Description
As a customer-obsessed company, Vodafone has a strict policy that it will not engage in anti-competitive practices. Most countries have laws designed to protect free and fair competition. These laws prohibit arrangements with competitors that restrain trade, such as price fixing, allocating customers or abuse of a dominant position. The laws may apply both to Vodafone and to organisations that we work with.
The Vodafone
Code of Conduct
The Vodafone Code of Conduct sets
out Vodafone’s Business Principles
together with guidance to explain
how they apply in practice to every
Vodafone employee
All our models are The Vodafone Way Heroes. They are:
Ivan Lastra Santamarina, Spain
Teresa Bujalance Rodriquez, Spain
Luis Jimenez Tunon, Spain
Tamer Atef, Egypt
Enrique Sanz Zazo, Spain
Enrique David Fernandez Sanz. Spain
Theodosis Gialamas (centre), Greece
Helen Edwards (left), UK
Begona Ibarreche Solaguren, Spain
Remember that all policies referred to in this document
can be found on the Company page of our intranet.
Contents
A message from our Chief Executive 5
Business Principles 6
Compliance with the law 8
Competition laws 8
Insider trading 9
Anti-bribery laws 9
Financial integrity 10
Financial integrity 10
Accurate and complete fnancial records 11
Contracts 11
Social and environmental considerations 11
Company assets 12
Public policy 13
Communications 14
Communications 14
Confdential information 15
Customers 16
Privacy 16
Employees 17
Equal opportunity 17
Harassment and bullying 18
Alcohol and drugs 19
Privacy 19
Environment 20
Communities and society 21
Health and safety 22
Individual conduct 23
Avoiding conficts of interest 23
Gifts, entertainment and payments 24
Personal investments 24
Outside employment and board memberships 25
Friends, relatives and co-worker relationships 26
Duty to report 27
3
“ As an international company,
we must ensure that we have
the trust and respect of each
and every local community
in which we operate. ”
44
5
A message from our
Chief Executive
Vittorio Colao
Vodafone Chief Executive Offcer
As an international company, we must
ensure that we have the trust and respect
of each and every local community
in which we operate. The Vodafone
Business Principles set out our ethical
standards to ensure we achieve this,
and this Code of Conduct explains what
these Business Principles are and how
they apply in practice to every Vodafone
employee. We all need to apply them to
ensure we are also admired for having
the highest standards of integrity.
Personally, I am passionate about
working for a company that upholds
such principles and ensures trust,
both internally and externally, to
achieve admiration by our customers,
shareholders and employees.
5
6
Business Principles
Compliance with the law We will comply with the provisions of all applicable domestic and international
laws and appropriate standards and principles.
Financial integrity We will provide the best possible return for our shareholders over the longer
term. We will base our investment decisions, acquisitions and business
relationships on economic criteria but will also take into account social and
environmental considerations.
Public policy We will voice our opinions on government proposals and other matters that
may affect Vodafone and our stakeholders. We will not make gifts or donations
to political parties or intervene in party political matters.
Communications We will communicate openly and transparently with all our stakeholders within
the bounds of commercial confdentiality. We will protect confdential information
from improper disclosure, and any authorised communication of confdential
information should be limited to individuals who need it to carry out their work.
Customers We will value the trust our customers place in us and will safeguard the
information provided to us.
Employees We will base relationships with and between employees on respect for individuals
and their human rights and will not tolerate child labour. We will not accept any
form of discrimination, harassment or bullying. We will pursue equality of
opportunity and inclusion for all employees through our employment policies
and practices.
Environment We will commit to protecting the environment. We will minimise our use of fnite
resources (such as energy, water and raw materials) and the release of harmful
emissions to the environment (including waste, air emissions and discharges to
water). We will seek to improve the environmental performance of the products
and services we provide, as well as support those that offer environmental and
social benefts to our customers.
Communities and society We will engage with local communities to help us understand and respond to
any concerns they may have, for example in relation to network deployment.
We will always provide our stakeholders with access to correct, relevant and
current information and build trust through integrity, transparency, honesty
and objectivity. We will invest in society in a way that makes effective use of
our resources, including support for charitable organisations.
Health and safety We will protect the health, safety and wellbeing of our customers, employees,
partners and the communities in which we operate and disclose any information
that comes to our knowledge that clearly demonstrates that any of our products
or services breach internationally accepted safety standards or guidelines.
Individual conduct We will act with honesty, integrity and fairness in our dealings both internally and
externally. We will not tolerate any form of bribery, including improper offers of
payments or gifts to or from employees. We will avoid any contracts that might
lead to, or suggest, a confict of interest between personal activities and the business.
We will neither give nor accept hospitality or gifts that might appear to incur an
obligation. We will pursue mutually benefcial relationships and seek to promote
the application of our Business Principles with our business partners and suppliers.
7
8
Competition laws
As a customer-obsessed company, Vodafone has a strict policy that it will
not engage in anti-competitive practices.
Most countries have laws designed to protect free and fair competition.
These laws prohibit arrangements with competitors that restrain trade,
such as price fxing, allocating customers or abuse of a dominant position.
The laws may apply both to Vodafone and to organisations that we work with.
Although the spirit of these laws is straightforward, their application
to particular situations can be quite complex. To ensure that Vodafone
complies fully with these laws and that we can identify any breach of the
laws outside Vodafone, each of us should have a basic knowledge of how
they apply to our work.
In particular, agreements between competitors often give rise to
competition law concerns. An ‘agreement’ can include an understanding
or even an intention to do something and can be concluded by something
as simple as a phone call. It may not be obvious who is a competitor and
there may be instances where our suppliers, customers and business
partners may be in competition with us.
Typical examples of anti-competitive behaviour include:
• Sharing of competitively sensitive information (eg prices, costs or sales volumes)
with competitors.
• Entering into agreements with competitors to fx the price of products or services,
including discounts, rebates or commissions.
• Entering into agreements not to compete with competitors for certain accounts or
regions or agreeing market shares.
• Agreements with resellers to fx the minimum resale price of products or services.
This is not an exhaustive list and if you have any concerns about situations that may give
rise to competition law issues, you should immediately contact your local Legal Department.
More information
A competition law training module
has been constructed by our legal
team and is accessible online by
clicking here.
All employees in competition sensitive
positions are required to complete the
training and all others are encouraged
to complete the training. Further
information on competition law,
contacts and guidelines can be found
online by clicking here.
Compliance with the law
We will comply with the provisions of all
applicable domestic and international laws
and appropriate standards and principles.
9
Insider trading
All Vodafone employees are expected to comply with all laws and
regulations applicable to dealing with Vodafone shares.
In many jurisdictions there are laws that prohibit the trading of shares or
manipulation of share prices based upon information you have by virtue
of your employment or business relationships. It is your responsibility to
comply with all applicable laws.
If you have access to inside information, you must not buy, sell or otherwise deal in
Vodafone shares. You must not pass on any inside information to third parties, as not only
will this be a breach of confdentiality, but you may also be committing an offence
if they go on to trade in Vodafone shares. This applies even if you are no longer a
Vodafone employee.
If you do have any doubts about whether you are entitled to deal in Vodafone shares,
you should contact the Group Company Secretarial department.
More information
For more information, see Vodafone’s
policy on Owning Shares in Vodafone
online by clicking here.
Anti-bribery laws
Vodafone employees must not accept or offer any form of bribe.
The law prohibits bribery in every kind of commercial setting. Additional
restrictions are in place in many countries that specifcally prohibit offering
or giving anything of value to government offcials to infuence offcial
action or secure an advantage.
We must never accept or offer any form of bribe, facilitation payment
(a payment to a government offcial to speed up a process), kickback
or any other form of improper payment. This applies to individuals and
companies in all countries. It also applies whether the payment is made
directly or indirectly, through an agent or partner. Local customs do not
provide an exception to this.
Any employee who is found to have been accepting or offering any form
of bribe will be subject to disciplinary action and may be dismissed.
To avoid any impropriety:
• Be cautious when offering or receiving gifts or entertainment.
• Even charitable donations can constitute improper payments if they are made to
facilitate a process or achieve a commercial advantage.
• Particular attention must be paid in case of any proposed gift or entertainment for
a government employee or public offcial.
• All business entertainment should be moderate in its expense.
• Travel and lodging expenses should be moderate and only offered for trips directly
promoting our products or services or benefting Vodafone.
• Ensure that any gifts are permitted under local law (and if in doubt seek approval
from your line manager).
• Obtain pre-approval as required by your local Vodafone policy.
More information
Further information on complying with
anti-corruption and anti-bribery laws
can be found online by clicking here.
For general legal advice, please see
Vodafone’s policy on Legal Advice and
Reporting online by clicking here.
