Vodafone Group Public Policy Principles
Vodafone interacts with governments, legislators, regulators and other public bodies in the course of its normal business activities. In undertaking such public policy activities, Vodafone adheres to the principles ("the principles") outlined below. Most public policy activity is undertaken by members of the Vodafone Public Policy Group in Vodafone Group and in local operating companies, but any Vodafone employee or agent may be required to deal with government and other public bodies and all are required to adhere to the principles when doing so.
These principles are supplementary to, and to be read in conjunction with, the Vodafone Business Principles.
1. Vodafone does not make political donations or support party political interests.
2. Vodafone does seek to inform policymakers, including government officials, legislators and regulators, about the nature of its business, the mobile industry and the business environment generally. Vodafone will develop policy positions (often, but not always, at the request of policymakers) which explain clearly what outcomes Vodafone seeks from the public policy process and why its proposals should be adopted.
3. Vodafone believes in transparency of government relations and "policy positions" are generally in written form. They will be clearly identifiable as representing the views of Vodafone, will be a matter of public record wherever possible and will be made available on request. Disclosure may be withheld where this would prejudice commercial confidentiality for Vodafone or other parties, or where, in exceptional circumstances, confidentiality has been expressly requested by government or other agencies.
4. Vodafone may invite public officials to attend certain corporate or other functions and will meet the expenses of such events. Such entertainment will be approved by a senior Public Policy Manager and will relate to specific business purposes. All inducements to public officials, whether financial or non-financial in nature, are a breach of Vodafone's Business Principles and will not be tolerated.
5. Vodafone encourages its employees to make active contributions to their local communities and this may include political and other public policy activities. Vodafone employees are, however, not expected to assume public responsibilities which might have any direct bearing upon public policy matters relating to the business activities of Vodafone. Vodafone employees are required, by Vodafone's Business Principles, to declare any potential conflict of interest and to seek advice from their manager.
6. Vodafone may occasionally use external consultants and other advisers on matters of public policy, although Vodafone believes that it should represent its own interests directly wherever possible. External advisers will be required to adhere to these principles.
7. Vodafone is a member of a large number of bodies, including trade associations, which may participate in public policy activities from time to time. Vodafone’s membership of such bodies is a matter of public record. Principle memberships as at November 2005 for the Vodafone Group include the GSM Association, GSM Europe, the Centre for European Policy Research, the European Policy Forum, the Internet Watch Foundation and the International Institute for Communications.
8. Vodafone does not participate in public policy activities in which it has no legitimate business interest.