent us from executing our strategies, hurt our liquidity or prevent us to meet unexpected financial requirements. For more 
information  regarding  economic  trends  and  how  they  affect  our  operations,  see  -  Risk  Factors  —  Market  Risks  —“The 
international economic environment could cause our business to decline.”

Inflation

Inflation  affects  the  purchasing  power  of  our  customers  (both  retail  and  corporate).  The  Russian,  Ukrainian  and 
Uzbekistani currencies, for example, have experienced significant inflation levels in recent years, which has caused the relative 
values of those currencies to decline. Although the inflation rates have broadly stabilized, economic and political developments 
may cause inflation rates to rise once again.

Foreign Currency Translation 

Our  audited  consolidated  financial  statements  are  presented  in  U.S.  dollars.  Amounts  included  in  these  financial 
statements were presented in accordance with IAS 21, using the current rate method of currency translation with the U.S. dollar 
as the reporting currency. Our results of operations are affected by increases or decreases in the value of the U.S. dollar or our 
functional  currencies. A  higher  average  exchange  rate  correlates  to  a  weaker  functional  currency. The  functional  currencies  of 
our group are the Russian ruble in Russia, the Pakistani rupee in Pakistan, the Algerian dinar in Algeria, the Bangladeshi taka in 
Bangladesh, the Ukrainian hryvnia in Ukraine, the Uzbekistani som in Uzbekistan, the Kazakhstani tenge in Kazakhstan.

CERTAIN PERFORMANCE INDICATORS

The following discussion provides a description of certain operating data that is not included in our financial statements. 
We provide this operating data because it is regularly reviewed by our management and our management believes it is useful in 
evaluating our performance from period to period as set out below. Our management believes that presenting information about 
Adjusted  EBITDA,  Adjusted  EBITDA  Margin,  mobile  customers,  mobile  ARPU,  mobile  data  customers,  capital  expenditures 
(excluding  licenses  and  right-of-use  assets)  and  local  currency  financial  measures  is  useful  in  assessing  the  usage  and 
acceptance of our mobile and broadband products and services. This operating data is unaudited. 

For  an  explanation  of  how  we  calculate Adjusted  EBITDA, Adjusted  EBITDA  Margin,  capital  expenditures  (excluding 
licenses  and  right-of-use  assets)  and  local  currency  financial  measures,    please  see Explanatory  Note  —  Non-IFRS  Financial 
Measures.  For  a  description  of  how  we  define  mobile  customers,  mobile  data  customers  and  mobile  ARPU,  please  see  the 
discussion below. 

Mobile customers 

Mobile  customers  are  generally  customers  in  the  registered  customer  base  as  of  a  given  measurement  date  who 
engaged  in  a  revenue  generating  activity  at  any  time  during  the  three  months  prior  to  such  measurement  date.  Such  activity 
includes  any  outgoing  calls,  customer  fee  accruals,  debits  related  to  service,  outgoing  SMS  and  MMS,  data  transmission  and 
receipt sessions, but does not include incoming calls, SMS and MMS or abandoned calls. Our total number of mobile customers 
also includes customers using mobile internet service via USB modems.  

Mobile data customers

Mobile data customers are mobile customers who have engaged in revenue generating activity during the three months 
prior  to  the  measurement  date  as  a  result  of  activities  including  USB  modem  Internet  access  using  2.5G/3G/4G/LTE/HSPA+ 
technologies. For Algeria, mobile data customers are 3G customers who have performed at least one mobile data event on the 
3G network during the previous four months. 

Mobile ARPU

Mobile ARPU measures the monthly average revenue per mobile user. We generally calculate mobile ARPU by dividing 
our mobile service revenue during the relevant period, including data revenue, roaming revenue and interconnect revenue, but 
excluding  revenue  from  connection  fees,  sales  of  handsets  and  accessories  and  other  non-service  revenue,  by  the  average 
number of our mobile customers during the period and dividing by the number of months in that period.

88

RESULTS OF OPERATIONS

In millions of U.S. dollars

Consolidated income statement data:
Service revenues
Sale of equipment and accessories
Other revenues / other income
Total operating revenues

Other operating income

Service costs
Cost of equipment and accessories
Selling, general and administrative expenses
Depreciation
Amortization
Impairment (loss) / reversal
Gain / (loss) on disposal of non-current assets
Gain / (loss) on disposal of subsidiaries

Operating profit

Finance costs
Finance income
Other non-operating gain / (loss)
Net foreign exchange gain / (loss)
Profit / (loss) before tax from continuing operations

Income tax expense
Profit / (loss) from continuing operations

Profit / (loss) after tax from discontinued operations
Gain / (loss) on disposal of discontinued operations
Profit / (loss) for the period

Attributable to:
The owners of the parent (continuing operations)
The owners of the parent (discontinued operations)
Non-controlling interest

Year ended 
December 31,

2020

2019

2018

7,471   
392   
117   
7,980   

5   

(1,508)  
(382)  
(2,641)  
(1,576)  
(343)  
(785)  
(37)  
(78)  

635   

(683)  
23   
111   
(60)  
26   

(342)  
(316)  

—   
—   
(316)  

(349)  
—   
33   
(316)  

8,240   
465   
158   
8,863   

350   

(1,554)  
(479)  
(2,965)  
(1,652)  
(394)  
(108)  
(43)  
1   

2,019   

(892)  
53   
21   
(20)  
1,181   

(498)  
683   

—   
—   
683   

621   
—   
62   
683   

8,526 
427 
133 
9,086 

— 

(1,701) 
(415) 
(3,697) 
(1,339) 
(495) 
(858) 
(57) 
30 

554 

(816) 
67 
(68) 
15 
(248) 

(369) 
(617) 

(300) 
1,279 
362 

(397) 
979 
(220) 
362 

The  tables  below  show  for  the  periods  indicated  selected  information  about  the  results  of  operations  in  each  of  our 
reportable  segments.  For  more  information  regarding  our  segments,  see  Note  2  —  Segment  Information  to  our  Audited 
Consolidated Financial Statements attached hereto.

89

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total Operating Revenue

In millions of U.S. dollars, includes intersegment revenue

2020

2019

2018

Year ended December 31,

Our cornerstone
Russia

Our growth engines
Pakistan
Ukraine
Kazakhstan
Uzbekistan

Our frontier markets
Algeria
Bangladesh
Other frontier markets

Other
HQ and eliminations

Total segments

3,819   

4,481   

4,654 

1,233   
933   
479   
198   

689   
537   
125   

(33)  

7,980   

1,321   
870   
486   
258   

775   
537   
172   

(37)  

8,863   

1,494 
688 
441 
315 

813 
521 
201 

(41) 

9,086 

In 2020, our consolidated total operating revenue decreased by 10.0% year-on-year primarily due to the devaluation of 
currencies  across  all  the  countries  in  which  we  operate.  Revenue  fell  on  the  back  of  significant  disruption  of  retail  operations 
faced by our operating companies, following store closures, which resulted in lower gross connections, device sales and airtime 
sales and a decline in roaming revenues. In particular, Russia and Pakistan revenues decreased compared to the prior year in 
local currency terms. These declines were partially offset by strong performance in Ukraine and Kazakhstan. For further details, 
please refer to “Reports of our reportable segments” below. 

Operating Profit

In 2020, our consolidated operating profit decreased to US$635 million compared to US$2,019 million in 2019 primarily 
due  to  an  impairment  loss  of  US$785  million  in  respect  of  our  operations  in  Russia  and  Kyrgyzstan,  refer  to  Note  10  — 
Impairment  Losses  of  our  audited  consolidated  financial  statements  attached  hereto).  Furthermore,  reduced  revenue  as 
described above also contributed to year-on-year reduction in operating profit.

90

 
 
 
 
 
 
 
 
 
 
Non-Operating Profits And Losses

Finance Costs

In 2020, our consolidated finance costs decreased by 23.4% year-on-year primarily due to an updated fair valuation of  
the put option liability on completion of the independent valuation process triggered by the exercise of put option by the Dhabi 
Group and lower interest charges on loans driven by a combination of lower average cost of debt across most countries and by a 
depreciation of the Russian ruble.

Finance Income 

In 2020, our consolidated finance income decreased by 56.6% to US$23 million primarily due to lower cash and deposit 

balances and partially due to currency devaluation on cash and deposits in the local currencies of our operating companies. 

Other Non-Operating Gain / (Loss) 

In 2020, we recorded an other non-operating gain of US$111 million, as compared to a non-operating gain of US$21 
million  in  2019.  The  driver  for  this  increase  related  to  one-off  non-operating  gains  in  2020  as  follows:  (1)  a  revaluation  of 
contingent consideration liability; and (2) a gain upon reaching a settlement in connection with the dispute concerning the sale of 
Telecel  Globe    Limited.  For  more  information  on  these  items  please  refer  to  Note  15  and  Note  7  respectively  of  our Audited 
Consolidated Financial Statements attached hereto. 

Net Foreign Exchange Gain / (Loss) 

In 2020, we recorded a loss of US$60 million from the net foreign exchange result for the year ended 2020. The year-
on-year change was primarily due to depreciation of the currencies of countries in which VEON operates compared to the US 
dollar, which had a negative impact on profit or loss upon translation of US dollar-denominated monetary liabilities, such as trade 
payables and debt. 

Income Tax Expense 

In 2020, our consolidated income tax expense decreased by 31.3% to US$342 million compared to US$498 million in 

2019. 

For more information regarding the factors affecting our total income tax expenses, please refer to Note 8 — Income 

Taxes of our Audited Consolidated Financial Statements attached hereto.

Profit / (Loss) For The Period Attributable To The Owners Of The Parent From Continuing Operations

In  2020,  the  year-on-year  change  of  our  profit  /  (loss)  for  the  period  attributable  to  the  owners  of  the  parent  from 

continuing operations was mainly due to a decrease in operating profit as discussed above. 

Profit / (Loss) For The Period Attributable To Non-Controlling Interest 

In  2020,  the  year-on-year  decrease  in  profit  /  (loss)  for  the  period  attributable  to  non-controlling  interest  was  mainly 

driven by a decrease in operating profit for our operations in Algeria. 

91

Adjusted EBITDA

In millions of U.S. dollars

Our cornerstone

Russia

Our growth engines

Pakistan

Ukraine

Kazakhstan
Uzbekistan

Our frontier markets

Algeria

Bangladesh

Other frontier markets

Other

HQ and eliminations

Total segments

Year ended December 31,

2020

2019

2018

1,504   

1,957   

1,677 

612   

630   

265   
68   

302   

228   

22   

669   

572   

270   
136   

354   

222   

63   

714 

387 

206 
136 

363 

183 

54 

(177)  

3,454   

(28)  

4,215   

(447) 

3,273 

In  2020,  our  total  Adjusted  EBITDA  decreased  by  18.1%  year-on-year  mainly  due  to  lower  revenues  as  discussed 
above  as  well  as  the  recognition  of  a  one-off  gain  of  US$350  million  in  2019  relating  to  a  revised  agreement  with  Ericsson  to 
upgrade the IT systems of VEON’s operating companies. The decrease was partially offset by lower general and administrative 
costs.

For more information on how we calculate Adjusted EBITDA and for the reconciliation of consolidated profit / (loss)  before tax 
from  continuing  operations,  the  most  directly  comparable  IFRS  financial  measure,  to  Adjusted  EBITDA,  for  the  years  ended 
December 31, 2020, 2019 and 2018 please refer to table below.

In millions of U.S. dollars

Profit / (loss) before tax from continuing operations

Depreciation

Amortization

Impairment loss / (reversal)

(Gain) / loss on disposal of non-current assets

(Gain) / loss on disposal of subsidiaries

Finance costs

Finance income

Other non-operating (gain) / loss

Net foreign exchange (gain) / loss

Total Segments Adjusted EBITDA

2020

26 

1,576   

343   

785   

37   

78   

683   

(23)  

(111)  

60   

2019

1,181   

1,652   

394   

108   

43   

(1)  

892   

(53)  

(21)  

20   

2018

(248) 

1,339 

495 

858 

57 

(30) 

816 

(67) 

68 

(15) 

3,454   

4,215   

3,273 

92

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RESULTS OF OUR REPORTABLE SEGMENTS

RUSSIA 

RESULTS OF OPERATIONS IN US$

In millions of U.S. dollars (except as indicated)

Total operating revenue
Mobile service revenue

- of which fixed-mobile convergence (“FMC”)
- of which mobile data
Fixed-line service revenue
Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

RESULTS OF OPERATIONS IN RUB 

Total operating revenue
Mobile service revenue
- of which FMC
- of which mobile data
Fixed-line service revenue
Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

SELECTED PERFORMANCE INDICATORS 

Mobile

Customers in millions
Mobile data customers in millions
ARPU in US$
ARPU in RUB

TOTAL OPERATING REVENUE

Year ended December 31,

2020

3,819
2,917
164
919
523
379

2,319

1,504

2019

4,481
3,485
151
972
539
457

2,523

1,957

2018

4,654
3,679
126
996
566
409

2,977

1,677

 39.4 %

 43.7 %

 36.0 %

Year ended December 31,

‘19-20
% change

 -14.8 %
 -16.3 %
 8.6 %
 -5.5 %
 -3.0 %
 -17.1 %

 -8.1 %

 -23.1 %

 -4.3 pp

‘19-20
% change

274,480
209,527
11,796
66,071
37,657
27,296

167,009

107,775

289,875
225,555
9,788
62,894
34,850
29,470

163,177

126,698

291,539
230,123
7,942
62,259
35,295
26,121

186,822

104,717

 39.3 %

 43.7 %

 35.9 %

 -5.3 %
 -7.1 %
 20.5 %
 5.1 %
 8.1 %
 -7.4 %

 2.3 %

 -14.9 %

 -4.4 pp

Year ended December 31,

2020

2019

2018

‘19-20
% change

‘18-19
% change

 -3.7 %
 -5.3 %
 19.8 %
 -2.4 %
 -4.8 %
 11.7 %

 -15.3 %

 16.7 %

 7.7 pp

‘18-19
% change

 -0.6 %
 -2.0 %
 23.2 %
 1.0 %
 -1.3 %
 12.8 %

 -12.7 %

 21.0 %

 7.8 pp

‘18-19
% change

49.9
32.9
4.6
333.0

54.6
35.5
5.3
340.0

55.3
36.8
5.4
336.0

 -8.6 %
 -7.3 %
 -13.2 %
 -2.1 %

 -1.3 %
 -3.5 %
 -1.9 %
 1.2 %

In millions of RUB (except as indicated)

2020

2019

2018

In 2020 our total operating revenue in Russia decreased by 14.8% (in USD terms) and by 5.3% (in local currency terms) 
year-on-year. Mobile service revenue was negatively impacted by a lower customer base as well as reduced roaming revenues 
due  to  travel  restrictions.  Meanwhile,  fixed-service  revenue  showed  strong  positive  performance  as  customers  relied  more 
heavily on fixed-line data at home due to lockdown restrictions.

ADJUSTED EBITDA

In 2020, our Russia Adjusted EBITDA decreased by 23.1% (in USD terms) and by 14.9% (in local currency terms) year-
on-year  ,  primarily  due  to  lower  revenues  as  stated  above,  as  well  as  an  increase  in  structural  operating  expenses  related  to 
increased network investments and higher interconnection costs due to the increased ratio of off-net traffic. 

NUMBER OF CUSTOMERS

As of December 31, 2020, we had 49.9 million mobile customers in Russia representing a decrease of 8.6% year-on-
year, the decrease which was primarily due to customer perceptions on network quality, as well as a reduction in sales through 
alternate distribution channels and loss of migrant customers from our subscriber base due to travel and lockdown restrictions. 
Mobile data customers also observed a decrease of 7.3% year-on-year.  

ARPU

Our mobile ARPU in Russia decreased by 13.2% (in USD terms) and by 2.1% (in local currency terms) year-on-year, 

mainly driven by lower revenues stemming from reduced activity. 

93

PAKISTAN 

RESULTS OF OPERATIONS IN US$ 

In millions of U.S. dollars (except as indicated)

Total operating revenue

Mobile service revenue

- of which mobile data

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

RESULTS OF OPERATIONS IN PKR

Year ended December 31,

2020

1,233

1,134

426

99

620

612

2019

1,321

1,229

370

92

652

669

2018

1,494

1,391

311

103

780

714

 49.6 %

 50.6 %

 47.8 %

‘19-20
% change

‘18-19
% change

 -6.7 %

 -7.7 %

 15.1 %

 7.6 %

 -4.9 %

 -8.5 %

 -1.0 pp

 -11.6 %

 -11.6 %

 19.0 %

 -10.7 %

 -16.4 %

 -6.3 %

 2.8 pp

Year ended December 31,

In millions of PKR (except as indicated)

2020

2019

2018

Total operating revenue

Mobile service revenue

- of which mobile data

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

SELECTED PERFORMANCE INDICATORS

199,280

183,367

68,965

15,913

100,092

99,188

 49.8 %

197,604

183,760

55,517

13,844

97,531

100,074

 50.6 %

181,722

169,277

38,230

12,445

94,911

86,811

 47.8 %

‘19-20
% change

‘18-19
% change

 0.8 %

 -0.2 %

 24.2 %

 14.9 %

 2.6 %

 -0.9 %

 -0.8 pp

 8.7 %

 8.6 %

 45.2 %

 11.2 %

 2.8 %

 15.3 %

 2.8 pp

Mobile

Customers in millions

Mobile data customers in millions

ARPU in US$

ARPU in PKR

TOTAL OPERATING REVENUE 

Year ended December 31,

2020

2019

2018

‘19-20
% change

‘18-19
% change

66.4

44.0

1.5

239.0

60.5

38.8

1.7

261.0

56.2

33.0

2.1

254.0

 9.8 %

 13.4 %

 -11.8 %

 -8.4 %

 7.7 %

 17.6 %

 -19.0 %

 2.8 %

In 2020, our Pakistan total operating revenue decreased by 6.7% (in USD terms) mainly due to the devaluation of the 
local currency. In local currency terms, revenue increased by 0.8% as a result of strong mobile data revenue supported by an 
expansion of the 4G network in 2020, which also led to overall customer base expansion by 9.8% in 2020.

ADJUSTED EBITDA 

In 2020 our Pakistan Adjusted EBITDA decreased by 8.5% (in USD terms) and by 0.9% (in local currency terms) when 
compared  with  2019,  which  was  primarily  attributable  to  the  classification  of  certain  costs  for  the  ex-Warid  license  paid  in  the 
form of security (under protest) as service costs in 2020, compared to prior year amortization of licenses below EBITDA. This 
impact was offset by the reversal of a provision, with an impact on Adjusted EBITDA of PKR 8.6 billion (USD 52 million) in the 
third quarter of 2020. 

NUMBER OF CUSTOMERS 

In  2020,  we  had  66.4  million  mobile  customers  in  Pakistan,  representing  an  increase  of  9.8%  year-on-year  driven 
primarily by growth in mobile data customers, which increased by 13.4% year-on-year. The increase arose on the back of our 
continued expansion of our data network in Pakistan.

ARPU 

In  2020,  our  mobile  ARPU  in  Pakistan  decreased  by  11.8%  (in  USD  terms)  and  by  8.4%  (in  local  currency  terms), 

mainly driven by reduced activity from the lockdown measures implemented in Pakistan, as described above.

94

UKRAINE 

RESULTS OF OPERATIONS IN US$

Year ended December 31,

In millions of U.S. dollars (except as indicated)

2020

2019

2018

Total operating revenue

Mobile service revenue

- of which mobile data

Fixed-line service revenue

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

RESULTS OF OPERATIONS IN UAH

In millions of UAH (except as indicated)

Total operating revenue

Mobile service revenue

- of which mobile data

Fixed-line service revenue

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

SELECTED PERFORMANCE INDICATORS

Mobile

Customers in millions

Mobile data customers in millions

ARPU in US$

ARPU in UAH

TOTAL OPERATING REVENUE

933

869

489

59

5

303

630

870

812

421

52

6

298

572

688

641

263

44

3

301

387

 67.5 %

 65.7 %

 56.3 %

‘19-20
% change

‘18-19
% change

 7.2 %

 7.0 %

 16.2 %

 13.5 %

 -16.7 %

 1.7 %

 10.1 %

 1.8 pp

 26.5 %

 26.7 %

 60.1 %

 18.2 %

 100.0 %

 -1.0 %

 47.8 %

 9.4 pp

Year ended December 31,

2020

25,158

23,418

13,191

1,602

138

8,181

16,979

 67.5 %

2019

22,392

20,903

10,847

1,350

139

7,709

14,683

 65.6 %

2018

18,720

17,421

7,177

1,206

93

8,190

10,529

 56.2 %

‘19-20
% change

‘18-19
% change

 12.4 %

 12.0 %

 21.6 %

 18.7 %

 -0.7 %

 6.1 %

 15.6 %

 1.9 pp

 19.6 %

 20.0 %

 51.1 %

 11.9 %

 49.5 %

 -5.9 %

 39.5 %

 9.4 pp

Year ended December 31,

2020

2019

2018

‘19-20
% change

‘18-19
% change

25.9

17.1

2.8

75.0

26.2

16.9

2.6

66.0

26.4

14.8

2.0

54.0

 -1.1 %

 1.2 %

 7.7 %

 13.6 %

 -0.8 %

 14.2 %

 30.0 %

 22.2 %

In 2020, our Ukraine total operating revenue increased by 7.2% (in USD terms) and by 12.4% (in local currency terms) 
year-on-year. The change was primarily due to strong growth in mobile data consumption owing to strong 4G adoption on the 
back  of  our  continued  focus  on  4G  connectivity  and  digitalizing  solutions  for  customers.  Fixed-line  revenue  also  grew  year  on 
year as customers continued to draw on fixed-line data at home as described above. 

ADJUSTED EBITDA

In 2020, our Ukraine Adjusted EBITDA increased by 10.1% (in USD terms) and by 15.6% (in local currency terms) year-
on-year, primarily due to solid revenue performance and lower service costs and commercial costs. This was offset partially by 
the increase in structural operating expenses when compared with the previous year.  

NUMBER OF CUSTOMERS

As of December 31, 2020, we had 25.9 million mobile customers in Ukraine representing a decrease of 1.1% year-on-
year. The decrease was a result of increased churn rate and lower gross additions owing to the closure of stores as a result of 
lockdown measures, as well as a reduction in multi-SIM users in the market and demographic trends in Ukraine. Our mobile data 
customers observed an increase of 1.2% year-on-year.

ARPU

In 2020, our mobile ARPU in Ukraine increased by 7.7% (in USD terms) and by 13.6% (in local currency terms) year on 

year, primarily due to usage growth during the year as described above.

95

KAZAKHSTAN

RESULTS OF OPERATIONS IN US$  

Year ended December 31,

In millions of U.S. dollars (except as indicated)

2020

2019

2018

Total operating revenue

Mobile service revenue

- of which mobile data

Fixed-line service revenue

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

RESULTS OF OPERATIONS IN KZT  

479

392

199

78

9

214

265

486

379

157

66

41

216

270

441

363

115

73

5

234

206

 55.3 %

 55.6 %

 46.7 %

‘19-20
% change

‘18-19
% change

 -1.4 %

 3.4 %

 26.8 %

 18.2 %

 10.2 %

 4.4 %

 36.5 %

 -9.6 %

 -78.0 %

 720.0 %

 -0.9 %

 -1.9 %

 -0.3 pp

 -7.7 %

 31.1 %

 8.9 pp

Year ended December 31,

In millions of KZT (except as indicated)

2020

2019

2018

Total operating revenue

Mobile service revenue

- of which mobile data

Fixed-line service revenue

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

SELECTED PERFORMANCE INDICATORS 

Mobile

Customers in millions

Mobile data customers in millions

ARPU in US$

ARPU in KZT

TOTAL OPERATING REVENUE  

197,775

161,873

82,383

32,198

3,704

88,403

186,039

144,925

59,986

25,423

15,691

82,586

109,373

103,454

 55.3 %

 55.6 %

151,799

125,125

39,789

25,228

1,446

80,679

71,119

 46.9 %

‘19-20
% change

‘18-19
% change

 6.3 %

 11.7 %

 37.3 %

 26.6 %

 22.6 %

 15.8 %

 50.8 %

 0.8 %

 -76.4 %

 985.1 %

 7.0 %

 5.7 %

 -0.3 pp

 2.4 %

 45.5 %

 8.7 pp

Year ended December 31,

2020

2019

2018

‘19-20
% change

‘18-19
% change

9.5

7.2

3.3

10.2

6.9

3.1

9.9

6.3

3.0

1,364.0

1,192.0

1,051.0

 -6.9 %

 4.3 %

 6.5 %

 14.4 %

 3.0 %

 9.5 %

 3.3 %

 13.4 %

In 2020, our Kazakhstan total operating revenue decreased by 1.4% (in USD terms) and increased by 6.3% (in local 
currency  terms)  year-on-year.  The  increase  in  local  currency  terms  was  primarily  due  to  strong  demand  for  our  data  services 
(specifically, growth of our 4G user base facilitated through an expansion of our 4G network). Revenue from fixed-line services 
was  also  strong,  as  the  popularity  of  our  convergent  products  contributed  to  a  larger  customer  base.  These  increases  were  
partially  offset  by  the  impact  of  higher  revenues  in  2019  stemming  from  compensation  received  in  relation  to  termination  of  a 
network sharing agreement with Kcell.

ADJUSTED EBITDA  

In 2020, our Kazakhstan Adjusted EBITDA decreased by 1.9% in (USD terms) and increased by 5.7% (in local currency 
terms)  year-on-year,  primarily  due  to  higher  revenues  as  described  above  that  was  offset  partially  by  the  increased  personnel 
costs, certain non-income taxes and technology expenses. 

NUMBER OF CUSTOMERS  

As of December 31, 2020, we had 9.5 million mobile customers in Kazakhstan representing an decrease of 6.9% year-
on-year. The decrease was mainly due to post IMEI registration barriers resulting in lower gross additions. The number of mobile 
data customers increased by 4.3% mainly due to improved bundle offers and data services.

ARPU 

In 2020, our mobile ARPU in Kazakhstan increased by 6.5% (in USD terms) and by 14.4% (in local currency terms) year on year, 
primarily due to data usage growth.

96

UZBEKISTAN

RESULTS OF OPERATIONS IN US$

Year ended December 31,

In millions of U.S. dollars (except as indicated)

2020

2019

2018

Total operating revenue

Mobile service revenue

- of which mobile data

Fixed-line service revenue

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

RESULTS OF OPERATIONS IN UZS

198

196

111

1

1

130

68

258

255

120

2

1

122

136

315

312

108

2

1

178

136

 34.3 %

 52.7 %

 43.2 %

‘19-20
% change

‘18-19
% change

 -23.3 %

 -23.1 %

 -7.5 %

 -50.0 %

 0.0 %

 6.6 %

 -50.0 %

 -18.4 pp

 -18.1 %

 -18.3 %

 11.1 %

 0.0 %

 0.0 %

 -31.5 %

 0.0 %

 9.5 pp

Year ended December 31,

In millions of UZS (except as indicated)

2020

2019

2018

Total operating revenue

Mobile service revenue

- of which mobile data

Fixed-line service revenue

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

SELECTED PERFORMANCE INDICATORS

Mobile

Customers in millions

Mobile data customers in millions

ARPU in US$

ARPU in UZS

TOTAL OPERATING REVENUE

1,985,465

1,966,778

1,114,049

11,489

7,198

1,307,334

679,613

2,275,256

2,251,950

1,059,616

13,229

10,077

1,071,233

1,204,023

2,537,768

2,516,756

871,670

17,390

3,622

1,439,916

1,097,852

 34.2 %

 52.9 %

 43.3 %

‘19-20
% change

‘18-19
% change

 -12.7 %

 -12.7 %

 5.1 %

 -13.2 %

 -28.6 %

 22.0 %

 -43.6 %

 -18.7 pp

 -10.3 %

 -10.5 %

 21.6 %

 -23.9 %

 178.2 %

 -25.6 %

 9.7 %

 9.6 pp

Year ended December 31,

2020

2019

2018

‘19-20
% change

‘18-19
% change

6.8

4.8

2.2

8.1

5.2

2.4

9.1

5.5

2.8

21,758

21,390

22,177

 -16.0 %

 -7.7 %

 -8.3 %

 1.7 %

 -11.0 %

 -5.5 %

 -14.3 %

 -3.5 %

In 2020, our Uzbekistan total operating revenue decreased by 23.3% (in USD terms) and by 12.7% (in local currency 
terms) year-on-year, primarily due to lower subscriber base impacted by a new excise duty and IMEI registration implementation 
as well as weaker business activity due to COVID-19 restrictions.  

ADJUSTED EBITDA

In  2020,  our  Adjusted  EBITDA  in  Uzbekistan  decreased  by  50.0%  (in  USD  terms)  and  by  43.6%  (in  local  currency 

terms) year on year, primarily due to reduced revenues as described above as well as increased structural operating expenses.

NUMBER OF CUSTOMERS

As of end of 2020, the number of mobile customers in our Uzbekistan segment decreased by 16.0% to 6.8 million. The 
decrease was the result of a strategic focus on high value customers resulting in higher churn rate.  The number of our mobile 
data customers also decreased by 7.7% year-on-year. 

ARPU

In 2020, our mobile ARPU in Uzbekistan decreased by 8.3% (in USD terms) and increased by 1.7% (in local currency 

terms) year on year, primarily due to the strategic focus on high value customers as described above.

97

ALGERIA 

RESULTS OF OPERATIONS IN US$

Year ended December 31,

In millions of U.S. dollars (except as indicated)

2020

2019

2018

Total operating revenue

Mobile service revenue

- of which mobile data

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

RESULTS OF OPERATIONS IN DZD

In millions of DZD (except as indicated)

Total operating revenue

Mobile service revenue

- of which mobile data

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

SELECTED PERFORMANCE INDICATORS

Mobile

Customers in millions

Mobile data customers in millions

ARPU in US$

ARPU in DZD

TOTAL OPERATING REVENUE

689

685

260

4

387

302

775

771

232

4

421

354

813

801

188

12

449

363

 43.8 %

 45.7 %

 44.6 %

‘19-20
% change

‘18-19
% change

 -11.1 %

 -11.2 %

 12.1 %

 0.0 %

 -8.1 %

 -14.7 %

 -1.9 pp

 -4.7 %

 -3.7 %

 23.4 %

 -66.7 %

 -6.2 %

 -2.5 %

 1.1 pp

Year ended December 31,

2020

87,201

86,661

32,890

540

48,954

38,282

 43.9 %

2019

92,513

91,870

27,665

643

50,241

42,272

 45.7 %

2018

94,773

93,409

21,978

1,364

52,376

42,398

 44.7 %

‘19-20
% change

‘18-19
% change

 -5.7 %

 -5.7 %

 18.9 %

 -16.0 %

 -2.6 %

 -9.4 %

 -1.8 pp

 -2.4 %

 -1.6 %

 25.9 %

 -52.9 %

 -4.1 %

 -0.3 %

 1.0 pp

Year ended December 31,

2020

2019

2018

‘19-20
% change

‘18-19
% change

14.1

9.2

4.0

502.0

14.6

8.8

4.2

501.0

15.8

9.2

4.3

504.0

 -3.4 %

 4.5 %

 -4.8 %

 0.2 %

 -7.6 %

 -4.3 %

 -2.3 %

 -0.6 %

In 2020, our Algeria total operating revenue decreased by 11.1% (in USD terms) and by 5.7% (in local currency terms) 
year-on-year, primarily due to lower subscriber base in an aggressively competitive market and the negative impact of a change 
in the Mobile Termination Rate (MTR), as well as the economic slowdown due to the COVID-19 pandemic. Data revenue growth 
remained strong due to higher usage as a result of 4G rollout. 

ADJUSTED EBITDA

In 2020, our Algeria Adjusted EBITDA decreased by 14.7% (in USD terms) and by 9.4% (in local currency terms) year-

on-year primarily due to the decrease in total revenue as described above, with operating expenses remaining relatively stable. 

NUMBER OF CUSTOMERS 

As of December 31, 2020, our customer base in Algeria segment decreased by 3.4% to 14.1 million year-on-year driven 
by the overall economic slowdown as a result of the pandemic. Mobile data customers showed a growth of 4.5% year on year 
mainly due to 4G roll out and increased demand for data.

ARPU

In  2020,  our  mobile  ARPU  in  Algeria  decreased  by  4.8%  (in  USD  terms)  and  increased  by  0.2%  (in  local  currency 
terms) year-on-year. The stable performance in local currency terms resulted from growth due to pricing and a more high-value 
customer base, offset by lower consumption due to a general economic slowdown as described above. 

98

BANGLADESH  

RESULTS OF OPERATIONS IN US$

Year ended December 31,

In millions of U.S. dollars (except as indicated)

2020

2019

2018

Total operating revenue

Mobile service revenue

- of which mobile data

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

RESULTS OF OPERATIONS IN BDT

In millions of BDT (except as indicated)

Total operating revenue

Mobile service revenue

- of which mobile data

Sales of equipment, accessories and other

Operating expenses

Adjusted EBITDA

Adjusted EBITDA margin

SELECTED PERFORMANCE INDICATORS

Mobile

Customers in millions

Mobile data customers in millions

ARPU in US$

ARPU in BDT

TOTAL OPERATING REVENUE

537

527

133

10

310

228

537

525

109

12

314

222

521

504

87

17

338

183

 42.5 %

 41.3 %

 35.1 %

‘19-20
% change

‘18-19
% change

 0.0 %

 0.4 %

 22.0 %

 -16.7 %

 -1.3 %

 2.7 %

 1.2 pp

 3.1 %

 4.2 %

 25.3 %

 -29.4 %

 -7.1 %

 21.3 %

 6.2 pp

Year ended December 31,

2020

45,601

44,726

11,286

875

26,286

19,315

 42.4 %

2019

45,284

44,332

9,194

952

26,522

18,762

 41.4 %

2018

43,653

42,211

7,250

1,442

28,306

15,347

 35.2 %

‘19-20
% change

‘18-19
% change

 0.7 %

 0.9 %

 22.8 %

 -8.1 %

 -0.9 %

 2.9 %

 1.0 pp

 3.7 %

 5.0 %

 26.8 %

 -34.0 %

 -6.3 %

 22.3 %

 6.2 pp

Year ended December 31,

2020

2019

2018

‘19-20
% change

‘18-19
% change

33.2

19.9

1.3

111.0

33.6

18.9

1.3

112.0

32.3

19.6

1.3

110.0

 -1.2 %

 5.3 %

 0.0 %

 -0.9 %

 4.0 %

 -3.6 %

 0.0 %

 1.8 %

In 2020, our Bangladesh total operating revenue was at par with prior year in USD terms and observed a slight growth 
of 0.7 % in local currency terms. Overall, the negative impact of the pandemic crisis was offset by consistent performance in the 
acceleration of service revenue growth following spectrum acquisition and enhanced network availability along with the continued 
expansion of Banglalink’s distribution footprint. 

ADJUSTED EBITDA

In  2020,  our  Bangladesh Adjusted  EBITDA  increased  by 2.7%  (in  USD  terms)  and  by  2.9%  (in  local  currency  terms) 
year-on-year. This was mainly due to consistent performance on revenue and operational savings, which was partially offset by 
the increase in minimum tax rates adversely impacting operating expenses.

NUMBER OF CUSTOMERS

As of December 31, 2020, the number of mobile customers in our Bangladesh segment decreased by 1.2% year-on-
year to 33.2  million. This was primarily due to higher churn rate when compared with last year. Our mobile data customers also 
saw an increase of 5.3% year-on-year. 

ARPU

In 2020, our mobile ARPU in Bangladesh remained stable in both USD and local currency terms when compared with 

last year.

99

LIQUIDITY AND CAPITAL RESOURCES 

Working Capital

Working capital is defined as current assets less current liabilities. 

As of December 31, 2020, we had negative working capital of US$1,560 million, compared to negative working capital 
of US$3,269 million as of December 31, 2019. The change was primarily due to decrease in short term borrowings and other 
liabilities and increase in cash position when compared to last year.

Our working capital is monitored on a regular basis by management. Our management expects to repay our debt as it 
becomes due from our operating cash flows or through additional borrowings. Although we have a negative working capital, our 
management believes that our cash balances and available credit facilities are sufficient to meet our present requirements.