10
Financial integrity
Vodafone’s money must not be used unless it is appropriately spent,
internal controls have been correctly followed and complete and accurate
fnancial records are made and kept. Vodafone maintains a system of
internal controls to reinforce our compliance with legal, accounting, tax
and other regulatory requirements. It is your duty to understand and
comply with these requirements.
It is your responsibility to familiarise yourself with local expenses and fnancial policies
that apply to your role.
You should only spend company funds if there is a legitimate business need and you
must ensure that the cost is reasonable and proportionate to the beneft.
Managers are responsible for all money spent and expenses incurred by their direct
reports and have a duty to ensure that they are carefully checked and appropriate.
Financial integrity means that you should always strive for the best possible deal. This
almost always requires that you solicit competing bids to make sure that you are getting
the best offer. While price is very important, there are also other factors to be taken into
account such as quality, service, reliability, sustainability and the terms and conditions
of the contract.
More information
For further information, check your
local delegations of authority and
fnancial policies.
See also Vodafone’s policy on
Committing the Organisation online
by clicking here.
Financial integrity
We will provide the best possible return for our
shareholders over the longer term. We will base
our investment decisions, acquisitions and
business relationships on economic criteria
but will also take into account social and
environmental considerations.
11
Accurate and complete fnancial records
Vodafone will accurately and honestly record all transactions. Vodafone
will keep records for an appropriate length of time and recognises that it
is equally important to store documents and to ensure that they are safely
destroyed once they are no longer of use.
If your job involves the fnancial recording of transactions, make sure that you are fully
familiar with all the Vodafone policies that apply.
Record all transactions correctly.
Never falsify any record or account (including time reports, expense accounts and any
other Vodafone records). We recognise that mistakes can be made but the correct course
of action is to let your line manager know so that they can help make any necessary
correction.
If you suspect or observe any of the conduct mentioned above or, for that matter, any
irregularities relating to fnancial integrity or fscal responsibility, no matter how small,
immediately report them to your local Fraud Risk and Security Department.
More information
For more information, please see
the Management and Retention of
Documents Policy online by
clicking here.
See also Vodafone’s policy on
Reporting Financial Information
to Vodafone Group online by
clicking here.
Contracts
Vodafone’s assets should not be committed or commercial arrangements
entered into without a contract. Contracts on Vodafone’s behalf must be in
writing and contain all the relevant terms to which the parties are agreeing.
Never sign any contract on behalf of Vodafone unless all the following requirements
are met:
• You are authorised to do so in accordance with your local contract approval process
and have sought legal advice where appropriate. If in doubt ask your manager.
• You have studied the contract, understood its terms and decided that entering into
the contract is in Vodafone’s best interests.
More information
For advice on contracts, contact your
local Legal Department.
Social and environmental considerations
Our decisions should be based on all relevant factors, including health and
safety, impact on local communities and impact on the environment.
Do:
• Ensure compliance with Vodafone’s Code of Ethical Purchasing.
• Ensure contractors and suppliers comply with Vodafone’s health and safety
requirements.
• Manage contractors and suppliers in such a way as to minimise the impact on the
environment.
• Take into account the guidance in this Code of Conduct under the Health and Safety,
Communities and Society and Environment sections.
More information
For further information on dealing
with suppliers and contractors,
please see Vodafone’s policy on
Contractor Control by
clicking here.
12
Company assets
Company assets belong to Vodafone and company funds, equipment and
other physical assets are not to be used for purely personal reasons.
Equipment
You have responsibility to take proper care of all company property used by you.
Any property issued to you must be kept secure and safe to minimise loss or damage and
should not be used for any activities other than those related to company business and
limited personal use in accordance with Vodafone guidelines.
Immediately report theft or loss of company equipment (including a loss of passwords or
account details) because this may present a security breach.
Intellectual property rights
Vodafone’s intellectual property rights (our trade marks, logos, copyrights, trade secrets,
know-how and patents) are amongst our most valuable assets. The consequences of
failing to properly recognise and protect our intellectual property rights can lead to loss
of their value. Any use of our intellectual property rights or intellectual property rights
belonging to others should be subject to agreement by the owner of those rights.
Do:
• Ensure that any use complies with Vodafone’s brand guidelines.
• Ensure Vodafone can protect all new inventions and ideas that can be patented;
patent applications must be fled before the invention can be discussed with anyone
other than a Vodafone employee.
• Report any suspected misuse of trade marks, logos or other Vodafone intellectual
property or counterfeit goods to your local Legal Department and always consult
your local Legal Department before responding to any offer to acquire intellectual
property rights from third parties or any allegation of infringement.
Don’t:
• Allow any third parties to use the Vodafone brand or logo without frst putting a
written agreement in place.
More information
Please refer to your local policies
on access to and use of company
equipment.
For further information about
Vodafone’s intellectual property rights,
click here to see the Group Brand
Policy, Group IPR Policy and the
Inventor Reward Rules.
Additional information on the Group
Intellectual Property strategy,
procedures and support, including
where to submit new ideas for patent
protection, can be found online by
clicking here.
13
We will build Vodafone’s reputation through proactive engagement with
government policy makers and other stakeholders such as the media,
NGOs, industry analysts and international institutions.
We will provide thought leadership on issues of importance to our industry
and its relationship with broader society and the environment.
If there are new government proposals of which you become aware and which are
relevant to Vodafone’s business, ensure that these are escalated to your external affairs
and regulatory departments to enable them to co-ordinate a response.
Don’t:
• Make a comment on behalf of Vodafone unless your comments have been approved
in accordance with the Vodafone Communications Policy.
• Use your position in Vodafone to try to infuence any other person (inside or outside
Vodafone) to make political contributions or provide support to any political parties
or politicians.
• Make any contributions or incur expenses using a Vodafone account for any political
campaign, political party, political candidate or any of their affliated organisations.
• Allow others to use resources such as work time, telephones, communications
services or meeting rooms to support any political campaign, political party, political
candidate or any of their affliated organisations.
More information
For more information, please see
Vodafone’s policy on Meeting
Regulatory Requirements online
by clicking here.
Public policy
We will voice our opinions on government
proposals and other matters that may affect
Vodafone and our stakeholders.
We will not make gifts or donations to political
parties or intervene in party political matters.
14
Communications
Provide clear and honest information at all times in language that is easy
to understand.
Make sure you communicate relevant information to your teams and to third parties in
a timely and clear manner. Act on information you receive without unnecessary delay.
Don’t:
• Make a comment on behalf of Vodafone to the media unless your comments
have been approved in accordance with your company’s policies, the Vodafone
Communications Policy and the Social Media Rules of Engagement. Failure to
comply with these requirements may lead to disciplinary action.
• Make any statement that could/will have a negative impact on Vodafone’s
reputation or its brand.
• Make reference to your employment or connections with Vodafone in any personal
communication in a way that could be interpreted, even by mistake, as a comment
or endorsement by Vodafone.
• Release any information about new products or services without the correct
approval. This is essential, as any leaked, incorrect or misleading messages can have
a real impact on the success or failure of products and services.
• Forget that when you are wearing Vodafone uniform or using company vehicles,
you are a representative of Vodafone.
When using social networking or similar sites in a personal capacity, use common
sense – if you would not say something in the real world, don’t say it in the online world.
Be yourself, but also respect the law and your fellow employees.
More information
For more information, see the
Communications Policy, the Public
and Media Relations Policy and the
Social Media Guidelines online by
clicking here.
Communications
We will communicate openly and transparently
with all our stakeholders within the bounds
of commercial confdentiality. We will protect
confdential information from improper disclosure,
and any authorised communication of confdential
information should be limited to individuals who
need it to carry out their work.
15
Confdential information
We all have a duty to protect Vodafone’s confdential information.
Confdential information can include legal agreements, technical
specifcations, business information and any other information which
is unlikely to be publicly known and has commercial value.
When we receive information from third parties, including other Vodafone
companies, we must ensure that this is treated with the same level of
security as our own confdential information. If information has been
provided for a particular purpose, it must only be used for that purpose.
We have created an Information Classifcation Standard to help us classify
information for the appropriate audience. It is your duty to ensure that any
information you create is classifed and only disclosed in accordance with
the Information Classifcation Standard.
Sharing information
Before sharing confdential information with third parties or within Vodafone:
• Check that there is a written agreement in place with any third party to protect
confdentiality.
• Check that Vodafone is permitted to share the information under the relevant
agreement.
• Ensure that any Vodafone documents are appropriately labelled as confdential
and disclosed under an obligation of confdentiality.
• Limit the distribution to people who have a need to know.
You should not disclose confdential information to anyone, not even your partner
or family members, in breach of a confdentiality agreement or the Information
Classifcation Standard.
Personal relationships
If you have family or other personal relationships with people employed by our
competitors, customers, suppliers or partners we not only expect you to preserve
Vodafone confdential information but you should also not solicit confdential
information from them about their company.
Competitors
You should not discuss any confdential information with any competitor (or accept
any such information from a competitor) as this is likely to break competition laws.
