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Business

Embedding positive behaviour

Our Code of Conduct outlines our ethical standards and expectations for every individual working for or with Vodafone. It emphasises lawfulness, integrity, respect, responsibility, and diversity and inclusion. We embed the code through a communications programme and mandatory 'Doing What’s Right' training.

CODE OF CONDUCT
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Developing effective behaviour reporting

At Vodafone, everyone has a voice. Our Speak Up service enables all colleagues and partners to report unlawful or abusive behaviour at work and protects them against retaliation. The process continues to be used, with 684 reports submitted in FY25. Vodafone reviews every report carefully and takes appropriate action, helping to build a safer and better workplace for all.

SPEAK UP

Our anti-bribery policy

Our policy on this issue is summarised in our Code of Conduct and states that employees or others working on our behalf must never offer or accept any kind of bribe. Our anti-bribery policy is consistent with the UK Bribery Act and the US Foreign Corrupt Practices Act and provides guidance about what constitutes a bribe and prohibits giving or receiving any excessive or improper gifts and hospitality. Any policy breaches can lead to dismissal or termination of contract.

our CODE OF CONDUCT
Facilitation payment

Facilitation payments are strictly prohibited, and our employees are provided with practical training and guidance on how to respond to demands for facilitation payments. The only exception is when an employee’s personal safety is at risk. In such circumstances, when a payment under duress is made, the incident must be reported as soon as possible afterwards. We consistently evaluate our anti-bribery programme by conducting periodic monitoring activities, risk assessments, policy compliance reviews, and internal audits to ensure its effective implementation.

To support our approach, we are also a member of Transparency International UK’s Business Integrity Forum.

Governance and risk assessment

Our Group Chief Executive and Executive Committee oversee our efforts to prevent bribery. They are supported by local market CEOs, who are responsible for ensuring that our anti-bribery programme is implemented effectively in their local market. They, in turn, are supported by local specialists and by a dedicated Financial Crime Group team. The Risk and Compliance Committee assists the Executive Committee in fulfilling duties with regards to risk management and policy compliance.

Our minimum anti-bribery standards for every Vodafone business include:

Risk Assessment

Conducting a comprehensive anti-bribery risk assessment.

Due diligence process

Ensuring there is a due diligence process for suppliers and business partners at the start of the business relationship.

Employee training

Completion of the global e-learning training for all employees1, as well as tailored training for higher risk teams.

1Exceptions apply for employees in Germany.

Gifts and Hospitality, sponsorships and charitable contributions

Registering gifts and hospitality in a designated platform in line with relevant policy requirements, as well as ensuring there is a process for approving local sponsorships and charitable contributions.

Engaging

Engaging employees to raise awareness of bribery risk

We run a multi-channel high-profile global communications programme, ‘Doing What’s Right’, to engage with employees and raise awareness and understanding of the policy. The ‘Doing What’s Right’ programme features e-learning training, including a specific anti-bribery module. For higher-risk employees, additional tailored training programmes are used to cover relevant scenarios for those employees. We also conduct internal communication campaigns using a range of materials to highlight some of the key messages around zero tolerance to bribery and corruption, including communications from senior management.

Explore our bribery risks and mitigation measures

Anti-bribery - principal risk categories and the mitigation measures

Risk Response
Operating in high-risk markets We undertake biennial risk assessments in each of our local operating companies, and at Group level, so we can understand and limit our exposure to risk.
Business acquisition and integration Anti-bribery pre and post due diligence is carried out on a target company. Red flags identified during the due diligence process are reviewed and assessed. Following acquisition, we implement our anti-bribery programme.
Spectrum licensing To reduce the risk of attempted bribery, a specialist spectrum policy team oversees our participation in all negotiations and auctions. We provide appropriate training and guidance for employees who interact with government officials on spectrum matters
Building and upgrading networks Our anti-bribery policy makes it clear that we never offer any form of inducement to secure a permit, lease or access to a site. We regularly remind all employees and contractors in network roles of this prohibition, through tailored training sessions and communications.
Working with third parties Suppliers and other relevant third parties working for or on behalf of Vodafone must comply with the principles set out in our Code of Conduct and Code of Ethical Purchasing, as well as have programmes in place to ensure suppliers’ employees and contractors are aware of these policies. Third-party due diligence is completed at the start of our business relationship with suppliers, other third parties and partners. Through their contracts with us, our suppliers, partners, and other third parties make a commitment to implement and maintain proportionate and effective anti-bribery compliance measures. We regularly remind current suppliers of our policy requirements and complete detailed compliance assessments across a sample of higher-risk and higher-value suppliers. Select high-risk third parties are trained to ensure awareness of our zero-tolerance policy.
Winning and retaining business We provide targeted training for our Vodafone Business and Partner Markets sales teams. In addition, we also maintain and monitor an online register of gifts and hospitality to ensure that inappropriate offers are not accepted or extended by our employees.
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Assurance boy

Assurance

Implementation of the anti-bribery policy is monitored regularly in all local markets as part of the annual assurance process, which reviews key anti-bribery controls. Appropriate remedial actions are put in place for any identified gaps.

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Healthy

Safety, health and wellbeing

We commit to providing a safe and healthy environment for all those working for or with us by embedding strong safety practices, risk management, and a culture of accountability across our operations. 

Workplace

Workplace equality

We believe the best innovations happen when diverse people with different perspectives collaborate. We are building an inclusive working environment where everyone can be themselves, belong, and thrive.