At Vodafone, we support and foster a culture of zero tolerance towards bribery or corruption in all our activities.
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
Our anti-bribery policy is consistent with the UK Bribery Act and the US Foreign Corrupt Practices Act. It 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.
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.
To support our approach, Vodafone is also a member of Transparency International UK’s Business Integrity Forum.
Governance and risk assessment
Our Chief Executive and Executive Committee oversee our efforts to prevent bribery. They are supported by local market Chief Executive Officers, 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 Group team that is solely focused on anti-bribery policy and compliance. The Risk and Compliance Committee assists the Executive Committee in fulfilling duties with regards to risk management and policy compliance.
As part of our anti-bribery programme, every Vodafone business must adhere to minimum global standards, which include:
Due diligence process
Ensuring there is a due diligence process for suppliers and business partners at the start of the business relationship.
Completion of the global e-learning training for all employees, as well as tailored training for higher risk teams.
Charitable contributions approval process
Using Vodafone’s global online gift and hospitality registration platform, as well as ensuring there is a process for approving local sponsorships and charitable contributions.
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 also features e-learning training, which includes a specific anti-bribery module. The latest module, DWR 3.0, was launched in September 2021 and is a video-based module requiring employees to identify risks they see playing out in the conversations on screen. Currently approximately 80% of the employees that were assigned the training have completed it and the training has received a five star rating from employees.
The bribery risks we face are constantly evolving. The table below summarises the principal risk categories and the mitigation measures adopted.
Implementation of the anti-bribery policy is monitored regularly in all local markets as part of the annual Group assurance process, which reviews key anti-bribery controls.
Due to the challenging travel conditions during the year, self-assessments and quality reviews were undertaken instead of local market visits in Egypt, Lesotho, Vodafone Procurement Company and Vodafone Roaming Services. We also conducted a thematic review across the key areas of high-risk sales intermediaries and representatives, and provided training to high-risk employees in Czech Republic, Ireland, Portugal and Romania. Further to this, Internal Audit completed audits of the anti-bribery programme in a number of local markets in Europe and Africa. The reviews demonstrate good implementation of the anti-bribery programme. Some areas for improvement relating to third-party risk management and training of high-risk employees were identified and appropriate action plans to improve the control environment were put in place.
The assurance programme was modified during the last financial year due to travel restrictions, and instead of local market visits, guided self-assessments were undertaken in Albania, Turkey, South Africa, Mozambique and the DRC.
There were no emerging or consistent themes from the reviews undertaken, and all identified areas for improvement have action plans to improve the control environment and anti-bribery programme.
As we adjust our way of conducting assurance to the new environment, the assurance plan for the coming year will include thematic reviews across the key areas of high-risk sales intermediaries and representatives and training to high-risk employees.
Internal Audit will also undertake a programme of audits covering the anti-bribery programme in a number of local markets in Vodafone and Vodacom.