Unsolicited information
If you receive any unsolicited information from a third party with proprietary
business information, return or delete the information, do not use it within Vodafone
and, if appropriate, respond politely to the sender asking them not to send any
further information.
It may not always be clear whether information is confdential – if in doubt, ask for
guidance from your local Legal Department.
More information
See the Information Classifcation
Standard online by clicking here.
If you are being approached by or
on behalf of a competitor and have
concerns, contact your Legal and
Fraud and Security Departments.
16
More information
For more information, click here
to see our dedicated site, Privacy
Matters, to learn more about what
privacy means to Vodafone and to
see Vodafone’s Privacy Principles.
To fnd out what privacy training
is available to you, contact your
Privacy Offcer.
Customers
We will value the trust our customers place in
us and will safeguard the information provided
to us.
Privacy
Customers trust Vodafone with their privacy and we place enormous
value on this trust. It’s our goal to create a culture of privacy across our
business and to be a trusted and responsible guardian of the privacy of
our customers.
To our customers, privacy means a number of different things – ensuring that their
private communications remain private, not being disturbed by inappropriate or
unwanted communications or spam, or ensuring that their personal information is
handled in the right way.
What is meant by ‘personal information’ is often a lot wider than you might think – for
example, it includes our customers’ mobile numbers, even where we don’t have a name
or address for them. Some types of information are particularly sensitive and can only
be handled in limited circumstances, such as:
• Information relating to their communications content (eg messages, voicemails);
• Traffc and location logs that we capture from our networks; or
• Information we capture that may reveal sensitive details about a person’s nationality,
health or sex life or their religion or beliefs.
Do:
• Respect our customers’ privacy in everything you do. For instance:
– When developing products and services, think about designing privacy in from
the outset
– When communicating with customers about privacy, make it clear and simple
– When relying upon other companies to handle our customers’ information,
consider carefully whether they are trusted and reliable and what safeguards
we can take
– Remember that privacy is about more than just keeping personal information secure.
• Find out who your Privacy Offcer is – every Vodafone company must have one.
• Undertake the Online Privacy Awareness Training available for all employees.
Don’t:
• Ever access or provide customer information to anyone without proper authorisation.
Not only will you be in breach of this Code, but you may also commit a criminal offence.
17
Equal opportunity
We are committed to creating an inclusive work environment where all
employees have equal opportunities through clearly defned employment
policies and practices, which shall apply to recruitment, selection,
promotion, discipline, development, compensation and termination.
We will comply with these policies at all times.
If any employees believe that they are a victim of discrimination, they should notify their
local Human Resources Department.
Do:
• Demonstrate respect and fairness in all your interactions with employees and
external parties consistent with Vodafone’s Business Principles, policies and
procedures.
• Understand relevant local legislation and culture that may have an impact on
workplace decisions.
• Report equal opportunity concerns through the appropriate Vodafone procedure.
• Ensure that all employment-related decisions, such as hiring new employees,
are free from discrimination and determined on the basis of merit and business
considerations alone.
• If you are concerned about another employee’s actions and behaviour, explain why
and ask them to stop or tell your manager.
Don’t:
• Tolerate unlawful discrimination of any kind.
More information
For further details please see your
local Equal Opportunities Policy.
Contact your local Human Resources
team if you have any questions
about any equal opportunity
employment laws.
Employees
We will base relationships with and between
employees on respect for individuals and their
human rights and will not tolerate child labour.
We will not accept any form of discrimination,
harassment or bullying. We will pursue equality
of opportunity and inclusion for all employees
through our employment policies and practices.
18
Harassment and bullying
Bullying and harassment have no place in Vodafone. Harassment can have
a serious impact on both the health and happiness of employees and the
productivity and success of the business. We are committed to ensuring
that our employees develop in a positive environment. Where we see any
harassment or bullying happening, we put a stop to it, fast.
We defne bullying and harassment as unwanted behaviour from another
person where you feel it is intimidating, malicious, offensive, insulting,
humiliating or degrading. It may be related to age, gender, sexual
orientation, race, disability, religion or belief, and can be either a repeated
or a one-off incident. It can be verbal, non-verbal or physical and isn’t
always face to face (eg displayed images, email, phone, social
networking websites). It doesn’t have to be targeted at an individual and
can be about creating an unwelcoming or hostile environment.
Harassment is illegal in many countries and employees must understand
and implement the requirements set by local laws. Guidance can be found
in your employee handbook and can be obtained from your local Human
Resources team.
Any examples of harassment will be taken very seriously and may lead to
disciplinary action, including potentially dismissal and legal action. If any
employees believe that they are victims of harassment or bullying, they
should notify their local Human Resources Department.
Some examples of what we class as harassment and bullying are:
• Insulting someone particularly on the grounds of his or her age, race, sex, disability,
sexual orientation or religion.
• Making fun of someone or putting them down.
• Excluding or isolating someone from work or social activities.
• Picking on someone because they have made a previous complaint of harassment.
• Unwelcome firtation, sexual advances or sexual assault.
• Touching or standing too close when not invited to.
• Displaying or circulating offensive materials (eg rude, racist or sexual pictures
or cartoons).
• Making decisions on the basis of sexual favours being accepted or rejected.
• Making inappropriate jokes or comments.
• Misuse of power or a position of authority.
Harassment and bullying are not limited to these examples.
Whether you are using company or personal communications, when discussing
employees, take care to ensure that you do not communicate derogatory, harassing
or abusive information. Remember to apply the same standard in all forms of
communication no matter how informal they may appear.
More information
If you do not feel you can talk to your
co-workers or manager about an issue
you can always speak to a member of
your local Ask HR team or your Human
Resources Business Partner.
For further details please see your
local Bullying and Harassment Policy.
19
Alcohol and drugs
We are committed to providing a positive and safe environment for
allour employees. We will not tolerate illegal substances, alcohol or
violence in the workplace. Any use, sale or distribution of illegal
substances will be treated with the utmost seriousness and may lead
to dismissal and legal action.
While alcohol is legal in many countries it is illegal or prohibited in others. It is your
responsibility to ensure that you comply with all applicable law.
Even if alcohol is not prohibited in your country it is not acceptable in the workplace unless
consumed in moderation at either a work event or as part of approved corporate hospitality
normally outside your working hours. You must remain professional and be able at all times
to carry out your work duties.
If you notice that an employee is or may be using illegal substances or consuming
alcohol in the workplace in breach of this Code of Conduct please support them by
notifying your local Human Resources team. Substance abuse can be destructive and
potentially dangerous to the individual and others.
Privacy
We will value the trust our employees place in us and will be a trusted and
responsible guardian of their privacy.
Do:
• Respect that employees have a right to a private life when working.
• Respect and protect the personal information of our employees to the same
extent as we do for our customers.
Don’t:
• Intrude into any aspect of an employee’s personal privacy, such as their PC, phone,
email account, or through use of workplace surveillance, without compliance with
your local workplace monitoring policy and authorisation from your Privacy Offcer.
More information
For further details please see our
Occupation Health & Safety and
Wellbeing Policies online by
clicking here.
For more information on support in
relation to alcohol or drug related
illnesses, please see Workplace
Options.
More information
For more information click here
to see Vodafone Privacy Principles.
Speak to your local Privacy Offcer
to learn about our policies on
workplace monitoring.
Any workplace monitoring that
does take place will be set out
clearly in these policies and will
apply to all forms of communication,
including your mobile phone use,
email, chat, etc.
Harassment and bullying (continued)
What can you do?
If you notice any discrimination, harassment or bullying among your work colleagues,
speak up; the victim of harassment may feel unable to do this and we need to support
each other. If it feels unsafe to raise the issue directly contact your local Human
Resources Department for advice on how to resolve the issue.
Travelling/working abroad
If you are travelling or working abroad ensure that you familiarise yourself with local
customs, regulations and the local Employee Handbook. Be sensitive to different
cultures; talk to local managers and the local Human Resources Department and adapt
your behaviour as necessary.
20
Vodafone recognises that our day-to-day operations will impact on the
environment in a number of ways. We are committed to minimising the
potentially harmful effects of our activities wherever and whenever possible.
We will adhere to relevant environmental legislation and international
standards. In countries where environmental legislation is not evident
or enforced, we will ensure that responsible practices for managing
environmental impacts are in place.
We will minimise our use of fnite resources (such as energy, water and
raw materials), and the release of harmful emissions to the environment
(including waste, air emissions and discharges to water).
We will seek to improve the environmental performance of the products
and services we provide, for example by increasing energy effciency, or
reducing waste.
We will support innovative developments in products and services that can
offer environmental and social benefts to our customers.
Consider what opportunities exist in your working life to contribute to Vodafone’s
environmental commitment, specifcally:
• Make sure you are familiar with the environmental laws, regulations and policies that
apply to your job.
