We are strongly committed to behaving ethically as set out in our Code of Conduct and have a zero tolerance approach to bribery


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 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 (pdf, 1.9 MB) 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 employees to act ethically, comply with legal requirements, apply our Business Principles and speak up if they suspect any breaches of the Code. It is designed to be a one-stop shop to help employees understand all our key policies and it is clearly linked with working in The Vodafone Way (see Our people).

We regularly review the Code to ensure it remains relevant to our business and will next update it in 2015/16. We are also members of the Institute of Business Ethics and Transparency International and use this to benchmark our ethics and compliance programmes against best practice.


We want to maintain a culture where employees do the right thing automatically, not just because they were told they have to or because they are afraid of potential consequences. 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.

The Code of Conduct learning and awareness programme, Doing What’s Right, is designed to help employees across the Group understand their responsibilities to our people, partners and shareholders. Through this programme, employees complete e-learning courses every two years on the Code of Conduct, anti-bribery, privacy, competition law and customer data security. Line managers attend face-to-face briefings from our senior leaders on the key topics of Vodafone’s Code of Conduct and their role as a people manager.

The Doing What’s Right programme is rolled out to new employees as early as possible when they join Vodafone, so that they are clear on our standards from the start. This applies to employees joining us through acquisitions as well as new starters.

In 2014/15, we ran a global survey to assess employees’ awareness of key aspects of the Code of Conduct and ran communication campaigns where improvements were needed. This included a targeted campaign to raise awareness of our Speak Up programme for reporting concerns.

We also conducted audits to understand how well the Code of Conduct is implemented across the business, following our efforts to improve the effectiveness of the accompanying policies. Local markets are using the results to further strengthen controls. See Governance for an overview of our compliance programme.

Reporting concerns

All employees and contractors are required to report any suspected breaches of our Code of Conduct, which is known as our Speak Up policy. The Speak Up process ensures a consistent approach in responding to concerns raised from across Vodafone.

Through our global external reporting scheme, employees and contractors can report concerns anonymously via a third party. This is part of our effort to promote a culture of transparency. Employees also have the option to report concerns directly to their line managers or local human resources teams.

Protecting innocent people is our priority at all times. Whistle-blowers who choose to report concerns anonymously can identify themselves to our external partner using a personal identification number in order to receive feedback. Vodafone has a non-retaliation policy and will not take action against anyone reporting a genuine concern.

Details of how to report concerns through the Speak Up process are included in our Code of Conduct (pdf, 1.9 MB) and on our Suppliers website.

In 2014/15, 602 reports were made through the Speak Up process, almost half (298) of which were raised through our external hotline and the rest through internal channels.

Types of concerns reported to external hotline

Chart showing the following data

Types of concerns %
People (bullying, victimisation and sexual harassment) 65
Integrity (conflicts of interest, corruption and fraud) 22
Health and safety 1
Other (eg policy breach, brand, security issue) 12

Taking action

We investigate reported concerns to resolve issues promptly and we take disciplinary action where appropriate. Any issue involving bribery, corruption or breaches of competition law must be reported immediately. Investigations into these issues are led by a senior member of the Group Legal team. A decision on the appropriate response to each Speak Up report is made based on the seriousness of the allegation and where the alleged breach took place.

Local markets must inform Group Corporate Security within 48 hours of any serious cases of fraud or dishonesty or any data loss, breaches or incidents affecting multiple markets.

The table shows the total number of dismissals of employees and contractors as a result of our investigations of concerns about fraud reported through the Speak Up process or raised through other channels.

Internal fraud by type that resulted in dismissal

  2012/13 2013/14 2014/15
Total 482 701 483
Manipulation of customer account1 234 377 181
Theft 77 83 119
Unauthorised release of customer data 79 112 64
False documents for fraud2 29 35 12
Fraudulent invoicing 7 0 8
Technical fraud 0 0 4
Procurement fraud 2 2 5
Other fraud3 54 92 90


  1. Unauthorised credits, removing call charges, manipulating loyalty points etc.
  2. False documents or reporting to inflate overtime, commissions etc.
  3. Includes false insurance claims, test SIM abuse, unauthorised sale of network unlock codes, misuse of company PBX, falsifying employment application, expenses fraud etc.