In Algeria,  under  the  terms  of  a  shareholder  agreement  between  Global Telecom  Holding  S.A.E.,  the  Fonds  National 
d’Investissement and others, our operating company may only distribute 42.5% of its net profit for a given financial year without 
receiving an approval from a qualified majority of its board. This effectively creates a restriction on the ability of  Global Telecom 
Holding S.A.E. to freely distribute the accumulated retained earnings of our operating company in Algeria. 

Consolidated Cash Flow Summary

(In millions of U.S. dollars)

Net cash flows from operating activities

Net cash flows from / (used in) investing activities

Net cash flows from / (used in) financing activities

Net increase / (decrease) in cash and cash equivalents

Net foreign exchange difference

Cash and cash equivalents at beginning of period

Cash and cash equivalents at end of period, net of overdraft **

2020

2,443 

2019

2018

2,949   

2,515 

(1,910)   

(1,888)   

1,997 

(103)   

(1,639)   

(3,916) 

430   

(48)   

(578)   

(9)   

596 

(119) 

1,204   

1,791   

1,314 

1,586 

1,204   

1,791 

For more details, see Consolidated Statement of Cash Flows in our Audited Consolidated Financial Statements.

In 2020 , net cash flows from operating activities decreased to US$2,443 million from US$2,949 million in  2019. The 
decrease was mainly due to a one off cash inflow of US$350 million in 2019 relating to revised arrangement with Ericsson and 
lower revenues during 2020 when compared with last year. 

For the year ended December 31, 2020, we recorded an outflow of US$1,910 million from investing activities, compared 
to  an  outflow  of  US$1,888  million  in  2019,  this  increase  reflects  the  continued  high  levels  network  investments  in  Russia,  this 
was  offset  by  increased  cash  outflows  in  2019  relating  to  the  amounts  pledged  as  collateral  for  the  Mandatory  Tender  Offer 
(MTO) with respect to acquisition of non-controlling interests in GTH.  Our total payments for the purchase of property, equipment 
and intangible assets amounted to US$1,778 million compared to US$1,683 million in 2019.

In 2020, net cash outflow for financing activities was US$103 million compared to net cash outflow of US$1,639 million 
in  2019. The  change  of  net  cash  flows  used  for  financing  activities  was  mainly  driven  by  significant  financing  and  refinancing 
activities in 2020, compared to the previous year. 

Indebtedness

As  of  December  31,  2020,  the  principal  amounts  of  our  external  indebtedness  represented  by  bank  loans  and  bonds 
amounted  to  US$7,678  million,  compared  to  US$7,519  million  as  of  December  31,  2019. As  of  December  31,  2020,  our  debt 
includes overdrawn bank accounts related to our cash-pooling program of US$8 million. 

As of December 31, 2020, VEON had the following principal amounts outstanding for interest-bearing loans and bonds 

as well as cash-pool overdrawn bank accounts:

100

 
 
 
 
 
 
 
 
 
Entity

Type of debt/ original lenders

Interest rate

Debt 
currency

Outstanding 
debt (mln)

Outstanding 
debt (USD mln)

Maturity 
date

VEON Holdings B.V.

Loan from Sberbank

7.35%

VEON Holdings B.V.

Loan from Sberbank

VEON Holdings B.V.

Loan from Sberbank

CBR Key Rate + 
2.2%

CBR Key Rate + 
2.2%

VEON Holdings B.V.

Loan from Alfa Bank

7.50%

VEON Holdings B.V.

Loan from VTB

CBR Key Rate + 
1.85%

VEON Holdings B.V. Notes

VEON Holdings B.V. Notes

VEON Holdings B.V. Notes

VEON Holdings B.V. Notes

VEON Holdings B.V. Notes

VEON Holdings B.V. Notes

VEON Holdings B.V. Notes

VEON Holdings B.V. Notes

VEON Holdings B.V. Cash-pool overdrawn accounts

VEON Holdings B.V. Total

3.38%

7.50%

5.95%

4.95%

4.00%

7.25%

6.30%

6.50%

 RUB 

 RUB 

 RUB 

 RUB 

 RUB 

 USD 

 USD 

 USD 

 USD 

 USD 

 USD 

 RUB 

 RUB 

30,000

37,500

12,500

30,000

30,000

1,250

417

529

533

1,000

700

20,000

10,000

406 06.03.2024

508 06.03.2023

169 06.03.2023

406 03.11.2025

406 07.09.2025

1,250 11.25.2027

417 03.01.2022

529 02.13.2023

533 06.17.2024

1,000 04.09.2025

700 04.26.2023

271 06.18.2025

135 09.11.2025

1

6,731

PJSC VimpelCom

VIP Finance Ireland (i)

7.75%

 USD 

262

262 02.02.2021

PJSC VimpelCom

Other PJSC VimpelCom

PJSC VimpelCom Total

PMCL

PMCL

PMCL

PMCL

PMCL

PMCL

PMCL

Loan from Habib Bank Limited

6M KIBOR + 0.35%  PKR 

Syndicated Loan Facility

Syndicated Loan Facility

6M KIBOR

6M KIBOR

 PKR 

 PKR 

Syndicated Loan Facility

6M KIBOR + 0.35%  PKR 

Syndicated Loan Facility

6M KIBOR + 0.55%  PKR 

Loan from Habib Bank Limited

6M KIBOR + 0.55%  PKR 

Other

5,000

2,909

1,810

12,837

33,848

10,000

Pakistan Mobile Communications Limited Total

Banglalink

Syndicated Loan Facility

9

271

31 06.15.2022

18 12.15.2023

11 12.15.2023

80 06.15.2022

211 09.02.2026

62 09.02.2026

11

424

Average bank 
deposit rate + 
4.25% 

 BDT 

6,341

75 09.24.2022

Banglalink

Syndicated Loan Facility

Average bank 
deposit rate + 3.0%

 BDT 

436

5 03.24.2021

Other

Banglalink Digital Communications Ltd. Total

PJSC Kyivstar

Loan from Alfa Bank

PJSC Kyivstar

Loan from OTP Bank

NBU Key rate + 
3.00%
10.15%

PJSC Kyivstar

Loan from Raiffeisen Bank

11.00%

PJSC Kyivstar

Loan from Alfa Bank

NBU Key rate + 
3.00%

UAH

UAH

UAH

UAH

1,480

1,000

1,400

120

PJSC Kyivstar Total

Other entities

Cash-pool overdrawn accounts 
and other

(i) Loan from VIP Finance Ireland (funded by the issuance of loan participation notes by VIP Finance Ireland)

8

88

52 12.14.2023

35 12.22.2023

50 11.26.2025

4 02.08.2021

141

23

7,678

101

For additional information on our outstanding indebtedness, please refer to Note 15 — Investments, Debt and Derivatives of our 
Audited Consolidated Financial Statements attached hereto. For a description of some of the risks associated with certain of our 
indebtedness,  see  “Item  3D.  Risk  Factors  —  Liquidity  and  Capital  Risks  —  Substantial  amounts  of  indebtedness  and  debt 
service obligations could materially decrease our cash flow, adversely affect our business and financial condition and prevent us 
from raising additional capital.” 

Cash Subject to Currency and Contractual Restrictions 

The company performed a test on the restricted net assets of consolidated subsidiaries and concluded the restricted 
net assets exceed 25% of the consolidated net assets of the company as of December 31, 2020. The company is subject to 
the  legal  restrictions  to  distribute  accumulated  profits  from  Algeria  by  virtue  of  a  local  shareholding  agreement  (i.e.  it  is 
allowed only to distribute 42.5% of current year profit), and the rest is restricted. As of December 31, 2020, VEON Ltd. had 
restricted net assets of 390%, compared to 58% in 2019, of total net assets. The relative increase in restricted net asset was 
primarily  due  to  the  impairment  of  our  Russia  and  Kyrgyzstan  CGU’s,  as  well  as  the  devaluation  of  exchange  rates  in  the 
countries in which VEON operates, thus lowering the book value of the company’s consolidated net assets compared to an 
unchanged share of the restricted assets. The restricted net assets in Algeria have no implications on the company’s ability to 
pay dividends. 

Accordingly,  separate  condensed  financial  statements  of  VEON  Ltd.  have  been  prepared,  in  accordance  with  Rule 
5-04 and Rule 12-04 of SEC Regulation S-X and presented within Note 25 — Condensed Separate Financial Information of 
VEON of our Audited Consolidated Financial Statements attached hereto.

FUTURE LIQUIDITY AND CAPITAL REQUIREMENTS 

Telecommunications  service  providers  require  significant  amounts  of  capital  to  construct  networks  and  attract 
customers. In the foreseeable future, our further expansion will require significant investment activity, including the purchase of 
equipment and possibly the acquisition of other companies.

In  2020,  our  capital  expenditures  excluding  licenses  and  right  of  use  assets  were  US$1,889  million  compared  to 

US$1,741 million in 2019. This was primarily due to investments in our networks in Russia, Pakistan, Ukraine and Bangladesh. 

We expect that our capital expenditures excluding licenses and right-of-use assets in 2021 will mainly consist 
of  investing  in  high-speed  data  networks  to  capture  mobile  data  growth,  including  the  continued  roll-out  of  4G/LTE  and  3G 
networks in Russia, Algeria, Bangladesh, Pakistan and Ukraine. We expect that these expenditures will continue to be significant 
in 2021. 

Management  anticipates  that  the  funds  necessary  to  meet  our  current  and  expected  capital  requirements  in  the 

foreseeable future (including with respect to any possible acquisitions) will come from:

•

•

•

•

•

•

Cash we currently hold; 

Operating cash flows; 

Export credit agency guaranteed financing; 

Borrowings under bank financings, including credit lines currently available to us; 

Syndicated loan facilities; and 

Issuances of debt securities on local and international capital markets.

As of December 31, 2020, we had an undrawn amount of US$1,625 million under existing credit facilities. For additional 
information on our outstanding indebtedness, please refer to Note 17 — Financial Risk Management of our Audited Consolidated 
Financial Statements attached hereto.

Management  expects  that  positive  cash  flows  from  our  current  operations  will  continue  to  provide  us  with  internal 
sources  of  funds.  The  availability  of  external  financing  depends  on  many  factors,  including  the  success  of  our  operations, 
contractual  restrictions,  availability  of  guarantees  from  export  credit  agencies,  the  financial  position  of  international  and  local 
banks, the willingness of international banks to lend to our companies and the liquidity of international and local capital markets. 

Our  future  cash  needs  are  subject  to  significant  uncertainties.  For  instance,  we  are  exposed  to  the  impact  of  future 
exchange  rates  on  our  U.S.  dollar  denominated  debt  obligations  and  future  requirements  for  U.S.  dollar  denominated  capital 
expenditures,  which  are  generally  funded  by  local  currency  cash  flows  of  our  subsidiaries.  Remittances  from  our  subsidiaries 

102

 
 
may also be restricted by local regulations or subject to material taxes when remitted. Despite these uncertainties, we believe 
that  our  cash  flows  from  operations  and  other  sources  of  funds  described  above  will  be  sufficient  to  meet  our  short  term  and 
foreseeable long-term cash requirements.

Below  is  the  reconciliation  of  Capital  expenditures  excluding  licenses  and  ROU  to  cash  flows  used  to  Purchase  of 

property, plant and equipment and intangible assets:

Capital expenditures *

Adjusted for:

Additions of licenses

Additions of right-of-use assets

Difference in timing between accrual and payment for capital expenditures

2020

2019

2018

1,889   

1,741   

1,415 

53   

446   

(164)  

50   

299   

(108)  

526 

— 

7 

Purchase of property, plant and equipment and intangible assets

1,778   

1,683   

1,948 

* Excluding licenses and right-of-use assets, refer to Note 2 — Segment information of the Audited Consolidated Financial Statements

Quantitative And Qualitative Disclosures About Market Risk

For  information  on  quantitative  and  qualitative  disclosures  about  market  risk  see  —  Quantitative  and  Qualitative 

Disclosures About Market Risk. 

Contractual Obligations

As of  December 31, 2020, we had the following contractual obligations:

Bank loans and bonds

Lease liabilities

Purchase obligations

Less than 
1 year

1-3 
years

3-5 years

More than 
5 years

842   

525   

778   

3,803   

3,123   

1,408   

896   

19   

639   

—   

239   

—   

Total

9,176 

2,299 

797 

Total financial liabilities, net of derivative assets

2,145   

4,718   

3,762   

1,647   

12,272 

For  the  description  of  the  contractual  obligations  please  refer  to  Note  11  —  Property  and  Equipment,  Note  12  — 
Intangible Assets & Goodwill, Note 15 — Investments, Debt and Derivatives and Note 17 — Financial Risk Management  of our 
Audited Consolidated Financial Statements attached hereto.

RESEARCH AND DEVELOPMENT

We now have the capacity to launch 4G/LTE in each of our reportable segments. We have acquired new spectrum in 
several  operating  companies  to  boost  our  network  capacity,  enhance  spectral  efficiency  and  enable  the  launch  of  new  Radio 
Access  Networks  Technologies.  For  example,  in  Russia,  we  are  working  closely  with  a  number  of  vendors  to  undertake  joint 
research and testing of technologies, with a focus on 5G, LTE Advanced Pro and LTE-unlicensed technology. For a discussion of 
the  risks  associated  with  new  technology,  see  -  Risk  Factors  —  Market  Risks  —  “Our  failure  to  keep  pace  with  technological 
changes and evolving industry standards could harm our competitive position and, in turn, materially harm our business.”

OFF-BALANCE SHEET ARRANGEMENTS

We did not have any off-balance sheet arrangements that have or are reasonably likely to have a current or future effect 
on  our  financial  condition,  changes  in  financial  condition,  revenue  or  expenses,  results  of  operations,  liquidity,  capital 
expenditures or capital resources that is material to investors.

RELATED PARTY TRANSACTIONS

We  have  entered  into  transactions  with  related  parties  and  affiliates.  See  “-—Major  Shareholders  and  Related  Party 
Transactions—B. Related Party Transactions” and Note 21 — Related Parties to our Audited Consolidated Financial Statements.

103

 
 
 
 
 
 
 
 
 
ADDITIONAL INFORMATION

Memorandum and Articles of Association

We  describe  below  the  material  provisions  of  our  memorandum  of  association  and  bye-laws,  certain  provisions  of 
Bermuda law relating to our organization and operation, and some of the terms of our share rights based on provisions of our 
memorandum of association, our bye-laws, applicable Bermuda law and certain agreements relating to our shares. Although we 
believe  that  we  have  summarized  the  material  terms  of  our  memorandum  of  association  and  bye-laws,  Bermuda  legal 
requirements and our share capital, this summary is not complete and is qualified in its entirety by reference to our memorandum 
of association, our bye-laws and applicable Bermuda law. All references to our bye-laws herein, unless otherwise noted, are to 
our amended and restated bye-laws, which were approved by our shareholders on July 30, 2018.

The  affirmative  vote  of  at  least  75.0%  of  the  shares  voted  at  a  shareholders  meeting  is  required  to  approve 

amendments to our bye-laws.

General 

VEON Ltd. is an exempted company limited by shares registered under the Companies Act on June 5, 2009, and our 
registered  office  is  located  at  Victoria  Place,  31  Victoria  Street,  Hamilton  HM  10,  Bermuda.  Our  registration  number  with  the 
Registrar of Companies in Bermuda is 43271. As set forth in paragraph 6 of our memorandum of association, VEON Ltd. was 
formed with unrestricted business objects. We are registered with the Dutch Trade Register (registration number 34374835) as a 
company  formally  registered  abroad  (formeel  buitenlandse  kapitaalvennootschap),  as  this  term  is  referred  to  in  the  Dutch 
Companies  Formally  Registered  Abroad  Act  (Wet  op  de  formeel  buitenlandse  vennootschappen),  which  means  that  we  are 
deemed a Dutch resident company for tax purposes in accordance with applicable Dutch tax regulations.

Issued Share Capital 

As  of  December  31,  2020,  the  authorized  share  capital  was  US$1,849,190.67,  divided  into  1,849,190,667  common 
shares, par value US$0.001, of which 1,756,731,135 common shares were issued and outstanding. All issued and outstanding 
shares are fully paid.

Subject to our bye-laws and to any shareholders’ resolution to the contrary, and without prejudice to any special rights 
previously conferred on the holders of any existing shares or class of shares, our board of directors has the power to issue up to 
five  percent  of  the  total  authorized  capital  of  the  company  as  common  shares  on  such  terms  and  conditions  as  the  board  of 
directors  may  determine;  provided  that  this  limitation  does  not  apply  to  the  issue  of  shares  in  connection  with  employee 
compensation awards approved by the board’s compensation and talent committee.

We  may  increase,  divide,  consolidate,  change  the  currency  or  denomination  of  or  reduce  our  share  capital  with  the 

approval of our shareholders. 

We may purchase our own shares for cancellation or acquire them as treasury shares in accordance with Bermuda law 

on such terms as the board of directors may determine. 

We may, under our bye-laws, at any time request any person we have cause to believe is interested in our shares to 

confirm details of our shares in which that person holds an interest. 

Common shares 

The holders of common shares are, subject to our bye-laws and Bermuda law, generally entitled to enjoy all the rights 

attaching to common shares. 

Except for treasury shares, each fully paid common share entitles its holder to:  

•

•

•

•

•

participate in shareholder meetings;  

have one vote on all issues voted upon at a shareholder meeting, except for the purposes of cumulative voting for the 
election of the board of directors, in which case each common share shall have the same number of votes as the total 
number of members to be elected to the board of directors and all such votes may be cast for a single candidate or may 
be distributed between or among two or more candidates;  

receive dividends approved by the board of directors (any dividend or other moneys payable in respect of a share which 
has remained unclaimed for six years from the date when it became due for payment shall, if the board of directors so 
resolves, be forfeited and cease to remain owing by VEON Ltd.); 

in the event of our liquidation, receive a pro rata share of our surplus assets; and 

exercise any other rights of a common shareholder set forth in our bye-laws and Bermuda law.

104

There are no sinking fund provisions attached to any of our shares. Holders of fully paid shares have no further liability 

to VEON Ltd. for capital calls. 

All rights of any share of any class held in treasury are suspended and may not be exercised while the share is held by 

VEON Ltd. in treasury.  

Shareholders’ Meetings 

Shareholders’ meetings are convened and held in accordance with our bye-laws and Bermuda law. Registered holders 

of shares as of the record date for the shareholder meeting may attend and vote.

Annual general meeting 

Our bye-laws and Bermuda law provide that our annual general meeting must be held each year at such time and place 

as the CEO or the board of directors may determine. 

Convening the annual general meeting requires that 30 clear days’ prior notice be given to each shareholder entitled to 
attend and vote at such annual general meeting. The notice must state the date, place and time at which the meeting is to be 
held, that the election of directors will take place and, as far as practicable, any other business to be conducted at the meeting. 

Under  Bermuda  law,  shareholders  may,  at  their  own  expense  (unless  the  company  otherwise  resolves),  require  a 
company to: (a) give notice to all shareholders entitled to receive notice of the annual general meeting of any resolution that the 
shareholders  may  properly  move  at  the  next  annual  general  meeting;  and  (b)  circulate  to  all  shareholders  entitled  to  receive 
notice of any general meeting a statement in respect of any matter referred to in the proposed resolution or any business to be 
conducted at such general meeting. The number of shareholders necessary for such a requisition is either: (1) any number of 
shareholders representing not less than 5.0% of the total voting rights of all shareholders entitled to vote at the meeting to which 
the requisition relates; or (2) not less than 100 registered shareholders. 

Special general meeting 

The CEO or the board of directors may convene a special general meeting whenever in their judgment such a meeting 
is necessary. The board of directors must, on the requisition in writing of shareholders holding not less than 10.0% of our paid up 
voting share capital, convene a special general meeting. Each special general meeting may be held at such time and place as 
the CEO or the board of directors may appoint.  

Convening a special general meeting requires that 30 clear days’ notice be given to each shareholder entitled to attend 
and  vote  at  such  meeting.  The  notice  must  state  the  date,  place  and  time  at  which  the  meeting  is  to  be  held  and  as  far  as 
possible any other business to be conducted at the meeting. 

Our bye-laws state that notice for all shareholders’ meetings may be given by: 

delivering such notice to the shareholder in person;  

sending such notice by letter or courier to the shareholder’s address as stated in the register of shareholders;  

transmitting such notice by electronic means in accordance with directions given by the shareholder; or 

accessing such notice on our website.

•

•

•

•

Shorter notice for general meetings 

A  shorter  notice  period  will  not  invalidate  a  general  meeting  if  it  is  approved  by  either:  (a)  in  the  case  of  an  annual 
general meeting, all shareholders entitled to attend and vote at the meeting, or (b) in the case of a special general meeting, a 
majority of shareholders having the right to attend and vote at the meeting and together holding not less than 95.0% in nominal 
value of the shares giving a right to attend and vote at the meeting. The accidental omission to give notice of a general meeting 
to,  or  the  non-receipt  of  notice  of  a  general  meeting  by,  any  shareholder  entitled  to  receive  notice  shall  not  invalidate  the 
proceedings at that meeting. 

Postponement or cancellation of general meeting 

The board of directors may postpone or cancel any general meeting called in accordance with the bye-laws (other than 
a  meeting  requisitioned  by  shareholders)  provided  that  notice  of  postponement  or  cancellation  is  given  to  each  shareholder 
before the time for such meeting. 

105

Quorum 

Subject to the Companies Act and our bye-laws, at any general meeting, two or more persons present in person at the 
start of the meeting and having the right to attend and vote at the meeting and holding or representing in person or by proxy at 
least 50.0% plus one share of our total issued and outstanding shares at the relevant time will form a quorum for the transaction 
of business. 

If within half an hour from the time appointed for the meeting a quorum is not present, then, in the case of a meeting 
convened on a requisition, the meeting shall be deemed cancelled and, in any other case, the meeting shall stand adjourned to 
the same day one week later, at the same time and place, or to such other day, time or place as the CEO may determine.

Voting Rights  

Under Bermuda law, the voting rights of our shareholders are regulated by our bye-laws and, in certain circumstances, 

the Companies Act. 

Subject to Bermuda law and our bye-laws, a resolution may only be put to a vote at a general meeting of any class of 

shareholders if: 

•

•

•

•

it is proposed by or at the direction of the board of directors;  

it is proposed at the direction of a court; 

it  is  proposed  on  the  requisition  in  writing  of  such  number  of  shareholders  as  is  prescribed  by,  and  is  made  in 
accordance with, the relevant provisions of the Companies Act or our bye-laws; or 

the chairman of the meeting in his absolute discretion decides that the resolution may properly be regarded as within 
the scope of the meeting. 

In addition to those matters required by Bermuda law or by the NASDAQ rules to be approved by a simple majority of 
shareholders  at  any  general  meeting,  the  following  actions  require  the  approval  of  a  simple  majority  of  the  votes  cast  at  any 
general meeting:  

•

•

•

any sale of all or substantially all of our assets;  

the appointment of an auditor; and  

removal of directors.  

Any  question  proposed  for  the  consideration  of  the  shareholders  at  any  general  meeting  may  be  decided  by  the 

affirmative votes of a simple majority of the votes cast, except for: 

•

•

•

•

•

•

whitewash procedure for mandatory offers, which requires the affirmative vote of a majority of the shareholders voting in 
person or by proxy at a general meeting, excluding the vote of the shareholder or shareholders in question and their 
affiliates; 

voting for directors, which requires directors to be elected by cumulative voting at each annual general meeting; 

changes to our bye-laws, which require a resolution to be passed by shareholders representing not less than 75.0% of 
the total voting rights of the shareholders who vote in person or by proxy on the resolution; 

any  merger,  consolidation,  amalgamation,  conversion,  reorganization,  scheme  of  arrangement,  dissolution  or 
liquidation,  which  requires  a  resolution  to  be  passed  by  shareholders  representing  not  less  than  75.0%  of  the  total 
voting rights of the shareholders who vote in person or by proxy on the resolution; 

loans to any director, which require a resolution to be passed by shareholders representing not less than 90.0% of the 
total voting rights of the shareholders who vote in person or by proxy on the resolution; and 

the  discontinuation  of  VEON  Ltd.  to  a  jurisdiction  outside  Bermuda,  which  requires  a  resolution  to  be  passed  by 
shareholders representing not less than 75.0% of the total voting rights of the shareholders who vote in person or by 
proxy on the resolution. 

Our bye-laws require voting on any resolution at any meeting of the shareholders to be conducted by way of a poll vote. 
Except where cumulative voting is required, each person present and entitled to vote at a meeting of the shareholders shall have 
one  vote  for  each  share  of  which  such  person  is  the  holder  or  for  which  such  person  holds  a  proxy  and  such  vote  shall  be 
counted by ballot or, in the case of a general meeting at which one or more shareholders are present by electronic means, in 
such manner as the chairman of the meeting may direct. A person entitled to more than one vote need not use all his votes or 
cast all the votes he uses in the same way.

If no instruction is received from a holder of our ADSs, the Depositary shall give a proxy to an individual selected by the 
board of directors to vote the number of shares represented by the uninstructed ADSs at any shareholders’ meeting. The board 
of directors’ proxy designee will then vote the shares in accordance with the votes of all other shares represented and voting at 

106

the  meeting,  excluding  any  votes  of  any  security  holder  of  the  company  beneficially  owning  more  than  five  percent  of  the 
securities entitled to vote at the meeting. 

Voting rights of common shares 

The holders of common shares, subject to the provisions of our bye-laws, are entitled to one vote per common share, 

except where cumulative voting applies when electing directors. 

Transfer Restrictions 

For such time as our common shares are fully paid and our ADSs listed on the NASDAQ Stock Market Inc., or our 
common  shares  are  listed  on  Euronext  Amsterdam  (or  another  appointed  exchange,  as  determined  from  time  to  time  by  the 
Bermuda Monetary Authority), there are no Bermuda law transfer restrictions applicable to our common shares. Were any of our 
common shares to not be fully paid, our bye-laws permit the board of directors to decline to register a transfer. At such time as 
our  ADSs  cease  to  be  listed  on  the  NASDAQ  Stock  Market  Inc.,  or  our  common  shares  cease  to  be  listed  on  Euronext 
Amsterdam (or another appointed exchange, as determined from time to time by the Bermuda Monetary Authority), the Bermuda 
Exchange  Control Act  1972  and  associated  regulations  require  that  the  prior  consent  of  the  Bermuda  Monetary Authority  be 
obtained for any transfers of shares.

Foreign Shareholders 

Our bye-laws have no requirements or restrictions with respect to foreign ownership of our shares. 

Board of Directors 

VEON Ltd. is governed by our board of directors, currently consisting of 12 directors. 

Subject  to  certain  material  business  decisions  that  are  reserved  to  the  board  of  directors,  the  board  of  directors 

generally delegates day-to-day management of our company to our co-CEOs.

All directors are elected by our shareholders to the board through cumulative voting. Each voting share confers on its 
holder a number of votes equal to the number of directors to be elected. The holder may cast those votes for candidates in any 
proportion, including casting all votes for one candidate.  

Under our bye-laws, the amount of any fees or other remuneration payable to directors is determined by the board of 
directors upon the recommendation of the compensation and talent committee. We may repay to any director such reasonable 
costs and expenses as he or she may incur in the performance of his or her duties.  

There is no requirement for the members of our board of directors to own shares. A director who is not a shareholder 
will nevertheless be entitled to attend and speak at general meetings and at any separate meeting of the holders of any class of 
shares.  

Neither Bermuda law nor our bye-laws establish any mandatory retirement age for our directors or executive officers.  

Dividends and Dividend Rights 

Pursuant  to  Bermuda  law,  we  are  prohibited  from  declaring  or  paying  a  dividend  if  there  are  reasonable  grounds  for 
believing that (a) we are, or would after the payment be, unable to pay our liabilities as they become due, or (b) the realizable 
value of our assets would, as a result of the dividend, be less than the aggregate of our liabilities. 

The board of directors may, subject to our bye-laws and in accordance with the Companies Act, declare a dividend to be 
paid to the shareholders holding shares entitled to receive dividends, in proportion to the number of shares held by them, and 
such dividend may be paid in cash or wholly or partly in shares or other assets, including through the issuance of our shares or 
other  securities,  in  which  case  the  board  of  directors  may  fix  the  value  for  distribution  in  specie  of  any  assets,  shares  or 
securities. We are not required to pay interest on any unpaid dividend. 

In  accordance  with  our  bye-laws,  dividends  may  be  declared  and  paid  in  proportion  to  the  amount  paid  up  on  each 

share. The holders of common shares are entitled to dividends if the payment of dividends is approved by the board of directors.

Dividends unclaimed for a period of six years from the date of payment may be forfeited. 

Our bye-laws and Bermuda law do not provide for pre-emptive rights of shareholders in respect of new shares issued 

by us.  

There  is  no  statutory  regulation  of  the  conduct  of  takeover  offers  and  transactions  under  Bermuda  law.  However,  our 
bye-laws provide that any person who, individually or together with any of its affiliates or any other members of a group, acquires 

107

beneficial ownership of any shares which, taken together with shares already beneficially owned by it or any of its affiliates or its 
group, in any manner, carry 50.0% or more of the voting rights of our issued and outstanding shares, must, within 30 days of 
acquiring such shares, make a general offer to all holders of shares to purchase their shares. 

Interested Party Transactions  

The  board  of  directors  have  the  right  to  approve  transactions  with  interested  parties,  subject  to  compliance  with 
Bermuda  law.  Prior  to  approval  by  the  board  of  directors,  as  the  case  may  be,  on  such  transaction,  all  interests  must  be  fully 
disclosed. 

Liquidation Rights 

If VEON Ltd. is wound up, the liquidator may, with the sanction of a resolution of the shareholders, divide among the 
shareholders in specie or in kind the whole or any part of our assets (whether they shall consist of property of the same kind or 
not)  and  may,  for  such  purpose,  set  such  value  as  he  deems  fair  upon  any  property  to  be  divided  as  aforesaid  and  may 
determine how such division shall be carried out as between the shareholders or different classes of shareholders. 

The liquidator may, with the same sanction, vest the whole or any part of such assets in trustees upon such trusts for 
the benefit of the shareholders as the liquidator thinks fit, but so that no shareholder may be compelled to accept any shares or 
other securities or assets on which there is any liability. 

The  holders  of  common  shares,  in  the  event  of  our  winding-up  or  dissolution,  are  entitled  to  our  surplus  assets  in 

respect of their holdings of common shares, pari passu and pro rata to the number of common shares held by each of them. 

Share Registration, Transfers and Settlement 

All  of  our  issued  shares  are  registered.  The  register  of  members  of  a  company  is  generally  open  to  inspection  by 
shareholders  and  by  members  of  the  general  public  without  charge.  The  register  of  members  is  required  to  be  open  for 
inspection for not less than two hours in any business day (subject to the ability of a company to close the register of members 
for not more than 30 days in a year). A company is required to maintain its share register in Bermuda but may, subject to the 
provisions of the Companies Act, establish a branch register outside of Bermuda. A company is required to keep at its registered 
office a register of directors and officers that is open for inspection for not less than two hours in any business day by members 
of the public without charge. Bermuda law does not, however, provide a general right for shareholders to inspect or obtain copies 
of any other corporate records.

108

QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK

We are exposed to market risk from adverse movements in foreign currency exchange rates and changes in interest 

rates on our obligations. 

As of  December 31, 2020, the largest currency exposure risks for our group were in relation to the Russian ruble, the 
Pakistani  rupee,  the Algerian  dinar,  the  Bangladeshi  taka,  the  Ukrainian  hryvnia,  the  Kazakh  tenge  and  the  Uzbekistani  som, 
because the majority of our cash flows from operating activities in Russia, Pakistan, Algeria, Bangladesh, Ukraine, Kazakhstan 
and Uzbekistan are denominated in each of these local currencies, respectively, while our debt, if not incurred in or hedged to the 
aforementioned currencies, is primarily denominated in U.S. dollars.

We  hold  approximately  74%  of  our  cash  and  bank  deposits  in  U.S.  dollars  in  order  to  hedge  against  the  risk  of  local 

currency devaluation.

To  reduce  balance  sheet  currency  mismatches,  we  hold  part  of  our  debt  in  Russian  ruble,  Pakistani  rupee  and  other 
currencies, as well as selectively enter into foreign exchange derivatives. Nonetheless, if the U.S. dollar value of the Bangladeshi 
taka, the Russian ruble, the Georgian lari, the Pakistani rupee, the Uzbekistani som, the Algerian dinar, the Ukrainian hryvnia or 
the  Kazakh  tenge  were  to  dramatically  decline,  it  could  negatively  impact  our  ability  to  repay  or  refinance  our  U.S.  dollar 
denominated indebtedness as well as could adversely affect our financial condition and results of operations. 

In accordance with our policies, we do not enter into any treasury transactions of a speculative nature.

For  more  information  regarding  our  translation  of  foreign  currency-denominated  amounts  into  U.S.  dollars  and  our 
exposure to adverse movements in foreign currency exchange rates, see — Operating and Financial Review and Prospects — 
Factors Affecting Comparability — Net Foreign Exchange (Loss)/Gain and Note 17 — Financial Risk Management to our Audited 
Consolidated Financial Statements. 

Our  treasury  function  has  developed  risk  management  policies  that  establish  guidelines  for  limiting  foreign  currency 
exchange rate risk. For more information on risks associated with currency exchange rates, see —  Risk Factors — Market Risks 
— “We are exposed to foreign currency exchange loss and currency fluctuation and translation risks.”

The following table summarizes information, as of  December 31, 2020, regarding the maturity of the part of our bank 

loans and bonds for which the foreign exchange revaluation directly affects our reported profit or loss:

Aggregate nominal amount of bank loans and bonds denominated 
in foreign currency outstanding as of December 31,

Fair Value as of 
December 31,

2020

2021

2022

2023

2024

2020

Total debt:

Fixed Rate (in US$ millions)

Average interest rate

Variable Rate (in US$ millions)

Average interest rate

TOTAL

809

6.82%

8

3.45%

817

547

6.72%

—

—

547

439

6.73%

—

—

439

100

6.63%

—

—

100

609

6.39%

—

—

609

816

8

824

As of December 31, 2020, the variable interest rate risk on the financing of our group was limited as 79% of the group’s 

bank loans and bonds portfolio was fixed rate debt. 

For more information on our market risks and financial risk management for derivatives and other financial instruments, 
see  Note  15  —  Investments,  Debt  and  Derivatives  and  Note  17  —  Financial  Risk  Management  to  our Audited  Consolidated 
Financial Statements.

109

 
DECLARATIONS

Introduction

This 2020 VEON’s Ltd. Annual Report dated March 15, 2021, comprises regulated information within the meaning of sections 1:1 
and 5:25c of the Dutch Act on Financial Supervision “Wet op het financieel toezicht.” 

Declarations

The Company’s co-CEOs, as required by section 5:25c, paragraph 2, under c of the Dutch Act on Financial Supervision, confirm 
that to the best of their knowledge:

•

•

•

The 2020 financial statements included in this Annual Report give a true and fair view of the assets, liabilities, financial 
position and profit or loss of the Company and the undertakings included in the consolidation taken as a whole.

The Director’s Report included in this Annual Report gives a true and fair view of the position of the Company and the 
undertakings  included  in  the  consolidation  taken  as  a  whole  as  of  December  31,  2020,  and  of  the  development  and 
performance of the business for the financial year then ended.

The Director’s Report includes a description of the principal risks and uncertainties that the Company faces. 

This Annual Report, including the 2020 financial statements, which are audited by PricewaterhouseCoopers Accountants N.V., 
has been presented to the Board. The 2020 financial statements and the independent auditor’s report relating to the audit of the 
2020 financial statements were discussed with the Audit and Risk Committee in the presence of the senior management and the 
external  independent  auditor.  The  Board  recommends  that  the  General  Meeting  of  Shareholders  adopts  the  2020  financial 
statements included in this Annual Report.

Amsterdam, the Netherlands

March 15, 2021 

Kaan Terzioğlu co-CEO

Sergi Herrero co-CEO

110

Consolidated Financial Statements

111

113

114

115

116

118

119

119

120

120

122

124

125

126

127

131

136

136

138

142

145

147

150

150

151

159

160

166

167

168

169

169

173

174

175

TABLE OF CONTENTS

Consolidated Income Statement.............................................................................................................................

Consolidated Statement Of Comprehensive Income............................................................................................

Consolidated Statement Of Financial Position......................................................................................................

Consolidated Statement Of Changes In Equity.....................................................................................................