• Look for opportunities to reduce waste – don’t print if you don’t need to, turn off
lights, don’t over order consumables.
• Dispose of any materials carefully – if you have access to recycling facilities then
make sure you know how to use them.
• Make the most of being online – it reduces the need for hard copies of documents,
saving paper and energy costs.
• Think of the environment when travelling – can you video conference or telephone
instead? Can you walk or use public transport? Can you car share?
• Build environmental considerations into your purchasing decisions.
More information
Please refer to your individual
operating company intranet site
for information on how we manage
our environmental issues or look
at vodafone.com/responsibility/
environment.
For more information about dealing
with suppliers, see Vodafone’s Ethical
Purchasing Policy online by
clicking here.
Environment
We will commit to protecting the environment. We will minimise our use of
fnite resources (such as energy, water and raw materials) and the release of
harmful emissions to the environment (including waste, air emissions and
discharges to water). We will seek to improve the environmental performance
of the products and services we provide, as well as support those that offer
environmental and social benefts to our customers.
21
Vodafone relies on local communities. Our network is set up and
maintained in the communities around us. Our customers are affected
by the way in which we operate in their communities and trust us to act
with integrity. We respect any concerns that these communities have
and always try to answer any questions or worries raised. We also provide
charitable support to many communities. Our aim is to work together for
the beneft of the communities and Vodafone.
Do:
• Be sensitive to the needs of the local community in which you are based and listen
to any concerns about Vodafone’s operations. Make sure issues are raised with the
relevant department.
• Use inclusive communication and engagement practices to ensure that different
groups in the community have an opportunity to be heard.
• Contact your local Vodafone Foundation to see what you can do in your
local community.
More information
For more information about network
deployment, see Vodafone’s
Responsible Network Deployment
Policy online by clicking here.
Vodafone has specifc processes to
address any concerns about the
effects of electromagnetic radiation:
please refer to the relevant policy
standard, and to your local EMF leader.
Communities and society
We will engage with local communities to help us understand and respond to
any concerns they may have, for example in relation to network deployment.
We will always provide our stakeholders with access to correct, relevant and
current information and build trust through integrity, transparency, honesty
and objectivity. We will invest in society in a way that makes effective use of
our resources, including support for charitable organisations.
22
It is the responsibility of all of us to take steps to protect the health, safety
and wellbeing of ourselves, each other, our partners, our customers and
the wider communities in which we operate.
Vodafone is committed to ensuring a stimulating, safe environment and
supporting health, wellbeing and work–life balance for all of our employees.
To achieve this, Vodafone expects our leaders to lead by example –
identify risks, establish controls and monitor performance for the area
they manage. Vodafone has dedicated health, safety and wellbeing
management systems and structures to manage health, safety and
wellbeing risks.
Vodafone reports, records and investigates our incidents, and
communicates our performance transparently internally and externally.
Do:
• Comply with the Vodafone Absolute Rules – these are designed to protect you from
risks we know can cause serious harm.
• Understand and comply with the policies, standards, procedures and arrangements
that Vodafone has put in place to ensure your health and safety at work.
• Ensure that our suppliers and partners identify, assess and manage risk for all
activities and services undertaken and/or products provided on Vodafone’s behalf
and can comply with all applicable laws relating to health and safety and Vodafone’s
Code of Ethical Purchasing.
• Report all accidents, unsafe practices and unsafe situations immediately. This will
help us prevent accidents in the future.
• Intervene when you see unsafe acts and conditions. If you are not sure how to do
something, or consider the activity to be dangerous, stop and seek advice.
• Act quickly to initiate an immediate investigation in the event of accidents or
emergencies. This includes if there is doubt over the safety of a product or service.
• Recommend innovation or improvements, and commend others doing the right thing.
• Consider the impact of work on your wellbeing and your work–life balance as well as
the wellbeing and work–life balance of others.
More information
Further information can be found
on the Vodafone intranet under
Health and Safety and Wellbeing
and Health and Safety Policy and
Procedures, the Absolute Rules
and the Employee Handbook.
You may fnd more information
on product safety online by
clicking here.
Health and safety
We will protect the health, safety and wellbeing
of our customers, employees, partners and the
communities in which we operate and disclose
any information that comes to our knowledge that
clearly demonstrates that any of our products or
services breaches internationally accepted safety
standards or guidelines.
23
Avoiding conficts of interest
We have a duty to always act in the best interests of Vodafone and its
customers. If a competing loyalty arises an individual may be subject to
a confict of interest. You should avoid circumstances that may lead to
either a confict of interest or the appearance of a confict. If you are in
a position that is a confict of interest, disciplinary action may be taken
against you including, potentially, dismissal.
To avoid a confict you should:
• Recognise when you are presented with situations that might result in you having
a loyalty that competes with your duties to Vodafone.
• Discuss any concerns with your line manager.
• Ensure that in performing your job you continue to act in the best interests of
Vodafone.
• Don’t allow yourself to be put in a position where you have a personal interest in,
or infuence over, a contract or relationship. If you do have a personal interest in the
outcome, avoid taking part in the decision-making process.
As a guide, ask yourself whether you would feel comfortable explaining your actions
to friends/co-workers/media.
If you are a director, be aware that additional duties may apply to you by virtue of your
role as a director under applicable law.
More information
If in doubt contact your local Human
Resources or Legal Department.
For more information, please see your
local policies on Conficts of Interest.
Individual conduct
We will act with honesty, integrity and fairness in our dealings both internally and
externally. We will not tolerate any form of bribery, including improper offers of
payments or gifts to or from employees. We will avoid any contracts that might lead
to, or suggest, a confict of interest between personal activities and the business.
We will neither give nor accept hospitality or gifts that might appear to incur an
obligation. We will pursue mutually benefcial relationships and seek to promote
the application of our Business Principles with our business partners and suppliers.
24
Gifts, entertainment and payments
Vodafone policy prohibits accepting signifcant gifts or any other business
courtesy (including discounts or benefts that are not made available to all
employees) from any of our customers, suppliers, partners or competitors.
We appreciate that business relationships will sometimes result in a need
to receive or offer a modest gift or hospitality. In fnding this balance,
we must ensure that we are not infuenced, or seen to be infuenced,
in our decisions by payments or gifts and that there is a genuine and legal
business purpose in accepting or giving the gift.
If you are offered any signifcant gifts, notify your line manager and only accept the gift
if it is approved. There may also be additional requirements in relation to registering gifts
in your company; check with your local Human Resources representative. Gifts may take
many forms including invitations to attend events. Gifts should always be infrequent,
modest and should not include any element of cash or a cash equivalent.
Remember:
• Don’t accept any gift that may create the appearance of impropriety.
• Never accept gifts from competitors or government offcials.
• Don’t accept gifts of cash or cash equivalents (eg gift certifcates or prepaid gift
cards) even if they have a low value.
• Never ask for gifts or hospitality.
While we appreciate that local customs may require the giving or accepting of modest
gifts this should always be in accordance with your local policy.
Equal care and consideration needs to be taken in offering gifts.
Personal investments
Personal investments in a supplier, business partner or competitor may
lead to a confict of interest.
Avoid signifcant investments that may cause you to act in a way that benefts you at the
expense of Vodafone. Senior managers and directors have a particularly broad infuence
in this regard and should take extra care in choosing their investments.
In many countries, investments by any employee in unconnected mutual funds or similar
vehicles that invest in a broad cross-section of publicly traded companies that may
include competitors, customers, suppliers or partners of Vodafone would generally not
be considered a confict. However, it remains your responsibility to check whether your
investments are permitted by local law and whether they require prior approval.
More information
For more information, please see:
Vodafone’s Corporate Hospitality
Policy online by clicking here.
Vodafone’s Charitable Donations
Policy online by clicking here.
25
Outside employment and board memberships
Working for a supplier, customer, partner or competitor (including as a
consultant or advisor, whether paid or unpaid) can create a confict of
interest. Membership on the boards of customers, suppliers, partners
or competitors of Vodafone is especially problematic from a confict of
interest perspective because board seats generally involve the ability
to infuence the actions of the third-party business.
Avoid employment with suppliers, customers, business partners or companies that
compete with Vodafone.
If you are engaged on an external board or in outside employment ensure that you do not
use your position within either company to infuence your role with the other company.
Some countries also have restrictions on the amount of time you can spend working.
Breaching these rules may affect your health and wellbeing and could expose
Vodafone to a fne. Disclose any outside employment to your local Human Resources
representative.
Seek guidance from your line manager or local Human Resources representative if you
have any doubts as to whether a potential board membership or outside employment
would constitute a confict of interest.
Remember:
• Don’t accept employment with a supplier, customer or partner if you have the ability
to infuence their relationship with Vodafone.
• Never accept concurrent employment or consultancy with a competitor.
