Outcomes of Telenor’s internal learning process from the Myanmar engagement

Telenor came to Myanmar with a purpose: To connect the people of Myanmar with each other – and the world. Built on Telenor Group’s more than 20 years of experience from operating in Asia, Telenor Myanmar became a leader in responsible business and lived its purpose of empowering societies and connecting customers to what matters most to them. Eight years later, Telenor was forced to exit.

Telenor was one of two international companies who won a telecom license in Myanmar in 2013. In September 2014, Telenor Myanmar launched commercial operations with a promise to make mobile communication accessible and affordable for all. The company expanded its coverage of voice and data services to reach more than 18 million people across the country covering 92% of the population.

The growth of Myanmar's telecom sector and the wider economy following the liberalization of the sector in 2014 points to the transformative effect connectivity can have on society, underpinned by innovation and major investments mobile operators continue to make. From 2013-2018, Telenor’s operations and investments in Myanmar added between 877 and 1,272 million USD yearly in economic value to Myanmar’s economy, according to a Frontier Economics report commissioned by Telenor.

In parallel to building a modern, efficient telecom network, Telenor Myanmar focused on employee development and solid governance principles. The team also focused on raising standards in the vast supply chain, contributed to social impact through programs focused on child online safety, use of technology to support birth and death registrations and worked extensively with civil society organisations.

On Monday 1 February 2021, a state of emergency was declared under military leadership in Myanmar. The conflict between different parties plunged the country into a civil-war like conflict, where the hardships suffered by the people of Myanmar were compounded by an escalating COVID-19 crisis and a deep economic recession.

The following period was extremely challenging for Telenor, its employees, customers and the Myanmar society as a whole. The challenges faced as a private company and a telecommunications operator were unprecedented, with dilemmas related to the safety and security of our employees, human rights concerns across the Myanmar society, and a legal and regulatory environment that no international guidelines or best practices have fully captured.

Immediately after the coup, Telenor set out clear principles for managing the crisis that followed the military takeover. An important principle was that no employee should have to sacrifice their life or health – the employee safety was always put first. Another important principle was that customers' safety had to be ensured. A third principle was that Telenor would run its operations based on good morals, ethics and integrity. On top of this, laws and regulations in the markets in which the company operated, Norwegian and international, had to be complied with.

As martial law was imposed, mobile sites were mined and armed military entered Telenor Myanmar’s offices to ensure compliance with its orders, it became clear that the above mentioned principles stood against each other and not all of them could be fully adhered to.

It became impossible to be a telecom operator in Myanmar and uphold international standards and safeguard customers' rights under such circumstances. Many advocated for Telenor to delete historical customer data, which was stored partly digitally and partly on physical hard drives in locations covered by martial law. Deleting data of this magnitude would have been time-consuming, likely to be detected while being carried out and the data would be recoverable. A more significant risk to customers was in Telenor’s view the increasing risk of forced activation of intercept equipment that would have allowed live surveillance of customers by the military. The intercept equipment was not turned on in Telenor Myanmar, but if employees had been threatened, it would likely have been. In the end, a sale was considered the least detrimental option for employees, customers and the wider Myanmar society.

The lessons learned contained in this document have led to specific and tangible improvements in Telenor’s internal policies and methods for handling human rights risks and crises. At the same time, the company hopes that these experiences can contribute to improving knowledge, guidelines and best practices for civil society organisations and other companies in similar situations.

For more information about Telenor’s engagement in Myanmar, see our Myanmar hub on Telenor.com

Mandate, purpose and method of lessons learned process

Mandate:

To facilitate and participate in an evaluation related to Telenor’s sale of Telenor Myanmar Limited (TML) and exit from Myanmar, including relevant circumstances leading up to the coup.

Purpose:

To identify potential learning points for the Telenor Group with respect to key decisions made and the process that led up to such decisions, including:

1. Organisation of decision-making processes

2. Adequacy of governance and organisation

3. The availability of sufficient information for decision-making and risk assessments

4. The adequacy of systems and processes in place to handle the crisis situation

Method:

The evaluation process has been based on information received from a number of workshops with relevant individuals involved at various stages of Telenor’s operations in Myanmar. .

The workshops have focused on key events/decisions in the following four segments:

1. Pre-coup (autumn 2020 to 31 January 2021)

2. From the coup to the announced sale of TML (1 February 2021 to 8 July 2021)

3. From the announced sale of TML until closing of the transaction (8 July 2021 to 25 March 2022)

4. Post-closing of the transaction (25 March 2022 to end of June 2022)

Seven workshops have been conducted, one for each of the four segments above, as well as one workshop for the Project Yangon Steering Committee and two summary workshops for participants that were unable to attend any of the four "segment" workshops.

Procedural aspects of the lessons learned process

• Genuine effort on the part of Telenor to learn valuable lessons from those most closely involved in the Myanmar operations.

• Not an internal investigation.

• Voluntary attendance, but participation encouraged.

• Chatham House Rule: participants encouraged to contribute with information openly and truthfully.

• Use of information: Telenor is free to use all information from the workshops, but this will be anonymised and will not be attributable to specific individuals.

• Final overview of lessons learned to be made public.

All participants have been given the opportunity to review and comment on draft summaries at the end of each workshop.