Consolidated Statement Of Cash Flows.................................................................................................................

General Information About The Group...................................................................................................................

1.... General Information............................................................................................................................................

Operating Activities Of The Group..........................................................................................................................

2.... Segment Information..........................................................................................................................................
3.... Operating Revenue.............................................................................................................................................
4.... Selling, General And Administrative Expenses...................................................................................................
5.... Trade And Other Receivables.............................................................................................................................
6.... Other Assets And Liabilities................................................................................................................................
7.... Provisions And Contingent Liabilities..................................................................................................................
8....

Income Taxes......................................................................................................................................................

Investing Activities Of The Group...........................................................................................................................
9.... Significant Transactions......................................................................................................................................
10..

Impairment Of Assets.........................................................................................................................................
11... Property And Equipment.....................................................................................................................................
12..

Intangible Assets.................................................................................................................................................

13..

Investments In Subsidiaries................................................................................................................................

Financing Activities Of The Group..........................................................................................................................
14.. Other non-operating gain / (loss)........................................................................................................................
15..

Investments, Debt and Derivatives.....................................................................................................................
16.. Cash And Cash Equivalents...............................................................................................................................
17.. Financial Risk Management...............................................................................................................................
18..

Issued Capital And Reserves..............................................................................................................................
19.. Earnings Per Share............................................................................................................................................
20.. Dividends Paid And Proposed............................................................................................................................

Additional Information.............................................................................................................................................
21.. Related Parties...................................................................................................................................................
22.. Events After The Reporting Period.....................................................................................................................
23.. Basis Of Preparation Of The Consolidated Financial Statements......................................................................
24.. Significant Accounting Policies...........................................................................................................................

112

CONSOLIDATED INCOME STATEMENT

for the years ended December 31

(In millions of U.S. dollars, except per share amounts)

Note

2020

2019

Service revenues

Sale of equipment and accessories

Other revenues / other income

Total operating revenues

Other operating income

Service costs

Cost of equipment and accessories

Selling, general and administrative expenses

Depreciation

Amortization

Impairment (loss) / reversal

Gain / (loss) on disposal of non-current assets

Gain / (loss) on disposal of subsidiaries

Operating profit

Finance costs

Finance income

Other non-operating gain / (loss)

Net foreign exchange gain / (loss)

Profit / (loss) before tax from continuing operations

Income tax expense

Profit / (loss) from continuing operations

Profit / (loss) after tax from discontinued operations

Gain / (loss) on disposal of discontinued operations

Profit / (loss) for the period

Attributable to:

The owners of the parent (continuing operations)

The owners of the parent (discontinued operations)

Non-controlling interest

Basic and diluted gain / (loss) per share attributable to ordinary equity 
holders of the parent:

From continuing operations

From discontinued operations

Total

7,471   

8,240   

392   

117   

465   

158   

7,980   

8,863   

5   

350   

(1,508)   

(382)   

(2,641)   

(1,576)   

(343)   

(785)   

(37)   

(78)   

635   

(683)   

23   

111   

(60)   

26   

(342)   

(316)   

—   

—   

(316)   

(349)   

—   

33   

(316)   

($0.20)   

$0.00   

($0.20)   

(1,554)   

(479)   

(2,965)   

(1,652)   

(394)   

(108)   

(43)   

1   

2,019   

(892)   

53   

21   

(20)   

1,181   

(498)   

683   

—   

—   

683   

621   

—   

62   

683   

$0.36   

$0.00   

$0.36   

3

9

4

11

12

10

9

14

8

9

9

19

19

19

The accompanying notes are an integral part of these consolidated financial statements.

2018

8,526 

427 

133 

9,086 

— 

(1,701) 

(415) 

(3,697) 

(1,339) 

(495) 

(858) 

(57) 

30 

554 

(816) 

67 

(68) 

15 

(248) 

(369) 

(617) 

(300) 

1,279 

362 

(397) 

979 

(220) 

362 

($0.23) 

$0.56 

$0.33 

113

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME

for the years ended December 31

(In millions of U.S. dollars)

Profit / (loss)

Items that may be reclassified to profit or loss

Foreign currency translation

Share of other comprehensive income / (loss) of Italy Joint Venture

Other

Items reclassified to profit or loss

Reclassification of accumulated foreign currency translation reserve to profit 
or loss upon disposal of foreign operation

Reclassification of accumulated share of other comprehensive income / 
(loss) of Italy Joint Venture to profit or loss

Other

Other comprehensive income / (loss) for the period, net of tax

Total comprehensive income / (loss) for the period, net of tax

Attributable to:

The owners of the parent

Non-controlling interests

Note

9

9

15

The accompanying notes are an integral part of these consolidated financial statements.

2020

(316)   

(623)   

—   

1   

96   

—   

(15)   

(541)   

(857)   

(800)   

(57)   

(857)   

2019

683   

49   

—   

26   

2018

362 

(819) 

(18) 

(7) 

—   

(79) 

—   

(19)   

56   

739   

733   

6   

739   

31 

5 

(887) 

(525) 

(138) 

(387) 

(525) 

114

 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF FINANCIAL POSITION

as of December 31

(In millions of U.S. dollars)

Assets

Non-current assets

Property and equipment

Intangible assets

Investments and derivatives

Deferred tax assets

Other assets

Total non-current assets

Current assets

Inventories

Trade and other receivables

Investments and derivatives

Current income tax assets

Other assets

Cash and cash equivalents

Total current assets

Total assets

Equity and liabilities

Equity

Equity attributable to equity owners of the parent

Non-controlling interests

Total equity

Non-current liabilities

Debt and derivatives

Provisions

Deferred tax liabilities

Other liabilities

Total non-current liabilities

Current liabilities

Trade and other payables

Debt and derivatives

Provisions

Current income tax payables

Other liabilities

Total current liabilities

Total equity and liabilities

The accompanying notes are an integral part of these consolidated financial statements.

115

Note

2020

2019

11

12

15

8

6

5

15

8

6

16

18

15

7

8

6

15

7

8

6

6,879 

4,152 

305 

186 

179 

7,340 

5,688 

235 

134 

163 

11,701 

13,560 

111 

572 

165 

73 

335 

1,594 

2,850 

169 

628 

82 

16 

354 

1,250 

2,499 

14,551 

16,059 

163 

850   

1,013 

1,226 

994 

2,220 

8,832 

7,759 

141 

127 

28 

138 

141 

33 

9,128 

8,071 

1,977 

1,224 

151 

175 

883 

4,410 

14,551 

1,847 

2,585 

222 

102 

1,012 

5,768 

16,059 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF CHANGES IN EQUITY

for the year ended December 31, 2020

(In millions of U.S. dollars)

As of January 1, 2020

Profit / (loss) for the period

Other comprehensive income / (loss)

Total comprehensive income / (loss)

Dividends declared

Other

20

As of December 31, 2020

1,749,127,404   

for the year ended December 31, 2019

Attributable to equity owners of the parent

Note

Number of shares 
outstanding

Issued 
capital

Capital 
Surplus

Other 
capital 
reserves

Accumulated 
deficit *

Foreign 
currency 
translation

Non-
controlling 
interests

Total

Total equity

1,749,127,404   

2   

12,753   

(1,887)   

(1,330)   

(8,312)   

1,226   

994   

2,220 

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

2   

—   

—   

—   

—   

—   

—   

(10)   

(10)   

—   

(1)   

(349)   

(4)   

(353)   

(262)   

26   

—   

(437)   

(437)   

—   

(26)   

12,753   

(1,898)   

(1,919)   

(8,775)   

(349)   

(451)   

(800)   

(262)   

(1)   

163   

33   

(90)   

(57)   

(87)   

—   

850   

(316) 

(541) 

(857) 

(349) 

(1) 

1,013 

(In millions of U.S. dollars)

As of December 31, 2018

Adjustments due to new accounting standards

As of January 1, 2019

Profit / (loss) for the period

Other comprehensive income / (loss)

Total comprehensive income / (loss)

Dividends declared
Changes in ownership interest in a subsidiary
that do not result in a loss of control

20

9

Other

As of December 31, 2019

1,749,127,404   

Note

Number of shares 
outstanding

Issued 
capital

Capital 
Surplus

Other 
capital 
reserves

Accumulated 
deficit *

Foreign 
currency 
translation

Non-
controlling 
interests

Total

Total equity

Attributable to equity owners of the parent

1,749,127,404   

—   

1,749,127,404   

—   

—   

—   

—   

—   

—   

2   

—   

2   

—   

—   

—   

—   

—   

—   

2   

12,753   

—   

12,753   

—   

—   

—   

—   

—   

—   

743   

—   

743   

—   

6   

6   

—   

(2,594)   

(42)   

(1,412)   

(8,416)   

3,670   

(891)   

2,779 

(3)   

—   

(3)   

(1)   

(4) 

(1,415)   

(8,416)   

3,667   

(892)   

2,775 

621   

1   

622   

(525)   

—   

(12)   

—   

105   

105   

—   

—   

(1)   

621   

112   

733   

62   

(56)   

6   

(525)   

(108)   

(2,594)   

1,986   

(55)   

2   

683 

56 

739 

(633) 

(608) 

(53) 

12,753   

(1,887)   

(1,330)   

(8,312)   

1,226   

994   

2,220 

* Certain of the consolidated entities by VEON Ltd. are restricted from remitting funds in the form of cash dividends or loans by a variety of regulations, contractual or local statutory requirements

The accompanying notes are an integral part of these consolidated financial statements.

116

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF CHANGES IN EQUITY

for the year ended December 31, 2018

(In millions of U.S. dollars, except for share 
amounts)

Note

Number of shares 
outstanding

Issued 
capital

Capital 
Surplus

Other 
capital 
reserves

Accumulated 
deficit *

Foreign 
currency 
translation

Non-
controlling 
interests

Total

Total equity

Attributable to equity owners of the parent

As of December 31, 2017

1,749,127,404   

2   

12,753   

Adjustments due to new accounting 
standards
As of January 1, 2018

—

—

—

1,749,127,404   

2   

12,753   

Profit / (loss) for the period

Other comprehensive income

Total comprehensive income

Dividends declared

Others

As of December 31, 2018

—   

—   

—   

—   

—   

1,749,127,404   

20

—   

—   

—   

—   

—   

2   

—   

—   

—   

—   

—   

729   

—

729   

—   

11   

11   

—   

3   

(1,486)   

(7,667)   

4,331   

(441)   

3,890 

46

—

46

11

57

(1,440)   

(7,667)   

4,377   

(430)   

3,947 

582   

5   

587   

(509)   

(50)   

—   

(736)   

(736)   

—   

(13)   

582   

(720)   

(138)   

(509)   

(60)   

(220)   

(167)   

(387)   

(93)   

19   

362 

(887) 

(525) 

(602) 

(41) 

12,753   

743   

(1,412)   

(8,416)   

3,670   

(891)   

2,779 

* Certain of the consolidated entities by VEON Ltd. are restricted from remitting funds in the form of cash dividends or loans by a variety of regulations, contractual or local statutory requirements,

The accompanying notes are an integral part of these consolidated financial statements.

117

 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF CASH FLOWS

for the years ended December 31

(In millions of U.S. dollars)

Operating activities

Note

2020

2019

2018

Profit / (loss) before tax from continuing operations

26   

1,181   

(248) 

Non-cash adjustments to reconcile profit before tax to net cash flows

Depreciation, amortization and impairment loss / (reversal)

2,704   

2,154   

2,692 

(Gain) / loss on disposal of non-current assets

(Gain) / loss on disposal of subsidiaries

Finance costs

Finance income

Other non-operating (gain) / loss

Net foreign exchange (gain) / loss

Changes in trade and other receivables and prepayments

Changes in inventories

Changes in trade and other payables

Changes in provisions, pensions and other

Interest paid

Interest received

Income tax paid

37   

78   

683   

(23)   

(111)   

60   

(107)   

40   

94   

(29)   

(644)   

23   

(388)   

43   

(1)   

892   

(53)   

(21)   

20   

(224)   

(28)   

52   

106   

(714)   

58   

(516)   

57 

(30) 

816 

(67) 

68 

(15) 

96 

(88) 

274 

40 

(736) 

60 

(404) 

15

Net cash flows from operating activities

2,443 

2,949   

2,515 

Investing activities

Purchase of property, plant and equipment and intangible assets

(1,778)   

(1,683)   

(1,948) 

Payments on deposits

Receipts from deposits

Proceeds from sale of Italy Joint Venture

Receipts from / (investment in) financial assets

Other proceeds from investing activities, net

(142)   

69   

—   

(89)   

30   

(922)   

698   

—   

(9)   

28   

(32) 

1,066 

2,830 

62 

19 

Net cash flows from / (used in) investing activities

(1,910) 

(1,888)   

1,997 

Financing activities

Proceeds from borrowings, net of fees paid *

Repayment of debt

Acquisition of non-controlling interest

Dividends paid to owners of the parent

Dividends paid to non-controlling interests

15

15

9

20

4,621   

(4,376)   

(1)   

(259)   

(88)   

2,610   

(2,978)   

(613)   

(520)   

(138)   

807 

(4,122) 

— 

(508) 

(93) 

Net cash flows from / (used in) financing activities

(103)   

(1,639)   

(3,916) 

Net increase / (decrease) in cash and cash equivalents

Net foreign exchange difference

Cash and cash equivalents at beginning of period

430   

(48)   

(578)   

(9)   

1,204   

1,791   

Cash and cash equivalents at end of period, net of overdraft **

16

1,586 

1,204   

596 

(119) 

1,314 

1,791 

* Fees paid for borrowings were US$29 (2019: US$23, 2018: US$64)

** Overdrawn amount was US$8 (2019: US$46)

The accompanying notes are an integral part of these consolidated financial statements.

118

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
GENERAL INFORMATION ABOUT THE GROUP

1

GENERAL INFORMATION

VEON Ltd. (“VEON”, the “Company”, and together with its consolidated subsidiaries, the “Group” or “we”) was incorporated 
in  Bermuda  on  June  5,  2009.  The  registered  office  of  VEON  is  Victoria  Place,  31  Victoria  Street,  Hamilton  HM  10,  Bermuda. 
VEON’s  headquarters  and  the  principal  place  of  business  are  located  at  Claude  Debussylaan  88,  1082  MD Amsterdam,  the 
Netherlands.

VEON generates revenue from the provision of voice, data and other telecommunication services through a range of mobile and 
fixed-line technologies, as well as selling equipment and accessories.  

VEON’s American Depository Shares (“ADSs”) are listed on the NASDAQ Global Select Market and VEON’s common shares 
are listed on Euronext Amsterdam, the regulated market of Euronext Amsterdam N.V. (“Euronext Amsterdam”). 

The consolidated financial statements were authorized by the Board of Directors for issuance on  March 15, 2021. The Company 
has the ability to amend and reissue the consolidated financial statements.

The  consolidated  financial  statements  are  presented  in  United  States  dollars  (“U.S.  dollar”  or  “US$”).  In  these  Notes,  U.S. 
dollar amounts are presented in millions, except for share and per share (or ADS) amounts and as otherwise indicated.

Major developments during the year ended December 31, 2020  

Financing activities

In July 2020, VEON successfully refinanced its existing RUB30 billion (US$422) bilateral term loan agreement with VTB Bank. 
For further details, refer to Note 15.

In June 2020, VEON Holdings B.V. entered into a new RUB bilateral term loan agreement with Sberbank for a total amount of 
RUB100 billion (US$1,450), which was used to refinance the existing Sberbank facilities. For further details please refer to Note 
15.

In April 2020, VEON established a Global Medium Term Note program for the issuance of bonds in multiple currencies, with a 
limit equivalent to US$6,500. In June, September and November 2020, VEON issued senior unsecured notes of RUB20 billion 
(US$288), RUB10 billion (US$135), and US$1.25 billion respectively, under the program. For further details, refer to  Note 15.

Coronavirus outbreak

The  global  outbreak  of  COVID-19  and  associated  containment  and  mitigation  measures  implemented  worldwide  have  had  a 
sustained impact on our operations and financial performance.

The  second  quarter  saw  the  full  impact  on  our  operations  of  the  lockdowns  imposed  across  our  markets  in  response  to 
COVID-19. This resulted in material disruption to our retail operations following store closures, impacting gross connections and 
airtime sales. Restrictions on travel resulted in a significant decline in roaming revenues and the loss of migrant customers from 
our subscriber base, particularly in Russia. 

Although VEON’s operations remained impacted by lockdown measures throughout the second half of the year, all operations 
saw a  recovery in the performance as our local businesses continue building resilience to the restrictions related to COVID-19. 
Demand for our data services remains strong, enabling us to continue to grow our data revenues. We also experienced a shift in 
data traffic from mobile to fixed networks as lockdowns encouraged remote working and home schooling alongside a greater use 
of devices through our domestic broadband services.

An  increase  in  demand  for  hard  currencies,  in  part  due  to  COVID-19,  resulted  in  the  devaluation  of  exchange  rates  in  the 
countries in which VEON operates. As such, during the year ended December 31, 2020, the book value of assets and liabilities 
of our foreign operations, in U.S. dollar terms, decreased significantly, with a corresponding loss of US$623 recorded against the 
foreign currency translation reserve in Other Comprehensive Income.

Our  management  has  taken  appropriate  measures  to  keep  our  personnel  safe  and  secure. As  of  the  date  of  these  financial 
statements,  other  than  as  described  above,  we  have  not  observed  any  particular  material  adverse  impacts  to  our  business, 
financial condition, and results of operations. The group liquidity is sufficient to fund the business operations for at least another 
12 months.

Other developments

In  October  2020,  VEON  concluded  an  agreement  for  the  sale  of  its  operating  subsidiary  in  Armenia,  to  Team  LLC  for  a 
consideration of US$51. For further details please refer to Note 9.

In September 2020, the Dhabi Group exercised its put option to sell us its 15% shareholding in Pakistan Mobile Communications 
Ltd ("PMCL"), the Company’s subsidiary in Pakistan. For further details please refer to  Note 15.

In the third quarter of 2020, VEON recorded impairment losses in respect of its operations in Russia and Kyrgyzstan of US$723 
and US$64, respectively. For further details please refer to Note 10.

119

OPERATING ACTIVITIES OF THE GROUP

2

SEGMENT INFORMATION

Management analyzes the Company’s operating segments separately because of different economic environments and stages 
of  development  in  different  geographical  areas,  requiring  different  investment  and  marketing  strategies. All  the  segments  are 
grouped and analyzed as three main markets - our cornerstone, our growth engines and our frontier markets - representing the 
Company's strategy and capital allocation framework. 

Management  evaluates  the  performance  of  the  Company’s  segments  on  a  regular  basis,  primarily  based  on  earnings  before 
interest, tax, depreciation, amortization, impairment, gain / loss on disposals of non-current assets, other non-operating gains / 
losses  and  share  of  profit  /  loss  of  joint  ventures  and  associates  (“Adjusted  EBITDA”)  along  with  assessing  the  capital 
expenditures  excluding  certain  costs  such  as  those  for  telecommunication  licenses  and  right-of-use  assets  (“CAPEX  excl. 
licenses and ROU”). Management does not analyze assets or liabilities by reportable segments. 

In  2019,  the  Company  adopted  the  new  accounting  standard  IFRS  16  Leases. Accordingly,  operating  lease  expenses  are  no 
longer  recorded  in  the  income  statement  but  are  instead  considered  in  recording  a  lease  liability  in  the  statement  of  financial 
position.  The  Company  applied  a  modified  retrospective  approach,  which  means  that  prior  period  comparatives  were  not 
restated. As a result, Adjusted EBITDA in 2020 and 2019 is not comparable to Adjusted EBITDA in 2018. 

In 2020, the Company has chosen to present results from remaining operating segments in ‘Other frontier markets’, separately to 
‘HQ and eliminations’. Prior year comparatives have been adjusted to conform to current year presentation. 

Financial  information  by  reportable  segment  for  the  periods  ended    December  31    is  presented  in  the  following  tables.  Inter-
segment  transactions  between  segments  are  not  material,  and  are  made  on  terms  which  are  comparable  to  transactions  with 
third parties.

Total revenue

Adjusted EBITDA

CAPEX excl licenses and ROU

2020

2019

2018

2020

2019

2018

2020

2019

2018

3,819   

4,481   

4,654   

1,504   

1,957   

1,677   

1,017   

976   

742 

1,233   

1,321   

1,494   

933   

479   

198   

689   

537   

125   

870   

486   

258   

775   

537   

172   

688   

441   

315   

813   

521   

201   

612   

630   

265   

68   

302   

228   

22   

669   

572   

270   

136   

354   

222   

63   

714   

387   

206   

136   

363   

183   

54   

249   

179   

119   

52   

213   

156   

108   

53   

199 

115 

66 

39 

95   

108   

107 

126   

33   

82   

38   

93 

43 

Our cornerstone

Russia

Our growth engines

Pakistan

Ukraine

Kazakhstan

Uzbekistan

Our frontier markets

Algeria

Bangladesh

Other frontier markets

Other

HQ and eliminations

(33)   

(37)   

(41)   

(177)   

(28)   

(447)   

19   

7   

11 

Total segments

7,980   

8,863   

9,086   

3,454   

4,215   

3,273   

1,889   

1,741   

1,415 

120

 
 
 
 
 
 
 
 
 
 
The  following  table  provides  the  reconciliation  of  consolidated  Profit  /  (loss)  before  tax  from  continuing  operations  to Adjusted 
EBITDA for the years ended December 31:

Profit / (loss) before tax from continuing operations

Depreciation

Amortization

Impairment loss / (reversal)

(Gain) / loss on disposal of non-current assets

(Gain) / loss on disposal of subsidiaries

Finance costs

Finance income

Other non-operating (gain) / loss

Net foreign exchange (gain) / loss

Total Segments Adjusted EBITDA

2020

26 

1,576   

343   

785   

37   

78   

683   

(23)   

(111)   

60   

2019

1,181   

1,652   

394   

108   

43   

(1)   

892   

(53)   

(21)   

20   

2018

(248) 

1,339 

495 

858 

57 

(30) 

816 

(67) 

68 

(15) 

3,454   

4,215   

3,273 

121

 
 
 
 
 
 
 
 
 
 
 
 
3

OPERATING REVENUE 

VEON generates revenue from the provision of voice, data and other telecommunication services through a range of wireless, 
fixed  and  broadband  Internet  services,  as  well  as  selling  equipment  and  accessories.  Products  and  services  may  be  sold 
separately or in bundled packages. 

Revenue from contracts with customers

The table below provides a breakdown of revenue from contracts with customers for the years ended  December 31.In 2020, the 
Company has presented ‘Service revenue’ (Mobile and Fixed) separately from ‘Sale of equipment and accessories’ and ‘Other 
revenue’, for each reportable segment. Prior year comparatives have been adjusted to conform to current year presentation.

Service revenue

Mobile

Fixed

Sale of Equipment 
and accessories

Other revenue

Total revenue

2020

2019

2018

2020

2019

2018

2020

2019

2018

2020

2019

2018

2020

2019

2018

Our cornerstone

Russia

 2,917   3,485   3,679    523    539    566    366    446    396   

13   

11   

13   3,819   4,481   4,654 

Our growth engines

Pakistan

Ukraine

Kazakhstan

Uzbekistan

Our frontier markets

 1,134   1,229   1,391    —    —    —   

11   

6   

8   

88   

86   

95   1,233   1,321   1,494 

  869    812    641   

59   

52   

44    —    —    —   

  392    379    363   

78   

66   

73   

7   

2   

4   

  196    255    312   

1   

2   

2    —    —    —   

5   

2   

1   

6   

3    933    870    688 

39   

1    479    486    441 

1   

1    198    258    315 

Algeria

  685    771    801    —    —    —   

4   

  527    525    504    —    —    —    —   

2   

1   

4    —   

2   

8    689    775    813 

5   

10   

11   

12    537    537    521 

  102    135    159   

19   

27   

32   

4   

8   

10    —   

2    —    125    172    201 

Bangladesh

Other frontier 
markets

Other

HQ and eliminations

(31)   

(37)   

(41)    —    —    —    —    —    —   

(2)    —    —   

(33)   

(37)   

(41) 

Total segments

 6,791   7,554   7,809    680    686    717    392    465    427    117    158    133   7,980   8,863   9,086 

Assets and liabilities arising from contracts with customers 

The following table provides a breakdown of contract balances and capitalized customer acquisition costs. 

Contract balances

Receivables (billed)

Contract assets (unbilled)

Contract liabilities

Capitalized costs

Customer acquisition costs

December 31, 
2020

December 31, 
2019

728   

41   

(233)   

748 

38 

(243) 

128   

101 

122

 
 
 
 
 
ACCOUNTING POLICIES

Revenue from contracts with customers

Service revenue

Service  revenue  includes  revenue  from  airtime  charges  from  contract  and  prepaid  customers,  monthly  contract  fees, 
interconnect  revenue,  roaming  charges  and  charges  for  value  added  services  (“VAS”).  VAS  includes  short  messages, 
multimedia messages, caller number identification, call waiting, data transmission, mobile internet, downloadable content, mobile 
finance services, machine-to-machine and other services. The content revenue relating to VAS is presented net of related costs 
when the VEON’s performance obligation is to arrange the provision of the services by another party (VEON acts as an agent), 
and gross when VEON is primarily responsible for fulfilling the obligation to provide such services to the customer.

 Revenue for services with a fixed term, including fixed-term tariff plans and monthly subscriptions, is recognized on a straight-
line basis over time. For pay-as-you-use plans, in which the customer is charged based on actual usage, revenue is recognized 
on  a  usage  basis.  Some  tariff  plans  allow  customers  to  rollover  unused  services  to  the  following  period.  For  such  tariff  plans, 
revenue is generally recognized on a usage basis. 

For contracts which include multiple service components (such as voice, text, data), revenue is allocated based on stand-alone 
selling price of each performance obligation. The stand-alone selling price for these services is usually determined with reference 
to the price charged per service under a pay-as-you-use plan to similar customers. 

Upfront fees, including activation or connection fees, are recognized on a straight-line basis over the contract term. For contracts 
with an indefinite term (for example, prepaid contracts), revenue from upfront fees is recognized over the average customer life.

Revenue  from  other  operators,  including  interconnect  and  roaming  charges,  is  recognized  based  on  the  price  specified  in  the 
contract, net of any estimated retrospective volume discounts. Accumulated experience is used to estimate and provide for the 
discounts.

All service revenue is recognized over time.

Sale of equipment and accessories

Equipment and accessories are usually sold to customers on a stand-alone basis, or together with service bundles. Where sold 
together  with  service  bundles,  revenue  is  allocated  pro-rata,  based  on  the  stand-alone  selling  price  of  the  equipment  and  the 
service bundle. 

The vast majority of equipment and accessories sales pertain to mobile handsets and accessories. Revenue for mobile handsets 
and accessories is recognized when the equipment is sold to a customer, or, if sold via an intermediary, when the intermediary 
has taken control of the device and the intermediary  has no remaining right of return. Revenue for fixed-line equipment  is not 
recognized until installation and testing of such equipment are completed and the equipment is accepted by the customer. 

All revenue from sale of equipment and accessories is recognized at a point in time.

Contract balances

Receivables and contracts assets mostly relate to amounts due from other operators and postpaid customers. Contract assets, 
often referred to as ‘Accrued receivables,’ are transferred to Receivables when the rights become unconditional, which usually 
occurs when the Group issues an invoice to the customer.

Contract  liabilities,  often  referred  to  as  ‘Deferred  revenue’,  relate  primarily  to  non-refundable  cash  received  from  prepaid 
customers  for  fixed-term  tariff  plans  or  pay-as-you-use  tariff  plans.  Contract  liabilities  are  presented  as  ‘Long-term  deferred 
revenue’,  ‘Short-term  deferred  revenue’  and  ‘Customer  advances’  in  Note  6.  All  current  contract  liabilities  outstanding  at  the 
beginning of the year have been recognized as revenue during the year.  

Customer acquisition costs

Certain incremental costs incurred in acquiring a contract with a customer (“customer acquisition costs”), are deferred in the 
consolidated statement of financial position, within 'Other assets' (see Note 6). Such costs generally relate to commissions paid 
to  third-party  dealers  and  are  amortized  on  a  straight-line  basis  over  the  average  customer  life,  within  ‘Selling,  general  and 
administrative expenses’.

The Group applies the practical expedient available for customer acquisition costs for which the amortization would have been 
shorter  than  12  months.  Such  costs  relate  primarily  to  commissions  paid  to  third-parties  upon  top-up  of  prepaid  credit  by 
customers and sale of top-up cards.

SOURCE OF ESTIMATION UNCERTAINTY

Average customer life 

Management estimates the average customer life for revenue (such as upfront fees) from contracts with an indefinite term and 
for customer acquisition costs. The average customer life is calculated based on historical data, specifically churn rates which 
are impacted by relevant country or market characteristics, customer demographic and the nature and terms of the product (such 
as mobile and fixed line, prepaid and postpaid).

123

4 

SELLING, GENERAL AND ADMINISTRATIVE EXPENSES

Selling, general and administrative expenses consisted of the following items for the years ended December 31:

Network and IT costs

Personnel costs

Customer associated costs

Losses on receivables

Taxes, other than income taxes

Other

Total selling, general and administrative expenses

797 

815 

653 

62 

57 

257 

2,641 

2020

2019

2018

1,176 

889 

867 

62 

217 

486 

791   

875   

720   

66   

158   

355   

2,965   

3,697 

In 2020, our subsidiary in Pakistan recorded a gain of PKR8.6 billion (US$52) in ‘Taxes, other than income taxes’, relating to the 
reversal of a non-income tax provision. Refer to Note 7 for further details.

LEASES 

On January 1, 2019, the Company adopted IFRS 16 Leases. The Company applied a modified retrospective approach, which 
means that prior period comparatives were not restated.

Lease expenses are no longer recorded in the income statement but are instead considered in recording a lease liability in the 
statement of financial position (see Note 15), except for short-term leases and leases for low value items which are immediately 
expensed as incurred. Total operating lease expense recognized in accordance with IAS 17 Leases in the consolidated income 
statement, primarily within "Network and IT costs", amounted to US$425 in 2018. 

ACCOUNTING POLICIES 

Customer associated costs 

Customer associated costs relate primarily to commissions paid to third-party dealers and marketing expenses. Certain dealer 
commissions  are  initially  capitalized  in  the  consolidated  statement  of  financial  position  and  subsequently  amortized  within 
"Customer associated costs", see Note 3 for further details.  

124

 
 
 
 
 
 
 
 
 
 
 
 
 
 
5 

TRADE AND OTHER RECEIVABLES

Trade and other receivables consisted of the following items as of December 31:

Trade receivables (gross)*

Expected credit losses

Trade receivables (net)

Other receivable, net of expected credit losses allowance

Total trade and other receivables

* Includes contract assets (unbilled receivables), see Note 3 for further details

2020

769   

(198)   

571   

1   

572   

2019

786 

(176) 

610 

18 

628 

The following table summarizes the movement in the allowance for expected credit losses for the years ended December 31:

Balance as of January 1

Accruals for expected credit losses

Recoveries

Accounts receivable written off

Reclassification

Foreign currency translation adjustment

Balance as of December 31

2020

176   

62   

(7)   

(16)   

—   

(17)   

2019

171 

66 

(8) 

(31) 

(24) 

2 

198   

176 

Set out below is the information about the Group’s trade receivables (including contract assets) using a provision matrix:

Contract assets

Current

< 30 days

Days past due

Between 31 
and 120 days

> 120 days

Total

December 31, 2020

Expected loss rate, %

Trade receivables

Expected credit losses

Trade receivables, net

December 31, 2019

Expected loss rate, %

Trade receivables

Expected credit losses

Trade receivables, net

ACCOUNTING POLICIES 

Trade and other receivables 

 1.0 %

41 

— 

41 

 1.1 %

38 

— 

38 

 1.3 %

468 

(6) 

462 

 1.6 %

446 

(7) 

439 

 13.6 %

 40.7 %

44 

(6) 

38 

 4.9 %

82 

(4) 

78 

27 

(11) 

16 

 36.5 %

52 

(19) 

33 

 92.6 %

189 

(175) 

14 

 86.9 %

168 

(146) 

22 

769 

(198) 

571 

786 

(176) 

610 

Trade and other receivables are measured at amortized cost and include invoiced amounts less expected credit losses. 

Expected credit losses 

The expected credit loss allowance (“ECL”) is recognized for all receivables measured at amortized cost at each reporting date. 
This  means  that  an  ECL  is  recognized  for  all  receivables  even  though  there  may  not  be  objective  evidence  that  the  trade 
receivable has been impaired. 

VEON  applies  the  simplified  approach  (i.e.  provision  matrix)  for  calculating  a  lifetime  ECL  for  its  trade  and  other  receivables, 
including unbilled receivables (contract assets). The provision matrix is based on the historical credit loss experience over the life 
of the trade receivables and is adjusted for forward-looking estimates if relevant. The provision matrix is reviewed on a quarterly 
basis.

125

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6 

OTHER ASSETS AND LIABILITIES

Other assets consisted of the following items as of December 31:

Other non-current assets

Customer acquisition costs (see Note 3)

Tax advances (non-income tax)

Other non-financial assets

Total other non-current assets

Other current assets

Advances to suppliers

Input value added tax

Prepaid taxes

Other assets

Total other current assets

Other liabilities consisted of the following items as of December 31:

Other non-current liabilities

Long-term deferred revenue (see Note 3)

Other liabilities

Total other non-current liabilities

Other current liabilities

Taxes payable (non-income tax)

Short-term deferred revenue (see Note 3)

Customer advances (see Note 3)

Other payments to authorities

Due to employees

Other liabilities

Total other current liabilities

2020

2019

128 

33 

18 

179 

91 

159 

43 

42 

335 

101 

30 

32 

163 

111 

158 

45 

40 

354 

2020

2019

17 

11 

28 

372 

158 

58 

95 

168 

32 

883 

18 

15 

33 

411 

161 

64 

97 

197 

82 

1,012 

126

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
7 

PROVISIONS AND CONTINGENT LIABILITIES

PROVISIONS

The following table summarizes the movement in provisions for the years ended December 31:

As of January 1, 2019

Arising during the year

Utilized

Unused amounts reversed

Transfer and reclassification

Discount rate adjustment and imputed interest (change in 
estimate)

Translation adjustments and other

As of December 31, 2019

Non-current

Current

As of January 1, 2020

Arising during the year

Utilized

Unused amounts reversed

Transfer and reclassification

Discount rate adjustment and imputed interest (change in 
estimate)

Translation adjustments and other

As of December 31, 2020

Non-current

Current

Non-income 
tax provisions

Decommi-
ssioning 
provision

Legal 
provision

Other 
provisions

150   

79   

(105)   

(4)   

5   

—   

1   

126   

—   

126   

126   

24   

(48)   

(10)   

—   

—   

(6)   

86   

—   

86   

93   

28   

(1)   

—   

5   

8   

5   

138   

138   

—   

138   

10   

(1)   

—   

—   

9   

(15)   

141   

141   

—   

44   

3   

(6)   

(15)   

(1)   

—   

1   

26   

—   

26   

26   

—   

—   

(3)   

—   

—   

(1)   

22   

—   

22   

57   

70   

(51)   

—   

(2)   

—   

(4)   

70   

—   

70   

70   

1   

(22)   

(6)   

—   

—   

—   

43   

—   

43   

Total

344 

180 

(163) 

(19) 

7 

8 

3 

360 

138 

222 

360 

35 

(71) 

(19) 

— 

9 

(22) 

292 

141 

151 

The timing of payments in respect of provisions is, with some exceptions, not contractually fixed and cannot be estimated with 
certainty. In addition, with respect to legal proceedings, given inherent uncertainties, there can be no guarantee that the ultimate 
outcome will be in line with VEON’s current expectations. 

See ‘Sources of estimation uncertainty’ below in this Note 7 for further details regarding assumptions and sources of uncertainty. 
For  further  details  regarding  risks  associated  with  income  tax  and  non-income  tax  positions,  please  refer  to  ‘Sources  of 
estimation uncertainty’ in Note 8.

In 2020, as a result of a change in estimate, Pakistan Mobile Communications Limited ("PMCL") reversed a non-income tax 
provision of PKR11.2 billion (US$68), of which PKR8.6 billion (US$52) was recorded as a gain in Selling, general and 
administration expenses. 

The Group has recognized a provision for decommissioning obligations associated with future dismantling of its towers in various 
jurisdictions.