• Always declare any outside employment and board memberships to your employer.
• Continually assess whether your dual loyalties are likely to place you in a position of
confict and report any concerns to your manager.
26
Friends, relatives and co-worker relationships
Business relationships with relatives, spouses and signifcant others
or close friends can lead to a confict of interest that can be diffcult
to resolve. Similarly, intimate relationships between co-workers can,
depending on the work roles and respective positions of the dating
co-workers, create an actual or apparent confict of interest. If you are
faced with the possibility of such a business or personal relationship
you should discuss the relationship with your manager.
Business relationships
If you are involved in a relationship, on behalf of Vodafone, with an organisation or
business where a partner or relative is employed, you should ensure that your line
manager is made aware of the personal relationship so that steps can be taken to ensure
that no confict of interest arises in the business relationship.
Remember:
• Do notify your manager of any potential confict.
• Do conduct your relationships with contractors and suppliers in a professional and
impartial manner.
• Don’t allow your personal relationships with contractors and suppliers to infuence
any business decisions that you make on behalf of Vodafone.
Co-worker relationships
If you become involved in an intimate relationship with a co-worker and you feel that
this may place you or your partner in a position of confict, you should discuss this issue
with your local Human Resources team. The issue will be handled sensitively but it may
be necessary to make changes to your working environment or reporting structure,
including potentially transferring one or both of the employees, to avoid any confict.
Don’t:
• Get involved in the hiring, supervising, management or career planning of any
relative or partner.
• Let your personal relationships infuence, or be seen to infuence, your decisions
at work.
More information
Refer to your local Employee
Handbook for further information.
27
For Vodafone to maintain its reputation we each need to assume
responsibility for our actions and to take action if something is not done in
the Vodafone way. If you suspect a breach of The Vodafone Code of Conduct
you should report it. Unless otherwise stated in this Code of Conduct or the
Vodafone Group Security Policy you should report all suspected breaches
frst to your line manager. If this is not appropriate in the circumstances you
should report the matter to your local Human Resources team, local Legal
Department or Group Corporate Security Department.
Each employee has a duty to report:
• Financial malpractice, dishonesty, money laundering, corruption or fraud.
• Failure to comply with a legal obligation that may result in criminal liability or
damage to Vodafone’s reputation.
• A serious breach of Vodafone policy relating to any criminal activity.
• Any breach or potential breach of data privacy or unlawful disclosure of sensitive
and confdential information.
• A serious breach of competition law (eg price fxing).
• Endangering health and safety of employees or the public or serious environmental
issues, including threats and assaults involving any Vodafone personnel.
• Any other suspected criminal activity.
• Serious confict of interest without disclosure.
• Any attempt to conceal any of the above.
If you have a concern that you feel is particularly sensitive, which cannot be dealt with
through the normal channels and is not covered by the Vodafone Group Security Policy,
you may report the matter to Group Legal.
More information
For further information refer to
the Security Policy online by
clicking here.
If you don’t feel comfortable talking to
your line manager or an internal team,
there’s the ‘Whistleblowing Procedure’
where you can report an incident
anonymously. You may also know
this procedure as ‘Speak Up’ or ‘Doing
what is Right’. The Whistleblowing
Procedure is an addition to, not a
replacement of the Security Policy and
can be found here.
Alternatively, in some countries
you may be able to contact the
appropriate ombudsman or
ombudswoman.
Duty to report
Further information
For any further information and for questions about The Vodafone Code of Conduct generally, please speak to your
manager or contact your HR team.
Vodafone Group Plc
Vodafone House
The Connection
Newbury
Berkshire
RG14 2FN
England
Tel: +44 (0) 1635 33251
doc_473050545.pdf
As a customer-obsessed company, Vodafone has a strict policy that it will not engage in anti-competitive practices. Most countries have laws designed to protect free and fair competition. These laws prohibit arrangements with competitors that restrain trade, such as price fixing, allocating customers or abuse of a dominant position. The laws may apply both to Vodafone and to organisations that we work with.
The Vodafone
Code of Conduct
The Vodafone Code of Conduct sets
out Vodafone’s Business Principles
together with guidance to explain
how they apply in practice to every
Vodafone employee
All our models are The Vodafone Way Heroes. They are:
Ivan Lastra Santamarina, Spain
Teresa Bujalance Rodriquez, Spain
Luis Jimenez Tunon, Spain
Tamer Atef, Egypt
Enrique Sanz Zazo, Spain
Enrique David Fernandez Sanz. Spain
Theodosis Gialamas (centre), Greece
Helen Edwards (left), UK
Begona Ibarreche Solaguren, Spain
Remember that all policies referred to in this document
can be found on the Company page of our intranet.
Contents
A message from our Chief Executive 5
Business Principles 6
Compliance with the law 8
Competition laws 8
Insider trading 9
Anti-bribery laws 9
Financial integrity 10
Financial integrity 10
Accurate and complete fnancial records 11
Contracts 11
Social and environmental considerations 11
Company assets 12
Public policy 13
Communications 14
Communications 14
Confdential information 15
Customers 16
Privacy 16
Employees 17
Equal opportunity 17
Harassment and bullying 18
Alcohol and drugs 19
Privacy 19
Environment 20
Communities and society 21
Health and safety 22
Individual conduct 23
Avoiding conficts of interest 23
Gifts, entertainment and payments 24
Personal investments 24
Outside employment and board memberships 25
Friends, relatives and co-worker relationships 26
Duty to report 27
3
“ As an international company,
we must ensure that we have
the trust and respect of each
and every local community
in which we operate. ”
44
5
A message from our
Chief Executive
Vittorio Colao
Vodafone Chief Executive Offcer
As an international company, we must
ensure that we have the trust and respect
of each and every local community
in which we operate. The Vodafone
Business Principles set out our ethical
standards to ensure we achieve this,
and this Code of Conduct explains what
these Business Principles are and how
they apply in practice to every Vodafone
employee. We all need to apply them to
ensure we are also admired for having
the highest standards of integrity.
Personally, I am passionate about
working for a company that upholds
such principles and ensures trust,
both internally and externally, to
achieve admiration by our customers,
shareholders and employees.
5
6
Business Principles
Compliance with the law We will comply with the provisions of all applicable domestic and international
laws and appropriate standards and principles.
Financial integrity We will provide the best possible return for our shareholders over the longer
term. We will base our investment decisions, acquisitions and business
relationships on economic criteria but will also take into account social and
environmental considerations.
Public policy We will voice our opinions on government proposals and other matters that
may affect Vodafone and our stakeholders. We will not make gifts or donations
to political parties or intervene in party political matters.
Communications We will communicate openly and transparently with all our stakeholders within
the bounds of commercial confdentiality. We will protect confdential information
from improper disclosure, and any authorised communication of confdential
information should be limited to individuals who need it to carry out their work.
Customers We will value the trust our customers place in us and will safeguard the
information provided to us.
Employees We will base relationships with and between employees on respect for individuals
and their human rights and will not tolerate child labour. We will not accept any
form of discrimination, harassment or bullying. We will pursue equality of
opportunity and inclusion for all employees through our employment policies
and practices.
Environment We will commit to protecting the environment. We will minimise our use of fnite
resources (such as energy, water and raw materials) and the release of harmful
emissions to the environment (including waste, air emissions and discharges to
water). We will seek to improve the environmental performance of the products
and services we provide, as well as support those that offer environmental and
social benefts to our customers.
Communities and society We will engage with local communities to help us understand and respond to
any concerns they may have, for example in relation to network deployment.
We will always provide our stakeholders with access to correct, relevant and
current information and build trust through integrity, transparency, honesty
and objectivity. We will invest in society in a way that makes effective use of
our resources, including support for charitable organisations.
Health and safety We will protect the health, safety and wellbeing of our customers, employees,
partners and the communities in which we operate and disclose any information
that comes to our knowledge that clearly demonstrates that any of our products
or services breach internationally accepted safety standards or guidelines.
Individual conduct We will act with honesty, integrity and fairness in our dealings both internally and
externally. We will not tolerate any form of bribery, including improper offers of
payments or gifts to or from employees. We will avoid any contracts that might
lead to, or suggest, a confict of interest between personal activities and the business.
We will neither give nor accept hospitality or gifts that might appear to incur an
obligation. We will pursue mutually benefcial relationships and seek to promote
the application of our Business Principles with our business partners and suppliers.
7
8
Competition laws
As a customer-obsessed company, Vodafone has a strict policy that it will
not engage in anti-competitive practices.
Most countries have laws designed to protect free and fair competition.
These laws prohibit arrangements with competitors that restrain trade,
such as price fxing, allocating customers or abuse of a dominant position.
The laws may apply both to Vodafone and to organisations that we work with.
Although the spirit of these laws is straightforward, their application
to particular situations can be quite complex. To ensure that Vodafone
complies fully with these laws and that we can identify any breach of the
laws outside Vodafone, each of us should have a basic knowledge of how
they apply to our work.
