Our success is underpinned by the strong commitment to ethical behaviour set out in our Code of Conduct and our zero tolerance approach on bribery

Ethics – Our approach

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 also 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, 1.79 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. An external review by Corpedia, the corporate governance division of the New York Stock Exchange, ranked Vodafone’s Code of Conduct in the 99th percentile for our sector, awarding it an ‘A minus’ grade.

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. The Code is designed to be a one stop shop for employees to find all the policies they need to understand, and is clearly linked with working in The Vodafone Way (see Our people).


We want to create 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.

A 15-minute online training course on the Code of Conduct uses a series of scenarios to encourage employees to act in The Vodafone Way and directs them to the Code of Conduct for further information.

We also provide face-to-face training sessions for line managers on what the Code of Conduct means for them.

The Code of Conduct learning and awareness programme, Doing What’s Right, was designed to be used worldwide, so our employees across the Group understand their responsibilities to our people, partners and shareholders.

As part of this programme we developed new e-Learning courses, available for the first time on tablets and mobile devices, that ask employees to apply the Code to real life scenarios to boost their practical understanding of it. We are enhancing our global policies to better support the Code by ensuring they are risk-focused, easily understood, and consistent across our operations.

Reporting concerns

All employees and contractors have a duty to report any breaches of our Code of Conduct, which is known as our Speak Up policy. Our global external reporting scheme allows employees and contractors from all local markets to report through a third party, and is part of our effort to promote a culture of transparency. This process ensures a consistent approach in responding to concerns raised from across the organisation.

Concerns may be reported anonymously and the protection of innocent people is our priority at all times. Whistle-blowers can identify themselves to our external partner using a PIN 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 are included in our Code of Conduct (pdf, 1.79 MB) and on our Suppliers website.

Taking action

We investigate reported concerns to resolve issues promptly and 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. Speak Up reports are subject to a triage process and a decision on the appropriate response is made based on the seriousness of the allegation and where the alleged breach took place.

Local markets must inform Group Corporate Security about any serious cases of fraud or dishonesty, data loss, breach or incident affecting multiple markets, and are required to escalate these reports within 48 hours.

See our Data on the number of dismissals and final warnings for employees and contractors, as a result of our investigations, along with the types of fraud reported.


Vodafone has a zero tolerance approach to any form of bribery. This is embedded across the Group through our robust global anti-bribery programme, which is aligned with the principles of the UK Bribery Act (2011) guidance:

  • Proportionate procedures: The programme is managed centrally to ensure a consistent approach, but also requires each market to tailor it to address specific risks and meet local needs, through training and other methods
  • Top-level commitment: Vodafone’s senior managers take an active role in implementing the programme. The Executive Committee receives regular updates on performance and progress from across the Group, and a new initiative in 2013/14 requires local CEOs in high-risk markets to 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 market and sharing their practices
  • Risk assessment: We further developed our global risk assessment model across the Group in 2013/14, whilst continuing to identify and put in place anti-bribery procedures that are appropriate to the local operating environment. This process is reviewed and updated annually
  • Due diligence: Our risk-based approach extends to identifying high-risk suppliers and business partners. Bribery requirements are included in the terms of our contracts with suppliers and anti-bribery questions are included in the qualification process for high-risk suppliers, 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, promoted on a dedicated intranet page with supporting guidance, and 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 high-risk areas (such as procurement, enterprise and government relations) have a practical understanding of the key issues. In 2013/14, our global Doing What’s Right programme included communications on our Code of Conduct policies and offered additional training for line managers on our main policies, including anti-bribery. To promote further engagement with our policies, we established a community webpage on our internal social media site, Circle, which allows users to post short updates and links to documents and useful websites
  • Corporate gifts and hospitality: Employees are required to comply with specific procedures and gain appropriate approval levels prior to giving and receiving corporate gifts and hospitality, and record these in our global Gift and Hospitality Register. To raise awareness of this issue, we run campaigns tailored to different cultures in our local markets. In India, for example, employees were sent a Happy Divali message with a reminder to send back any gifts other than consumables (which should be shared with colleagues)
  • Monitoring and review: Our global anti-bribery working group includes representatives from each of our markets, and meets bi-monthly 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 2013/14, the group hosted a global event to share successes and challenges of the programme and refreshed the related intranet site to improve internal communications and encourage sharing of topical news stories and issues.

In focus: CEO Action Plan drives anti-bribery engagement

Senior executives in local markets where bribery poses a higher than normal risk committed to a year-long CEO Action Plan in 2013/14. The Action Plan aimed to encourage participants to lead by example to drive employee engagement with the anti-bribery compliance programme. Results were reported quarterly to Regional CEOs. The initiative successfully increased employee awareness of anti-bribery activities and has been extended for a second year.