Ethics – Our approach

Vodafone’s success is underpinned by our strong commitment to ethical behaviour in the way we do business. We expect our employees to uphold the high standards set out in our Code of Conduct which also includes our Business Principles.

To meet these standards we must create a culture where employees understand what we require of them, recognise their responsibility to raise concerns, and have the confidence to do so. Our anti-bribery programme, supported by training and monitoring, is a particular focus.

Setting high standards

Our Code of Conduct, revised and updated in 2012/13, explains what is expected of everyone working for and with Vodafone including employees, contractors, subsidiaries, joint ventures and suppliers. It also sets out Vodafone’s responsibilities to our people, partners and shareholders.

Available in 14 languages, the Code requires people to act ethically, comply with legal requirements, apply our Business Principles and speak up if they suspect any breaches of the Code. The refreshed Code is designed to be a one stop shop for employees to find all the policies they need to understand and is clearly linked with working in the Vodafone Way (see Our people).


Employees across the Group receive regular communications, online refresher training, face-to-face sessions and team briefings on various aspects of our compliance programme, depending on their role.

A 15-minute online training course on the refreshed Code of Conduct was rolled out in our markets in 2012/13, using a series of scenarios to encourage employees to act in the Vodafone Way and direct them to the Code of Conduct for further information. We also introduced face-to-face training sessions for line managers on what the Code of Conduct means for them.

The Vodafone Code of Conduct

To raise awareness of the refreshed Code of Conduct, we released a video compilation of short messages from senior leaders across Vodafone about what the Code means to them.

Reporting concerns

All employees and contractors have a duty to report any breaches of our Code of Conduct, which is known as our ‘Speak Up’ policy. We have launched a global external reporting scheme which allows employees and contractors to report through a third party. This new process enables us to consolidate existing whistle blowing practice in local markets, increases visibility and ensures consistency of approach in responding to concerns raised from across the organisation. Concerns may be reported anonymously and the protection of innocent people is our priority at all times. People can identify themselves to our external partner using a PIN and receive feedback. Vodafone has a non-retaliation policy and will not take any action against anyone reporting a genuine concern, even if this is proven not to result in a breach of compliance.

Taking action

We investigate reported concerns to resolve issues promptly and take appropriate disciplinary action. Any issue involving bribery, corruption or breaches of competition law must be reported immediately. Any resulting investigation will be led by a senior member of Group Legal. Speak Up reports are subject to a triage process and a decision on the appropriate response is made based on the seriousness of the allegation and the location. Local markets have to inform Group Corporate Security about any serious cases of fraud or dishonesty, data loss or breach or incident affecting multiple markets and are required to escalate these reports with 48 hours.

See Data on the number of dismissals and final warnings for employees and contractors, as a result of our investigations, and the types of fraud reported.


Vodafone has a zero tolerance approach to any form of bribery. This is embedded throughout the Group through our robust global anti-bribery programme, which is aligned with the six principles of the UK Bribery Act guidance:

  • Proportionate procedures: The programme is managed centrally to ensure a consistent approach, but also requires each market to tailor the programme and controls to address specific risks and meet local needs, through training and other methods

  • Top-level commitment: Vodafone’s senior managers take an active role in implementing the programme. The Executive Committee receives regular updates on performance and progress from across the Group

  • Risk assessment: We developed a more consistent approach to risk assessment across the Group in 2012/13, whilst continuing to identify and put in place anti-bribery procedures that are appropriate to the local operating environment. This process is reviewed and updated annually

  • Due diligence: Our risk-based approach extends to identify high risk suppliers and business partners. Bribery requirements are included in the terms of our contracts with suppliers and anti-bribery questions are included in the qualification process for high risk suppliers, as well as our performance management programme for strategic suppliers (see Supply chain)

  • Communication and training: Our anti-bribery policy is included in our Code of Conduct, promoted on a dedicated intranet page with supporting guidance, and supported by a global training and communication programme that includes an anti-bribery eLearning tool available to all employees. Face-to-face workshops in all our markets help ensure employees working in high-risk areas (such as procurement, enterprise and government relations) have a practical understanding of the key issues

  • Corporate Gifts and Hospitality: Employees are required to comply with specific procedures and gain appropriate approval levels prior to giving and receiving corporate gifts and hospitality, and record these in our global gift and hospitality register. To raise awareness of this issue, we run campaigns tailored to different cultures in our local markets. For example, in India employees were sent a Happy Divali message with a reminder to send back any gifts other than consumables (as long as they were shared with colleagues)

  • Monitoring and review: Our global anti-bribery working forum, with representatives from each of our markets, meets monthly to discuss progress on implementing our anti-bribery programme and to share best practice. We regularly monitor and review compliance with anti-bribery requirements and address any new or emerging risks

In focus: Working with suppliers to understand and comply with Vodafone’s policy on gifts

During 2012/13, we investigated two instances of excessive gifts offered to our employees from suppliers. We have a strict policy on gifts and hospitality as part of our anti-bribery programme. We worked with the relevant suppliers to investigate these incidents and find out whether the gifts were appropriate or not. In both cases, disciplinary action was taken against the individuals concerned and the gifts were donated to charity.