In particular, agreements between competitors often give rise to
competition law concerns. An ‘agreement’ can include an understanding
or even an intention to do something and can be concluded by something
as simple as a phone call. It may not be obvious who is a competitor and
there may be instances where our suppliers, customers and business
partners may be in competition with us.
Typical examples of anti-competitive behaviour include:
• Sharing of competitively sensitive information (eg prices, costs or sales volumes)
with competitors.
• Entering into agreements with competitors to fx the price of products or services,
including discounts, rebates or commissions.
• Entering into agreements not to compete with competitors for certain accounts or
regions or agreeing market shares.
• Agreements with resellers to fx the minimum resale price of products or services.
This is not an exhaustive list and if you have any concerns about situations that may give
rise to competition law issues, you should immediately contact your local Legal Department.
More information
A competition law training module
has been constructed by our legal
team and is accessible online by
clicking here.
All employees in competition sensitive
positions are required to complete the
training and all others are encouraged
to complete the training. Further
information on competition law,
contacts and guidelines can be found
online by clicking here.
Compliance with the law
We will comply with the provisions of all
applicable domestic and international laws
and appropriate standards and principles.
9
Insider trading
All Vodafone employees are expected to comply with all laws and
regulations applicable to dealing with Vodafone shares.
In many jurisdictions there are laws that prohibit the trading of shares or
manipulation of share prices based upon information you have by virtue
of your employment or business relationships. It is your responsibility to
comply with all applicable laws.
If you have access to inside information, you must not buy, sell or otherwise deal in
Vodafone shares. You must not pass on any inside information to third parties, as not only
will this be a breach of confdentiality, but you may also be committing an offence
if they go on to trade in Vodafone shares. This applies even if you are no longer a
Vodafone employee.
If you do have any doubts about whether you are entitled to deal in Vodafone shares,
you should contact the Group Company Secretarial department.
More information
For more information, see Vodafone’s
policy on Owning Shares in Vodafone
online by clicking here.
Anti-bribery laws
Vodafone employees must not accept or offer any form of bribe.
The law prohibits bribery in every kind of commercial setting. Additional
restrictions are in place in many countries that specifcally prohibit offering
or giving anything of value to government offcials to infuence offcial
action or secure an advantage.
We must never accept or offer any form of bribe, facilitation payment
(a payment to a government offcial to speed up a process), kickback
or any other form of improper payment. This applies to individuals and
companies in all countries. It also applies whether the payment is made
directly or indirectly, through an agent or partner. Local customs do not
provide an exception to this.
Any employee who is found to have been accepting or offering any form
of bribe will be subject to disciplinary action and may be dismissed.
To avoid any impropriety:
• Be cautious when offering or receiving gifts or entertainment.
• Even charitable donations can constitute improper payments if they are made to
facilitate a process or achieve a commercial advantage.
• Particular attention must be paid in case of any proposed gift or entertainment for
a government employee or public offcial.
• All business entertainment should be moderate in its expense.
• Travel and lodging expenses should be moderate and only offered for trips directly
promoting our products or services or benefting Vodafone.
• Ensure that any gifts are permitted under local law (and if in doubt seek approval
from your line manager).
• Obtain pre-approval as required by your local Vodafone policy.
More information
Further information on complying with
anti-corruption and anti-bribery laws
can be found online by clicking here.
For general legal advice, please see
Vodafone’s policy on Legal Advice and
Reporting online by clicking here.
10
Financial integrity
Vodafone’s money must not be used unless it is appropriately spent,
internal controls have been correctly followed and complete and accurate
fnancial records are made and kept. Vodafone maintains a system of
internal controls to reinforce our compliance with legal, accounting, tax
and other regulatory requirements. It is your duty to understand and
comply with these requirements.
It is your responsibility to familiarise yourself with local expenses and fnancial policies
that apply to your role.
You should only spend company funds if there is a legitimate business need and you
must ensure that the cost is reasonable and proportionate to the beneft.
Managers are responsible for all money spent and expenses incurred by their direct
reports and have a duty to ensure that they are carefully checked and appropriate.
Financial integrity means that you should always strive for the best possible deal. This
almost always requires that you solicit competing bids to make sure that you are getting
the best offer. While price is very important, there are also other factors to be taken into
account such as quality, service, reliability, sustainability and the terms and conditions
of the contract.
More information
For further information, check your
local delegations of authority and
fnancial policies.
See also Vodafone’s policy on
Committing the Organisation online
by clicking here.
Financial integrity
We will provide the best possible return for our
shareholders over the longer term. We will base
our investment decisions, acquisitions and
business relationships on economic criteria
but will also take into account social and
environmental considerations.
11
Accurate and complete fnancial records
Vodafone will accurately and honestly record all transactions. Vodafone
will keep records for an appropriate length of time and recognises that it
is equally important to store documents and to ensure that they are safely
destroyed once they are no longer of use.
If your job involves the fnancial recording of transactions, make sure that you are fully
familiar with all the Vodafone policies that apply.
Record all transactions correctly.
Never falsify any record or account (including time reports, expense accounts and any
other Vodafone records). We recognise that mistakes can be made but the correct course
of action is to let your line manager know so that they can help make any necessary
correction.
If you suspect or observe any of the conduct mentioned above or, for that matter, any
irregularities relating to fnancial integrity or fscal responsibility, no matter how small,
immediately report them to your local Fraud Risk and Security Department.
More information
For more information, please see
the Management and Retention of
Documents Policy online by
clicking here.
See also Vodafone’s policy on
Reporting Financial Information
to Vodafone Group online by
clicking here.
Contracts
Vodafone’s assets should not be committed or commercial arrangements
entered into without a contract. Contracts on Vodafone’s behalf must be in
writing and contain all the relevant terms to which the parties are agreeing.
Never sign any contract on behalf of Vodafone unless all the following requirements
are met:
• You are authorised to do so in accordance with your local contract approval process
and have sought legal advice where appropriate. If in doubt ask your manager.
• You have studied the contract, understood its terms and decided that entering into
the contract is in Vodafone’s best interests.
More information
For advice on contracts, contact your
local Legal Department.
Social and environmental considerations
Our decisions should be based on all relevant factors, including health and
safety, impact on local communities and impact on the environment.
Do:
• Ensure compliance with Vodafone’s Code of Ethical Purchasing.
• Ensure contractors and suppliers comply with Vodafone’s health and safety
requirements.
• Manage contractors and suppliers in such a way as to minimise the impact on the
environment.
• Take into account the guidance in this Code of Conduct under the Health and Safety,
Communities and Society and Environment sections.
More information
For further information on dealing
with suppliers and contractors,
please see Vodafone’s policy on
Contractor Control by
clicking here.
12
Company assets
Company assets belong to Vodafone and company funds, equipment and
other physical assets are not to be used for purely personal reasons.
Equipment
You have responsibility to take proper care of all company property used by you.
Any property issued to you must be kept secure and safe to minimise loss or damage and
should not be used for any activities other than those related to company business and
limited personal use in accordance with Vodafone guidelines.
Immediately report theft or loss of company equipment (including a loss of passwords or
account details) because this may present a security breach.
Intellectual property rights
Vodafone’s intellectual property rights (our trade marks, logos, copyrights, trade secrets,
know-how and patents) are amongst our most valuable assets. The consequences of
failing to properly recognise and protect our intellectual property rights can lead to loss
of their value. Any use of our intellectual property rights or intellectual property rights
belonging to others should be subject to agreement by the owner of those rights.
Do:
• Ensure that any use complies with Vodafone’s brand guidelines.
• Ensure Vodafone can protect all new inventions and ideas that can be patented;
patent applications must be fled before the invention can be discussed with anyone
other than a Vodafone employee.
• Report any suspected misuse of trade marks, logos or other Vodafone intellectual
property or counterfeit goods to your local Legal Department and always consult
your local Legal Department before responding to any offer to acquire intellectual
property rights from third parties or any allegation of infringement.
Don’t:
• Allow any third parties to use the Vodafone brand or logo without frst putting a
written agreement in place.
More information
Please refer to your local policies
on access to and use of company
equipment.
For further information about
Vodafone’s intellectual property rights,
click here to see the Group Brand
Policy, Group IPR Policy and the
Inventor Reward Rules.
Additional information on the Group
Intellectual Property strategy,
procedures and support, including
where to submit new ideas for patent
protection, can be found online by
clicking here.
13
We will build Vodafone’s reputation through proactive engagement with
government policy makers and other stakeholders such as the media,
NGOs, industry analysts and international institutions.
We will provide thought leadership on issues of importance to our industry
and its relationship with broader society and the environment.
If there are new government proposals of which you become aware and which are
relevant to Vodafone’s business, ensure that these are escalated to your external affairs
and regulatory departments to enable them to co-ordinate a response.
