How Cellfie Mobile Built Trust, Training Uptake and Stronger Speak-Up Culture

Cellfie Mobile introduced a comprehensive Anti-Bribery and Corruption Policy in 2016. The policy establishes a zero-tolerance approach toward bribery and corruption and applies to all Cellfie personnel and authorized representatives. 

The policy clearly prohibits offering, promising, authorizing, paying or accepting bribes, directly or indirectly, and explicitly forbids engaging third parties to do so on the company’s behalf. It also reinforces compliance with all applicable local and international anti-corruption laws.

To mitigate risks associated with business courtesies, Cellfie Mobile established detailed rules governing gifts, hospitality and sponsorships. These include strict value thresholds, frequency limits and approval requirements, particularly for interactions involving government officials.

In practice, the company supports implementation through a gifts and hospitality platform tool and maintains appropriate tracking/registration requirements; the policy also makes clear that cash or cash equivalents are never acceptable as gifts or hospitality.

The policy assigns clear ownership to the Chief Ethics and Compliance Officer and requires ongoing review, testing and improvement of internal controls. Dedicated registers are maintained for gifts, hospitality, social investments, charitable contributions and commercial sponsorships, ensuring traceability and accountability. 

Beyond policy governance, Cellfie Mobile reinforced accountability by integrating ethics and compliance into company KPIs and introducing recognition mechanisms (e.g., a Compliance Excellence Award). The compliance function also uses an effectiveness cycle including annual employee surveys, monitoring and testing results, internal investigation learnings and annual risk assessment focus areas (“pulse checks”), with insights shared with senior management.

Cellfie Mobile strengthened its compliance program by building internal partnerships, particularly with their Human Resources function, to integrate ethics and compliance into the employee lifecycle and corporate culture. Joint training and awareness initiatives improved engagement and ensured consistent communication of ethical standards across the organization. 

To embed compliance in daily operations, the company introduced a “train-the-trainer” approach, enabling employees across functions to act as compliance supporters and provide peer guidance. This fostered shared ownership and made compliance more accessible and practical. 

By developing strong relationships and internal alliances, the Ethics & Compliance function has evolved from a perceived “watchdog” to a trusted partner, strengthening both employee engagement and the overall culture of integrity.

Recognizing that corruption risks can arise through intermediaries, Cellfie Mobile requires due diligence for authorized representatives and business partners and expects third parties to comply with the company’s Anti- Bribery and Corruption Policy and relevant standards. To support consistency, the compliance function uses a semi-automated third-party due diligence system that helps assess business partners and generate a risk rating, with final decisions remaining human-led. 

Any suspected violations must be reported promptly to the Ethics & Compliance Office, reinforcing shared responsibility across the value chain.

Cellfie Mobile reinforced internal reporting mechanisms by providing clear channels for employees and partners to raise concerns, including a speak-up line and dedicated email addresses; the company also captures concerns through exit interviews and uses employee survey feedback to strengthen trust in confidentiality and improve channel effectiveness. 

Violations of the policy may result in disciplinary action, including termination of employment, ensuring enforcement credibility. The compliance function also uses carefully crafted “lessons learned” communications after investigations to reinforce expectations while avoiding details that could identify individuals.

The Chief Executive Officer personally developed and introduced a Ways of Working document, alias Cellfie Style, to strengthen the company’s corporate employees in terms of the expected ways of ethical conduct, supported by clear “Dos and Don’ts”:

• “How to BE THE WINNER – to dream scary, speakup bravely, dive deep for actionable insights, learn to teach and own like a CEO;
• How to BUILD THE WINNING TEAM by believing in people’s transformation, role-modeling with actions, giving feedback openly and directly, knowing the team and them win;
• DELIVER WHAT MATTERS - Aim higher than the rest, ask the customer, trust the data, calibrate around objectives, and do not wait, act now!”

Build compliance as a trusted partner, not a “watchdog.” Trust and practical day-to-day guidance make employees more willing to ask for help early and share concerns.

Reinforce “tone at the middle” to make the training stick. Even with leadership support, middle managers can make or break participation when operational priorities compete with compliance deadlines.

Keep engagement human and interactive. Avoid “robotic” training—more practical, participatory formats and internal communication helped sustain attention and uptake.

Ensure adherence to “fit and proper” standards across the organization and value chain, beginning with the CEO and senior leadership, and embedded in hiring, onboarding, and third-party selection processes to promote values-based decision-making and accountability.