127

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONTINGENT LIABILITIES

The Group had contingent liabilities as of December 31, 2020 as set out below.

VEON - Securities Class Action 

On  November  4,  2015,  a  class  action  lawsuit  was  filed  in  the  United  States  against  VEON  and  certain  of  its  then  current  and 
former officers by Charles Kux-Kardos, on behalf of himself and other investors in the Company alleging certain violations of the 
U.S.  federal  securities  laws  in  connection  with  the  Company’s  public  disclosures  relating  to  its  operations  in  Uzbekistan.  On 
December  4,  2015,  a  second  complaint  was  filed  by  Westway  Alliance  Corp.  that  asserts  essentially  the  same  claims  in 
connection with essentially the same disclosures.  

On April 27, 2016, the court consolidated the two actions and appointed Westway as lead plaintiff. On May 6, 2016, a motion for 
reconsideration  was  filed  on  the  appointment  of  Westway  as  lead  plaintiff  and  on  September  26,  2016,  the  court  affirmed  the 
selection of Westway as the lead plaintiff. An amended complaint was filed on December 9, 2016.  

On September 19, 2017, the Court in the Southern District of New York rendered a decision granting in part VEON’s motion to 
dismiss the Amended Complaint. 

On February 9, 2018, VEON filed its Answer and Affirmative Defenses to the allegations that remain in the Amended Complaint 
after the Court’s September 19, 2017 Order. Motions to dismiss were filed by all the individual defendants on February 9, 2018. 
On April  13,  2018,  plaintiff  dismissed  its  claims  voluntarily  against  one  of  the  individual  defendants.  On August  30,  2018,  the 
Court granted the motions to dismiss by all of the individual defendants remaining in the action, and the time for appeal has now 
expired. On May 17, 2019, VEON filed a motion for judgment on the pleadings, arguing that Westway lacked standing as a result 
of  the  September  19,  2017  order  because  it  had  not  purchased  any  securities  on  or  after  the  date  of  the  earliest  alleged 
misstatement.  On  May  21,  2019,  the  Rosen  Law  Firm  submitted  a  letter  to  the  Court  on  behalf  of  Boris  Lvov  seeking  a  pre-
motion conference for leave to file a motion to intervene and substitute Lvov as lead plaintiff. On May 24, 2019, Westway filed a 
letter opposing Mr. Lvov’s request, and VEON filed a letter taking no position.  Westway filed its opposition to VEON’s motion on 
June 17, 2019, and VEON filed its reply papers on June 28, 2019.  On April 17, 2020, the Court denied Westway's motion and 
ordered  VEON's  motion  to  proceed.  On  March  31,  2020,  VEON’s  motion  for  judgment  on  the  pleadings  was  denied  without 
prejudice.  Westway  filed  its  Second  Amended  Complaint  on  April  14,  2020,  adding  three  additional  named  plaintiffs  and 
allegations  that  VEON  lacked  adequate  internal  controls  as  of  the  start  date  of  the  Alleged  Class  Period  and  had  a  duty  to 
disclose that fact to investors no later than December 4, 2010. On May 15, 2020, VEON filed a motion to dismiss the Second 
Amended Complaint. 

On March 11, 2021, the Court granted VEON’s motion to dismiss the Second Amended Complaint, holding that VEON had no 
duty to disclose information concerning its internal controls as of the start date of the Alleged Class Period, and that Westway 
therefore  lacked  standing  to  bring  any  claims  against  VEON  as  Lead  Plaintiff  or  otherwise.   The  Court  ordered  that  the  Lead 
Plaintiff  selection  process  be  reopened,  and  that  any  motions  for  appointment  as  Lead  Plaintiff  be  filed  by April  8,  2021.   The 
Company intends to vigorously defend the action at all phases of the proceedings. 

VAT on Replacement SIMs 

SIM Cards Issued June 2009 to December 2011

On  April  1,  2012,  the  National  Board  of  Revenue  (“NBR”)  issued  a  demand  to  Banglalink  Digital  Communications  Limited 
(“Banglalink”) for BDT 7.74 billion (US$91) for unpaid SIM tax (VAT and supplementary duty). The NBR alleged that Banglalink 
evaded SIM tax on new SIM cards by issuing them as replacements. On the basis of 5 random SIM card purchases made by the 
NBR,  the  NBR  concluded  that  all  SIM  card  replacements  issued  by  Banglalink  between  June  2009  and  December  2011 
(7,021,834  in  total)  were  new  SIM  connections  and  subject  to  tax.  Similar  notices  were  sent  to  three  other  operators  in 
Bangladesh.  Banglalink  and  the  other  operators  filed  separate  petitions  in  the  High  Court,  which  stayed  enforcement  of  the 
demands. 

In  an  attempt  to  assist  the  NBR  in  resolving  the  dispute,  the  Government  ordered  the  NBR  to  form  a  Review  Committee 
comprised of the NBR, the Commissioner of Taxes (“LTU”), Bangladesh Telecommunication Regulatory Commission (“BTRC”), 
Association  of  Mobile  Telecom  Operators  of  Bangladesh  (“AMTOB”)  and  the  operators  (including  Banglalink).  The  Review 
Committee  identified  a  methodology  to  determine  the  amount  of  unpaid  SIM  tax  and,  after  analyzing 1,200  randomly  selected 
SIM cards issued Banglalink, determined that only 4.83% were incorrectly registered as replacements. The Review Committee’s 
interim report was signed off by all the parties, however, the Convenor of the Review Committee reneged on the interim report 
and unilaterally published a final report that was not based on the interim report or the findings of the Review Committee. The 
operators objected to the final report. 

The NBR Chairman and operators’ representative agreed that the BTRC would prepare further guidelines for verification of SIM 
users. Although the BTRC submitted its guidelines (under which Bangalink’s exposure was determined to be 8.5% of the original 
demand), the Convenor of the Review Committee submitted a supplementary report which disregarded the BTRC’s guidelines 
and assessed Banglalink’s liability for SIM tax to be BDT 7.62 billion (US$90). The operators refused to sign the supplementary 
report. 

128

On May 18, 2015, Banglalink received an updated demand from the LTU claiming Banglalink had incorrectly issued 6,887,633 
SIM cards as replacement SIM cards between June 2009 and December 2011 and required Banglalink to pay BDT 5.32 billion 
(US$63) in SIM tax. The demand also stated that interest may be payable. Similar demands were sent to the other operators. 

On June 25, 2015, Banglalink filed an application to the High Court to stay the updated demand, and a stay was granted. On 
August 13, 2015, Banglalink filed its appeal against the demand before the Appellate Tribunal and deposited 10% of the amount 
demanded in order to proceed. The other operators also appealed their demands. On May 26, 2016, Banglalink presented its 
legal arguments and on September 28, 2016, the appeals of all the operators were heard together. 

The Bangladesh Appellate Tribunal rejected the appeal of Banglalink and all other operators on June 22, 2017. On July 11, 2017, 
Banglalink filed an appeal of the Appellate Tribunal’s judgment with the High Court Division of the Supreme Court of Bangladesh. 
The appeal is pending.  

SIM Cards Issued July 2012 to June 2015

On November 20, 2017, the LTU issued a final demand to Banglalink for BDT 1.69 billion (US$20) for unpaid tax on SIM card 
replacements issued by Banglalink between July 2012 and June 2015. On February 20, 2018, Banglalink filed its appeal against 
this  demand  before  the Appellate  Tribunal  and  deposited  10%  of  the  amount  demanded  in  order  to  proceed.  By  its  judgment 
dated February 10, 2020, the Appellate Tribunal rejected Banglalink’s appeal.  Banglalink appealed to the High Court Division. 
Before  hearing  the  appeal,  the  Court  suo  moto  took  up  as  a  preliminary  question  whether,  based  on  new  law,  the  matter  is 
subject to an appeal or an application for revision. On March 2, 2021, the Court determined that an application for revision is the 
correct  procedure  and  dismissed  the  appeal.  Banglalink  will  file  an  appeal  before  the  Appellate  Division  and  is  obligated  to 
deposit 10% of the disputed amount in order to continue its challenge. As of December 31, 2020, the Company has recorded a 
provision of US$11 (2019: US$11).

Dispute concerning sale of Telecel Globe Limited 

Global  Telecom  Holding  S.A.E.  (“GTH”)  and  Niel  Natural  Resources  Investments  S.A.  ("Niel")  entered  into  a  Share  Purchase 
Agreement on March 28, 2013, as amended from time to time (the “SPA”) in relation to the proposed purchase by Niel of GTH's 
majority  stake  in  Telecel  Globe  Limited  ("Telecel")  and  telecommunications  operations  in  the  Central  African  Republic  and 
Burundi.  The  parties  subsequently  entered  into  three  amendments  to  the  original  SPA  between April  and August  2013  due  to 
Niel’s  failure  to  timely  close  the  intended  transaction.  Pursuant  to  the  terms  of  the  amendments,  the  parties  extended  the 
Longstop  Date  each  time  in  exchange  for  payments  of  deposits  by  Niel.  As  Niel  ultimately  failed  to  close  the  intended 
transaction, the deposits paid to GTH were not refunded, which was in accordance with the terms of the SPA which is no longer 
in force. GTH completed the sale of Telecel in October 2014, to another purchaser for consideration less than had been agreed 
with Niel.  

During 2019, Niel commenced legal activities in relation to the deposit monies retained by GTH. For further details, refer to the 
Group’s audited annual consolidated financial statements as of and for the year ended December 31, 2019.

In June 2020, a settlement agreement was reached between GTH and Niel, which was subject to Niel’s satisfaction of certain 
conditions precedent, whereby GTH would pay US$9 to Niel to resolve all claims and counterclaims at issue in the dispute, as 
well as associated proceedings brought by Niel in the Netherlands and Egypt. The US$41 remainder of the value deferred on the 
balance sheet was released to profit and loss, within 'Other non-operating gain / (loss)'.

In November 2020, the conditions of the settlement agreement were met and the settlement payment of US$9 from GTH to Niel 
was made.

Other contingencies and uncertainties

In  addition  to  the  individual  matters  mentioned  above,  the  Company  is  involved  in  other  disputes,  litigation  and  regulatory 
inquiries and investigations, both pending and threatened, in the ordinary course of its business. The Company’s dispute with the 
Pakistan Telecommunication Authority over its license renewal in Pakistan, explained in Note 15 below, is an example of such a 
matter.  The  total  value  of  all  other  individual  contingencies  that  are  able  to  be  quantified  and  are  above  US$5,  other  than 
disclosed above, amounts to US$484 (2019: US$69). Due to the high level of estimation uncertainty, as described in ‘Source of 
estimation uncertainty’ in this  Note 7 and in Note 8, it is not practicable for the Company to reliably estimate the financial effect 
for certain contingencies and therefore no financial effect has been included within the preceding disclosure. The Company does 
not  expect  any  liability  arising  from  these  contingencies  to  have  a  material  effect  on  the  results  of  operations,  liquidity,  capital 
resources  or  financial  position  of  the  Company.  Furthermore,  the  Company  believes  it  has  provided  for  all  probable  liabilities 
arising in the ordinary course of its business.

For  the  ongoing  matters  described  above,  where  the  Company  has  concluded  that  the  potential  loss  arising  from  a  negative 
outcome  in  the  matter  cannot  be  estimated,  the  Company  has  not  recorded  an  accrual  for  the  potential  loss.  However,  in  the 
event  a  loss  is  incurred,  it  may  have  an  adverse  effect  on  the  results  of  operations,  liquidity,  capital  resources,  or  financial 
position of the Company.  

129

ACCOUNTING POLICIES

Provisions  are  recognized  when  the  Group  has  a  present  obligation  (legal  or  constructive)  as  a  result  of  a  past  event,  it  is 
probable  that  an  outflow  of  resources  embodying  economic  benefits  will  be  required  to  settle  the  obligation  and  a  reliable 
estimate can be made of the amount of the obligation. Provisions are discounted using a current pre-tax rate if the time value of 
money is significant. Contingent liabilities are possible obligations arising from past events, whose existence will be confirmed 
only by the occurrence or non-occurrence of one or more uncertain future events not wholly within the control of the Group.

SOURCE OF ESTIMATION UNCERTAINTY

The Group is involved in various legal proceedings, disputes and claims, including regulatory discussions related to the Group’s 
business, licenses, tax positions and investments, and the outcomes of these are subject to significant uncertainty. Management 
evaluates,  among  other  factors,  the  degree  of  probability  of  an  unfavorable  outcome  and  the  ability  to  make  a  reasonable 
estimate of the amount of loss. Unanticipated events or changes in these factors may require the Group to increase or decrease 
the amount recorded for a matter that has not been previously recorded because it was not considered probable.  

In  the  ordinary  course  of  business,  VEON  may  be  party  to  various  legal  and  tax  proceedings,  including  as  it  relates  to 
compliance with the rules of the telecom regulators in the countries in which VEON operates, competition law and anti-bribery 
and corruption laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”). Non-compliance with such rules and laws may 
cause  VEON  to  be  subject  to  claims,  some  of  which  may  relate  to  the  developing  markets  and  evolving  fiscal  and  regulatory 
environments in which VEON operates. In the opinion of management, VEON’s liability, if any, in all pending litigation, other legal 
proceeding or other matters, other than what is discussed in this Note, will not have a material effect upon the financial condition, 
results of operations or liquidity of VEON.

130

8

INCOME TAXES

Current income tax is the expected tax expense, payable or receivable on taxable income or loss for the period, using tax rates 
enacted or substantively enacted at reporting date, and any adjustment to tax payable in respect of previous years. 

Income tax payable 

Current income tax payable consisted of the following items as of December 31: 

Current tax payable

Uncertain tax provisions

Total income tax payable

2020   

2019 

30   

145   

175   

36 

66 

102 

The  balance  of  uncertain  tax  provisions  is  shown  net  of  income  tax  assets  which  can  be  utilized  to  offset  future  tax  charges 
should they arise, resulting in a reduction of the current period provision by US$10 (2019: US$51), with the gross amount being 
US$155 (2019: US$117).

VEON is involved in a number of disputes, litigation and regulatory proceedings in the ordinary course of its business,  pertaining 
to income  tax claims. The total value of these individual contingencies that are able to be quantified amounts to US$112. Due to 
the high level of estimation uncertainty, as described in ‘Source of estimation uncertainty’ disclosed below in this Note 8, it is not 
practicable for the Company to reliably estimate the financial effect for certain contingencies and therefore no financial effect has 
been  included  within  the  preceding  disclosure. The  Company  does  not  expect  any  liability  arising  from  these  contingencies  to 
have a material effect on the results of operations, liquidity, capital resources or financial position of the Company, however we 
note  that  an  unfavorable  outcome  of  some  or  all  of  the  specific  matters  could  have  a  material  adverse  impact  on  results  of 
operations  or  cash  flows  for  a  particular  period. This  assessment  is  based  on  our  current  understanding  of  relevant  facts  and 
circumstances. As such, our view of these matters is subject to inherent uncertainties and may change in the future. For further 
details on with respect to VEON’s uncertain tax provisions and tax risks, please refer to the ‘Accounting policies’ and ‘Source of 
estimation uncertainty’ disclosed below in this Note 8.

Income tax assets 

The Company reported current income tax assets of US$73 (2019: US$16). 

These tax assets mainly relate to advance tax payments in our operating companies which can only be offset against income tax 
liabilities in that relevant jurisdiction, in fiscal periods subsequent to balance sheet date.  

Income tax expense

Income tax expense consisted of the following for the years ended  December 31: 

Current income taxes

Current year

Adjustments in respect of previous years

Total current income taxes

Deferred income taxes

Movement of temporary differences and losses

Changes in tax rates

Changes in recognized deferred tax assets

Adjustments in respect of previous years

Other

Total deferred tax expense / (benefit)

Income tax expense

131

2020

2019

2018

404   

(1)   

403   

(72)   

—   

2   

9   

—   

(61)   

342   

495   

5   

500   

477 

9 

486 

(36)   

(152) 

(1)   

39   

3   

(7)   

(2)   

498   

6 

— 

28 

1 

(117) 

369 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Effective tax rate  

The table below outlines the reconciliation between the statutory tax rate in the Netherlands (25%) and the effective income tax 
rates for the Group, together with the corresponding amounts, for the years ended December 31:

2020

2019

2018 Explanatory notes

Profit / (loss) before tax from 
continuing operations

Income tax benefit / (expense) 
at statutory tax rate (25%)

26 

  1,181 

(248) 

(7) 

(295) 

62 

Difference due to the effects of:

Different tax rates in different 
jurisdictions

Non-deductible expenses

Non-taxable income

Adjustments in respect of 
previous years

Movements in (un)recognized 
deferred tax assets

Withholding taxes

Uncertain tax positions

Change in income tax rate

(28) 

20 

89 

(210) 

(90) 

(120) 

37 

5 

49 

Certain jurisdictions in which VEON operates have income tax rates which 
are different to the Dutch statutory tax rate of 25%. Profitability in countries 
with higher tax rates (including Pakistan, Algeria and Bangladesh) has a 
negative impact on the effective tax rate.

The Group incurs certain expenses which are non-deductible in the 
relevant jurisdiction. In 2020, as in previous years, such expenses include 
impairment losses (unless resulting in a change in temporary differences), 
certain non-income tax charges (i.e. minimum tax regimes) and some intra-
group expenses (i.e. interest on internal loans).

The Group earns certain income which is non-taxable in the relevant 
jurisdiction. In 2020, non-taxable income included the revaluation of  
contingent consideration liability, as well as a gain relating to the settlement 
in connection with the dispute concerning the sale of Telecel Globe Limited. 
For further details, refer to Note 15 and Note 7, respectively.

(3) 

(49) 

(39)  The effect of prior year adjustments mainly relates to updated tax positions.

(89) 

(13) 

(354) 

(56) 

(50) 

45 

Movements in (un)recognized deferred tax assets are primarily caused by 
tax losses and other credits for which no deferred tax asset has been 
recognized. This primarily occurs in holding entities in the Netherlands 
(2020: US$101, 2019: US$42, 2018: US$147) and in GTH (2020: nil, 2019: 
US$43, 2018: US$213.

Withholding taxes are recognized to the extent that dividends from foreign 
operations are expected to be paid in the foreseeable future. In 2020, 
similar to previous years, expenses relating to withholding taxes were 
primarily influenced by dividends expected from Russia, Algeria and 
Pakistan.

The tax legislation in the markets in which VEON operates is unpredictable 
and gives rise to significant uncertainties (see ‘Source of estimation 
uncertainty’ below). Movements in uncertain tax positions stem from such 
uncertainties. The impact of movements in uncertain tax positions is 
presented net of any corresponding deferred tax assets recognized.

(17) 

Changes in tax rates impact the valuation of existing temporary differences. 
The nominal tax rates did not change in our operating jurisdictions in 2020. 
Nominal tax rate changes occurred in Pakistan in 2019 and 2018 and 
Uzbekistan in 2018.

(6) 

(1) 

— 

6 

1 

Other

15 

(33) 

(78) 

In 2019, the Group recorded an increase in income tax liabilities of US$29 
as a result of the settlement with the Egyptian Tax Authority for outstanding 
tax liabilities for GTH. Refer to Note 7 for further details.

Income tax benefit / (expense)

(342) 

(498) 

(369) 

Effective tax rate

 1,315.4 %

 42.2 %  -148.8 %

132

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Deferred taxes 

The Group reported the following deferred tax assets and liabilities in the statement of financial position as of  December 31:

Deferred tax assets

Deferred tax liabilities

Net deferred tax position

The following table shows the movements of net deferred tax positions in  2020:

2020

186   

(127)   

59   

2019

134 

(141) 

(7) 

Property and equipment

Intangible assets

Trade receivables

Provisions

Accounts payable

Withholding tax on undistributed earnings

Tax losses and other balances carried forwards

Non-recognized deferred tax assets

Other

Net deferred tax positions

Movement in deferred taxes

Opening 
balance

Net income 
statement 
movement

Other 
movements

Closing 
balance

(288)   

(38)   

47   

31   

156   

(52)   

2,026   

(1,894)   

5   

(7)   

(23)   

19   

1   

1   

7   

(8)   

113   

(46)   

(3)   

61   

37   

5   

(5)   

(4)   

(23)   

—   

82   

(85)   

(2)   

5   

(274) 

(14) 

43 

28 

140 

(60) 

2,221 

(2,025) 

— 

59 

The following table shows the movements of net deferred tax positions in  2019:

Property and equipment

Intangible assets

Trade receivables

Provisions

Accounts payable

Withholding tax on undistributed earnings

Tax losses and other balances carried forwards

Non-recognized deferred tax assets

Other

Net deferred tax positions

Movement in deferred taxes

Opening 
balance

Net income 
statement 
movement

Other 
movements

Closing 
balance

(275)   

(60)   

32   

30   

113   

(50)   

2,173   

(1,955)   

9   

17   

5   

22   

16   

2   

11   

(2)   

(68)   

—   

12   

(2)   

(18)   

—   

(1)   

(1)   

32   

—   

(79)   

61   

(16)   

(22)   

(288) 

(38) 

47 

31 

156 

(52) 

2,026 

(1,894) 

5 

(7) 

133

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Unused tax losses and other credits carried forwards 

VEON recognizes a deferred tax asset for unused tax losses and other credits carried forwards, to the extent that it is probable 
that the deferred tax asset will be utilized. The amount and expiry date of unused tax losses and other carry forwards for which 
no deferred tax asset is recognized are as follows:

As of December 31, 2020

Tax losses expiry

Recognized losses

Recognized DTA

Non-recognized losses

Non-recognized DTA

Other credits carried forwards expiry

Recognized credits

Recognized DTA

Non-recognized credits

Non-recognized DTA

0-5 years

6-10 years

More than 10 
years

Indefinite

Total

—   

—   

(107)   

27   

(1,546)   

(1,006)   

387   

252   

(19)   

19   

—   

—   

(102)   

102   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(172)   

49   

(6,660)   

1,272   

—   

—   

(492)   

115   

(279) 

76 

(9,212) 

1,911 

(121) 

121 

(492) 

115 

As of As of December 31, 2019

0-5 years

6-10 years

More than 10 
years

Indefinite

Total

Tax losses expiry

Recognized losses

Recognized DTA

Non-recognized losses

Non-recognized DTA

Other credits carried forwards expiry

Recognized credits

Recognized DTA

Non-recognized credits

Non-recognized DTA

—   

—   

—   

—   

(1,292)   

(1,645)   

279   

357   

(13)   

13   

—   

—   

(46)   

46   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(280)   

73   

(6,486)   

1,258   

—   

—   

(143)   

31   

(280) 

73 

(9,423) 

1,894 

(59) 

59 

(143) 

31 

Losses  mainly  relate  to  our  holding  entities  in  Luxembourg  (2020:  US$6,285;  2019:  US$6,052)  and  the  Netherlands  (2020: 
US$2,659; 2019: US$2,937).

VEON  reports  the  tax  effect  of  the  existence  of  undistributed  profits  that  will  be  distributed  in  the  foreseeable  future.  The 
Company  has  a  deferred  tax  liability  of US$60  (2019:  US$52),  relating  to  the  tax  effect  of  the  undistributed  profits  that  will  be 
distributed in the foreseeable future, primarily in its Russian, Algerian and Pakistan operations. 

As of December 31, 2020, undistributed earnings of VEON’s foreign subsidiaries (outside the Netherlands) which are indefinitely 
invested and will not be distributed in the foreseeable future, amounted to US$5,241 (2019: US$6,194). Accordingly, no deferred 
tax liability is recognized for this amount of undistributed profits.

134

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ACCOUNTING POLICIES 

Income taxes 

Income tax expense represents the aggregate amount determined on the profit for the period based on current tax and deferred 
tax. In cases where the tax relates to items that are charged to other comprehensive income or directly to equity, the tax is also 
charged respectively to other comprehensive income or directly to equity.

Uncertain tax positions 

The  Group’s  policy  is  to  comply  with  the  applicable  tax  regulations  in  the  jurisdictions  in  which  its  operations  are  subject  to 
income  taxes.  The  Group’s  estimates  of  current  income  tax  expense  and  liabilities  are  calculated  assuming  that  all  tax 
computations filed by the Company’s subsidiaries will be subject to a review or audit by the relevant tax authorities. Uncertain tax 
positions  are  generally  assessed  individually,  using  the  most  likely  outcome  method.  The  Company  and  the  relevant  tax 
authorities may have different interpretations of how regulations should be applied to actual transactions (refer below for details 
regarding risks and uncertainties) 

Deferred taxation 

Deferred taxes are recognized using the liability method and thus are computed as the taxes recoverable or payable in future 
periods in respect of deductible or taxable temporary differences between the tax bases of assets and liabilities and their carrying 
amounts in the Company’s financial statements.

SOURCE OF ESTIMATION UNCERTAINTY

Tax risks

The  tax  legislation  in  the  markets  in  which  VEON  operates  is  unpredictable  and  gives  rise  to  significant  uncertainties,  which 
could complicate our tax planning and business decisions. Tax laws in many of the emerging markets in which we operate have 
been in force for a relatively short period of time as compared to tax laws in more developed market economies. Tax authorities 
in  our  markets  are  often  somewhat  less  advanced  in  their  interpretation  of  tax  laws,  as  well  as  in  their  enforcement  and  tax 
collection methods.  

Any sudden and unforeseen amendments of tax laws or changes in the tax authorities’ interpretations of the respective tax laws 
and/or double tax treaties, could have a material adverse effect on our future results of operations, cash flows or the amounts of 
dividends  available  for  distribution  to  shareholders  in  a  particular  period  (e.g.  introduction  of  transfer  pricing  rules,  Controlled 
Foreign Operation (“CFC”) legislation and more strict tax residency rules).  

Management believes that VEON has paid or accrued all taxes that are applicable. Where uncertainty exists, VEON has accrued 
tax liabilities based on management’s best estimate. From time to time, we may also identify tax contingencies for which we have 
not recorded an accrual. Such unaccrued tax contingencies could materialize and require us to pay additional amounts of tax. 
The potential financial effect of such tax contingencies are disclosed in Note 7 and above in this Note 8, unless not practicable to 
do so.

Uncertain tax positions 

Uncertain tax positions are recognized when it is probable that a tax position will not be sustained. The expected resolution of 
uncertain tax positions is based upon management’s judgment of the likelihood of sustaining a position taken through tax audits, 
tax courts and/or arbitration, if necessary. Circumstances and interpretations of the amount or likelihood of sustaining a position 
may  change  through  the  settlement  process.  Furthermore,  the  resolution  of  uncertain  tax  positions  is  not  always  within  the 
control of the Group and it is often dependent on the efficiency of the legal processes in the relevant taxing jurisdictions in which 
the Group operates. Issues can, and often do, take many years to resolve.

Recoverability of deferred tax assets 

Deferred  tax  assets  are  recognized  to  the  extent  that  it  is  probable  that  the  assets  will  be  realized.  Significant  judgment  is 
required to determine the amount that can be recognized and depends foremost on the expected timing, level of taxable profits, 
tax  planning  strategies  and  the  existence  of  taxable  temporary  differences.  Estimates  made  relate  primarily  to  losses  carried 
forward in some of the Group’s foreign operations. When an entity has a history of recent losses, the deferred tax asset arising 
from unused tax losses is recognized only to the extent that there is convincing evidence that sufficient future taxable profit will 
be generated. Estimated future taxable profit is not considered such evidence unless that entity has demonstrated the ability by 
generating significant taxable profit for the current year or there are certain other events providing sufficient evidence of future 
taxable profit. New transactions and the introduction of new tax rules may also affect judgments due to uncertainty concerning 
the interpretation of the rules and any transitional rules. 

135

INVESTING ACTIVITIES OF THE GROUP

9 

SIGNIFICANT TRANSACTIONS

SIGNIFICANT TRANSACTIONS IN 2020

Sale of Armenian operations

In  October  2020,  VEON  concluded  an  agreement  for  the  sale  of  its  operating  subsidiary  in  Armenia,  to  Team  LLC  for  a 
consideration  of  US$51.  Accordingly  the  net  carrying  value  of  assets  amounting  US$33  were  derecognized  along  with 
reclassification of cumulative foreign currency translation reserve of US$96 to profit and loss, resulting in the net loss of US$78.

GTH restructuring

In 2020, VEON continued the restructuring of Global Telecom Holding S.A.E. (“GTH”) which commenced in 2019 (see further 
details  below),  with  the  intragroup  transfer  of  Mobilink  Bank  and  GTH  Finance  B.V.  completed  in  March  and  April  2020, 
respectively. As the operating assets of GTH had previously been, and will continue to be, fully consolidated within the balance 
sheet  of  the  VEON  Group,  there  was  no  material  impact  on  these  consolidated  financial  statements  stemming  from  these 
intragroup transfers. The intragroup transfer for Djezzy is continuing.  

SIGNIFICANT TRANSACTIONS IN 2019 AND 2018

Mandatory tender offer for shares of GTH

In August 2019, VEON completed the purchase of 1,914,322,110 shares, representing approximately 40.55% of GTH’s issued 
shares,  in  connection  with  its  Mandatory  Tender  Offer  (“MTO”)  which  had  commenced  in  July  2019.  The  total  price  for  the 
purchase  of  such  shares  was  EGP  9,725  million  (approximately  US$587),  reflecting  the  offer  price  per  share  of  EGP  5.08. 
Following the completion of the MTO and as a result of further purchases by GTH, as of December 31, 2019, VEON and GTH 
hold  approximately  99.54%  of  GTH's  total  outstanding  equity.  The  MTO  was  funded  by  a  combination  of  cash  on  hand  and 
utilization of undrawn credit facilities (refer to Note 15 for further details).

These  transactions  represent  a  purchase  of  non-controlling  interests  ("NCI")  without  a  change  of  control.  Consequently,  the 
difference  between  the  book  value  of  NCI  (negative  value  of  US$1,986)  and  the  cost  of  acquisition  (US$608)  was  recorded 
directly within ‘Other capital reserves’in the statement of changes in equity (loss of US$2,594).

Following  the  successful  completion  of  the  MTO,  VEON  continued  with  the  restructuring  of  GTH,  which  included  successful 
delisting  of  GTH’s  shares  from  the  Egyptian  Exchange  and  the  approval  by  GTH  shareholders  of  VEON’s  offer  to  acquire 
substantially all of the operating assets of GTH, both of which occurred on September 9, 2019.

Following that approval, VEON completed the intragroup transfers of Jazz, Banglalink and Med Cable. The operating assets of 
GTH had previously been, and will continue to be, fully consolidated within the balance sheet of the VEON Group, and as such, 
there is no material impact on these consolidated financial statements stemming from these asset transfers.

Revised technology infrastructure partnership with Ericsson

In  February  2019,  the  Company  announced  a  revised  arrangement  with  Ericsson  to  upgrade  its  core  IT  systems  in  several 
countries in the coming years and to release Ericsson from the development and delivery of the Full Stack Revenue Manager 
Solution.  This  revised  arrangement  enables  VEON  to  continue  upgrading  IT  infrastructure  with  new  digital  business  support 
systems (DBSS) using existing software from Ericsson which is already deployed in certain operating companies within VEON. 
The parties signed binding terms to vary the existing agreements and as a result VEON received US$350 during the first half of 
2019. The settlement amount was recorded in the income statement within ‘Other operating income’.

Termination of network sharing in Kazakhstan

In  April  2019,  the  Group  received  a  settlement  amount  of  US$38  from  Kcell  Joint  Stock  Company  (“Kcell”),  related  to  the 
termination of the network sharing agreement between Kcell and our subsidiary in Kazakhstan. This amount has been recorded 
in "Other revenue/other income" within the consolidated income statement.

136

Sale of Italy Joint Venture

In July 2018, VEON entered into an agreement with CK Hutchison Holdings Ltd for the sale of its 50% stake in the Italy Joint 
Venture. In September 2018 the transaction was completed, and cash consideration was received in the amount of EUR 2,450  
(US$2,830).

Share of profit / (loss) of the Italy Joint Venture for 2018 and 2017 was reclassified to “Profit / (loss) after tax from discontinued 
operations.”

The effect of the disposal is detailed below:

Cash consideration received

Derecognition of assets classified as held for sale

Release cumulative share of other comprehensive income / (loss) of Italy Joint Venture

Release cumulative foreign currency translation reserve related to Italy Joint Venture

Gain / (loss) on disposal of discontinued operations

2018

2,830 

(1,599) 

(31) 

79 

1,279 

137

 
 
 
 
 
10 

IMPAIRMENT OF ASSETS

Property and equipment and intangible assets are tested regularly for impairment. The Company assesses, at the end of each 
reporting  period,  whether  there  exist  any  indicators  that  an  asset  may  be  impaired  (i.e.  asset  becoming  idle,  damaged  or  no 
longer in use). If there are such indicators, the Company estimates the recoverable amount of the asset. Impairment losses of 
continuing operations are recognized in the income statement in a separate line item.

Goodwill  is  tested  for  impairment  annually  (at  September  30)  or  when  circumstances  indicate  the  carrying  value  may  be 
impaired. Refer to Note 12 for an overview of the carrying value of goodwill per cash-generating unit (“CGU”). The Company’s 
impairment  test  is  primarily  based  on  fair  value  less  cost  of  disposal  calculations  (Level  3  in  the  fair  value  hierarchy)  using  a 
discounted  cash  flow  model,  based  on  cash  flow  projections  from  business  plans  prepared  by  management.  The  Company 
considers the relationship between its market capitalization and its book value, as well as weighted average cost of capital and 
the quarterly financial performances of each CGU when reviewing for indicators of impairment in interim periods. In addition to 
the above, the Company also considered the impact of COVID-19 when reviewing for indicators of impairment (refer to  Note 1). 

Impairment losses in 2020

In  recent  years,  Beeline  Russia  has  seen  a  decline  in  its  subscriber  and  revenue  market  share  on  the  back  of  competitive 
pressures in the market, which have impacted both revenues and profitability. This underperformance has negatively impacted 
the fair value of our Russian business, and over time has eroded the existing headroom over the book value of the business. The 
impact of a weaker Russian ruble, along with ongoing COVID lockdowns and associated travel restrictions, have had a negative 
impact  on  consumer  spending,  which  weakened  particularly  during  the  third  quarter  of  2020.  Together  with  a  slower  than 
anticipated  recovery  in  Beeline’s ARPU,  which  has  in  turn  impacted  our  future  projected  revenue,  a  revision  to  our  previous 
estimates has been deemed necessary. 

Based on these revisions, VEON recorded an impairment of US$723 against the carrying value of goodwill in Russia in the third 
quarter of 2020. The recoverable amount of the CGU of US$3,001 was determined based on fair value less costs of disposal 
calculations  (Level  3  in  the  fair  value  hierarchy)  using  a  discounted  cash  flow  model,  based  on  cash  flow  projections  from 
business plans prepared by management.

Also  in  the  third  quarter  of  2020,  due  to  the  unstable  political  environment  and  uncertainties  arising  with  respect  to  the 
recoverability  of  our  operating  assets  in  Kyrgyzstan,  VEON  has  fully  impaired  the  carrying  value  of  all  operating  assets  of 
Kyrgyzstan. As a result, the Company recorded a total impairment loss of US$64.

Additionally,  in  regard  with  the  Company’s  commitment  to  network  modernization,  the  Company  continuously  re-evaluates  the 
plans  for  its  existing  network,  primarily  with  respect  to  equipment  purchased  but  not  installed,  and  consequently  recorded  an 
impairment loss of US$5.

2020

Russia

Kyrgyzstan

Other

Property and 
equipment

Intangible 
assets

Goodwill

Other

Total 
impairment

—   

38   

5   

43   

—   

8   

—   

8   

723   

—   

—   

723   

—   

18   

(7)   

11   

723 

64 

(2) 

785 

Impairment losses in 2019 and 2018  

Due  to  operational  performance  of  operating  companies  and  the  Company’s  continuous  re-evaluation  of  its  equipment 
purchased  but  not  installed,  in  2019  and  2018  the  Company  recorded  an  impairment  of  US$108  and  US$858,  respectively. 
Impairment  losses  were  allocated  first  to  the  existing  carrying  value  of  goodwill,  and  then  subsequently  to  property  and 
equipment and intangible assets based on relative carrying values. 