Don’t:
• Make a comment on behalf of Vodafone unless your comments have been approved
in accordance with the Vodafone Communications Policy.
• Use your position in Vodafone to try to infuence any other person (inside or outside
Vodafone) to make political contributions or provide support to any political parties
or politicians.
• Make any contributions or incur expenses using a Vodafone account for any political
campaign, political party, political candidate or any of their affliated organisations.
• Allow others to use resources such as work time, telephones, communications
services or meeting rooms to support any political campaign, political party, political
candidate or any of their affliated organisations.
More information
For more information, please see
Vodafone’s policy on Meeting
Regulatory Requirements online
by clicking here.
Public policy
We will voice our opinions on government
proposals and other matters that may affect
Vodafone and our stakeholders.
We will not make gifts or donations to political
parties or intervene in party political matters.
14
Communications
Provide clear and honest information at all times in language that is easy
to understand.
Make sure you communicate relevant information to your teams and to third parties in
a timely and clear manner. Act on information you receive without unnecessary delay.
Don’t:
• Make a comment on behalf of Vodafone to the media unless your comments
have been approved in accordance with your company’s policies, the Vodafone
Communications Policy and the Social Media Rules of Engagement. Failure to
comply with these requirements may lead to disciplinary action.
• Make any statement that could/will have a negative impact on Vodafone’s
reputation or its brand.
• Make reference to your employment or connections with Vodafone in any personal
communication in a way that could be interpreted, even by mistake, as a comment
or endorsement by Vodafone.
• Release any information about new products or services without the correct
approval. This is essential, as any leaked, incorrect or misleading messages can have
a real impact on the success or failure of products and services.
• Forget that when you are wearing Vodafone uniform or using company vehicles,
you are a representative of Vodafone.
When using social networking or similar sites in a personal capacity, use common
sense – if you would not say something in the real world, don’t say it in the online world.
Be yourself, but also respect the law and your fellow employees.
More information
For more information, see the
Communications Policy, the Public
and Media Relations Policy and the
Social Media Guidelines online by
clicking here.
Communications
We will communicate openly and transparently
with all our stakeholders within the bounds
of commercial confdentiality. We will protect
confdential information from improper disclosure,
and any authorised communication of confdential
information should be limited to individuals who
need it to carry out their work.
15
Confdential information
We all have a duty to protect Vodafone’s confdential information.
Confdential information can include legal agreements, technical
specifcations, business information and any other information which
is unlikely to be publicly known and has commercial value.
When we receive information from third parties, including other Vodafone
companies, we must ensure that this is treated with the same level of
security as our own confdential information. If information has been
provided for a particular purpose, it must only be used for that purpose.
We have created an Information Classifcation Standard to help us classify
information for the appropriate audience. It is your duty to ensure that any
information you create is classifed and only disclosed in accordance with
the Information Classifcation Standard.
Sharing information
Before sharing confdential information with third parties or within Vodafone:
• Check that there is a written agreement in place with any third party to protect
confdentiality.
• Check that Vodafone is permitted to share the information under the relevant
agreement.
• Ensure that any Vodafone documents are appropriately labelled as confdential
and disclosed under an obligation of confdentiality.
• Limit the distribution to people who have a need to know.
You should not disclose confdential information to anyone, not even your partner
or family members, in breach of a confdentiality agreement or the Information
Classifcation Standard.
Personal relationships
If you have family or other personal relationships with people employed by our
competitors, customers, suppliers or partners we not only expect you to preserve
Vodafone confdential information but you should also not solicit confdential
information from them about their company.
Competitors
You should not discuss any confdential information with any competitor (or accept
any such information from a competitor) as this is likely to break competition laws.
Unsolicited information
If you receive any unsolicited information from a third party with proprietary
business information, return or delete the information, do not use it within Vodafone
and, if appropriate, respond politely to the sender asking them not to send any
further information.
It may not always be clear whether information is confdential – if in doubt, ask for
guidance from your local Legal Department.
More information
See the Information Classifcation
Standard online by clicking here.
If you are being approached by or
on behalf of a competitor and have
concerns, contact your Legal and
Fraud and Security Departments.
16
More information
For more information, click here
to see our dedicated site, Privacy
Matters, to learn more about what
privacy means to Vodafone and to
see Vodafone’s Privacy Principles.
To fnd out what privacy training
is available to you, contact your
Privacy Offcer.
Customers
We will value the trust our customers place in
us and will safeguard the information provided
to us.
Privacy
Customers trust Vodafone with their privacy and we place enormous
value on this trust. It’s our goal to create a culture of privacy across our
business and to be a trusted and responsible guardian of the privacy of
our customers.
To our customers, privacy means a number of different things – ensuring that their
private communications remain private, not being disturbed by inappropriate or
unwanted communications or spam, or ensuring that their personal information is
handled in the right way.
What is meant by ‘personal information’ is often a lot wider than you might think – for
example, it includes our customers’ mobile numbers, even where we don’t have a name
or address for them. Some types of information are particularly sensitive and can only
be handled in limited circumstances, such as:
• Information relating to their communications content (eg messages, voicemails);
• Traffc and location logs that we capture from our networks; or
• Information we capture that may reveal sensitive details about a person’s nationality,
health or sex life or their religion or beliefs.
Do:
• Respect our customers’ privacy in everything you do. For instance:
– When developing products and services, think about designing privacy in from
the outset
– When communicating with customers about privacy, make it clear and simple
– When relying upon other companies to handle our customers’ information,
consider carefully whether they are trusted and reliable and what safeguards
we can take
– Remember that privacy is about more than just keeping personal information secure.
• Find out who your Privacy Offcer is – every Vodafone company must have one.
• Undertake the Online Privacy Awareness Training available for all employees.
Don’t:
• Ever access or provide customer information to anyone without proper authorisation.
Not only will you be in breach of this Code, but you may also commit a criminal offence.
17
Equal opportunity
We are committed to creating an inclusive work environment where all
employees have equal opportunities through clearly defned employment
policies and practices, which shall apply to recruitment, selection,
promotion, discipline, development, compensation and termination.
We will comply with these policies at all times.
If any employees believe that they are a victim of discrimination, they should notify their
local Human Resources Department.
Do:
• Demonstrate respect and fairness in all your interactions with employees and
external parties consistent with Vodafone’s Business Principles, policies and
procedures.
• Understand relevant local legislation and culture that may have an impact on
workplace decisions.
• Report equal opportunity concerns through the appropriate Vodafone procedure.
• Ensure that all employment-related decisions, such as hiring new employees,
are free from discrimination and determined on the basis of merit and business
considerations alone.
• If you are concerned about another employee’s actions and behaviour, explain why
and ask them to stop or tell your manager.
Don’t:
• Tolerate unlawful discrimination of any kind.
More information
For further details please see your
local Equal Opportunities Policy.
Contact your local Human Resources
team if you have any questions
about any equal opportunity
employment laws.
Employees
We will base relationships with and between
employees on respect for individuals and their
human rights and will not tolerate child labour.
We will not accept any form of discrimination,
harassment or bullying. We will pursue equality
of opportunity and inclusion for all employees
through our employment policies and practices.
18
Harassment and bullying
Bullying and harassment have no place in Vodafone. Harassment can have
a serious impact on both the health and happiness of employees and the
productivity and success of the business. We are committed to ensuring
that our employees develop in a positive environment. Where we see any
harassment or bullying happening, we put a stop to it, fast.
We defne bullying and harassment as unwanted behaviour from another
person where you feel it is intimidating, malicious, offensive, insulting,
humiliating or degrading. It may be related to age, gender, sexual
orientation, race, disability, religion or belief, and can be either a repeated
or a one-off incident. It can be verbal, non-verbal or physical and isn’t
always face to face (eg displayed images, email, phone, social
networking websites). It doesn’t have to be targeted at an individual and
can be about creating an unwelcoming or hostile environment.
Harassment is illegal in many countries and employees must understand
and implement the requirements set by local laws. Guidance can be found
in your employee handbook and can be obtained from your local Human
Resources team.
Any examples of harassment will be taken very seriously and may lead to
disciplinary action, including potentially dismissal and legal action. If any
employees believe that they are victims of harassment or bullying, they
should notify their local Human Resources Department.
Some examples of what we class as harassment and bullying are:
• Insulting someone particularly on the grounds of his or her age, race, sex, disability,
sexual orientation or religion.
• Making fun of someone or putting them down.
• Excluding or isolating someone from work or social activities.
• Picking on someone because they have made a previous complaint of harassment.
• Unwelcome firtation, sexual advances or sexual assault.
• Touching or standing too close when not invited to.
• Displaying or circulating offensive materials (eg rude, racist or sexual pictures
or cartoons).
• Making decisions on the basis of sexual favours being accepted or rejected.
• Making inappropriate jokes or comments.