Wikborg Rein's high-level impressions of Telenor’s Myanmar crisis management process based on workshop inputs

Based on our participation in the workshops, our clear impression is that there was broad consensus that the outcome of the crisis-handling – Telenor’s orderly exit from Myanmar through an M&A process – was the best possible outcome in the circumstances. We did not hear any views expressing dissent around the end outcome for Telenor.

Notwithstanding some criticism and dissenting views, the general impression is of minimal conflict and well-functioning collaborations, both within and between different teams.

There is greater divergence of views as regards the quality of some of the internal processes that formed part of the crisis management process, most notably how Telenor handled internal information sharing and stakeholder dialogue with a specific sub-set of external stakeholders.

There was widespread internal alignment on the need to work proactively to find a solution to Telenor's exit from Myanmar. Intra-Group collaboration was facilitated by a strong fundament of unity around Telenor's core values and principles. Individuals involved in the crisis management process were dedicated and focused on making the best of a challenging situation.

Overall, Telenor’s crisis management framework functioned well in the event, although this should be viewed in the context of the successful outcome (i.e., Telenor's successful exit), bearing in mind that additional issues could have been revealed in the event of a less successful outcome.

Lesson #1 – New risk-based approach to crisis management: The risk-based crisis management process adopted by the Steering Committee – which involved defining priorities based on risk, with quality assurance from external and internal contributors – was highly successful and should be followed in future crisis situations. The early identification of people safety as a key priority governing crisis management is an example of this approach being successfully applied in practice.

Context: From the outset, the Steering Committee based its decision-making on a holistic and continuously updated risk assessment, grounded in input from all relevant internal functions, as well as external experts. This ensured an effective and well-reasoned decision-making process based on a wide appreciation of relevant risks, which was carried through all the way up to the Telenor ASA Board.

Lesson #2 – Crisis preparedness: Telenor’s standard processes for entering new markets could usefully include discussions around business continuity (including putting in place evacuation protocols) and considerations relating to a responsible exit. Such discussions might subsequently facilitate prompt decision-making during a crisis.

Context: There seems to have been limited pre-crisis focus on potential exit options and staff evacuation scenarios. Although the extent to which this would have made a difference in practice is not clear, responsible exit considerations are fast becoming part of best practice principles expected of large organisations such as Telenor and could usefully be embedded in the organisation.

Lesson #3 – Internal information flows: In a future crisis, more consideration should be given to ensuring that top management representatives with functional responsibility communicate more effectively to their respective expert level reports to foster understanding of and trust in the decision-making process among all contributors.

Context: Capacity and confidentiality constraints limited the flow of information from the top down, resulting in a lack of understanding of, and, for some, a lack of faith in, the crisis decision-making process. This lack of understanding/faith seems, however, to have been based on incomplete insight into the decision-making process, as all relevant expert functions were represented at Steering Committee level. It could likely have been remedied through more effective communication about the well-informed, risk-based nature of the decision-making processes of the Steering Committee and Telenor ASA Board.

Lesson #4 – NGO/CSO stakeholder dialogue: In a situation where stakeholder dialogue with and transparency towards NGOs and other civil society organisations (CSOs) are tempered by confidentiality constraints, Telenor should strive to share as much information as possible with teams responsible for dialogue with such stakeholders (this also applies to other stakeholders where information could end up in the public domain). This may equip relevant teams with the tools to engage in a more nuanced dialogue, with the aim of mitigating the risk that NGO/CSO stakeholders perceive Telenor's communications as deliberately misleading. This lesson does not apply to dialogue with other stakeholders, which generally appears to have been well received.

Context: There is widespread sentiment within certain teams that a lack of internal information sharing resulted in misunderstandings and miscommunications in dialogue with NGO/CSO stakeholders, with ensuing negative consequences for Telenor’s reputation and standing. In contrast, communication with various other stakeholders, such as public authorities, politicians and Telenor's owners, seem to have been successful.

Lesson #5 – Human rights risk assessment: When conducting human rights and sustainability risk assessments within the context of a wider risk assessment (e.g., in a crisis), such assessments should be documented as standalone so that they can more easily be shared with specific external stakeholders such as NGOs, which tend to focus more singularly on human rights and sustainability considerations.

Context: Although Telenor conducted a holistic (360) risk assessment, including human rights impact assessments and sustainability assessments, in connection with its various options for exiting Myanmar, these assessments were intertwined with internal communications and other considerations and sharing externally would have resulted in increased people security risks. This resulted in a perception – and subsequent criticism of Telenor – among some stakeholders that Telenor had not conducted a human rights risk assessment in connection with the sale.

Lesson #6 – Crisis management procedures: Telenor's risk-based crisis management approach departed from existing written procedures, but worked well and would be adaptable in future crisis situations. Existing procedural documents for crisis management should be updated to reflect this new, dynamic approach.

Context: The coup revealed that Telenor's existing (pre-coup) crisis management procedures were not fully fit for purpose (i.e., were not especially useful in the context of the coup). In practice, this was alleviated by Telenor's dynamic approach to crisis management (as described in lesson # 1). Codifying this in writing can ensure a similarly adaptable approach becomes Telenor's new procedural norm for crisis management.