2019
Kyrgyzstan

Other

2018

Algeria

Armenia

Bangladesh

Georgia

Kyrgyzstan

Other

138

Property and 
equipment

Intangible 
assets

Goodwill

Total 
impairment

33   
18   

51   

—   

46   

221   

31   

—   

37   

335   

3   
—   

3   

—   

10   

230   

19   

—   

40   

299   

54   
—   

54   

125   

25   

—   

—   

74   

—   

224   

90 
18 

108 

125 

81 

451 

50 

74 

77 

858 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
KEY ASSUMPTIONS 

The recoverable amounts of CGUs have been determined based on fair value less costs of disposal calculations, using cash flow 
projections from business plans prepared by management. 

The Company bases its impairment calculation on detailed budgets and forecast calculations which are prepared separately for 
each  of  the  Company’s  CGUs.  These  budgets  and  forecast  calculations  are  prepared  for  a  period  of  five  years. A  long-term 
growth rate is applied to project future cash flows after the fifth year.

The tables below show key assumptions used in fair value less costs of disposal calculations for CGUs with material goodwill or 
those CGUs for which an impairment has been recognized. 

Discount rates

Discount rates are initially determined in US dollars based on the risk-free rate for  20-year maturity bonds of the United States 
Treasury,  adjusted  for  a  risk  premium  to  reflect  both  the  increased  risk  of  investing  in  equities  and  the  systematic  risk  of  the 
specific CGU relative to the market as a whole. 

The equity market risk premium and small capitalization premium is sourced from independent market analysts. The systematic 
risk, beta, represents the median of the raw betas of the entities comparable in size and geographic footprint with the ones of the 
Company (“Peer Group”). The debt risk premium is based on the median of Standard & Poor’s long-term credit rating of the 
Peer Group. The weighted average cost of capital is determined based on target debt-to-equity ratios representing the median 
historical five year capital structure for each entity from the Peer Group. 

The  discount  rate  in  functional  currency  of  a  CGU  is  adjusted  for  the  long-term  inflation  forecast  of  the  respective  country  in 
which the business operates, as well as applicable country risk premium.

Discount rate 
(local currency)

2020

2019

2018

 10.1 %

 11.6 %

 18.2 %

 — 

 10.3 %

 — 

 13.8 %

 — 

 — 

 9.1 %

 10.4 %

 14.5 %

 — 

 9.2 %

 14.1 %

 14.5 %

 — 

 — 

 10.3 %

 11.1 %

 14.4 %

 12.2 %

 8.4 %

 14.8 %

 13.1 %

 12.5 %

 10.6 %

Russia

Algeria

Pakistan

Bangladesh

Kazakhstan

Kyrgyzstan *

Uzbekistan

Armenia

Georgia

 * In 2020, VEON fully impaired the carrying value of all operating assets of Kyrgyzstan, therefore discount rate was not determined

Revenue growth rates

The  revenue  growth  rates  during  the  forecast  period  vary  based  on  numerous  factors,  including  size  of  market,  GDP  (Gross 
Domestic Product), foreign currency projections, traffic growth, market share and others. A long‑term growth rate into perpetuity 
is estimated based on a percentage that is lower than or equal to the country long-term inflation forecast, depending on the CGU.

Average annual revenue growth rate during forecast 
period

Terminal growth rate

2020

2019

2018

2020

2019

2018

 4.3 %

 4.3 %

 9.7 %

 — 
 5.3 %

 — 
 3.2 %

 — 

 — 

 1.4 %

 1.0 %

 3.9 %

 — 
 5.3 %

 1.6 %

 4.1 %

 — 

 — 

 1.1 %

 0.7 %

 3.5 %

 0.6 %

 2.8 %

 2.8 %

 5.5 %

 0.2 %

 2.1 %

 1.8 %

 1.0 %

 5.8 %

 — 
 3.1 %

 — 
 5.1 %

 — 

 — 

 1.6 %

 1.0 %

 2.7 %

 — 
 3.3 %

 5.0 %

 6.0 %

 — 

 — 

 1.3 %

 0.9 %

 4.0 %

 4.0 %

 1.1 %

 5.0 %

 6.3 %

 0.8 %

 3.0 %

Russia

Algeria

Pakistan

Bangladesh

Kazakhstan

Kyrgyzstan *

Uzbekistan

Armenia

Georgia

* In 2020, VEON fully impaired the carrying value of all operating assets of Kyrgyzstan, therefore revenue growth rates were not determined

139

Operating margin

The Company estimates operating margin based on pre-IFRS 16 Adjusted EBITDA divided by Total Operating Revenue for each 
CGU and each future year. The forecasted operating margin is based on the budget and forecast calculations and assumes cost 
optimization  initiatives  which  are  part  of  on-going  operations,  as  well  as  regulatory  and  technological  changes  known  to  date, 
such as telecommunication license issues and price regulation among others.

Average operating margin during the forecast period

Terminal period operating margin

2020

 31.2 %

 39.9 %

 42.0 %

 — 

 49.5 %

 — 

 34.0 %

 — 

 — 

2019

 34.7 %

 42.6 %

 47.3 %

 — 

 49.9 %

 31.4 %

 51.4 %

 — 

 — 

2018

 34.6 %

 44.0 %

 47.9 %

 35.4 %

 46.5 %

 39.9 %

 43.9 %

 23.6 %

 24.5 %

2020

 35.7 %

 40.4 %

 44.6 %

 — 

 50.0 %

 — 

 34.0 %

 — 

 — 

2019

 34.5 %

 43.1 %

 47.3 %

 — 

 50.1 %

 33.0 %

 52.4 %

 — 

 — 

2018

 34.7 %

 45.0 %

 49.1 %

 35.7 %

 46.7 %

 39.0 %

 44.1 %

 23.4 %

 25.6 %

Russia

Algeria

Pakistan

Bangladesh

Kazakhstan

Kyrgyzstan *

Uzbekistan

Armenia

Georgia

  *  In  2020,  VEON  fully  impaired  the  carrying  value  of  all  operating  assets  of  Kyrgyzstan,  therefore  operating  margin  assumptions  were  not 
determined

CAPEX

CAPEX is defined as purchases of property and equipment and intangible assets excluding licenses, goodwill and right-of-use 
assets.  The  cash  flow  forecasts  for  capital  expenditures  are  based  on  the  budget  and  forecast  calculations  and  include  the 
network roll-outs plans and license requirements. 

The cash flow forecasts for license and spectrum payments for each operating company for the initial five years include amounts 
for expected renewals and newly available spectrum. Beyond that period, a long-run cost of spectrum is assumed. Payments for 
right-of-use assets are considered in the operating margin as described above.

Average CAPEX as a percentage of revenue during 
the forecast period

Terminal period CAPEX as a percentage of revenue

2020

 27.9 %

 15.2 %

 19.6 %

 — 

 19.8 %

 — 
 21.4 %

 — 
 — 

2019

 19.9 %

 12.5 %

 17.2 %

 — 

 20.0 %

 26.9 %
 19.4 %

 — 
 — 

2018

 19.8 %

 15.1 %

 16.7 %

 14.9 %

 17.7 %

 17.2 %
 16.2 %

 21.0 %
 23.8 %

2020

 21.0 %

 14.0 %

 18.9 %

 — 

 19.0 %

 — 
 21.0 %

 — 
 — 

2019

 18.5 %

 12.0 %

 17.1 %

 — 

 19.5 %

 20.0 %
 20.1 %

 — 
 — 

2018

 15.0 %

 14.0 %

 14.0 %

 12.0 %

 17.0 %

 15.0 %
 16.2 %

 14.0 %
 14.0 %

Russia

Algeria

Pakistan

Bangladesh

Kazakhstan

Kyrgyzstan *
Uzbekistan

Armenia
Georgia

* In 2020, VEON fully impaired the carrying value of all operating assets of Kyrgyzstan, therefore CAPEX assumptions were not determined

140

SENSITIVITY TO CHANGES IN ASSUMPTIONS 

 The following table illustrates the potential additional impairment for the Russia CGU and the potential impairment or remaining 
headroom for the Algeria CGU if certain key parameters would adversely change by one percentage point within both the explicit 
forecast and terminal periods ('+/- 1.0 pp'), as well as the change in key assumptions required in order for the recoverable 
amount of the CGU to be equal to its book value ('Break-even').

Any  additional  adverse  changes  in  the  key  parameters  by  more  than  one  percentage  point  would  increase  the  amount  of 
impairment exposure approximately proportionally.

Sensitivity analysis

Discount rate

Change in key assumption

Headroom / (impairment)

Average annual revenue growth rate

Change in key assumption

Headroom / (impairment)

Average operating margin

Change in key assumption

Headroom / (impairment)

Average CAPEX / revenue

Change in key assumption

Headroom / (impairment)

Russia

Algeria

Assumption 
used *

+/- 1.0 pp

Break-even 
**

Assumption 
used *

+/- 1.0 pp Break-even

10.1%

0.0 pp

—

3.9%

0.0 pp

—

32.0%

0.0 pp

—

26.8%

0.0 pp

—

11.1%

1.0 pp

(473)

2.9%

(1.0) pp

(250)

31.0%

(1.0) pp

(375)

27.8%

1.0 pp

(380)

10.1%

0.0 pp

—

3.9%

0.0 pp

—

32.0%

0.0 pp

—

26.8%

0.0 pp

—

11.6%

0.0 pp

75

3.8%

0.0 pp

75

40.0%

0.0 pp

75

15.0%

0.0 pp

75

12.6%

1.0 pp

(44)

2.8%

12.2%

0.6 pp

—

2.9%

(1.0) pp

(0.9) pp

(12)

—

39.0%

(1.0) pp

19

16.0%

1.0 pp

22

38.7%

(1.3) pp

—

16.4%

1.4 pp

—

* Combined average based on explicit forecast period of five years (2021-2025) and terminal period (2026), excludes intervening period of 2020 

** Following the recognition of an impairment loss in the third quarter of 2020, the book value of the Russia CGU is equal to its recoverable amount. As such, the 'break-even' assumptions  for 
the Russia are equivalent to the Assumptions used.

SOURCE OF ESTIMATION UNCERTAINTY 

The Group has significant investments in property and equipment, intangible assets, goodwill and other investments. 

Estimating  recoverable  amounts  of  assets  and  CGUs  must,  in  part,  be  based  on  management’s  evaluations,  including  the 
determination  of  the  appropriate  CGUs,  the  relevant  discount  rate,  estimation  of  future  performance,  the  revenue-generating 
capacity of assets, timing and amount of future purchases of property and equipment, assumptions of future market conditions 
and the long-term growth rate into perpetuity (terminal value). In doing this, management needs to assume a market participant 
perspective. Changing the assumptions selected by management, in particular, the discount rate and growth rate assumptions 
used  to  estimate  the  recoverable  amounts  of  assets,  could  significantly  impact  the  Group’s  impairment  evaluation  and  hence 
results.

A significant part of the Group’s operations is in countries with emerging markets. The political and economic situation in these 
countries may change rapidly and recession may potentially have a significant impact on these countries. On-going recessionary 
effects in the world economy and increased macroeconomic risks impact our assessment of cash flow forecasts and the discount 
rates applied. 

There are significant variations between different markets with respect to growth, mobile penetration, average revenue per user 
(“ARPU”),  market  share  and  similar  parameters,  resulting  in  differences  in  operating  margins.  The  future  development  of 
operating margins is important in the Group’s impairment assessments, and the long-term estimates of these margins are highly 
uncertain. This is particularly the case for emerging markets that are not yet in a mature phase.

141

11  PROPERTY AND EQUIPMENT

The  following  table  summarizes  the  movement  in  the  net  book  value  of  property  and  equipment  for  the  years  ended 

December 31:

Net book value

Telecomm-
unications 
equipment

Land,  
buildings and 
constructions

Office and 
other 
equipment

Equipment not 
installed and 
assets under 
construction

Right-of-
use assets

Total

As of January 1, 2019

3,937 

202 

393   

329 

2,023 

6,884 

Additions

Disposals

Depreciation charge for the year

Impairment

Transfers

Translation adjustment

As of December 31, 2019

Additions

Disposals

Depreciation charge for the year

Impairment

Transfers

Translation adjustment

As of December 31, 2020

Cost

Accumulated depreciation and 
impairment

80   

(36)   

(1,032)   

(30)   

1,210   

177   

4,306 

47   

(50)   

(1,009)   

(28)   

1,282   

(498)   

4,050 

10,893   

—   

(1)   

(33)   

(1)   

29   

20   

216 

2   

(5)   

(28)   

(1)   

5   

(30)   

159 

8   

(6)   

(139)   

(3)   

131   

33   

417   

32   

(10)   

(123)   

(2)   

111   

(57)   

368   

377   

1,330   

1,453   

299 *  

1,840  *

(7)   

—   

(17)   

(1,370)   

28   

(35)   

(85) 

(448)   

(1,652) 

— 

— 

146 

(51) 

— 

404 

416 

1,985 

7,340 

1,626   

446 

2,153 

(12)   

—   

(7)   

(1,396)   

(14)   

(91) 

(416)   

(1,576) 

(5)   

(2)   

(43) 

— 

(59)   

(260)   

(904) 

568 

687   

1,734 

2,526 

6,879 

15,813 

(6,843)   

(218)   

(962)   

(119)   

(792)   

(8,934) 

* Prior year comparatives have been re-presented to conform with current year presentation.

There were no material changes in estimates related to property and equipment in 2020 other than the impairment described in 
Note 10 of US$43 (2019: US$51) and lease term reassessments in Russia and Ukraine (included in ‘Additions’) which had the 
effect of increasing right-of-use assets by US$181. Please refer to Note 15 for more information regarding Source of estimation 
uncertainty for lease terms.  

During 2020, VEON acquired property and equipment in the amount of US$601 (2019: US$480), which were not paid for as of 
year-end.

Property and equipment pledged as security for bank borrowings amounts to US$865 as of December 31, 2020 (2019: US$652), 
and primarily relate to securities for borrowings of PMCL.

142

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table summarizes the movement in the net book value of right-of-use assets ("ROU") for the year ended  
December 31:

Net book value

As of January 1, 2019

Additions

Disposals

Depreciation charge for the year

Impairment

Transfers

Translation adjustment

As of December 31, 2019

Additions

Disposals

Depreciation charge for the year

Impairment

Transfers

Translation adjustment

As of December 31, 2020

Cost

Accumulated depreciation and impairment

COMMITMENTS 

ROU - 
Telecommunicati
ons Equipment

ROU - Land, 
Buildings and 
Constructions

ROU - Office and 
Other Equipment

1,601 

236   

(27)   

(306)   

—   

18   

116   

1,638 

339   

(14)   

(309)   

(1)   

—   

(217)   

1,436   

2,021   

(585)   

415 

63   

(6)   

(140)   

—   

(18)   

30   

344 

102   

—   

(105)   

(4)   

(2)   

(42)   

293   

496   

(203)   

7   

—   

(2)   

(2)   

—   

—   

—   

3   

5   

—   

(2)   

—   

—   

(1)   

5   

9   

(4)   

Total

2,023 

299 

(35) 

(448) 

— 

— 

146 

1,985 

446 

(14) 

(416) 

(5) 

(2) 

(260) 

1,734 

2,526 

(792) 

Capital commitments for the future purchase of equipment are as follows as of December 31:

Less than 1 year

Between 1 and 5 years

Total commitments

2020

2019

747   

19   

766   

677 

19 

696 

Capital commitments arising from telecommunications licenses 

VEON’s  ability  to  generate  revenue  in  the  countries  it  operates  is  dependent  upon  the  operation  of  the  wireless 
telecommunications  networks  authorized  under  its  various  licenses  for  GSM-900/1800,  “3G”  (UMTS  /  WCDMA)  mobile 
radiotelephony communications services and “4G” (LTE). 

Under  the  license  agreements,  operating  companies  are  subject  to  certain  commitments,  such  as  territory  or  population 
coverage, level of capital expenditures, and number of base stations to be fulfilled within a certain timeframe. If we are found to 
be involved in practices that do not comply with applicable laws or regulations, we may be exposed to significant fines, the risk of 
prosecution or the suspension or loss of our licenses, frequency allocations, authorizations or various permissions, any of which 
could harm our business, financial condition, results of operations, or cash flows. 

After  expiration  of  the  license,  our  operating  companies  might  be  subject  to  additional  payments  for  renewals,  as  well  as  new 
license capital and other commitments.

143

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ACCOUNTING POLICIES 

Property and equipment is stated at cost, net of any accumulated depreciation and accumulated impairment losses. 

Depreciation  is  calculated  on  a  straight-line  basis  over  the  estimated  useful  lives  of  the  assets.  The  useful  of  life  of  VEON's 
assets generally fall within the following ranges: 

Class of property and equipment

Telecommunication equipment

Buildings and constructions

Office and other equipment

Right-of-use assets

Useful life

3 – 20 years

10 – 50 years

3 – 10 years

Equivalent lease term

Each asset’s residual value, useful life and method of depreciation is reviewed at the end of each financial year and  adjusted 
prospectively, if necessary. 

SOURCE OF ESTIMATION UNCERTAINTY 

Depreciation and amortization of non-current assets  

Depreciation  and  amortization  expenses  are  based  on  management  estimates  of  useful  life,  residual  value  and  amortization 
method  of  property  and  equipment  and  intangible  assets.  Estimates  may  change  due  to  technological  developments, 
competition,  changes  in  market  conditions  and  other  factors  and  may  result  in  changes  in  the  estimated  useful  life  and  in  the 
amortization or depreciation charges. Technological developments are difficult to predict and our views on the trends and pace of 
developments may change over time. Some of the assets and technologies in which the Group invested several years ago are 
still in use and provide the basis for new technologies. 

The  useful  lives  of  property  and  equipment  and  intangible  assets  are  reviewed  at  least  annually,  taking  into  consideration  the 
factors  mentioned  above  and  all  other  relevant  factors.  Estimated  useful  lives  for  similar  types  of  assets  may  vary  between 
different  entities  in  the  Group  due  to  local  factors  such  as  growth  rate,  maturity  of  the  market,  historical  and  expected 
replacements  or  transfer  of  assets  and  quality  of  components  used.  Estimated  useful  life  for  right-of-use  assets  is  directly 
impacted by the equivalent lease term, refer to Note 15 for more information regarding Source of estimation uncertainty for lease 
terms.

144

12 

INTANGIBLE ASSETS 

The following table summarizes the movement in the net book value of intangible assets for the years ended December 31:

Net book value

Telecommuni-
cation 
licenses, 
frequencies & 
permissions

Software

Brands and 
trademarks

Customer 
relationships

Other 
intangible 
assets

As of January 1, 2019

1,195   

264   

178   

177   

Additions

Disposals
Amortization charge for the 
year

Impairment

Transfer

Translation adjustment

50   

—   

(159)   

(3)   

—   

17   

177   

—   

(155)   

—   

8   

22   

—   

—   

(30)   

—   

—   

1   

—   

—   

(42)   

—   

—   

7   

As of December 31, 2019

1,100   

316   

149   

142   

Additions

Disposals
Amortization charge for the 
year

Impairment

Transfer

Translation adjustment

53   

—   

(139)   

(5)   

—   

(88)   

188   

(6)   

(159)   

(3)   

6   

(41)   

As of December 31, 2020

921   

301   

Cost

2,170   

1,041   

3   

—   

(23)   

—   

—   

(12)   

117   

457   

5   

—   

(15)   

—   

—   

(16)   

Goodwill

3,816   

—   

—   

—   

(54)   

—   

197   

Total

5,655 
— 

239 

(2) 

(394) 

(57) 

— 

247 
— 

3,959   

5,688 

13   

—   

—   

(723)   

—   

(567)   

267 

(6) 

(343) 

(731) 

— 

(723) 

25   

12   

(2)   

(8)   

—   

(8)   

3   

22   

5   

—   

(7)   

—   

(6)   

1   

116   

1,530   

15   

148   

2,682   

4,152 

4,845   

10,191 

Accumulated amortization and 
impairment

(1,249)   

(740)   

(340)   

(1,414)   

(133)   

(2,163)   

(6,039) 

During 2020, there were no material change in estimates related to intangible assets other than the impairment described in Note 
10 of US$731 (2019: US$57).

During 2020, VEON acquired intangible assets in the amount of US$56 (2019: US$49), which were not yet paid for as of year-
end. 

GOODWILL

During the year, the movement in goodwill for the Group, per CGU, consisted of the following: 

December 31,
2020

Impairment

Translation 
adjustment

Addition

December 31,
2019

1,131   

1,053   

324   

140   

34   

(723)   

—   

—   

—   

—   

2,682   

(723)   

(424)   

(114)   

(11)   

(14)   

(4)   

(567)   

13   

—   

—   

—   

—   

13   

2,265 

1,167 

335 

154 

38 

3,959 

CGU

Russia

Algeria

Pakistan

Kazakhstan

Uzbekistan

Total

145

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CGU

Russia

Algeria

Pakistan

Kazakhstan

Kyrgyzstan

Uzbekistan

Total

COMMITMENTS 

December 31,
2019

Impairment

Translation 
adjustment

December 31,
2018

2,265   

1,167   

335   

154   

—   

38   

3,959   

—   

—   

—   

—   

(54)   

—   

(54)   

247   

(9)   

(36)   

1   

—   

(6)   

2,018 

1,176 

371 

153 

54 

44 

197   

3,816 

Capital commitments for the future purchase of intangible assets are as follows as of December 31:

Less than 1 year

Between 1 and 5 years

Total commitments

ACCOUNTING POLICIES 

2020

2019

31   

—   

31   

77 

5 

82 

Intangible assets acquired separately are carried at cost less accumulated amortization and impairment losses. 

Intangible assets with a finite useful life are generally amortized with the straight-line method over the estimated useful life of the 
intangible asset. The amortization period and the amortization method for intangible assets with finite useful lives are reviewed at 
least annually and fall within the following ranges:

Class of intangible asset

Telecommunications licenses, frequencies 
and permissions
Software

Brands and trademarks

Customer relationships

Other intangible assets

Useful life

3-20 years

3-10 years

3-15 years

10-21 years

4-10 years

Goodwill is recognized for the future economic benefits arising from net assets acquired that are not individually identified and 
separately  recognized.  Goodwill  is  not  amortized  but  is  tested  for  impairment  annually  and  as  necessary  when  circumstances 
indicate that the carrying value may be impaired, see Note 10 for further details.

SOURCE OF ESTIMATION UNCERTAINTY 

Refer also to Note 11 for further details regarding source of estimation uncertainty. 

Depreciation and amortization of non-current assets  

Estimates in the evaluation of useful lives for intangible assets include, but are not limited to, the estimated average customer 
relationship  based  on  churn,  the  remaining  license  or  concession  period  and  the  expected  developments  in  technology  and 
markets. 

The  actual  economic  lives  of  intangible  assets  may  be  different  than  estimated  useful  lives,  thereby  resulting  in  a  different 
carrying  value  of  intangible  assets  with  finite  lives.  We  continue  to  evaluate  the  amortization  period  for  intangible  assets  with 
finite  lives  to  determine  whether  events  or  circumstances  warrant  revised  amortization  periods. A  change  in  estimated  useful 
lives is a change in accounting estimate, and depreciation and amortization charges are adjusted prospectively.

146

 
 
 
 
 
 
 
 
 
 
13 

INVESTMENTS IN SUBSIDIARIES

The Company held investments in material subsidiaries for the years ended  December 31  as detailed in the table below. The 
equity interest presented represents the economic rights available to the Company.

Name of significant subsidiary

VEON Amsterdam B.V.

VEON Holdings B.V.

PJSC VimpelCom

JSC “Kyivstar”

LLP “KaR-Tel”

LLC “Unitel”

LLC “VEON Georgia”

CJSC “VEON Armenia”

LLC “Sky Mobile”

VEON Luxembourg Holdings S.à r.l.

VEON Luxembourg Finance Holdings S.à r.l.

VEON Luxembourg Finance S.A.

Global Telecom Holding S.A.E

Omnium Telecom Algérie S.p.A.*

Optimum Telecom Algeria S.p.A.*

Pakistan Mobile Communications Limited

Country of 
incorporation

Nature of 
subsidiary

Netherlands

Netherlands

Russia

Ukraine

Holding

Holding

Operating

Operating

Kazakhstan

Operating

Uzbekistan

Georgia

Armenia

Kyrgyzstan

Luxembourg

Luxembourg

Luxembourg

Egypt

Algeria

Algeria

Pakistan

Operating

Operating

Operating

Operating

Holding

Holding

Holding

Holding

Holding

Operating

Operating

Equity interest held by the 
Group

2020

2019

 100.0 %

 100.0 %

 100.0 %

 100.0 %

 75.0 %

 100.0 %

 80.0 %

 — %

 50.1 %

 100.0 %

 100.0 %

 100.0 %

 99.6 %

 45.4 %

 45.4 %

 85.0 %

 100.0 %

 100.0 %

 100.0 %

 100.0 %

 75.0 %

 100.0 %

 80.0 %

 100.0 %

 50.1 %

 100.0 %

 100.0 %

 100.0 %

 99.5 %

 45.4 %

 45.4 %

 85.0 %

Banglalink Digital Communications Limited

Bangladesh

Operating

 100.0 %

 100.0 %

*  The  Group  has  concluded  that  it  controls  Omnium  Telecom  Algérie  S.p.A  and  Optimum  Telecom  Algeria  S.p.A,  see  'Significant  accounting 
judgments' below for further details.

The  Company  is  subject  to  legal  restrictions  to  distribute  accumulated  profits  from  Algeria  by  virtue  of  local  shareholding 
agreement (i.e. it is allowed only to distribute 42.5% of current year profit), and the rest is restricted 

MATERIAL PARTLY-OWNED SUBSIDIARIES 

Financial information of subsidiaries that have material non-controlling interests (“NCIs”) is provided below:

Name of significant subsidiary

2020

2019

2020

2019

2020

2019

Equity interest  
held by NCIs

Book values of 
material NCIs

Profit / (loss) attributable 
to material NCIs

LLP “KaR-Tel” (“Kar-Tel”)

Omnium Telecom Algérie S.p.A. (“OTA”)

 25.0 %

 54.4 %

 25.0 %  

 54.4 %  

97   

783   

106   

871   

26   

43   

27 

55 

The summarized financial information of these subsidiaries before intercompany eliminations for the years ended December 31 
are detailed below.

147

Summarized income statement

Operating revenue

Operating expenses

Other (expenses) / income

Profit / (loss) before tax

Income tax expense

Profit / (loss) for the year

Total comprehensive income / (loss)

Attributed to NCIs

Dividends paid to NCIs

Kar-Tel

2020

2019

446   

(316)   

4   

134   

(28)   

106   

106   

26   

—   

461   

(319)   

(6)   

136   

(29)   

107   

107   

27   

—   

2018

410   

(319)   

6   

97   

(20)   

77   

77   

19   

—   

Summarized statement of financial position

Kar-Tel

2020

2019

Property and equipment

Intangible assets

Other non-current assets

Trade and other receivables

Cash and cash equivalents

Other current assets

Debt and derivatives

Provisions

Other liabilities

Total equity

Attributed to:

Equity holders of the parent

Non-controlling interests

276   

94   

162   

21   

37   

31   

(75)   

(6)   

(152)   

388   

291   

97   

OTA

2020

2019

689   

(564)   

(17)   

108   

(29)   

79   

79   

43   

46   

271   

86   

185   

18   

39   

12   

(63)   

(6)   

(119)   

775   

(621)   

(17)   

137   

(36)   

101   

101   

55   

69   

OTA

2020

492   

116   

1,071   

31   

67   

50   

(102)   

(23)   

(267)   

2018

813 

(754) 

(11) 

48 

(47) 

1 

1 

1 

76 

2019

600 

158 

1,187 

34 

67 

42 

(134) 

(22) 

(334) 

423   

1,435   

1,598 

317   

106   

652   

783   

727 

871 

Summarized statement of cash flows

Net operating cash flows

Net investing cash flows

Net financing cash flows

Net foreign exchange difference

Net increase / (decrease) in cash 
equivalents

Kar-Tel

OTA

2020

184   

(88)   

(97)   

(2)   

(3)   

2019

199   

(84)   

(104)   

—   

11   

2018

148   

(42)   

(90)   

(3)   

13   

2020

211   

(102)   

(103)   

(5)   

1   

2019

305   

(84)   

(205)   

(1)   

15   

2018

245 

(118) 

(193) 

(5) 

(71) 

148

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SIGNIFICANT ACCOUNTING JUDGMENTS 

Control over subsidiaries 

Subsidiaries,  which  are  those  entities  over  which  the  Company  is  deemed  to  have  control,  are  consolidated.  In  certain 
circumstances,  significant  judgment  is  required  to  assess  if  the  Company  is  deemed  to  have  control  over  entities  where  the 
Company’s ownership interest does not exceed  50%. The Group has concluded that it controls Omnium Telecom Algérie S.p.A 
and  Optimum Telecom Algeria  S.p.A  even  though  its  subsidiary,  Global Telecom  Holding  S.A.E.  owned  less  than   50%  of  the 
ordinary shares. This is because the Company can exercise operational control through terms of a shareholders’ agreement. Our 
partner in Algeria can acquire our shares at fair market value under call option arrangements exercisable solely at its discretion 
between October 1, 2021 and December 31, 2021. Concurrently, we have a right to require our partner in Algeria to acquire our 
shares under put option arrangements exercisable solely at our discretion between July 1, 2021 and September 30, 2021. Both 
option arrangements did not have any impact on our ability to consolidate Omnium Telecom Algérie S.p.A and Optimum Telecom 
Algeria S.p.A.  

149

FINANCING ACTIVITIES OF THE GROUP

14  OTHER NON-OPERATING GAIN / (LOSS)

Other non-operating gains / (losses) consisted of the following for the years ended December 31:

Ineffective portion of hedging activities *

Change of fair value of other derivatives

Gain /(loss) from money market funds *

Loss from early debt redemption

Other gains / (losses)

Other non-operating gain / (loss), net

2020

2019

2018

15   

6   

12   

—   

78   

111   

20   

(17)   

21   

—   

(3)   

21   

8 

(58) 

— 

(30) 

12 

(68) 

* Prior year comparatives have been re-presented to conform with current year presentation.

Included in ‘Other gains / (losses)' in 2020 is a gain of US$41 relating to the revaluation of contingent consideration liability, as 
well as a gain of US$41 relating to the settlement in connection with the dispute concerning the sale of Telecel Globe Limited. 
For further details, refer to Note 15 and Note 7, respectively.

150

 
 
 
 
 
 
15

INVESTMENTS, DEBT AND DERIVATIVES 

INVESTMENTS AND DERIVATIVE ASSETS  

The Company holds the following investments and derivatives as of December 31:

At fair value

Derivatives not designated as hedges

Derivatives designated as net investment hedges

Investments in debt instruments *

Other

At amortized cost

Security deposits and cash collateral

Other investments

Total investments and derivatives

Non-current

Current

Carrying value

2020

2019

20 

3 

75 

8 

106 

325 

39 

364 

470 

305 

165 

11 

— 

34 

— 

45 

256 

16 

272 

317 

235 

82 

* Investments in debt instruments relate to government bonds or bills and are measured at fair value through other comprehensive income (with recycling).

Security deposits 

The  ex-Warid  license  renewal  was  due  in  May  2019.  Pursuant  to  directions  from  the  Islamabad  High  Court,  the  Pakistan 
Telecommunication Authority (“PTA”) issued a license renewal decision on July 22, 2019 requiring payment of US$40 per MHz 
for 900 MHz spectrum and US$30 per MHz for 1800 MHz spectrum, equating to an aggregate price of approximately US$450 
(excluding applicable taxes of approximately 13%). On August 17, 2019, Jazz appealed the PTA’s order to the Islamabad High 
Court. On August 21, 2019, the Islamabad High Court suspended the PTA’s order pending the outcome of the appeal and subject 
to Jazz making payment in the form of security (under protest) as per the options given in the PTA’s order.

In September 2019, Jazz deposited approximately US$225 in order to maintain its appeal in the Islamabad High Court regarding 
the PTA's underlying decision on the license renewal. There were no specific terms and conditions attached to the deposit. The 
deposit is recorded as a non-current financial asset in the statement of financial position.

In May, 2020 a further US$57 was paid under protest, presented within 'Receipts from / (payment on) deposits' in the statement 
of cash flows. The most recent hearing on this matter was concluded before the Islamabad High Court on March 1, 2021 and a 
judgment is now pending.

151

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DEBT AND DERIVATIVES 

The Company holds the following outstanding debt and derivatives as of  December 31:

At fair value

Derivatives not designated as hedges

Derivatives designated as net investment hedges

Contingent consideration

At amortized cost

Principal amount outstanding

Interest accrued

Discounts, unamortized fees, hedge basis adjustment

Bank loans and bonds

Lease liabilities

Put-option liability over non-controlling interest

Other financial liabilities

Total debt and derivatives

Non-current

Current

Bank loans and bonds 

Carrying value

2020

2019

52 

1 

— 

53 

52 

161 

41 

254 

7,678 

7,519 

85 

(5)   

7,758 

1,912 

273 

60 

10,003 

10,056 

8,832 

1,224 

79 

(10) 

7,588 

2,083 

342 

77 

10,090 

10,344 

7,759 

2,585 

The Company had the following principal amounts outstanding for interest-bearing loans and bonds at December 31:

Borrower

Type of debt

Guarantor

Currency

Interest rate

Maturity

2020

2019

Principal amount 
outstanding

VEON Holdings

VEON Holdings

VEON Holdings

VEON Holdings

VEON Holdings

VEON Holdings

VEON Holdings

VEON Holdings

VEON Holdings

VEON Holdings

GTH Finance B.V.
PJSC VimpelCom, via VIP 
Finance Ireland
PMCL

PMCL

PMCL

PMCL

PMCL

Banglalink

Banglalink

PJSC Kyivstar

PJSC Kyivstar

Loans

Loans

Loans

Notes

Notes

Notes

Notes

Notes

Notes

Notes

Notes

Eurobonds

Loans

Loans

Loan

Loan

Loan

Loan

Loans

Loans

Loans

None

None

None

None

None

PJSC 
VimpelCom
None

None

None

None

VEON Holdings

None

None

None

EKN *

None

None

None

None

None

None

Other bank loans and bonds

Total bank loans and bonds

* Exportkreditnämnden (The Swedish Export Credit Agency) 

RUB

RUB

RUB

US$

US$

US$

US$

US$

RUB

US$

US$

US$

PKR

PKR

US$

PKR

PKR

US$

BDT

8.75% to 10.0%

7.35% to 7.50%

CBR Key Rate + 1.85% to 
2.20%

5.95%

3.95% to 4.95%

7.50%

3.38%

7.25%

6.30% to 6.50 %

4.00%

2022

2024-2025

2023-2025

2023

2024

2022

2027

2023

2025

2025

6.25% to 7.25%

2020-2023

7.75 %

6mKIBOR + 0.35%

6mKIBOR + 0.8%

6mLIBOR + 1.9%

6mKIBOR + 0.55%

6mKIBOR

3mLIBOR + 2.50%

2021

2022

2020

2020

2026

2023

2020

Average bank deposit rate 
+ 3.0% to 4.25%

2021-2022

UAH

NBU Key rate + 3.00%

2021-2023

UAH

10.15% to 11.00%

2023-2025

152

—   

2,303 

812   

1,083   

529   

533   

417   

1,250   

700   

406   

— 

— 

529 

1,133 

417 

— 

— 

— 

1,000   

700 

— 

262 

111   

—   

—   

273   

29   

—   

80   

56   

85   

52 

1,200 

262 

192 

34 

75 

121 

41 

300 

116 

— 

— 

96 

7,678 

7,519 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SIGNIFICANT CHANGES IN DEBT AND DERIVATIVES

Reconciliation of cash flows from financing activities

Balance as of January 1, 2019

Cash flows

Proceeds from borrowings, net of fees paid

Repayment of debt

Interest paid

Non-cash movements

Interest and fee accruals

Lease additions, disposals, impairment and modifications

Foreign currency translation

Other non-cash movements

Balance as of December 31, 2019

Cash flows

Proceeds from borrowings, net of fees paid

Repayment of debt

Interest paid

Non-cash movements

Interest and fee accruals

Lease additions, disposals, impairment and modifications

Foreign currency translation

Other non-cash movements

Balance as of December 31, 2020

FINANCING ACTIVITIES IN 2020

Bank loans and 

bonds Lease liabilities

7,366   

1,999   

2,610   

(2,612)   

(566)   

599   

—   

193   

(2)   

—   

(366)   

(148)   

178   

262   

158   

—   

Total

9,365 

2,610 

(2,978) 

(714) 

777 

262 

351 

(2) 

7,588   

2,083   

9,671 

4,621   

(4,054)   

(494)   

546   

—   

(398)   

(51)   

—   

(322)   

(150)   

156   

432   

(286)   

—   

4,621 

(4,376) 

(644) 

702 

432 

(684) 

(51) 

7,758   

1,913   

9,671 

Optional early redemption of US$600 million 3.95% Senior notes due June 2021

In  December  2020,  VEON  Holdings  B.V.  completed  optional  early  redemption  of  all  of  its  outstanding  US$600  million  3.95% 
Senior  Notes  due  June  2021,  pursuant  to  Condition  5.3  of  the  2021  Notes. The  Notes  were  redeemed  in  full  at  a  redemption 
price equal to 101.00% of the principal amount thereof, plus accrued and unpaid interest and additional amounts due thereon.

