Ethics: Performance 2007/08
We have:
Introduced a Group Duty to Report policy
Rolled out in April 2007, the new policy requires all employees, contractors and suppliers to report any ethical concerns. The policy makes it mandatory to report incidences of dishonesty. Failure to report a concern could lead to disciplinary action. The Duty to Report Policy is consistent with European and universal human rights standards, the UK Public Interest Disclosure Act and the US Sarbanes-Oxley Act.
Launched a Group-wide security awareness programme
Our new security portal within the Vodafone global intranet lists all our security policies and outlines lessons learned from previous investigations. It is updated monthly and includes an e-learning tool to raise employee awareness of ethical issues. The ‘teach and test’ training module enables employees to improve their level of security awareness. We rolled out this programme to employees in all operating companies in 2007/08. Security awareness is also now included in induction training for new employees. We have appointed a Group Security Awareness Advisor to oversee this programme. So far, 800 employees have used the ‘teach and test’ module and this number will rise when we make it mandatory in 2008.
Introduced an anti-corruption training programme
The online course explains to employees how to ensure they comply with Vodafone’s anti-corruption policy and relevant business principles, and anti-corruption law as it applies to Vodafone. Over 582 employees from 11 operating companies have registered for the course since it began in 2007/08, 282 of whom had completed the course by 31st March 2008.
Surveyed employees on how ethical our business is
In our people surveys, we ask our employees to rate Vodafone on being ethical in its business dealings. Of those surveyed in the 2007 Vodafone People survey, 74% rated Vodafone positively for being ethical in its business dealings, down from 75% in 2005.
Continued to monitor and tackle cases of internal fraud
A total of 615 reported cases of breaches of ethics, internal fraud or other internal dishonesty resulted in 429 employees and 186 contractors being dismissed or receiving their final warning in 2007/08, compared with 445 the previous year. Of these 615 cases, 7 related to incidents of fraud exceeding €20,000. The remaining 608 disciplinary cases related to incidents below the value of €20,000. A considerable number of these incidents (216 cases) related to theft of money or handsets, SIM cards and other equipment. Other incidents involved manipulation of customers’ accounts (182 cases) and unauthorised release of customer information (67 cases).

The increase in reported cases of internal fraud is due to improved reporting methodology across the Group. Each operating company now reports monthly by business area and by type of fraud or crime. This enables us to identify and share best practices across the Group. We will use this information to roll out an internal fraud and crime reduction and awareness programme to all operating companies from April 2008. This will tackle the issues of opportunity, motivation and rationalisation of fraud.
Investigated 55 reported security issues
Reported issues included cases of fraud by employees or airtime and handset dealers, collusion between employees and dealers, ethical issues within the supply chain and passing of commercially sensitive material. Of these, 15 investigations related to phishing scams (trying to obtain important information) targeting Vodafone, its employees or customers. This has become a security awareness issue and we have published advice on our website: http://www.vodafone.com/start/misc/scams.html on how to report these scams to law enforcement authorities.