Vodafone has a zero-tolerance approach to any form of bribery. We aim to establish a culture of compliance that puts ‘Doing What’s Right’ at the centre of day-to-day business activity. This is embedded across the Group through our robust global anti-bribery programme, which is aligned with the guiding principles of the UK Bribery Act:

  • Proportionate procedures: Our anti-bribery programme is managed centrally to ensure a consistent approach across our local markets. We have developed a framework of procedures for implementation by local markets. The level of implementation and effectiveness of these procedures is tested regularly. Each market is required to consider local bribery risks through the annual Risk Assessment process. Local risks are managed by implementing additional procedures or tailoring existing procedures, for example by providing bespoke training or employee communications.
  • Top-level commitment: Vodafone’s senior managers take an active role in implementing the global anti-bribery programme and it has sponsorship from a member of the Executive Committee. Local CEOs in higher-risk markets must commit to a set of specific anti-bribery programme actions (see below). Nominated policy champions are also responsible for implementing the anti-bribery programme in their local markets and sharing their practices. This top-level commitment helps to embed a culture of compliance across the organisation.
  • Risk assessment: We made further updates to our global risk assessment model across the Group in 2014/15 as part of our annual process review. This model provides a consistent framework to identify and analyse new and emerging bribery risks in our local markets, which shape policy and procedures across the Group. The growth of our fixed-line telecommunications business brings potential bribery risks related to obtaining the permits required to lay and service cables. In 2014/15, we included a specific question in our anti-bribery risk assessment to ensure local market policy champions are aware of the developments taking place and engage with relevant teams to ensure they understand the risks and controls.
  • Due diligence: Our risk-based approach extends to identifying high-risk suppliers and business partners. Our anti-bribery requirements cover suppliers through questions in the qualification process and terms in supplier contracts, as well as our performance management programme for strategic suppliers (see Responsible supply chain).
  • Communication and training: Our anti-bribery policy is included in our Code of Conduct and promoted on a dedicated intranet page with clear and concise guidance. It is supported by a global training and communication programme that includes an anti-bribery e-learning tool available to all employees. Face-to-face workshops in all our markets help ensure employees working in higher-risk areas (such as procurement, enterprise and government relations) have a practical understanding of the key issues. In 2014/15, our global Doing What’s Right programme included communications on our Code of Conduct and offered additional training for line managers on our main policies, including anti-bribery. To promote further engagement with our policies, we maintain a community webpage on our internal social media site, Circle, which allows users to post short updates and links to useful documents and websites and to seek advice where required.
  • Corporate gifts and hospitality: Employees are required to comply with specific procedures and gain appropriate approval prior to giving and receiving corporate gifts and hospitality and record these in our global Gift and Hospitality Register. To raise awareness of this requirement, we run campaigns tailored to different cultures in our local markets. For example, the CEO of Vodafone Qatar sent a message to employees in the lead-up to Ramadan to remind them of the policy and the key points to remember about giving and receiving gifts.
  • Monitoring and review: Our global anti-bribery champions meet quarterly to discuss our anti-bribery programme and share best practice. The group regularly monitors and reviews compliance with anti-bribery requirements and addresses any new or emerging risks. In November 2014, the anti-bribery champions gathered at a summit in Amsterdam to share the successes and challenges of the programme. The focus of the summit was on tracking the effectiveness of the anti-bribery programme and identifying improvement opportunities.

In focus: CEO action promotes external anti-bribery engagement

For the second year, senior executives in local markets where bribery risks are more acute committed to a CEO Action Plan for 2014/15. The Action Plan aimed to encourage participants to lead by example and engage employees in our anti-bribery compliance programme. Results were reported quarterly to regional CEOs. A key focus for 2014/15 was engagement with external parties by communicating Vodafone’s anti-bribery principles to suppliers and contributing to collaborative initiatives. For example, Vodafone India organised a compliance dialogue for multinationals operating in India, in collaboration with the Confederation of British Industry. This engagement helps Vodafone better manage third-party risks and promoted responsible business practices outside the organisation, with a view to contributing to an improved business environment.

In focus: Anti-bribery standards for community-development projects

The Vodafone Foundation contributes financial and technical support to promote economic development in the local markets where we operate. Vodafone engages with charities to deliver programmes, many of which take place in locations where the risk of corruption is relatively high. To prevent the misuse of Foundation funds, anti-bribery controls have been incorporated into the Vodafone Foundation Governance Framework. Specific controls include anti-bribery training for Foundation employees and trustees, due diligence of projects and grant recipients and monitoring of projects and Foundation activities. This framework helps Vodafone to manage this risk and ensure our charitable giving benefits those individuals and communities for whom it is intended.