Financing activities in Ukraine

In  December  2020,  VEON's  operating  company  in  Ukraine,  Kyivstar,  signed  three  bilateral  unsecured  loan  agreements  with 
Raiffeisen  Bank  Aval  Joint  Stock  Company  (“Raiffeisen”),  Joint  Stock  Company  Alfa-Bank  (“Alfa-Bank”)  and  Joint  Stock 
Company OTP Bank (“OTP”), for an aggregate amount of UAH4.1 billion (US$146). The loan agreement with Raiffeisen has a 
5-year term with a fixed interest rate of 11.00% and the loan agreements with Alfa-Bank and OTP each have a 3-year term with a 
floating rate equal to NBU Key Rate + 3.00% and a fixed interest rate of 10.15% respectively.

Exercise of 15% PMCL put option

In September 2020, the Dhabi Group exercised its put option to sell us its 15% shareholding in PMCL, the Company’s subsidiary 
in Pakistan. VEON updated the fair value of its put option liability following the completion of an independent valuation process 
which determined a fair value for the shareholding of US$273, resulting in a gain of US$59 recorded in ‘Finance costs’ within the 
Consolidated  Income  Statement.  Completion  of  the  transfer  remains  subject  to  the  conclusion  of  the  contractual  transfer 
mechanics with the Dhabi Group. Once the transaction is completed, VEON will indirectly own 100% of PMCL.

Global Medium Term Note program

In  April  2020,  VEON  Holdings  B.V.  established  a  Global  Medium  Term  Note  program  for  the  issuance  of  bonds  (the  "MTN 
Program"), with a program limit of US$6,500, or the equivalent thereof in other currencies. In June,  September and November 
2020,  VEON  Holdings  B.V.  issued  senior  unsecured  notes  of  RUB20  billion  (US$288),  RUB10  billion  (US$135)  and 
US$1.25 billion, respectively, under the MTN Program, maturing in June 2025, September 2025 and November 2027.

153

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Refinancing of loan agreement with VTB

In  July  2020,  VEON  Holdings  B.V.  successfully  refinanced  its  existing  RUB30  billion  (US$422),  bilateral  term  loan  agreement 
with VTB Bank. This refinancing extended the final maturity of the existing loan between VTB Bank and VEON Holdings B.V. to 
July 2025 and amended the interest cost from a fixed rate of 8.75% to floating rate equal to CBR Key Rate + 1.85 p.p.

Refinancing of loan agreement with Sberbank

In  June  2020,  VEON  Holdings  B.V.  entered  into  a  new  RUB  bilateral  term  loan  agreement  with  Sberbank.  The  agreement 
comprises four facilities for a total amount of RUB100 billion (US$1,450) with final maturity dates ranging between two and four 
years.  Shortly  after  the  agreement  was  signed,  VEON  Holdings  B.V.  fully  utilized  three  facilities  for  a  total  amount  of 
RUB87.5  billion  (US$1,281)  and  used  the  proceeds  to  prepay  all  outstanding  amounts  under  the  Sberbank  term  facilities 
agreement signed in May 2017. 

In  July  2020,  VEON  drew  down  the  remaining  RUB12.5  billion  available  under  the  facility  agreement.  Subsequently,  in 
September 2020, VEON repaid one of the facilities of RUB20 billion, originally maturing in June 2022, in full with no fees. The 
repaid facility cannot be re-borrowed.

Contingent consideration

In  2015,  International  Wireless  Communications  Pakistan  Limited  and  Pakistan  Mobile  Communications  Ltd  (“PMCL”),  each 
indirect  subsidiaries  of  the  Company,  signed  an  agreement  with  Warid  Telecom  Pakistan  LLC  and  Bank  Alfalah  Limited,  to 
combine their operations in Pakistan. In July 2016, the transaction was closed and PMCL acquired 100% of the voting shares in 
Warid Telecom (Pvt) Limited (“Warid”) for a consideration of 15% of the shares in PMCL. As a result, VEON gained control over 
Warid.

As part of the share purchase agreement, an earn-out payment was agreed in the event that a tower transaction is effected by 
PMCL  within  four  years  from  the  acquisition  date.  The  earn-out  would  also  apply  if  another  telecommunications  operator  in 
Pakistan effects a tower transaction, provided the transaction meets certain parameters, in the same timeframe. The contingent 
consideration would be settled with a transfer of PMCL shares.

As of June 2020, the probability of completion of a tower deal in Pakistan prior to the relevant deadline, upon which contingent 
consideration would be paid, became remote. As a result, the fair value of Contingent consideration was revised downwards to 
zero, with a corresponding gain of US$41 recognized in the consolidated income statement. 

Extension and extinguishment of Banglalink syndicated loan

In  April  2020,  Banglalink  Digital  Communications  Limited,  a  wholly-owned  subsidiary,  extended  the  maturity  of  its  US$300 
syndicated  loan  by  an  additional  two  years  to  2022.  Following  this  extension,  VEON  Digital Amsterdam  B.V.,  the  Company's 
wholly-owned  subsidiary,  acquired  the  loan  from  the  original  lenders,  leading  to  extinguishment  of  this  financial  liability  within 
VEON's consolidated financial statements. No material transactional costs were incurred.

Drawdowns under the Revolving Credit Facility

In  March  2020,  VEON  Holdings  B.V.,  the  Company's  wholly-owned  subsidiary,  executed  two  drawdowns  under  its  existing 
revolving credit facility for an aggregate amount of US$600. Although these drawdowns are short-term in nature, VEON Holdings 
B.V. has an enforceable right to roll them over until final maturity date of the facility in February 2022. All outstanding drawdowns 
under this facility have been fully repaid during June 2020 (US$100) and July 2020 (US$500). In March 2021, VEON entered into 
a new multi-currency revolving credit facility agreement, refer to Note 22 for further details.

Refinancing of RUB debt - AO "Alfa-Bank"

In  March  2020,  VEON  Holdings  B.V.  amended  and  restated  the  existing  facility  with  AO  "Alfa-Bank",  increasing  its  size  and 
utilization from RUB17.5 billion to RUB30 billion (US$165). Following this amendment and restatement, the final maturity of this 
facility has been set to March 2025.

GTH bonds prepayment

In February 2020, GTH Finance B.V., the Company’s subsidiary, repaid at par the US$500 6.25% bonds, originally maturing 
April, 2020.

US$300 tap issuance of existing senior notes

In January 2020, VEON Holdings B.V., issued US$300 in senior unsecured notes due 2025, which are consolidated and form a 
single series with the US$700 4.00% senior notes due in 2025 issued by VEON Holdings B.V. in October 2019. VEON used the 
net proceeds of the tap issuance to refinance certain existing outstanding debt.

154

155

FINANCING ACTIVITIES IN 2019

VEON Holdings BV new notes

In October 2019, VEON Holdings issued US$700 4.00% senior unsecured notes due 2025. The net proceeds of the notes issued 
have been used primarily to refinance drawings on the revolving credit facility used to fund the MTO for GTH.  

Pakistan Mobile Communications Limited new bilateral term facility   

In June 2019, PMCL entered into a bilateral secured PKR 14,369 million (approximately US$92) term facility with a local bank. 
The facility has a tenor of 7 years and bears interest at 6-month KIBOR increased by a margin of 0.75% per annum. The security 
is based on terms comparable with PMCL's existing debt.

Pakistan Mobile Communications Limited new syndicated term facility and Islamic facility 

In June 2019, PMCL entered into a secured syndicated term facility and an Islamic financing facility for a joint amount of up to 
PKR  45,000  million  (approximately  US$287)  and  a  period  of  up  to 7  years. The  cost  of  both  facilities  corresponds  to  6-month 
KIBOR increased by a margin of 0.75% per annum. The security is based on terms comparable with PMCL's existing debt.

Banglalink Digital Communications Limited new syndicated term facility agreement

In April  2019,  Banglalink  entered  into  a  new  US$300  syndicated  term  facility  agreement  with  several  international  banks. The 
facility  is  guaranteed  by  VEON  Holdings  for  nil  consideration. The  facility  has  a  tenor  of 12  months  with  extension  options  for 
another 24 months upon agreement with the lenders, and was used to refinance the principal amount of Banglalink’s US$300 
bond that matured in May 2019.

FAIR VALUES 

As of December 31, 2020, the carrying amounts of all financial assets and liabilities are equal to or approximate their respective 
fair values as shown in the table at the beginning of this note, with the exception of: 

• 'Bank loans and bonds, including interest accrued', for which fair value is equal to US$8,031 (2019: US$7,887); and

• 'Lease liabilities', for which fair value has not been determined.

As of December 31, 2020 and December 31, 2019, all of the Group's financial instruments carried at fair value in the statement 
of  financial  position  were  measured  based  on  Level  2  inputs,  except  for  the  Contingent  consideration,  for  which  fair  value  is 
classified as Level 3.

All  movements  in  Contingent  consideration  in  the  years  ended  December  31,  2020  and  2019  relate  to  changes  in  fair  value, 
which are unrealized, and are recorded in “Other non-operating gain / (loss)” within the consolidated income statement.  

Fair values are estimated based on quoted market prices for our bonds, derived from market prices or by discounting contractual 
cash  flows  at  the  rate  applicable  for  the  instruments  with  similar  maturity  and  risk  profile.  Observable  inputs  (Level  2)  used  in 
valuation techniques include interbank interest rates, bond yields, swap curves, basis swap spreads, foreign exchange rates and 
credit default spreads. 

On a quarterly basis, the Company reviews if there are any indicators for a possible transfer between fair value hierarchy levels. 
This depends on how the Company is able to obtain the underlying input parameters when assessing the fair valuations.

During the years ended December 31, 2020 and 2019, there were no transfers between Level 1, Level 2 and Level 3 fair value 
measurements. 

HEDGE ACCOUNTING 

The following table sets out the Company’s hedging instruments designated as net investment hedges as of December 31:

Hedging instruments*

Designated 
rate

Excluded 
component

Hedged
item

Currency

Aggregated designated nominal 
value of hedged items, million

2020

2019

Foreign currency forward 
contracts

Forward

foreign 
currency basis 
spread

PJSC 
VimpelCom

RUB

26,758  **

88,220  **

* Refer to the Debt and Derivatives section above in this Note for information regarding the carrying amounts of the hedging instruments. 

** Hedging instruments have a weighted average term to maturity of 1 year as of December 31, 2020 (2019: 1 year ).

156

 
 
There is an economic relationship between the hedged net investments and the hedging instruments due to the translation risk 
inherent in the hedged items that matches the foreign exchange risk of the hedging instruments. The hedge ratio for each of the 
above  relationships  was  set  at  1:1  as  the  underlying  risk  of  the  hedging  instruments  is  identical  to  the  hedged  risk  and  the 
nominal value of hedging instruments has not exceeded the amounts of respective net investments. Hedge ineffectiveness might 
arise from:

•

•

the value of a net investment falling below the related designated nominal value of the hedging instrument, or 

counterparties’ credit risk impacting the hedging instrument but not the hedged net investment. 

During the periods covered by these consolidated financial statements, the amount of ineffectiveness was immaterial. 

During 2020, the fair values of the Company’s derivatives designated as net investment hedges increased due to depreciation of 
the Russian ruble, resulting in a US$178gain recorded against the foreign currency translation reserve. This gain partially offset 
the translation loss related to our foreign operations described in Note 1.

Impact of hedge accounting on equity 

The below table sets out the reconciliation of each component of equity and the analysis of other comprehensive income (all of 
which are attributable to the equity owners of the parent):

As of January 1, 2019

Foreign currency revaluation of the foreign operations and other

Effective portion of foreign currency revaluation of the hedging instruments *

Change in fair value of foreign currency basis spreads

Amortization of time-period related foreign currency basis spreads

As of December 31, 2019

Foreign currency revaluation of the foreign operations

Effective portion of foreign currency revaluation of the hedging instruments *

Change in fair value of foreign currency basis spreads

Amortization of time-period related foreign currency basis spreads

Other movements in foreign currency translation reserve

As of December 31, 2020

Foreign currency 
translation reserve

Cost of hedging 
reserve **

(8,416)   

332   

(228)   

—   

—   

(8,312)   

(615)   

178   

—   

—   

(26)   

(8,775)   

5 

— 

— 

23 

(19) 

9 

— 

— 

7 

(15) 

— 

1 

*  Amounts  represent  the  changes  in  fair  value  of  the  hedging  instruments  and  closely  approximate  the  changes  in  value  of  the  hedged  items  used  to 

recognize hedge ineffectiveness.

** Movements in the cost of hedging reserve are included within "Other" in respective section of statement of other comprehensive income.

157

 
 
 
 
 
 
 
 
 
 
 
 
ACCOUNTING POLICIES AND SOURCES OF ESTIMATION UNCERTAINTY 

Put options over non-controlling interest  

Put options over non-controlling interest of a subsidiary are accounted for as financial liabilities in the Company’s consolidated 
financial statements. The put-option redemption liability is measured at the discounted redemption amount. Interest over the put-
option redemption liability will accrue in line with the effective interest rate method, until the options have been exercised or are 
expired. 

Derivative contracts 

VEON enters into derivative contracts, including swaps and forward contracts, to manage certain foreign currency and interest 
rate exposures. Any derivative instruments for which no hedge accounting is applied are recorded at fair value with any fair value 
changes  recognized  directly  in  profit  or  loss.  Although  some  of  the  derivatives  entered  into  by  the  Company  have  not  been 
designated  in  hedge  accounting  relationships,  they  act  as  economic  hedges  and  offset  the  underlying  transactions  when  they 
occur.

Hedges of a net investment 

The  Company  applies  net  investment  hedge  accounting  to  mitigate  foreign  currency  translation  risk  related  to  the  Company’s 
investments in foreign operations. The portion of the gain or loss on the hedging instrument that is determined to be an effective 
hedge  is  recognized  in  other  comprehensive  income  within  the  “Foreign  currency  translation”  line  item.  Where  the  hedging 
instrument’s  foreign  currency  retranslation  is  greater  (in  absolute  terms)  than  that  of  the  hedged  item,  the  excess  amount  is 
recorded  in  profit  or  loss  as  ineffectiveness. The  gain  or  loss  on  the  hedging  instrument  relating  to  the  effective  portion  of  the 
hedge  that  has  been  recognized  in  other  comprehensive  income  shall  be  reclassified  from  equity  to  profit  or  loss  as  a 
reclassification  adjustment  on  the  disposal  or  partial  disposal  of  the  foreign  operation.  Cash  flows  arising  from  derivative 
instruments  for  which  hedge  accounting  is  applied  are  reported  in  the  statement  of  cash  flows  within  the  line  item  where  the 
underlying cash flows of the hedged item are recorded.

Fair value of financial instruments  

All financial assets and liabilities are measured at amortized cost, except those which are measured at fair value as presented 
within this Note.

Where the fair value of financial assets and liabilities recorded in the statement of financial position cannot be derived from active 
markets, their fair value is determined using valuation techniques, including discounted cash flows models. The inputs to these 
models are taken from observable markets, but when this is not possible, a degree of judgment is required in establishing fair 
values.  The  judgments  include  considerations  regarding  inputs  such  as  liquidity  risk,  credit  risk  and  volatility.  Changes  in 
assumptions about these factors could affect the reported fair value of financial instruments. 

Measurement of lease liabilities 

Lease liabilities are measured upon initial recognition at the present value of the future lease and related fixed services payments 
over the lease term, discounted with the country specific incremental borrowing rate as the rate implicit in the lease is generally 
not available. Subsequently lease liabilities are measured at amortized cost using the effective interest rate method. 

A  significant  portion  of  the  lease  contracts  included  within  Company’s  lease  portfolio  includes  lease  contracts  which  are 
extendable through mutual agreement between VEON and the lessor, or lease contracts which are cancellable by the Company 
immediately or on short notice. The Company includes these cancellable future lease periods within the assessed lease term, 
which increases the future lease payments used in determining the lease liability upon initial recognition. 

The Company continuously assesses whether a revision of lease terms is required due to a change in management judgment 
regarding, for example, the exercise of extension and/or termination options. VEON's determination of the lease term is based on 
facts and circumstances related to the underlying leased asset and lease contracts.

158

16  CASH AND CASH EQUIVALENTS

Cash and cash equivalents are held for the purpose of meeting short-term cash commitments rather than for investment or other 
purposes. Cash and cash equivalents are comprised of cash at bank and on hand and highly liquid investments that are readily 
convertible to known amounts of cash, are subject to only an insignificant risk of changes in value and have an original maturity 
of less than three months. 

Cash and cash equivalents consisted of the following items as of December 31:

Cash and cash equivalents at banks and on hand

Cash equivalents with original maturity of less than three months

Cash and cash equivalents

Less overdrafts

2020

694 

900 

1,594 

(8)   

2019

932 

318 

1,250 

(46) 

Cash and cash equivalents, net of overdrafts, as presented in the consolidated statement of cash 
flows

1,586 

1,204 

Cash at bank earns interest at floating rates based on bank deposit rates. Short-term deposits are made for varying periods of 
between one day and three months, depending on the immediate cash requirements of the Company, and earn interest at the 
respective short-term deposit rates. 

The  imposition  of  currency  exchange  controls  or  other  similar  restrictions  on  currency  convertibility  in  the  countries  in  which 
VEON operates could limit VEON’s ability to convert local currencies or repatriate local cash in a timely manner or at all, as well 
as remit dividends from the respective countries. As of  December 31, 2020, there were no restricted cash and cash equivalent 
balances (2019: nil).

Cash balances include investments in money market funds of US$543 (2019: US$155), which are carried at fair value through 
profit or loss with gains presented within ‘Other non-operating gain / (loss)’ within the consolidated income statement.

As  of  December  31,  2020,  some  bank  accounts  forming  part  of  a  cash  pooling  program  and  being  an  integral  part  of  the 
Company’s  cash  management  remained  overdrawn  by  US$8  (2019:  US$46).  Even  though  the  total  balance  of  the  cash  pool 
remained positive, the Company has no legally enforceable right of set-off and therefore the overdrawn accounts are presented 
as  debt  and  derivatives  within  the  statement  of  financial  position. At  the  same  time,  because  the  overdrawn  accounts  are  an 
integral part of the Company’s cash management, they were included as cash and cash equivalents within the statement of cash 
flows.

159

 
 
 
 
 
 
 
 
 
17

FINANCIAL RISK MANAGEMENT

The  Group’s  principal  financial  liabilities  consist  of  loans  and  borrowings  and  trade  and  other  payables.  The  main  purpose  of 
these financial liabilities is to finance the Group’s operations. The Group has trade and other receivables, cash and short-term 
deposits that are derived directly from its operations. 

The Group is exposed to market risk, credit risk and liquidity risk. The Company’s Board of Directors manages these risks with 
support of the treasury function, who proposes the appropriate financial risk governance framework for the Group, identifies and 
measures  financial  risks  and  suggests  mitigating  actions.  The  Company’s  Board  of  Directors,  supported  by  its  Finance 
Committee, approves the financial risk management framework and oversees its enforcement.

INTEREST RATE RISK 

The Company is exposed to the risk of changes in market interest rates primarily due to the its long-term debt obligations. The 
Company manages its interest rate risk exposure through a portfolio of fixed and variable rate borrowings and hedging activities.

As of December 31, 2020, approximately 79% of the Company’s borrowings are at a fixed rate of interest (2019: 91%). 

The Group is exposed to possible changes in interest rates on variable interest loans and borrowings, partially mitigated through 
related derivative financial instruments, cash and cash equivalents and current deposits. With all other variables held constant, 
the  Company’s  profit  before  tax  is  affected  through  changes  in  the  floating  rate  of  borrowings  while  the  Company’s  equity  is 
affected through the impact of a parallel shift of the yield curve on the fair value of hedging derivatives. An increase or decrease 
of  100  basis  points  in  interest  rates  would  have  an  immaterial  impact  on  the  Company’s  income  statement  and  other 
comprehensive income.

FOREIGN CURRENCY RISK  

The Company’s exposure to the risk of changes in foreign exchange rates relates primarily to the debt denominated in currencies 
other than the functional currency of the relevant entity, the Company’s operating activities (predominantly capital expenditures at 
subsidiary  level  denominated  in  a  different  currency  from  the  subsidiary’s  functional  currency)  and  the  Company’s  net 
investments in foreign subsidiaries. 

The Company manages its foreign currency risk by selectively hedging committed exposures. 

The Company hedges part of its exposure to fluctuations on the translation into U.S. dollars of its foreign operations by holding 
the borrowings in foreign currencies or by foreign exchange swaps and forwards. During the periods covered by these financial 
statements, the Company used foreign exchange forwards to mitigate foreign currency translation risk related to the Company’s 
net investment in PJSC VimpelCom.

160

Foreign currency sensitivity 

The  following  table  demonstrates  the  sensitivity  to  a  possible  change  in  exchange  rates  against  the  US  dollar  with  all  other 
variables  held  constant.  Additional  sensitivity  changes  to  the  indicated  currencies  are  expected  to  be  approximately 
proportionate. The table shows the effect on the Company’s profit before tax (due to changes in the value of monetary assets 
and  liabilities,  including  foreign  currency  derivatives)  and  equity  (due  to  application  of  hedge  accounting  or  existence  of  quasi 
equity loans). The Company’s exposure to foreign currency changes for all other currencies is not material.

Change in foreign exchange rate against US$

Effect on profit / (loss) 
before tax

Effect on other 
comprehensive income

10% 
depreciation

10% 
appreciation

10% 
depreciation

10% 
appreciation

2020

Russian Ruble

Bangladeshi Taka

Pakistani Rupee

Georgian Lari

Other currencies (net)

2019

Russian Ruble

Bangladeshi Taka

Pakistani Rupee

Georgian Lari

Other currencies (net)

35

(30)

(4)

(36)

8

(9)

(27)

(10)

(36)

(4)

(39)

33

4

40

(9)

11

30

11

39

5

32

—

—

—

4

119

—

—

—

—

(39)

—

—

—

(4)

(145)

—

—

—

—

161

CREDIT RISK 

The  Company  is  exposed  to  credit  risk  from  its  operating  activities  (primarily  from  trade  receivables),  and  from  its  treasury 
activities, including deposits with banks and financial institutions, derivative financial instruments and other financial instruments. 
See Note 16 for further information on restrictions on cash balances.  

Trade receivables consist of amounts due from customers for airtime usage and amounts due from dealers and customers for 
equipment sales. VEON’s credit risk arising from the services the Company provides to customers is mitigated to a large extent 
due  to  the  majority  of  its  active  customers  being  subscribed  to  a  prepaid  service  as  of  December  31,  2020  and  2019,  and 
accordingly not giving rise to credit risk. For postpaid services, in certain circumstances, VEON requires deposits as collateral for 
airtime usage. Equipment sales are typically paid in advance of delivery, except for equipment sold to dealers on credit terms. 

VEON’s credit risk arising from its trade receivables from dealers is mitigated due to the risk being spread across a large number 
of dealers. Management periodically reviews the history of payments and credit worthiness of the dealers. The Company also 
has receivables from other local and international operators from interconnect and roaming services provided to their customers, 
as well as receivables from customers using fixed-line services, such as business services, wholesale services and services to 
residents.  Receivables  from  other  operators  for  roaming  services  are  settled  through  clearing  houses,  which  helps  to  mitigate 
credit risk in this regard. 

VEON  holds  available  cash  in  bank  accounts,  as  well  as  other  financial  assets  with  financial  institutions  in  countries  where  it 
operates.  To  manage  credit  risk  associated  with  such  asset  holdings,  VEON  allocates  its  available  cash  to  a  variety  of  local 
banks and local affiliates of international banks within the limits set forth by its treasury policy. Management periodically reviews 
the creditworthiness of the banks with which it holds assets. In respect of financial instruments used by the Company’s treasury 
function, the aggregate credit risk the Group may have with one counterparty is managed by reference to, amongst others, the 
long-term credit ratings assigned for that counterparty by Moody’s, Fitch Ratings and Standard & Poor’s and CDS spreads of that 
counterparty.  The  limits  are  set  to  minimize  the  concentration  of  risks  and  therefore  mitigate  financial  loss  through  potential 
counterparty’s failure. 

Value Added Tax (“VAT”) is recoverable from tax authorities by offsetting it against VAT payable to the tax authorities on VEON’s 
revenue  or  direct  cash  receipts  from  the  tax  authorities.  Management  periodically  reviews  the  recoverability  of  the  balance  of 
input value added tax and believes it is fully recoverable. 

VEON  issues  advances  to  a  variety  of  its  vendors  of  property  and  equipment  for  its  network  development.  The  contractual 
arrangements  with  the  most  significant  vendors  provide  for  equipment  financing  in  respect  of  certain  deliveries  of  equipment. 
VEON periodically reviews the financial position of vendors and their compliance with the contract terms. 

The Company’s maximum exposure to credit risk for the components of the statement of financial position at December 31, 2020 
and 2019 is the carrying amount as illustrated in Note 5, Note 15, Note 16 and within this Note 17.

162

LIQUIDITY RISK

The  Company  monitors  its  risk  to  a  shortage  of  funds  using  a  recurring  liquidity  planning  tool.  The  Company’s  objective  is  to 
maintain a balance between continuity of funding and flexibility through the use of bonds, bank overdrafts, bank loans and lease 
contracts. The Company’s policy is to create a balanced debt maturity profile. As of December 31, 2020, 5% of the Company’s 
debt  (2019:  21%)  will  mature  in  less  than  one  year  based  on  the  carrying  value  of  bank  loans,  bonds  and  other  borrowings 
reflected in the financial statements. The Company assessed the concentration of risk with respect to refinancing its debt and 
concluded  it  to  be  low  based  on  liquidity  in  the  markets  the  Company  has  access  to,  and  recent  history  of  refinancing.  The 
Company believes that access to sources of funding is sufficiently available and the Company’s policy is to diversify the funding 
sources where possible.

Available facilities

The Company had the following available facilities as of December 31:

Amounts in millions of transactional currency

US$ equivalent amounts

Final 
availability 
period

Facility 
amount

Utilized

Available

Facility 
amount

Utilized

Available

2020

VEON Holdings B.V. – Revolving 
Credit Facility *

PMCL - Term Facility

Feb 2022

US$1,585 *

—

US$1,585

1,585   

Kartel - Term Facility

Nov 2023

KZT 10,000

KZT 5,000

KZT 5,000

Sep 2021

PKR 14,369

PKR 9,999

PKR 4,370

—   

62   

12   

1,585 

28 

12 

90   

24   

* Facility amount of US$1,586 is available until February 2021. Subsequently, a  reduced facility amount of US$1,382 is available until February 2022. In March 2021, 
VEON entered into a new multi-currency revolving credit facility agreement, refer to Note 22 for further details.   

Amounts in millions of transactional currency

US$ equivalent amounts

Final 
availability 
period

Facility 
amount

Utilized

Available

Facility 
amount

Utilized

Available

Feb 2022

US$1,688

—

US$1,688

1,688   

—   

1,688 

2019

VEON Holdings B.V. – Revolving 
Credit Facility *

PMCL - Syndicated Term Facility 
and Islamic Finance Facility

PMCL - Term Facility

Sep 2020

PKR 14,369

PKR 2,963

PKR 11,406  

Mar 2020

PKR 45,000

PKR 15,885

PKR 29,115  

291   

93   

103   

19   

188 

74 

* Facility amount of US$1,688 is available until February 2020. Subsequently a reduced facility amount of US$1,586 is available until February 2021. In March 2021, 
VEON entered into a new multi-currency revolving credit facility agreement, refer to Note 22 for further details.

163

 
 
 
 
Maturity profile

The table below summarizes the maturity profile of the Group’s financial liabilities based on contractual undiscounted payments. 
Payments related to variable interest rate financial liabilities and derivatives are included based on the interest rates and foreign 
currency exchange rates applicable as of December 31, 2020 and 2019, respectively. The total amounts in the table differ from 
the carrying amounts as stated in Note 15 as the below table includes both undiscounted principal amounts and interest while 
the carrying amounts are measured using the effective interest rate method.

As of December 31, 2020

Bank loans and bonds

Lease liabilities

Derivative financial liabilities

Gross cash inflows

Gross cash outflows

Trade and other payables

Other financial liabilities

Warid non-controlling interest put option liability

Less than 1 
year

1-3 years

3-5 years

More than 5 
years

Total

842   

525   

3,803   

896   

3,123   

639   

1,408   

239   

(228)   

237   

1,977   

—   

273   

—   

—   

—   

60   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

9,176 

2,299 

(228) 

237 

1,977 

60 

273 

Total financial liabilities

3,626   

4,759   

3,762   

1,647   

13,794 

Related derivatives financial assets

Gross cash inflows

Gross cash outflows

Related derivative financial assets

152   

(149)   

3   

—   

—   

—   

—   

—   

—   

—   

—   

—   

152 

(149) 

3 

Total financial liabilities, net of derivative assets

3,629   

4,759   

3,762   

1,647   

13,797 

As of December 31, 2019

Bank loans and bonds

Lease liabilities

Derivative financial liabilities

Gross cash inflows

Gross cash outflows

Trade and other payables *

Other financial liabilities

Warid non-controlling interest put option liability

Less than 1 
year

1-3 
years

3-5 years

More than 5 
years

2,100   

581   

(1,150)   

1,311   

1,847   

41   

342   

3,909   

920   

2,009   

728   

(378)   

483   

—   

77   

—   

—   

—   

—   

—   

—   

794   

420   

—   

—   

—   

—   

—   

Total

8,812 

2,649 

(1,528) 

1,794 

1,847 

118 

342 

Total financial liabilities

5,072   

5,011   

2,737   

1,214   

14,034 

Related derivatives financial assets

Gross cash inflows

Gross cash outflows

Related derivative financial assets

(273)   

262   

(11)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(273) 

262 

(11) 

Total financial liabilities, net of derivative assets

5,061   

5,011   

2,737   

1,214   

14,023 

164

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CAPITAL MANAGEMENT 

The primary objective of the Company’s capital management is to ensure that it maintains healthy capital ratios, so as to secure 
access to debt and capital markets at all times and maximize shareholder value. The Company manages its capital structure and 
makes adjustments to it in light of changes in economic conditions. To maintain or adjust the capital structure, the Company may 
adjust  the  dividend  payment  to  shareholders,  return  capital  to  shareholders  or  issue  new  shares.  Current  credit  ratings  of  the 
Company support its capital structure objectives. Since 2019, VEON’s dividend policy targets paying at least 50% of prior year 
Equity  Free  Cash  Flow  after  licenses.  There  were  no  changes  made  in  the  Company’s  objectives,  policies  or  processes  for 
managing capital during 2020.

The Net Debt to Adjusted EBITDA ratio is an important measure used by the Company to assess its capital structure. Net Debt 
represents the principal amount of interest-bearing debt less cash and cash equivalents and bank deposits. Adjusted EBITDA is 
defined as last twelve months earnings before interest, tax, depreciation, amortization and impairment, loss on disposals of non-
current assets, other non-operating losses and share of profit / (loss) of joint ventures. For reconciliation of ‘Profit / (loss) before 
tax  from  continuing  operations’  to  ‘Adjusted  EBITDA,’  refer  to Note  2.  VEON's  internal  target  is  to  keep  Net  Debt  to Adjusted 
EBITDA  at  around  2.0x  on  the  basis  of  the  so  called  "GAAP  freeze"  principle,  i.e.  under  the  IAS  17  framework,  which  is 
equivalent to 2.4x on the post-IFRS 16 basis.  

Further, this ratio is included as a financial covenant in the credit facilities of the Company. For most of our credit facilities the Net 
Debt to Adjusted EBITDA ratio is calculated at consolidated level of VEON Ltd. and is “pro-forma” adjusted for acquisitions and 
divestments of any business bought or sold during the relevant period. Under these credit facilities, the Company is required to 
maintain the Net Debt to Adjusted EBITDA ratio below 3.5x (on the basis of the so called "GAAP freeze" principle). The Company 
has not breached any financial covenants during the period covered by these financial statements.

165

18

ISSUED CAPITAL AND RESERVES

The following table details the common shares of the Company as of December 31:

Authorized common shares (nominal value of US$0.001 per share)

1,849,190,667 

1,849,190,667 

Issued shares, including 7,603,731 shares held by a subsidiary of the Company

1,756,731,135 

1,756,731,135 

The holders of common shares are, subject to our by-laws and Bermuda law, generally entitled to enjoy all the rights attaching to 
common shares. All issued shares are fully paid-up. 

As of December 31, 2020, the Company’s largest shareholders and remaining free float are as follows:

2020

2019

Shareholder

L1T VIP Holdings S.à r.l. (“LetterOne”)

Stichting Administratiekantoor Mobile Telecommunications Investor *

Free Float, including 7,603,731 shares held by a subsidiary of the Company

Total outstanding common shares

Common 
shares

840,625,001 

145,947,562 

770,158,572 

1,756,731,135 

common and 
voting 
shares

 47.9 %

 8.3 %

 43.8 %

 100.0 %

*  LetterOne  is  the  holder  of  the  depositary  receipts  issued  by  Stichting  and  is  therefore  entitled  to  the  economic  benefits  (dividend  payments,  other 
distributions and sale proceeds) of such depositary receipts and, indirectly, of the 145,947,562 common shares represented by the depositary receipts. According to 
the conditions of administration entered into between Stichting and LetterOne (“Conditions of Administration”) in connection with the transfer of 145,947,562 ADSs 
from LetterOne to Stichting on March 29, 2016, Stichting has the power to vote and direct the voting of, and the power to dispose and direct the disposition of, the 
ADSs, in its sole discretion, in accordance with the Conditions of Administration and Stichting’s articles of association.

Nature and purpose of reserves

Other capital reserves are mainly used to recognize the results of transactions that do not result in a change of control with non-
controlling interest (see Note 13). The foreign currency translation reserve is used to record exchange differences arising from 
the translation of the financial statements of foreign subsidiaries, net of any related hedging activities (see Note 15).

166

 
 
 
 
 
 
 
 
19  EARNINGS PER SHARE

Earnings per common share for all periods presented has been determined by dividing profit available to common shareholders 
by the weighted average number of common shares outstanding during the period. 

The  following  table  sets  forth  the  computation  of  basic  and  diluted  earnings  per  share  for  continuing  operations,  for  the  years 
ended December 31:

Continuing operations

2020

2019

2018

(In millions of U.S. dollars, except share and per share amounts)

Numerator:

Profit / (loss) for the period attributable to the owners of the parent

(349)   

621   

(397) 

Denominator:

Weighted average common shares outstanding for basic earnings per share (in millions)

Denominator for diluted earnings per share (in millions)

Basic (loss) / earnings per share

Diluted (loss) / earnings per share

1,749   

1,749   

($0.20)   

($0.20)   

1,749   

1,749   

$0.36   

$0.36   

1,749 

1,749 

($0.23) 

($0.23) 

The following table sets forth the computation of basic and diluted earnings per share for discontinued operations, for the years 
ended December 31:

Discontinued operations

2020

2019

2018

(In millions of U.S. dollars, except share and per share amounts)

Numerator:

Profit / (loss) for the period attributable to the owners of the parent

—   

—   

979 

Denominator:

Weighted average common shares outstanding for basic earnings per share (in millions)

Denominator for diluted earnings per share (in millions)

Basic (loss) / earnings per share

Diluted (loss) / earnings per share

1,749   

1,749   

$0.00   

$0.00   

1,749   

1,749   

$0.00   

$0.00   

1,749 

1,749 

$0.56 

$0.56 

167

 
 
 
 
 
 
 
 
 
 
20  DIVIDENDS PAID AND PROPOSED

Pursuant to Bermuda law, VEON is restricted from declaring or paying a dividend if there are reasonable grounds for believing 
that 

(a) VEON is, or would after the payment be, unable to pay its liabilities as they become due, or 

(b)

the realizable value of VEON assets would, as a result of the dividend, be less than the aggregate of VEON liabilities.

There were no dividends declared by VEON in respect of the year 2020. The following table provides an overview of dividends 
announced by VEON in respect of the year 2019:

Dividends declared

Dividends paid

Dividends, US$ cents 
per share

Final for 2019

Interim for 2019

February 2020

August 2019

March 2020

August 2019

15

13

The  Company  makes  appropriate  tax  withholdings  of  up  to  15%  when  the  dividends  are  being  paid  to  the  Company’s  share 
depository, The Bank of New York Mellon. For ordinary shareholders at Euronext Amsterdam, dividends are paid in euro.

DIVIDENDS DECLARED TO NON-CONTROLLING INTERESTS

During 2020, 2019 and 2018, certain subsidiaries of the Company declared dividends, of which a portion was paid or payable to 
non-controlling interests as shown in the table below:

Name of subsidiary

Omnium Telecom Algeria S.p.A

VIP Kazakhstan Holding AG

TNS Plus LLP

Other

Total dividends declared to non-controlling interests

2020

45 

24 

16 

2 

87 

2019

69 

24 

12 

3 

108 

2018

76 

— 

13 

4 

93 

In  2020,  PMCL,  a  subsidiary  of  the  Company,  declared  dividends  to  its  shareholders,  of  which  US$25  (2019:  US$24,  2018: 
US$11) was declared to non-controlling shareholders of PMCL. Dividends declared to non-controlling interests of PMCL reduces 
the principal amount of the put-option liability over non-controlling interest on the date of declaration. As of December 31, 2020, 
there is no remaining amount payable to non-controlling interests (2019: none, 2018: US$7).

168

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ADDITIONAL INFORMATION

21

RELATED PARTIES

As  of  December  31,  2020,  the  Company  has  no  ultimate  controlling  shareholder.  See  also  Note  18  for  details  regarding 
ownership structure. 

COMPENSATION TO DIRECTORS AND SENIOR MANAGERS OF THE COMPANY 

The following table sets forth the total compensation paid to our directors and senior managers, who are considered to be key 
management of the company:

Short-term employee benefits

Long-term employee benefits

Share-based payments

Termination benefits

Total compensation to directors and senior management *

2020

2019

2018

35 

1 

— 

4 

40 

48 

— 

3 

— 

51 

33 

— 

— 

2 

35 

* The number of directors and senior managers vary from year to year. Total compensation paid to directors and senior management approximates the 

amount charged in the consolidated income statement for that year.

Under the Company’s bye-laws, the Board of Directors of the Company established a compensation and talent committee, which 
has  the  overall  responsibility  for  approving  and  evaluating  the  compensation  and  benefit  plans,  policies  and  programs  of  the 
Company’s directors, officers and employees and for supervising the administration of the Company’s equity incentive plans and 
other compensation and incentive programs.

Compensation of Key Senior Managers

The following table sets forth the total remuneration expense to the key senior managers in 2020 and 2019 (gross amounts in 
whole euro and whole US$ equivalents). For further details on compensation and changes to key senior managers, please refer 
to the Explanatory notes below.

Kaan 
Terzioglu
Group Co-
CEO

Sergi 
Herrero
Group Co-
CEO

Ursula 
Burns

Serkan 
Okandan

Trond 
Westlie

Murat 
Kirkgoz
Deputy 

Kjell 
Johnsen

Group CEO

Group CFO

Group CFO

Group CFO Group COO

Scott 
Dresser
Group 
General 
Counsel

Alex 
Kazbegi
Chief 
Strategy 
Officer

Joop 
Brakenhoff
& 
Compliance 
Officer

In whole euros

2020

Short-term employee benefits

Base salary

  1,323,000    1,181,368    1,162,750    864,000   

16,810    211,600   

—    1,300,000    553,500    224,100 

Annual incentive

  930,418    769,643    540,984    525,730   

—   

80,302   

—    2,300,000    338,378    147,813 

Other

  439,657    2,158,022    554,328    297,341    212,631   

40,360    299,333   

24,100    104,124   

39,908 

Long-term employee benefits

76,366    706,925   

—   

—   

—   

—   

—   

—   

Share-based payments

88,056   

58,707    111,403   

76,316   

(217,080)   

(7,954)   

(217,080)   

(65,526)   

Termination benefits

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

— 

8,775 

— 

Total remuneration expense *

  2,857,497    4,874,665    2,369,465    1,763,387   

12,361    324,308   

82,253    3,558,574    996,002    420,596 

2019

Short-term employee benefits

Base salary

  220,500    342,036    5,500,000   

—    1,500,000    264,500    1,250,000    1,300,000    394,795   

Annual incentive

  472,151    514,460   10,461,000   

—    1,455,216    211,713    4,184,355    2,258,882    700,000   

Other

  105,999    1,560,229    1,146,503   

Long-term employee benefits

Share-based payments

Termination benefits

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

24,100   

35,750   

46,857   

29,100    677,662   

—   

—   

—   

—   

64,842   

8,242   

(828,047)   

(697,504)   

—   

—   

—   

—   

—   

—   

—   

Total remuneration expense

  798,650    2,416,725   17,107,503   

—    3,044,158    520,205    4,653,165    2,890,478    1,772,457   

— 

— 

— 

— 

— 

— 

— 

* Total remuneration expense for 2020 excludes accrued payroll taxes of EUR9 million (US$10) recorded in ‘Selling, general and administrative expenses’ incurred by 
the Company pertaining to payments made to Ursula Burns, Kjell Johnson.

169

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In whole US dollars

2020

Short-term employee benefits

Base salary

Annual incentive

Other

Kaan 
Terzioglu

Group Co-
CEO

Sergi 
Herrero

Group Co-
CEO

Ursula 
Burns

Serkan 
Okandan

Trond 
Westlie

Murat 
Kirkgoz

Kjell 
Johnsen

Group CEO

Group CFO

Group CFO

Deputy 

Group CFO Group COO

Scott 
Dresser

Group 
General 

Alex 
Kazbegi

Joop 
Brakenhoff

Chief 
Strategy 

Chief 
Internal Audit 

  1,508,380    1,346,902    1,325,676    985,064   

19,165    241,250   

—    1,482,157    631,057    255,501 

  1,060,789    877,486    616,787    599,396   

—   

91,554   

—    2,622,278    385,792    168,525 

  501,262    2,460,406    632,001    339,005    242,425   

46,015    341,276   

27,477    118,714   

45,500 

Long-term employee benefits

87,066    805,980   

—   

—   

—   

—   

—   

—   

Share-based payments

  100,394   

66,933    127,013   

87,009   

(247,497)   

(9,069)   

(247,497)   

(74,708)   

Termination benefits

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

— 

10,005 

— 

Total remuneration expense *

  3,257,891    5,557,707    2,701,477    2,010,474   

14,093    369,750   

93,779    4,057,204    1,135,563    479,531 

2019

Short-term employee benefits

Base salary

Annual incentive

Other

  246,782    382,805    6,155,568   

—    1,678,791    296,027    1,398,993    1,454,952    441,852   

  528,429    575,781   11,707,890   

—    1,628,669    236,948    4,683,106    2,528,128    783,436   

  118,633    1,746,199    1,283,159   

Long-term employee benefits

Share-based payments

Termination benefits

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

26,973   

40,011   

52,442   

32,569    758,435   

—   

—   

—   

—   

72,571   

9,224   

(926,745)   

(780,642)   

—   

—   

—   

—   

—   

—   

—   

Total remuneration expense

  893,844    2,704,785   19,146,617   

—    3,407,004    582,210    5,207,796    3,235,007    1,983,723   

— 

— 

— 

— 

— 

— 

— 

* Total remuneration expense for 2020 excludes accrued payroll taxes of EUR9 million (US$10) recorded in ‘Selling, general and administrative expenses’ incurred by 
the Company pertaining to payments made to Ursula Burns, Kjell Johnson.

Explanatory notes

Base salary includes any holiday allowances pursuant to the terms of an individual’s employment agreement. Annual incentive 
expense includes amounts accrued under the short-term incentive in respect of performance during the current year, as well as 
any special recognition bonus. Other short-term employee benefits include certain allowances (for example, pension allowance 
or reimbursement of certain losses etc.) and support (for example, relocation support).

Share-based payments expense relates to amounts accrued under the value growth cash-based multi-year incentive plans, see 
below for further details.

Changes in Key Senior Managers

Ursula Burns stepped down as Group CEO with effect from March 1, 2020. Sergi Herrero and Kaan Terzioğlu were appointed as 
Co-CEOs with effective from March 1, 2020, having previously served as Joint COOs since September 2, 2019 and November 1, 
2019, respectively. 

On May 1, 2020, Serkan Okandan joined VEON as Group CFO. Trond Westlie stepped down from the role of Group CFO on 
September 30, 2019. Murat Kirkgoz served as Deputy Group CFO from August 1, 2019 to April 30, 2020.

Kjell Johnsen stepped down from the role of Group COO on November 1, 2019. 

The Key Senior Managers of VEON include Group (co-)CEOs, Group CFO, Group COO and Group General Counsel. In addition 
to the Key Senior Managers disclosed, VEON has also voluntarily disclosed other senior managers. Alex Kazbegi was appointed 
Group Chief Strategy Officer effective from February 18, 2019, and Joop Brakenhoff was appointed Group Chief Internal Audit & 
Compliance Officer, effective July 1, 2020. 

170

 
 
 
 
 
Compensation of Board of Directors  

The following table sets forth the total remuneration expense to the members of the Board of Directors members in 2020 and 
2019 (gross amounts in whole euro and whole US dollar equivalents). For details on changes in Board of Directors, please refer 
to explanations below. 

In whole euros

2020

2019

2020

2019

2020

2019

Retainer

Committees

Other compensation

Alexander Pertsovsky

47,917   

40,000   

—   

Steve Pusey

Kaan Terzioglu

204,167   

—   

58,333   

—   

92,708   

—   

9,063   

Total compensation

3,395,361    1,962,708   

746,136   

328,567   

500,000   

750,000   

4,641,497    3,041,275 

In whole US dollars

2020

2019

2020

2019

2020

2019

Retainer

Committees

Other compensation

Hans Holger Albrecht

Guillaume Bacuvier

Osama Bedier

Ursula Burns

Mariano De Beer

Peter Derby

Mikhail Fridman

Gennady Gazin

Amos Genish

Yaroslav Glazunov

Andrei Gusev

Gunnar Holt

Sir Julian Horn-Smith
Robert Jan van de Kraats

Guy Laurence

204,167   

—   

72,917   

105,114   

250,000   

23,125   

308,333   

250,000   

68,750   

323,864   

204,167   

204,167   

—   

—   

—   

—   

87,500   

87,500   

60,417   

40,000   

—   

—   

53,909   

25,000   

5,952   

—   

—   

—   

629,167   

250,000   

33,333   

80,000   

204,167   

13,350   

—   

—   

60,417   

40,000   

87,500   

—   

—   

308,333   

250,000   

118,750   

105,114   
308,333   

250,000   
250,000   

10,511   
85,417   

104,167   

250,000   

12,500   

—   

—   

—   

69,643   

25,000   
30,000   

30,000   

—   

—   

Hans Holger Albrecht

Guillaume Bacuvier

Osama Bedier

Ursula Burns

Mariano De Beer

Peter Derby

Mikhail Fridman

Gennady Gazin

Amos Genish
Yaroslav Glazunov

Andrei Gusev

Gunnar Holt

232,775   

—   

83,134   

119,843   

279,799   

26,365   

351,537   

279,799   

78,383   

369,244   

232,775   

232,775   

—   

—   

—   

—   

99,761   

99,761   

68,883   

44,768   

—   

—   

60,335   

27,980   

6,661   

—   

—   

—   

717,326   

279,799   

38,004   

89,536   

232,775   
15,221   

—   
—   

99,761   
—   

68,883   

44,768   

—   

351,537   

279,799   

135,389   

Sir Julian Horn-Smith

119,843   

279,799   

11,984   

Robert Jan van de Kraats

351,537   

279,799   

97,386   

Guy Laurence

118,763   

279,799   

14,252   

Alexander Pertsovsky

54,631   

44,768   

—   

Steve Pusey

Kaan Terzioglu

232,775   

—   

66,507   

—   

103,758   

—   

10,143   

—   
—   

—   

77,944   

27,980   

33,576   

33,576   

—   

—   

Total

2020

277,084   

2019

— 

128,239   

303,909 

377,083   

275,000 

323,864   

291,667   

291,667   

5,952 

— 

— 

60,417   

40,000 

662,500   

330,000 

291,667   

13,350   

— 

— 

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

500,000   

750,000   

560,417   

790,000 

—   

—   
—   

—   

—   

—   

—   

—   

—   
—   

—   

—   

—   

—   

427,083   

319,643 

115,625   
393,750   

275,000 
280,000 

116,667   

280,000 

47,917   

40,000 

262,500   

— 

—   

101,771 

Total

2020

315,909   

2019

— 

146,208   

340,134 

429,920   

307,779 

369,244   

332,536   

332,536   

6,661 

— 

— 

68,883   

44,768 

755,330   

369,335 

332,536   
15,221   

— 
— 

—   

—   

—   

—   

—   

—   

—   

—   

—   
—   

—   

—   

—   

—   

—   

—   

—   

—   

—   
—   

570,060   

839,396   

638,943   

884,164 

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

486,926   

357,743 

131,827   

307,779 

448,923   

313,375 

133,015   

313,375 

54,631   

44,768 

299,282   

— 

—   

113,901 

Total compensation

3,871,123    2,196,655   

850,687   

367,731   

570,060   

839,396   

5,291,870    3,403,782 

Changes in Board of Directors

Ursula  Burns  was  appointed  Group  CEO  and  Chairman  of  the  VEON  Ltd.  board  of  directors  on  December  12,  2018.  
Accordingly, her total compensation for 2019 and until March 1, 2020, has been included in the section “Compensation of Key 
Senior Managers” above, except for payments received in respect of her role on Board Committees. Ursula Burns stepped down 
as Group CEO on March 1, 2020, and later stepped down as Chairman on June 1, 2020. 

On  June  1,  2020  VEON  announced  the  results  of  the  elections  conducted  at  its  Annual  General  Meeting  of  Shareholders. 
Shareholders  elected  five  new  members  to  the  Company’s  Board  of  Directors,  Hans  Holger Albrecht,  Mariano  De  Beer,  Peter 

171

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Derby, Amos  Genish  and  Stephen  Pusey,  as  well  as  seven  previously  serving  directors:  Osama  Bedier,  Mikhail  M.  Fridman, 
Gennady Gazin, Andrei Gusev, Gunnar Holt, Robert Jan van de Kraats and Alexander Pertsovsky.

Following the election of the directors, Gennady Gazin was appointed as Chairman of VEON’s Board of Directors, effective June 
1, 2020.

Value growth cash-based multi-year incentive plans 

To stimulate and reward leadership efforts that result in sustainable success, value growth cash-based multi-year incentive plan 
(“Incentive    Plans”)  were  designed  for  members  of  our  recognized  leadership  community.  The  participants  in  the  Incentive 
Plans may receive cash payouts after the end of each relevant award performance period. 

Vesting is based on the attainment of certain Key Performance Indicators (“KPIs”), such as absolute share price, total return per 
share or value growth of certain VEON businesses.  Options may be exercised by the participant at any time during  a  defined 
exercise period, subject to the Company’s insider trading policy.

Short Term Incentive Scheme 

The  Company’s  Short  Term  Incentive  (“STI”)  Scheme  provides  cash  pay-outs  to  participating  employees  based  on  the 
achievement of established KPIs over the period of one calendar year. KPIs are set every year at the beginning of the year and 
evaluated in the first quarter of the next year. The KPIs are partially based on the financial and operational results (such as total 
operating  revenue,  EBITDA  and  equity  free  cash  flow)  of  the  Company,  or  the  affiliated  entity  employing  the  employee,  and 
partially based on individual targets that are agreed upon with the participant at the start of the performance period based on his 
or her specific role and activities. The weight of each KPI is decided on an individual basis. 

Pay-out  of  the  STI  award  is  scheduled  in  March  of  the  year  following  the  assessment  year  and  is  subject  to  continued  active 
employment  during  the  year  of  assessment  (except  in  limited  “good  leaver”  circumstances  in  which  case  there  is  a  pro-rata 
reduction)  and  is  also  subject  to  a  pro-rata  reduction  if  the  participant  commenced  employment  after  the  start  of  the  year  of 
assessment. Pay-out of the STI award is dependent upon final approval by the compensation and talent committee.

172

22

EVENTS AFTER THE REPORTING PERIOD

VEON enters into a US$1,250 multi-currency revolving credit facility agreement

In  March  2021,  VEON  successfully  entered  into  a  new  multi-currency  revolving  credit  facility  agreement  (the  “RCF”)  of 
US$1,250. The RCF replaces the revolving credit facility signed in February 2017, which is now cancelled. The RCF has an initial 
tenor  of  three  years,  with  the  Company  having  the  right  to  request  two  one-year  extensions,  subject  to  lender  consent. 
International banks from Asia, Europe and the US have committed to the RCF. The new RCF caters for USD LIBOR cessation 
with  the  secured  overnight  financing  rate  (SOFR)  administered  by  the  Federal  Reserve  Bank  of  New  York  agreed  as  the 
replacement  risk  free  rate  with  credit  adjustment  spreads  agreed  for  interest  periods  with  a one  month,  three  months  and  six 
month  tenor.  SOFR  will  apply  to  interest  periods  commencing  on  and  from  October  31,  2021  (or  earlier  if  USD  LIBOR  is  no 
longer published or ceases to be representative prior to that date). The Company will have the option to make each drawdown in 
either U.S. dollars or euro.

VEON subsidiary Banglalink successfully acquires 9.4MHz in spectrum auction 

In March 2021, Banglalink, the Company's wholly-owned subsidiary in Bangladesh, acquired 4.4MHz spectrum in the 1800MHz 
band  and  5MHz  spectrum  in  2100MHz  band  following  successful  bids  at  an  auction  held  by  the  BTRC.  The  newly  acquired 
spectrum  will  see  Banglalink  increase  its  total  spectrum  holding  from 30.6MHz  to  40MHz.  Banglalink  will  invest  approximately 
BDT 10 billion (US$115) to purchase the spectrum.

173

23  BASIS OF PREPARATION OF THE CONSOLIDATED FINANCIAL STATEMENTS

BASIS OF PREPARATION 

These  consolidated  financial  statements  have  been  prepared  in  accordance  with  International  Financial  Reporting  Standards 
(“IFRS”) as issued by the International Accounting Standards Board and adopted by the European Union, effective at the time of 
preparing the consolidated financial statements and applied by VEON.

The consolidated income statement has been presented based on the nature of the expense, other than ‘Selling, general and 
administrative expenses’, which has been presented based on the function of the expense. 

The consolidated financial statements have been prepared on a historical cost basis, unless otherwise disclosed. 

BASIS OF CONSOLIDATION

The consolidated financial statements comprise the financial statements of the Company and its subsidiaries. Subsidiaries are all 
entities  (including  structured  entities)  over  which  the  Company  has  control.  Please  refer  to  Note  13    for  a  list  of  significant 
subsidiaries.   

Intercompany transactions, balances and unrealized gains or losses on transactions between Group companies are eliminated. 
When necessary, amounts reported by subsidiaries have been adjusted to conform with the Group’s accounting policies.

When the Group ceases to consolidate a subsidiary due to loss of control, the related subsidiary’s assets (including goodwill), 
liabilities,  non-controlling  interest  and  other  components  of  equity  are  de-recognized. This  may  mean  that  amounts  previously 
recognized  in  other  comprehensive  income  are  reclassified  to  profit  or  loss.  Any  consideration  received  is  recognized  at  fair 
value, and any investment retained is re-measured to its fair value, and this fair value becomes the initial carrying amount for the 
purposes of subsequently accounting for the retained interest. Any resultant gain or loss is recognized in the income statement.

FOREIGN CURRENCY TRANSLATION 

The consolidated financial statements of the Group are presented in U.S. dollars. Each entity in the Group determines its own 
functional currency and amounts included in the financial statements of each entity are measured using that functional currency. 

Upon  consolidation,  the  assets  and  liabilities  measured  in  the  functional  currency  are  translated  into  U.S.  dollars  at  exchange 
rates prevailing on the balance sheet date; whereas income and expenses are generally translated into U.S. dollars at historical 
monthly  average  exchange  rates.  Foreign  currency  translation  adjustments  resulting  from  the  process  of  translating  financial 
statements  into  U.S.  dollars  are  reported  in  other  comprehensive  income  and  accumulated  within  a  separate  component  of 
equity.

174

24

SIGNIFICANT ACCOUNTING POLICIES

SIGNIFICANT ACCOUNTING JUDGMENTS, ESTIMATES AND ASSUMPTIONS 

The  preparation  of  these  consolidated  financial  statements  has  required  management  to  apply  accounting  policies  and 
methodologies based on complex and subjective judgments, as well as estimates based on past experience and assumptions 
determined  to  be  reasonable  and  realistic  based  on  the  related  circumstances.  The  use  of  these  judgments,  estimates  and 
assumptions  affects  the  amounts  reported  in  these  consolidated  financial  statements.  The  final  amounts  for  items  for  which 
estimates  and  assumptions  were  made  in  the  consolidated  financial  statements  may  differ  from  those  reported  in  these 
statements due to the uncertainties that characterize the assumptions and conditions on which the estimates are based.

The sources of uncertainty identified by the Group are described together with the applicable Note, as follows:

Significant accounting judgment / source of estimation uncertainty

Described in

Revenue recognition

Deferred tax assets and uncertain tax positions

Provisions and contingent liabilities

Impairment of non-current assets

Control over subsidiaries

Note 3

Note 8

Note 7

Note 10

Note 13

Depreciation and amortization of non-current assets

Note 11 and Note 12

Fair value of financial instruments

Measurement of lease liabilities

Note 15

Note 15

NEW STANDARDS AND INTERPRETATIONS 

Not yet adopted by the Group 

Certain  new  accounting  standards  and  interpretations  have  been  published  that  are  not  mandatory  for  December  31,  2020 
reporting periods and have not been early adopted by the Group. These standards are not expected to have a material impact on 
VEON financial statements in current or future reporting periods or on foreseeable future transactions. 

Adopted in 2020

A  number  of  new  and  amended  standards  became  effective  as  of  January  1,  2020,  which  did  not  have  a  material  impact  on 
VEON  financial  statements.  The  Group  has  not  early  adopted  any  other  standards,  interpretations  or  amendments  that  have 
been issued but have not yet become effective.

In May 2020, the IASB issued an amendment to IFRS 16 'Leases', providing an option to apply a practical expedient in respect of 
accounting for certain rent concessions arising as a direct consequence of COVID-19, such as rent holidays and temporary rent 
reductions.  Under  this  amendment,  which  became  effective  in  2020,  lessees  are  exempted  from  having  to  consider  whether 
these rent concessions are lease modifications. The Group has chosen not to apply the practical expedient available, and will 
therefore account for any rent concessions as lease modifications.

Amsterdam, March 15, 2021

VEON Ltd.

175

Company financial statements

COMPANY STATEMENT OF FINANCIAL POSITION

Before appropriation of profit

as at December 31

(In millions of U.S. dollars)

Assets

Non-current assets

Intangible fixed assets

Tangible fixed assets

Financial fixed assets

Total non-current assets

Current assets

Receivables

Cash and cash equivalents

Total current assets

Total assets

Equity and liabilities

Equity

Issued capital

Capital surplus

Reserve results of subsidiaries

Foreign currency translation reserve

Retained earnings / (accumulated deficit)

Result for the year

Total equity

Provisions

Non-current liabilities

Current liabilities

Total equity and liabilities

Note

2020

2019

1

2

3

4

5

6

7

8

9

8   

8   

138   

154   

241   

79   

320   

474   

2   

11,449   

525   

(8,775)   

(2,689)   

(349)   

163   

29   

9   

273   

474   

10 

15 

1,152 

1,177 

352 

41 

393 

1,570 

2 

11,449 

1,079 

(8,312) 

(3,613) 

621 

1,226 

41 

10 

293 

1,570 

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           177

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
COMPANY INCOME STATEMENT

for the year ended December 31

(In millions of U.S. dollars)

General and administrative expenses

Other operating gains

Recharged expenses to group companies

Operating  (loss) / profit

Finance income

Finance expenses

(Loss) / Profit before tax

Income tax

Share in results of subsidiaries after tax

Net result for the year

Note

12

13

13

14

3

2020

(101)   

—   

3   

(98)   

1   

(3)   

(100)   

—   

(249)   

(349)   

2019

(160) 

350 

21 

211 

8 

(2) 

217 

— 

404 

621 

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           178

 
 
 
 
 
 
 
 
 
 
 
 
 
 
COMPANY AND GROUP ACTIVITIES

VEON Ltd. (“VEON” or the “Company”), registered with the Chamber of Commerce in Amsterdam under number 34374835, was 
incorporated on June 5, 2009. 

For  details  of  the  Company’s  and  its  group  of  companies  (“VEON  Group”)  principal  activities,  reference  is  made  to  Note  1 
(General Information about the Group) to the Consolidated Financial Statements. 

The company financial statements are presented in United States dollars (“U.S. dollar” or “US$”). In these notes, U.S. dollar 
amounts are presented in millions unless otherwise indicated.

ACCOUNTING POLICIES

General

The  Company  financial  statements  have  been  prepared  in  accordance  with  Title  9  of  Book  2  of  the  Dutch  Civil  Code.  In 
accordance with the provisions of Article 362, paragraph 8, Title 9 of Book 2 of the Dutch Civil Code the accounting policies used 
are the same as those explained in the Notes to the Consolidated Financial Statements, prepared under IFRS as adopted by the 
European  Union,  except  for  the  accounting  policies  disclosed  below.  For  an  appropriate  interpretation,  the  Company  financial 
statements should be read in conjunction with the consolidated financial statements.

The balance sheet and income statement include references. These refer to the notes.

Comparison with previous year

The valuation principles and method of determining the results are the same as those used in the previous year.

Subsidiaries

Subsidiaries are all entities (including intermediate subsidiaries) over which the Company has control. The Company controls an 
entity when it is exposed, or has rights, to variable returns from its involvement with the subsidiary and has the ability to affect 
those returns through its power over the subsidiary. Subsidiaries are recognized from the date on which control is transferred to 
the Company or its intermediate holding entities. They are derecognized from the date that control ceases.

Investments in subsidiaries are measured at net asset value. Net asset value is based on the measurement of assets, provisions 
and liabilities and determination of profit based on the principles applied in the consolidated financial statements.

If the valuation of a subsidiary based on the net asset value is negative, it will be stated at nil. If and insofar as the Company can 
be  held  fully  or  partially  liable  for  the  debts  of  the  subsidiary  or  has  the  firm  intention  of  enabling  the  participation  to  settle  its 
debts, a provision is recognized for this.

Newly acquired subsidiaries are initially recognized on the basis of the fair value of their identifiable assets and liabilities at the 
acquisition date. For subsequent valuations, the principles that apply for these financial statements are used.

The amount by which the carrying amount of the subsidiary has changed since the previous financial statements as a result of 
the net result achieved by the subsidiary is recognized in the income statement.

Equity interests

For a full list of equity interests, reference is made to the list including entity details filed in accordance with Articles 379 and 414, 
Title 9 of Book 2 of the Dutch Civil Code at the Dutch Chamber of Commerce.

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           179

 
 
 
 
Notes to the Company statement of financial position
(in millions of U.S. dollars unless otherwise stated)

1

INTANGIBLE FIXED ASSETS

Software

Balance as at December 31

Movements in these items were as follows:

Balance as at January 1

Additions

Amortization

Balance as at December 31

Cost

Accumulated amortization and impairment

2020

2019

8   

8   

10   

1   

(3)   

8   

72   

(64)   

10 

10 

9 

4 

(3) 

10 

71 

(61) 

There are no limited property rights to intangible fixed assets and no security in the form of intangible fixed assets have been 
provided for liabilities. Nor have any obligations arisen from the acquisition of intangible fixed assets.

2

TANGIBLE FIXED ASSETS

Equipment

Balance as at December 31

Movements in these items were as follows:

Balance as at January 1

Additions

Disposals

Depreciation

Balance as at December 31

Cost

Accumulated amortization

2020

2019

8   

8   

15   

—   

(4)   

(3)   

8   

28   

(20)   

15 

15 

17 

7 

(2) 

(7) 

15 

34 

(19) 

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           180

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Company statement of financial position
(in millions of U.S. dollars unless otherwise stated)

3

FINANCIAL FIXED ASSETS

Investments in subsidiaries

Investment in sub lease - non current

Balance as at December 31

Movements in investments in subsidiaries were as follows:

Balance as at January 1 

Share premium collection

Changes in ownership interest in a subsidiary that do not result in a loss of control

Result of participating interests after tax

Dividend received from subsidiaries

Investment in subsidiary*

Currency translation adjustments

Other comprehensive (loss) / income related to subsidiaries

Other movements in subsidiaries

Balance as at December 31

* Refer to Note 9 of the Consolidated Financial Statement for further information.

2020

134   

4   

138   

1,152   

(317)   

—   

(249)   

—   

—   

(437)   

(14)   

(1)   

134   

2019

1,152 

0 

1,152 

3,587 

— 

(2,594) 

404 

(650) 

350 

105 

7 

(57) 

1,152 

Other  movements  in  subsidiaries  relates  to  direct  equity  movements  at  the  level  of  the  subsidiaries  in  connection  with 
movements in the hedge reserves and investments held at fair value through other comprehensive income.

3.1

Investment in sublease

VEON  has  entered  into  a  lease  arrangement  as  a  lessor  that  is  considered  to  be  finance  leases.  VEON  leases  subleases  a 
portion of an office building and as they transfer substantially all of the risks and rewards of ownership of the asset it is classified 
as finance leases.

The maturity analysis of lease receivable, including the undiscounted lease payments to be received are as follows:

Less than 1 year

1-3 years

3-5 years

More than 5 years

Balance as at December 31

Undiscounted finance income

Net investment in the sublease

4

RECEIVABLES

Amounts due from group companies

Value added tax

Other receivables and prepayments

Balance as at December 31

2020

2019

— 

4 

— 

— 

4 

— 

4 

2020

233   

2   

5   

240   

— 

— 

— 

— 

— 

— 

— 

2019

345 

6 

1 

352 

All amounts are due within one year. No interest is applicable on the receivables from subsidiaries and other participating interest 
and  no  maturity  has  been  agreed.  The  fair  value  of  the  receivables  approximates  the  book  value,  due  to  their  short-term 
character.

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           181

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
5

CASH AND CASH EQUIVALENTS

Cash and cash equivalents at banks and on hand

Balance as at December 31

6

EQUITY

for the year ended December 31, 2020

2020

2019

79   

79   

41 

41 

(In millions of U.S. dollars)

As at January 1, 2020*

Profit for the period

Other comprehensive loss

Total comprehensive loss

Result appropriation

Movement in legal reserve due to 
currency restrictions

Dividends declared

Other

As at December 31, 2020

Issued 
capital

Capital 
Surplus

Reserve 
Results of 
Subsidiaries

Foreign 
currency 
translation 
reserves

Retained 
Earnings / 
(accumulated 
deficit)

Result for 
the year

Total equity

2   

—   

—   

—   

—   

—   

—   

—   

2   

11,449   

571   

(8,312)   

(3,105)   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

(46)   

—   

—   

—   

(437)   

(437)   

—   

—   

—   

(26)   

—   

(14)   

(14)   

621   

46   

(262)   

25   

621   

(349)   

—   

(349)   

(621)   

—   

—   

—   

11,449   

525   

(8,775)   

(2,689)   

(349)   

1,226 

(349) 

(451) 

(800) 

— 

— 

(262) 

(1) 

163 

* Legal reserve was adjusted to conform with the calculation as of December 31, 2020

for the year ended December 31, 2019

Issued 
capital

Capital 
Surplus

Reserve 
Results of 
Subsidiaries

Foreign 
currency 
translation

Retained 
Earnings / 
(accumulated 
deficit)

Result for 
the year

Total equity

2   

—   

—   

—   

—   

—   

—   

—   

2   

11,449   

1,351   

(8,416)   

(1,301)   

—   

—   

—   

—   

—   

0   

0   

—   

—   

105   

105   

—   

—   

7   

7   

582   

621   

—   

621   

582   

(582)   

—   

(272)   

—   

272   

—   

—   

—   

—   

—   

—   

(1)   

(2,594) 

(525)   

(54)   

—   

—   

3,667 

621 

112 

733 

— 

— 

(2,594) 

(525) 

(55) 

11,449   

1,079   

(8,312)   

(3,613)   

621   

1,226 

(In millions of U.S. dollars)

As at January 1, 2019

Profit for the period

Other comprehensive loss

Total comprehensive loss

Result appropriation

Movement in legal reserve due to 
currency restrictions

Change in ownership interest in a 
subsidiary that do not result in a 
loss of control

Dividends declared

Other

As at December 31, 2019

Issued capital

Reference  is  made  to  Note  18  (Issued  capital  and  reserves)  to  the  Consolidated  Financial  Statements  for  issued  capital 
disclosures.

Capital surplus

Capital surplus represents primarily contributions into the Company from the shareholders. 

Results of subsidiaries

The reserve Results of subsidiaries comprise the amount of profits that cannot be repatriated from subsidiaries due to dividend 
distribution  restrictions,  as  well  as  withholding  tax  for  undistributed  profits  in  subsidiaries  that  are  not  covered  by  deferred  tax 
liabilities.

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           182

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Company statement of financial position
(in millions of U.S. dollars unless otherwise stated)

Appropriation of result

Management proposes the following appropriation of result, which has not yet been reflected in the financial statements.

Proposed final dividends

Transfer to Retained earnings / (Accumulated deficit)

Net results

2020

—   

(349)   

(349)   

2019

— 

621 

621 

During the year an amount of US$262 (2019: US$525) was paid as dividend out of the retained earnings/accumulated deficit. In 
2019, management proposed a final dividend in the amount of US$264 (US 15 cents per share) to be paid out of the retained 
earnings/accumulated deficit.

7 

PROVISIONS

Legal provisions

Restructuring provision

Balance as at December 31

2020

2019

8   

21   

29   

10 

31 

41 

The  legal  provision  relates  to  the  future  direct  and  incremental  expected  legal  fees  associated  with  the  resolution  of  the 
investigations  of  our  business  in  Uzbekistan.  Reference  is  made  to  Note  7  (Provisions  and  contingent  liabilities)  to  the 
Consolidated Financial Statements.

The restructuring provision of US$21 (2019: US$31) relates to staff redundancies at the corporate headquarters in Amsterdam.

The movements in provisions were as follows:

Balance as at January 1 

Arising during the year

Utilized

Unused amounts reversed

Balance as at December 31

US$29 (2019: US$41) of the provisions qualify as short-term (in effect less than one year).

8 

NON-CURRENT LIABILITIES

Lease liabilities

Loan from subsidiary

Balance as at December 31

The movements in loans were as follows:

Balance as at January 1 

Balance as at IFRS 16 adoption

Repayment

Foreign exchange (gains) / losses

Balance as at December 31

2020

2019

41   

—   

(12)   

—   

29   

39 

31 

(19) 

(10) 

41 

2020

2019

9   

—   

9   

10 

— 

10 

2020

2019

10   

—   

(2)   

1   

9   

— 

12 

(2) 

— 

10 

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           183

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
9 

CURRENT LIABILITIES

Payable to group companies

Lease liabilities

Accounts payable

Taxes and social security contributions

Accruals and other payables

Due to employees

Balance as at December 31

2020

238   

3   

4   

1   

27   

—   

273   

2019

228 

2 

4 

— 

58 

1 

293 

The fair value of the current liabilities approximates the book value, due to their short-term character. All current liabilities fall due 
within one year.

10  WORKFORCE

The  average  number  of  staff  employed  by  the  Company  in  2020  was  41  (2019:  61).  These  employees  are  located  in  the 
Netherlands.

11  COMMITMENTS NOT SHOWN IN THE BALANCE SHEET

Liability

The  Company  has  issued  liability  statements  pursuant  to Article  403,  Title  9  of  Book  2  of  the  Dutch  Civil  Code  for  its  100% 
indirect subsidiary VEON Wholesale Services B.V..

Fiscal unity VAT

The  Company  forms  part  of  the  fiscal  unity  for  value  added  tax  purposes  with  VEON Amsterdam  B.V.,  VEON  Holdings  B.V., 
VEON  Digital  Amsterdam  B.V.,  VEON  Global  Services  B.V.,  VEON  Central  Procurement  B.V.  and  Global  Telecom  Holding 
S.A.E., which makes these companies jointly and severally liable for VAT liabilities of the fiscal unity.

Balance and interest set-off agreement

On September 26, 2019 the Company, together with some of its subsidiaries, entered into a new multi-entity and multi-currency 
cash pooling agreement with Citibank. Each party to the agreement has irrevocably and unconditionally undertaken, as joint and 
several  debtor,  to  Citibank  to  perform  all  payment  obligations  of  each  other  party  under  the  agreement.  Before  that  date,  the 
Company had such arrangement with ING Bank, which was terminated following the new agreement with Citibank. 

Other commitments, contingencies and uncertainties

For other commitments, contingencies and uncertainties related to VEON Ltd. not included in the balance sheet according to the 
first sentence of Article 381, paragraph 1, Title 9 of Book 2 of the Dutch Civil Code – such as the VEON-Securities Class Action 
and the Canadian action brought by the Catalyst Capital Group Inc. – reference is made to the disclosure mentioned in Note 7 
(Provisions and contingent liabilities) to the Consolidated Financial Statements.

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           184

 
 
 
 
 
 
 
 
 
 
 
12  GENERAL AND ADMINISTRATIVE EXPENSES

Employee benefits

Advisory fees

Depreciation and amortization

Other expenses

Total general and administrative expenses

12.1  Employee benefits

Salaries and wages

Social premiums

Other personnel expenses

Recharged expenses

Total employee benefits

13 

FINANCE INCOME AND EXPENSES

Finance income

Interest income banks and others

Finance expenses

Interest expense loans group company

Interest expense banks and others

Foreign exchange losses

Net financial (expense) / income

14 

INCOME TAXES

2020

2019

44   

13   

6   

38   

101   

52 

6 

7 

95 

160 

2020

2019

38   

1   

1   

4   

44   

41 

1 

1 

9 

52 

2020

2019

1   

1   

—   

(1)   

(2)   

(3)   

(2)   

8 

8 

(1) 

(2) 

1 

(2) 

6 

During the year there were no income and deferred tax expenses. 

For the corporate income tax, no deferred tax asset is recognized for unutilized net operating losses because it is not probable 
that future taxable profit will be available. The unutilized net operating losses per December 31, 2020 amount to US$974 (2019: 
US$976).

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           185

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Notes to the Company statement of financial position
(in millions of U.S. dollars unless otherwise stated)

15  SUBSEQUENT EVENTS

For subsequent events, please refer to Note 22 (Events after the reporting period) of the Consolidated Financial Statements.

16  ADDITIONAL NOTES TO THE COMPANY FINANCIAL STATEMENTS

Remuneration of and loans to members of the Global Executive Committee and the Board

The  remuneration,  including  pension  charges  and  other  benefits,  of  current  and  former  members  of  the  Board  charged  to  the 
Company,  its  subsidiaries  and  other  group  companies  in  the  current  year  is  disclosed  in  Note  21  (Related  parties)  to  the 
Consolidated Financial Statements.

Principal Accountant Fees and Services

PricewaterhouseCoopers  Accountants  N.V.  have  served  as  our  independent  public  accountants  for  the  fiscal  year  ended 
December 31, 2020. The following table presents the aggregate fees for professional services and other services rendered by 
PricewaterhouseCoopers Accountants N.V. and their member firms in 2020 and 2019:

Audit fees

Audit-related fees

Tax fees

Total other non-audit related services

Total principal accountant fees and services

Audit Services

PricewaterhouseCoopers 
Accountants N.V.

Other PwC Global 
Network Firms

2020

2019

2020

2019

4.8   

1.0   

—   

—   

5.8   

4.1   

1.0   

—   

—   

5.1   

5.1   

0.1   

—   

0.1   

5.3   

5.8 

0.3 

— 

— 

6.1 

Audit services mainly consisted of the audit of (consolidated) financial statements, the review of quarterly (consolidated) financial 
statements and Sarbanes-Oxley Section 404 attestation services.

Audit-related Services

Audit-related services are assurance and related services which are reasonably related to the performance of audit or review and 
generally  include  services  regarding  specific  regulatory  filings,  including  comfort  and  consent  letters,  and  other  agreed-upon 
services related to accounting records and systems.

Amsterdam, March 15, 2021 

VEON Ltd.

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           186

 
 
 
 
 
 
 
 
 
Notes to the Company statement of financial position
(in millions of U.S. dollars unless otherwise stated)

OTHER INFORMATION

Provisions governing profit appropriation

The provisions governing profit appropriation are described in articles 19 and 20 as applicable on the signing date of this Annual 
Report of the Bye-laws of VEON.

The Board may, subject to these bye-laws and in accordance with the Companies Act 1981 of Bermuda (the ”Act”), declare a 
dividend to be paid to the Members (as defined in the bye-laws) holding shares entitled to the payment of dividends, in proportion 
to the numbers of shares held by them, and such dividend may be paid in cash or wholly or partly in specie, including without 
limitation the issue by VEON of shares or other securities, in which case the Board may fix the value for distribution in specie of 
any assets, shares or securities. No unpaid dividend shall bear interest as against VEON. The exact amount and timing of any 
dividend declarations and payments shall, subject to the requirements of the Act, be determined by the Board.

The Board may fix any date as the record date for determining the Members entitled to receive any dividend.

The Company may pay dividends in proportion to the amount paid up on each share where a larger amount is paid up on some 
shares than on others.

The  Board  may  declare  and  make  such  other  distributions  (in  cash  or  in  specie)  to  the  Members  holding  shares  entitled  to 
distributions  as  may  be  lawfully  made  out  of  the  assets  of  VEON.  No  unpaid  distribution  shall  bear  interest  as  against  the 
Company.

Except, insofar as the rights attaching to, or the terms of issue of, any shares otherwise provide:

all dividends shall be declared and paid according to the amounts paid up on the shares in respect of which the dividend is paid, 
but no amount paid up on a share in advance of a call may be treated for the purpose of this Bye-law as paid up on the share; 
and

dividends shall be apportioned and paid pro rate according to the amounts paid up on the shares in respect of which the dividend 
is paid during any portion or portions of the period in respect of which the dividend is paid.

The Board may, before declaring a dividend, set aside out of the surplus or profits of VEON, such amount as it thinks proper as a 
reserve to be used to meet contingencies or for any other purpose.

Independent auditor’s report

The independent auditor’s report is set forth on the next pages.

VEON Ltd I Company financial statements as of and for the year ended December 31, 2020   

           187

 
 
 
 
Independent auditor’s report

To: the general meeting and the board of directors of VEON Ltd.

Report on the financial statements 2020

Our opinion
In our opinion:
•

the consolidated financial statements of VEON Ltd. together with its subsidiaries (‘the Group’) give a true and fair 
view of the financial position of the Group as at 31 December 2020 and of its result and cash flows for the year then 
ended in accordance with International Financial Reporting Standards as adopted by the European Union (EU-IFRS) 
and with Part 9 of Book 2 of the Dutch Civil Code;

•

the company financial statements of VEON Ltd. (‘the Company’) give a true and fair view of the financial position of 
the Company as at 31 December 2020 and of its result for the year then ended in accordance with Part 9 of Book 2 of 
the Dutch Civil Code.

What we have audited
We have audited the accompanying financial statements 2020 of VEON Ltd., Bermuda. The financial statements include the 
consolidated financial statements of the Group and the company financial statements.

The consolidated financial statements comprise:
•
•

the consolidated statement of financial position as at 31 December 2020;
the following statements for 2020: the consolidated income statement, the consolidated statements of comprehensive 
income, changes in equity and cash flows; and
the notes, comprising the significant accounting policies and other explanatory information.

•

The Company financial statements comprise:
•
•
•

the company statement of financial position as at 31 December 2020;
the company income statement for the year then ended;
the notes, comprising the accounting policies applied and other explanatory information. 

The financial reporting framework applied in the preparation of the financial statements is EU-IFRS and the relevant 
provisions of Part 9 of Book 2 of the Dutch Civil Code for the consolidated financial statements and Part 9 of Book 2 of the 
Dutch Civil Code for the company financial statements.

The basis for our opinion
We conducted our audit in accordance with Dutch law, including the Dutch Standards on Auditing. We have further described 
our responsibilities under those standards in the section ‘Our responsibilities for the audit of the financial statements’ of our 
report.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Independence
We are independent of VEON Ltd. in accordance with the European Union Regulation on specific requirements regarding 
statutory audit of public-interest entities, the ‘Wet toezicht accountantsorganisaties’ (Wta, Audit firms supervision act), the 
‘Verordening inzake de onafhankelijkheid van accountants bij assuranceopdrachten’ (ViO, Code of Ethics for Professional 
Accountants, a regulation with respect to independence) and other relevant independence requirements in the Netherlands. 
Furthermore, we have complied with the ‘Verordening gedrags- en beroepsregels accountants’ (VGBA, Dutch Code of 
Ethics).

VEON Ltd I Independent auditor’s report 

        188

 
            
 
 
 
 
 
 
 
Our audit approach
Overview and context
VEON Ltd. is a telecommunications company providing voice and data services through a range of traditional and 
broadband mobile and fixed-line technologies in various countries throughout the world. The Group is comprised of several 
components and therefore we considered our Group audit scope and approach as set out in the section ‘The scope of our 
Group audit.’ We paid specific attention to the areas of focus driven by the operations of the Group, as set out below.

As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial 
statements. In particular, we considered where management made important judgements, for example, in respect of 
significant accounting estimates that involved making assumptions and considering future events that are inherently 
uncertain. In Note 24 of the consolidated financial statements, the Company describes the areas of judgement in applying 
accounting policies and the key sources of estimation uncertainty. Of these we considered, given the significant estimation 
uncertainty and the related higher inherent risks of material misstatement, the valuation of goodwill and the valuation of 
‘uncertain income tax positions’ and ‘non-income tax provisions’ to be key audit matters as set out in the section ‘Key audit 
matters’ of this report.

The Group operates in countries which pose elevated risks of non-compliance with anti-bribery and corruption laws and 
regulations. Due to this increased risk of non-compliance, we dedicated significant time and resources during our audit to 
this area and have therefore identified it as a key audit matter.

Furthermore, we spent significant time and resources to audit revenue recognition, which required us to ascertain the 
reliability of the systems and related controls in view of the existence of various legacy revenue systems throughout the 
Group. Consequently, we considered this to be a key audit matter.

The key audit matters referenced above are further explained in the section ‘Key audit matters’ of this report. 

As in all of our audits, we also addressed the risk of management override of controls, including evaluating whether there 
was evidence of bias by management that may represent a risk of material misstatement due to fraud.

We ensured that the audit teams at both Group and component level included the appropriate skills and competences which 
are needed for the audit of a telecommunications company operating in a global environment, including activities in emerging 
economies. We therefore included experts and specialists in the areas of, amongst others, IT, tax, treasury, forensics and 
valuations in our team.

The outline of our audit approach was as follows:

Materiality
•

Overall materiality: USD 86 million

Audit scope
•

We conducted audit work at the corporate headquarters in the 
Netherlands and at significant subsidiaries of the Group in 
Russia, Pakistan, Algeria, Ukraine, Bangladesh and Uzbekistan.
Virtual site visits were conducted with the component auditors of 
the six significant subsidiaries.
Audit coverage: 92% of consolidated Adjusted EBITDA, 92% of 
consolidated revenue and 92% of consolidated total assets.

Key audit matters
•
•

Valuation of goodwill
Valuation of ‘uncertain income tax positions’ and ‘valuation of 
non-income tax provisions’
Compliance with anti-bribery and corruption laws and 
regulations
Revenue recognition

•

•

•

•

VEON Ltd I Independent auditor’s report 

        189

 
 
 
 
 
            
 
 
 
 
 
 
 
Materiality
The scope of our audit is influenced by the application of materiality, which is further explained in the section ‘Our 
responsibilities for the audit of the financial statements’.

Based on our professional judgement, we determined certain quantitative thresholds for materiality, including the overall 
materiality for the financial statements as a whole as set out in the table below. These, together with qualitative 
considerations, helped us to determine the nature, timing and extent of our audit procedures on the individual financial 
statement line items and disclosures and to evaluate the effect of identified misstatements, both individually and in 
aggregate, on the financial statements as a whole and on our opinion.

Overall Group 
materiality

USD 86 million (2019: USD 90 million).

Basis for determining 
materiality

We used our professional judgement to determine overall materiality. As a basis 
for our judgement, we used 2,5% of Adjusted EBITDA.

As disclosed in Note 2 of the consolidated financial statements, Adjusted EBITDA 
is defined by the Company as profit/(loss) from continuing operations before 
interest, tax, depreciation, amortization and impairment (loss)/reversal, gain/(loss) 
on disposals of non-current assets, gain/(loss) on disposal of subsidiaries, other 
non-operating gains/(loss), net foreign exchange gain/(loss) and share of profit/
(loss) of joint ventures and associates.

We used Adjusted EBITDA as the primary benchmark based on our analysis of the 
common information needs of users of the financial statements. Adjusted EBITDA 
is predominantly used by the Company’s equity and debt holders to assess the 
financial performance of the Group, given the volatility of the Company’s profit 
before taxes. On this basis, we believe that Adjusted EBITDA is an important 
metric for the financial performance of the Company and, as such, an appropriate 
materiality benchmark.

To each component in our audit scope, we, based on our judgement, allocate 
materiality that is less than our overall Group materiality. The range of materiality 
allocated across components was between USD 15 million and USD 60 million.

Rationale for benchmark 
applied

Component materiality

We also take misstatements and/or possible misstatements into account that, in our judgement, are material for qualitative 
reasons.

We agreed with the Audit and Risk Committee of the Board of Directors that we would report to them misstatements 
identified during our audit above USD 4,3 million (2019: USD 4,5 million) as well as misstatements below that amount that, in 
our view, warranted reporting for qualitative reasons.

The scope of our Group audit
VEON Ltd. is the parent company of a group of entities. The financial information of this group is included in the consolidated 
financial statements of VEON Ltd.

We tailored the scope of our audit to ensure that we, in aggregate, provide sufficient coverage of the financial statements for 
us to be able to give an opinion on the financial statements as a whole, taking into account the management structure of the 
Group, the nature of operations of its components, the accounting processes and controls, and the markets in which the 
components of the Group operate. In establishing the overall Group audit strategy and plan, we determined the type of work 
required to be performed at component level by the Group engagement team in the Netherlands and by each component 
auditor.

Of the VEON Ltd. Group operating locations, as disclosed in Note 2 of the consolidated financial statements, the Group audit 
primarily focused on the significant components in Russia, Pakistan, Algeria, Ukraine, Bangladesh, and Uzbekistan. For 
these components, certain consolidated processes and significant or higher risk areas, notably the valuation of goodwill and 
compliance with anti-bribery and corruption laws and regulations, are processes included at the corporate headquarters in 
the Netherlands and are therefore in the audit scope of the Group engagement team.

We subjected the Russia, Pakistan, and Ukraine components to audits of their complete financial information, as those 
components are individually financially significant to the Group. We further subjected the Algeria, Bangladesh, and 
Uzbekistan components to audits of their complete financial information as they include significant or higher risk areas, 
notably in the areas of revenue recognition and compliance with anti-bribery and corruption laws and regulations. To obtain 
sufficient audit coverage based on our professional judgement, the corporate headquarters and certain non-significant 
components were also selected for specific audit procedures.

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The Company engages various service organizations in its revenue and treasury processes, which are material to the 
financial statements. Audit work on the IT General Controls of these service organizations has been performed by their 
independent auditors who have prepared reports in accordance with ISAE 3402 ‘Assurance Reports on Controls at a Service 
Organization’. We assessed the objectivity and competence of the independent auditors of the service organizations and 
reviewed the assurance reports that include the scope and results of the assurance procedures performed. We concluded 
that we could rely on the assurance reports issued by the independent auditors of the service organizations in combination 
with our own testing of complementary user entity controls.

In total, in performing these procedures, we achieved the following coverage on the financial line items:

Adjusted EBITDA

Revenue

Total assets

92%

92%

92%

None of the remaining components represented more than 7% of total consolidated Adjusted EBITDA, 6% of total 
consolidated revenue or 3% of total consolidated assets. For the remaining components, we performed, amongst other 
things, analytical procedures to corroborate our assessment that there were no significant risks of material misstatements 
within those components.

The Group engagement team performed the audit work for the corporate headquarters in the Netherlands. For all 
components in the scope of the Group audit, we used component auditors who are familiar with the local laws and 
regulations to perform the audit work.

Where component auditors performed the work, we determined the level of involvement we needed to have in their audit 
work to be able to conclude whether we had obtained sufficient and appropriate audit evidence as a basis for our opinion on 
the consolidated financial statements as a whole.

We issued instructions to the component audit teams in our audit scope. These instructions included, amongst others, our 
risk analysis, materiality and scope of the work. We explained to the component audit teams the structure of the Group, the 
main developments that are relevant for the component auditors, the risks identified, the materiality levels to be applied and 
our global audit approach. We had individual calls with each of the component audit teams during the year and upon 
conclusion of their work. During these calls, we discussed any significant accounting and audit issues identified by the 
component auditors, their reports, the findings of their procedures and other matters, which could be of relevance for the 
consolidated financial statements.

The Group engagement team typically visits the component auditors of Russia, Pakistan, Algeria, Ukraine, Bangladesh and 
Uzbekistan. Due to circumstances surrounding COVID-19 in the current year, various travel restrictions were imposed 
worldwide. As such, the Group engagement team performed virtual site reviews for each of these locations, which included 
our review of selected working papers of the component auditors. We frequently met virtually with the component teams and 
local management throughout the year to ensure sufficient oversight. The component audit teams also participated virtually 
in the audit planning workshop hosted by the Group engagement team.

The Group engagement team performed the audit work at the corporate headquarters on the Group consolidation, financial 
statement disclosures and a number of complex audit and accounting items. These included, amongst others, goodwill 
impairment assessment and the assessment and follow-up of the claims from the whistle-blower allegations and the other 
cases monitored at the corporate headquarters.

By performing the procedures above at components, combined with additional procedures at Group level, we have been 
able to obtain sufficient and appropriate audit evidence on the Group’s financial information, as a whole, to provide a basis 
for our opinion on the financial statements.

Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in the audit of the financial 
statements. We have communicated the key audit matters to the Audit and Risk Committee of the Board of Directors. The 
key audit matters are not a comprehensive reflection of all matters identified by our audit and that we discussed. In this 
section, we described the key audit matters and included a summary of the audit procedures we performed on those 
matters.

In comparison to the previous year, the key audit matters are similar in nature to those reported in 2019 and are inherent to 
the nature of the Company’s business and its operations.

We addressed the key audit matters in the context of our audit of the financial statements as a whole and in forming our 
opinion thereon. We do not provide separate opinions on these matters or on specific elements of the financial statements. 
Any comment or observation we made on the results of our procedures should be read in this context.

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Key audit matter

Our audit work and observations

Valuation of goodwill
Notes 10 and 12

As described in Notes 10 and 12 to the consolidated 
financial statements, the Company’s consolidated 
goodwill balance amounts to USD 2,682 million at 
December 31, 2020. The Company conducts an 
annual goodwill impairment test as of September 30, 
or when circumstances indicate that the carrying 
value of goodwill may be impaired. During the annual 
goodwill impairment test in the current year, the 
Company concluded USD 723 million of goodwill 
impairment charges were to be recorded for the 
cash-generating unit (‘CGU’) Russia. 

Management further performed a subsequent 
triggering events analysis as of 31 December 2020 
and determined that no additional goodwill 
impairment should be recorded. 

Potential impairment is identified by comparing the 
recoverable value, in particular the fair value less 
cost of disposal, of a CGU to the carrying value. 

Fair value is estimated by management using a 
discounted cash flow model, based on cash flow 
projections from business plans prepared by 
management. In estimating the fair value of the cash-
generating units, management uses assumptions 
relating to the discount rate as well as the projected 
revenue growth rate, projected operating margin, 
projected capital expenditure, and the related 
terminal rates. The Company’s assumptions are 
affected by expected future market conditions and 
the continuing challenging economic and political 
environments in the territories where the Company’s 
subsidiaries operate and which are inherently 
uncertain.

The focuses of our audit effort were the Russia CGU, 
given the USD 723 million impairment recognized in 
the current year, and the Algeria CGU, due to the 
limited headroom of USD 75 million calculated in the 
annual goodwill impairment test. The amount of 
goodwill associated with the Russian and Algerian 
CGUs as of 31 December 2020 was USD 1,131 
million and USD 1,053 million, respectively.

We considered this area to be a key audit matter due 
to the magnitude of the goodwill balance as well as 
the fact that the determination of the fair value less 
cost of disposal is complex, subjective, and, given the 
estimation uncertainty, requires substantial 
judgement from management.

In the context of the annual goodwill impairment test, 
we have performed procedures, with the help of our 
valuation specialists, which varied in depth per CGU 
based on our risk assessment with respect to the 
volatility of the economic circumstances, the extent of 
the related goodwill balance as compared to our 
materiality used and the headroom available between 
the carrying value and the fair value less costs to 
dispose. We paid particular focus to the Russian 
CGU with goodwill impaired in the current year, as 
well as the Algerian CGU where limited headroom 
was available. Our audit procedures included, 
amongst others:

•

•

•

•

•

•

•

Assessing the appropriateness of management’s 
identification of the Company’s CGUs.
Evaluating the design and testing the operational 
effectiveness of the related internal controls, 
including the completeness, accuracy, and 
relevance of underlying data used in the models.
Performing a retrospective review of the prior 
year estimates by comparing the current year 
actual results to those projected in the prior year.
Testing the composition of future cash flow 
forecasts by evaluating (i) the current and past 
performance of the CGUs, (ii) the consistency 
with external market and industry data, and (iii) 
the corroboration of strategic initiatives with 
evidence obtained in other areas of the audit. 
Specific attention was given to the Russia and 
Algeria CGUs’ valuation of strategic initiatives 
and whether such initiatives could be 
corroborated from a market participant’s 
perspective and the impact of the 
macroeconomic environments in Russia and 
Algeria on the business plan.
Assessing any indications of management bias 
in determining the significant assumptions.
Recalculating the carrying values and confirming 
the exchange rates applied. 
Assessing the adequacy of the Company’s 
disclosures regarding assumptions, sensitivities 
and headroom as included in the accounting 
policies and in Note 10 to the financial 
statements.

Our procedures did not result in material findings with 
respect to the goodwill impairment assessment at 
31 December 2020 nor the respective disclosures in 
the financial statements.

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Key audit matter

Our audit work and observations

Valuation of ‘uncertain income tax positions’ and 
‘non-income tax provisions’
Notes 7 and 8

With the assistance of our tax specialists, we have 
performed the following procedures, amongst others:

As described in Notes 7 and 8 to the consolidated 
financial statements, the Company recorded 
provisions of USD 155 million related to uncertain 
income tax positions and USD 86 million related to 
non-income tax provisions at December 31, 2020. 
Given that the tax legislation in the markets in which 
the Company operates is unpredictable and gives 
rise to significant uncertainties, the Company’s 
estimate of tax liabilities may differ from 
interpretations by the relevant tax authorities as to 
how regulations should be applied to actual 
transactions. Judgement is therefore required by 
management to determine whether it is probable that 
an uncertain income tax position will not be sustained 
and to estimate the amounts in the range of most 
likely outcomes. Judgement is also required by 
management in determining the degree of probability 
of an unfavourable outcome for non-income tax 
claims and the ability of management to make a 
reasonable estimate of the amount of loss.

We believe the valuation of ‘uncertain income tax 
positions’ and ‘non-income tax provisions’ to be a key 
audit matter based on the significant judgements 
made by management when assessing the likelihood 
of an uncertain income tax treatment being accepted 
by a tax authority and estimating the effect of the 
uncertainty, as well as assessing the degree of 
probability of an unfavourable non-income tax 
outcome and the ability to make a reasonable 
estimate of the amount of cash outflow. This in turn 
required significant auditor attention and effort in 
performing procedures to evaluate management’s 
estimation uncertainty. 

•

•

•

•

•

•

•

•

Evaluating the design and testing the operational 
effectiveness of controls relating to ‘uncertain 
income tax positions’ and ‘non-income tax 
provisions’.
Evaluating management’s assessment of both 
the identification and possible outcomes of each 
‘uncertain income tax position’ and ‘non-income 
tax provision’, including management’s 
assessment of the technical merits of each 
claim.
Testing the valuation of the Group’s uncertain 
income tax positions, including evaluating the 
reasonableness of management’s assessment 
of whether tax positions are probable of being 
sustained and management’s estimate of the 
effect of the uncertainty based on the application 
of relevant tax laws.
Testing the valuation of the Group’s non-income 
tax provisions, including evaluating the 
reasonableness of management’s assessment 
of the probability of an unfavourable outcome of 
the non-income tax positions and the 
reasonableness of the estimated amount of loss 
based on the application of relevant tax laws.
Validating the information used in the calculation 
of the liability for ‘uncertain income tax positions’ 
and ‘non-income tax provisions’, including 
evaluating correspondence with tax authorities, 
together with the status and results of any tax 
audits, and assessing the outcomes of court 
decisions for industry-wide issues.
Evaluating management’s assessment of any 
interest and penalties associated with the tax 
claims.
Obtaining tax and legal letters from the Group’s 
external tax and legal advisors and reconciling 
these to the positions taken.
Assessing the adequacy of the Group’s 
disclosures.

Our procedures did not result in material findings with 
respect to the positions at 31 December 2020 nor the 
respective disclosures in the financial statements.

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Key audit matter

Our audit work and observations

Compliance with anti-bribery and corruption laws 
and regulations
Note 7

With the assistance of our forensic specialists, we 
have performed the following procedures, amongst 
others:

As described by the Company in Note 7 to the 
consolidated financial statements and the 
accompanying Directors’ Report, the Group operates 
in markets which pose increased risks of non-
compliance with anti-bribery and corruption laws and 
regulations.   As such, there is a heightened risk of 
potential liability associated with such non-
compliance. We dedicated a significant amount of 
time in our audit to this increased risk and therefore 
have also determined this to be a key audit matter.  

•

•

•

•

•

•

•

•
•

•

•

Understanding the local and international laws 
and applicable industry regulations governing 
the Group.
Understanding and evaluating the Group’s 
interactions and communication with 
government officials.
Assessing the adequacy of the Group policies 
and procedures addressing the risk of non-
compliance with anti-bribery and corruption laws 
and regulations.
Testing the effectiveness of controls which 
respond to the risk of non-compliance with anti-
bribery and corruption laws and regulations, 
which include code of conduct compliance, 
response to whistleblower allegations, vendor 
due diligence, and employee access rights.
Assessing any non-compliance with anti-bribery 
and corruption laws and regulations within 
significant, unusual, or related party 
transactions.
Assessing charitable contributions and 
donations to government officials. 
Evaluating actions undertaken by management 
upon identification of potential instances of 
bribery or corruption. Our procedures included 
the use of forensic expertise and testing of 
selected investigations, including assessing and 
challenging management’s investigatory 
response to actual or suspected instances of 
fraud to support conclusions reached and 
remedial actions taken.
Obtaining external legal confirmations.
Reading the minutes of the Board of Directors 
and the other executive committee meetings.
Attending discussions in the Audit and Risk 
Committee on the results of internal and external 
investigations and on the design and 
effectiveness of the Company’s compliance 
programs and internal controls relating to the 
prevention and detection of bribery and 
corruption.
Assessing the adequacy of the Company’s 
disclosures.

Our procedures did not result in material findings with 
respect to compliance with anti-bribery and corruption 
laws and regulations or the respective disclosures in 
the financial statements.

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Key audit matter

Revenue recognition
Note 3

As described in Note 3 to the consolidated financial 
statements, the Company’s consolidated revenue 
balance was USD 7,980 million at December 31, 
2020 and is made up of billions of relatively small 
transactions in combination with multiple tariff plans, 
with the largest volume of plans in Russia. 
Throughout the Group, there is a large number and 
wide variety of legacy billing and other operating 
support systems in the revenue process that result in 
an increased risk of revenue recognition.

The magnitude of revenue and complexity in the 
recognition processes arising from a variety of legacy 
systems with IT control deficiencies requires 
substantial audit effort with respect to the design, 
implementation, and operating effectiveness of 
mitigating controls and substantive test procedures to 
be performed. Therefore, we considered this a key 
audit matter.

Our audit work and observations

With the assistance of our IT specialists, we have 
performed the following procedures, amongst others:

•

•

•

•

•

•

•

Understanding and testing the IT environment in 
which billing, rating and other relevant support 
systems reside, including the change 
management and restricted access procedures 
in place. 
Testing the design and operational effectiveness 
of the revenue and receivables cycle related 
controls. 
Testing the end-to-end reconciliation from 
mediation to billing and rating systems to the 
general ledger. The testing also included tracing 
material journals, between the billing or 
intelligent network systems and the general 
ledger, to underlying documentation and 
confirming the rationale.
Reconciling the amounts of vouchers and other 
top-up transactions with respect to prepaid 
services to the transactional cash receipts data 
per the cash system. 
Performing tests on the accuracy of customer bill 
generation and testing of a sample of the credits 
and discounts applied to customer bills. 
Performing test calls and reconciling these with 
the billed amounts; and
Testing cash receipts for a sample of customers 
back to the customer invoice.

Our procedures did not result in material findings with 
respect to the revenues recorded for the year 2020 
nor the respective disclosures in the financial 
statements.

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Report on the other information included in the annual report

In addition to the financial statements and our auditor’s report thereon, the annual report contains other information that 
consists of:
•
•

the directors’ report;
the other information pursuant to Part 9 of Book 2 of the Dutch Civil Code;

Based on the procedures performed as set out below, we conclude that the other information:
•
•

is consistent with the financial statements and does not contain material misstatements;
contains the information that is required by Part 9 of Book 2 of the Dutch Civil Code.

We have read the other information. Based on our knowledge and understanding obtained in our audit of the financial 
statements or otherwise, we have considered whether the other information contains material misstatements.

By performing our procedures, we comply with the requirements of Part 9 of Book 2 of the Dutch Civil Code and the Dutch 
Standard 720. The scope of such procedures was substantially less than the scope of those performed in our audit of the 
financial statements.

Management is responsible for the preparation of the other information, including the directors’ report and the other 
information in accordance with Part 9 of Book 2 of the Dutch Civil Code.

Report on other legal and regulatory requirements

Our appointment
We were appointed as auditors of VEON Ltd. on 28 July 2014 by the board of directors following the passing of a resolution 
by the shareholders at the annual meeting held on 28 July 2014. Our appointment has been renewed annually by 
shareholders representing a total period of uninterrupted engagement appointment of seven years.

No prohibited non-audit services
To the best of our knowledge and belief, we have not provided prohibited non-audit services as referred to in Article 5(1) of 
the European Regulation on specific requirements regarding statutory audit of public-interest entities.

Services rendered
The services, in addition to the audit, that we have provided to the Company and its controlled entities, for the period to 
which our statutory audit relates, are disclosed in Note 16 to the Company financial statements.

Responsibilities for the financial statements and the audit

Responsibilities of management and the board of directors for the financial statements
Management is responsible for:
•

the preparation and fair presentation of the financial statements in accordance with EU-IFRS and with Part 9 of Book 
2 of the Dutch Civil Code; and for
such internal control as the board of directors determines is necessary to enable the preparation of the financial 
statements that are free from material misstatement, whether due to fraud or error.

•

As part of the preparation of the financial statements, management is responsible for assessing the Company’s ability to 
continue as a going concern. Based on the financial reporting frameworks mentioned, management should prepare the 
financial statements using the going-concern basis of accounting unless management either intends to liquidate the 
Company or to cease operations, or has no realistic alternative but to do so. Management should disclose events and 
circumstances that may cast significant doubt on the Company’s ability to continue as a going concern in the financial 
statements.

The board of directors is responsible for overseeing the Company’s financial reporting process.

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Our responsibilities for the audit of the financial statements
Our responsibility is to plan and perform an audit engagement in a manner that allows us to obtain sufficient and appropriate 
audit evidence to provide a basis for our opinion. Our objectives are to obtain reasonable assurance about whether the 
financial statements as a whole are free from material misstatement, whether due to fraud or error and to issue an auditor’s 
report that includes our opinion. Reasonable assurance is a high but not absolute level of assurance, which makes it 
possible that we may not detect all material misstatements. Misstatements may arise due to fraud or error. They are 
considered to be material if, individually or in the aggregate, they could reasonably be expected to influence the economic 
decisions of users taken on the basis of the financial statements.

Materiality affects the nature, timing and extent of our audit procedures and the evaluation of the effect of identified 
misstatements on our opinion.

A more detailed description of our responsibilities is set out in the appendix to our report.

Amsterdam, the Netherlands, 15 March 2021
PricewaterhouseCoopers Accountants N.V.

W.J. van der Molen RA

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Appendix to our auditor’s report on the financial statements 2020 of VEON 
Ltd.

In addition to what is included in our auditor’s report, we have further set out in this appendix our responsibilities 
for the audit of the financial statements and explained what an audit involves.

The auditor’s responsibilities for the audit of the financial statements
We have exercised professional judgement and have maintained professional scepticism throughout the audit in 
accordance with Dutch Standards on Auditing, ethical requirements and independence requirements. Our audit 
consisted, amongst other things, of the following:
•

Identifying and assessing the risks of material misstatement of the financial statements, whether due to 
fraud or error, designing and performing audit procedures responsive to those risks, and obtaining audit 
evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a 
material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve 
collusion, forgery, intentional omissions, misrepresentations, or the intentional override of internal control.
Obtaining an understanding of internal control relevant to the audit in order to design audit procedures 
that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the 
effectiveness of the Company’s internal control.
Evaluating the appropriateness of accounting policies used and the reasonableness of accounting 
estimates and related disclosures made by management.
Concluding on the appropriateness of management’s use of the going-concern basis of accounting, and 
based on the audit evidence obtained, concluding whether a material uncertainty exists related to events 
and/or conditions that may cast significant doubt on the Company’s ability to continue as a going concern. 
If we conclude that a material uncertainty exists, we are required to draw attention in our auditor’s report 
to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our 
opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor’s report 
and are made in the context of our opinion on the financial statements as a whole. However, future events 
or conditions may cause the Company to cease to continue as a going concern.
Evaluating the overall presentation, structure and content of the financial statements, including the 
disclosures, and evaluating whether the financial statements represent the underlying transactions and 
events in a manner that achieves fair presentation.

•

•

•

•

Considering our ultimate responsibility for the opinion on the consolidated financial statements, we are 
responsible for the direction, supervision and performance of the Group audit. In this context, we have 
determined the nature and extent of the audit procedures for components of the Group to ensure that we 
performed enough work to be able to give an opinion on the financial statements as a whole. Determining 
factors are the geographic structure of the Group, the significance and/or risk profile of Group entities or 
activities, the accounting processes and controls, and the industry in which the Group operates. On this basis, 
we selected Group entities for which an audit or review of financial information or specific balances was 
considered necessary.

We communicate with the board of directors regarding, amongst other matters, the planned scope and timing of 
the audit and significant audit findings, including any significant deficiencies in internal control that we identify 
during our audit. In this respect, we also issue an additional report to the Audit and Risk Committee in 
accordance with Article 11 of the EU Regulation on specific requirements regarding statutory audit of public-
interest entities. The information included in this additional report is consistent with our audit opinion in this 
auditor’s report.

We provide the board of directors with a statement that we have complied with relevant ethical requirements 
regarding independence, and to communicate with them all relationships and other matters that may reasonably 
be thought to bear on our independence, and where applicable, related safeguards.

From the matters communicated with the board of directors, we determine those matters that were of most 
significance in the audit of the financial statements of the current period and are therefore the key audit matters. 
We describe these matters in our auditor’s report unless law or regulation precludes public disclosure about the 
matter or when, in extremely rare circumstances, not communicating the matter is in the public interest.

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