• Misuse of power or a position of authority.
Harassment and bullying are not limited to these examples.
Whether you are using company or personal communications, when discussing
employees, take care to ensure that you do not communicate derogatory, harassing
or abusive information. Remember to apply the same standard in all forms of
communication no matter how informal they may appear.
More information
If you do not feel you can talk to your
co-workers or manager about an issue
you can always speak to a member of
your local Ask HR team or your Human
Resources Business Partner.
For further details please see your
local Bullying and Harassment Policy.
19
Alcohol and drugs
We are committed to providing a positive and safe environment for
allour employees. We will not tolerate illegal substances, alcohol or
violence in the workplace. Any use, sale or distribution of illegal
substances will be treated with the utmost seriousness and may lead
to dismissal and legal action.
While alcohol is legal in many countries it is illegal or prohibited in others. It is your
responsibility to ensure that you comply with all applicable law.
Even if alcohol is not prohibited in your country it is not acceptable in the workplace unless
consumed in moderation at either a work event or as part of approved corporate hospitality
normally outside your working hours. You must remain professional and be able at all times
to carry out your work duties.
If you notice that an employee is or may be using illegal substances or consuming
alcohol in the workplace in breach of this Code of Conduct please support them by
notifying your local Human Resources team. Substance abuse can be destructive and
potentially dangerous to the individual and others.
Privacy
We will value the trust our employees place in us and will be a trusted and
responsible guardian of their privacy.
Do:
• Respect that employees have a right to a private life when working.
• Respect and protect the personal information of our employees to the same
extent as we do for our customers.
Don’t:
• Intrude into any aspect of an employee’s personal privacy, such as their PC, phone,
email account, or through use of workplace surveillance, without compliance with
your local workplace monitoring policy and authorisation from your Privacy Offcer.
More information
For further details please see our
Occupation Health & Safety and
Wellbeing Policies online by
clicking here.
For more information on support in
relation to alcohol or drug related
illnesses, please see Workplace
Options.
More information
For more information click here
to see Vodafone Privacy Principles.
Speak to your local Privacy Offcer
to learn about our policies on
workplace monitoring.
Any workplace monitoring that
does take place will be set out
clearly in these policies and will
apply to all forms of communication,
including your mobile phone use,
email, chat, etc.
Harassment and bullying (continued)
What can you do?
If you notice any discrimination, harassment or bullying among your work colleagues,
speak up; the victim of harassment may feel unable to do this and we need to support
each other. If it feels unsafe to raise the issue directly contact your local Human
Resources Department for advice on how to resolve the issue.
Travelling/working abroad
If you are travelling or working abroad ensure that you familiarise yourself with local
customs, regulations and the local Employee Handbook. Be sensitive to different
cultures; talk to local managers and the local Human Resources Department and adapt
your behaviour as necessary.
20
Vodafone recognises that our day-to-day operations will impact on the
environment in a number of ways. We are committed to minimising the
potentially harmful effects of our activities wherever and whenever possible.
We will adhere to relevant environmental legislation and international
standards. In countries where environmental legislation is not evident
or enforced, we will ensure that responsible practices for managing
environmental impacts are in place.
We will minimise our use of fnite resources (such as energy, water and
raw materials), and the release of harmful emissions to the environment
(including waste, air emissions and discharges to water).
We will seek to improve the environmental performance of the products
and services we provide, for example by increasing energy effciency, or
reducing waste.
We will support innovative developments in products and services that can
offer environmental and social benefts to our customers.
Consider what opportunities exist in your working life to contribute to Vodafone’s
environmental commitment, specifcally:
• Make sure you are familiar with the environmental laws, regulations and policies that
apply to your job.
• Look for opportunities to reduce waste – don’t print if you don’t need to, turn off
lights, don’t over order consumables.
• Dispose of any materials carefully – if you have access to recycling facilities then
make sure you know how to use them.
• Make the most of being online – it reduces the need for hard copies of documents,
saving paper and energy costs.
• Think of the environment when travelling – can you video conference or telephone
instead? Can you walk or use public transport? Can you car share?
• Build environmental considerations into your purchasing decisions.
More information
Please refer to your individual
operating company intranet site
for information on how we manage
our environmental issues or look
at vodafone.com/responsibility/
environment.
For more information about dealing
with suppliers, see Vodafone’s Ethical
Purchasing Policy online by
clicking here.
Environment
We will commit to protecting the environment. We will minimise our use of
fnite resources (such as energy, water and raw materials) and the release of
harmful emissions to the environment (including waste, air emissions and
discharges to water). We will seek to improve the environmental performance
of the products and services we provide, as well as support those that offer
environmental and social benefts to our customers.
21
Vodafone relies on local communities. Our network is set up and
maintained in the communities around us. Our customers are affected
by the way in which we operate in their communities and trust us to act
with integrity. We respect any concerns that these communities have
and always try to answer any questions or worries raised. We also provide
charitable support to many communities. Our aim is to work together for
the beneft of the communities and Vodafone.
Do:
• Be sensitive to the needs of the local community in which you are based and listen
to any concerns about Vodafone’s operations. Make sure issues are raised with the
relevant department.
• Use inclusive communication and engagement practices to ensure that different
groups in the community have an opportunity to be heard.
• Contact your local Vodafone Foundation to see what you can do in your
local community.
More information
For more information about network
deployment, see Vodafone’s
Responsible Network Deployment
Policy online by clicking here.
Vodafone has specifc processes to
address any concerns about the
effects of electromagnetic radiation:
please refer to the relevant policy
standard, and to your local EMF leader.
Communities and society
We will engage with local communities to help us understand and respond to
any concerns they may have, for example in relation to network deployment.
We will always provide our stakeholders with access to correct, relevant and
current information and build trust through integrity, transparency, honesty
and objectivity. We will invest in society in a way that makes effective use of
our resources, including support for charitable organisations.
22
It is the responsibility of all of us to take steps to protect the health, safety
and wellbeing of ourselves, each other, our partners, our customers and
the wider communities in which we operate.
Vodafone is committed to ensuring a stimulating, safe environment and
supporting health, wellbeing and work–life balance for all of our employees.
To achieve this, Vodafone expects our leaders to lead by example –
identify risks, establish controls and monitor performance for the area
they manage. Vodafone has dedicated health, safety and wellbeing
management systems and structures to manage health, safety and
wellbeing risks.
Vodafone reports, records and investigates our incidents, and
communicates our performance transparently internally and externally.
Do:
• Comply with the Vodafone Absolute Rules – these are designed to protect you from
risks we know can cause serious harm.
• Understand and comply with the policies, standards, procedures and arrangements
that Vodafone has put in place to ensure your health and safety at work.
• Ensure that our suppliers and partners identify, assess and manage risk for all
activities and services undertaken and/or products provided on Vodafone’s behalf
and can comply with all applicable laws relating to health and safety and Vodafone’s
Code of Ethical Purchasing.
• Report all accidents, unsafe practices and unsafe situations immediately. This will
help us prevent accidents in the future.
• Intervene when you see unsafe acts and conditions. If you are not sure how to do
something, or consider the activity to be dangerous, stop and seek advice.
• Act quickly to initiate an immediate investigation in the event of accidents or
emergencies. This includes if there is doubt over the safety of a product or service.
• Recommend innovation or improvements, and commend others doing the right thing.
• Consider the impact of work on your wellbeing and your work–life balance as well as
the wellbeing and work–life balance of others.
More information
Further information can be found
on the Vodafone intranet under
Health and Safety and Wellbeing
and Health and Safety Policy and
Procedures, the Absolute Rules
and the Employee Handbook.
You may fnd more information
on product safety online by
clicking here.
Health and safety
We will protect the health, safety and wellbeing
of our customers, employees, partners and the
communities in which we operate and disclose
any information that comes to our knowledge that
clearly demonstrates that any of our products or
services breaches internationally accepted safety
standards or guidelines.
23
Avoiding conficts of interest
We have a duty to always act in the best interests of Vodafone and its
customers. If a competing loyalty arises an individual may be subject to
a confict of interest. You should avoid circumstances that may lead to
either a confict of interest or the appearance of a confict. If you are in
a position that is a confict of interest, disciplinary action may be taken
against you including, potentially, dismissal.
To avoid a confict you should:
• Recognise when you are presented with situations that might result in you having
a loyalty that competes with your duties to Vodafone.
• Discuss any concerns with your line manager.
• Ensure that in performing your job you continue to act in the best interests of
Vodafone.
• Don’t allow yourself to be put in a position where you have a personal interest in,
or infuence over, a contract or relationship. If you do have a personal interest in the
outcome, avoid taking part in the decision-making process.
As a guide, ask yourself whether you would feel comfortable explaining your actions
to friends/co-workers/media.
If you are a director, be aware that additional duties may apply to you by virtue of your
role as a director under applicable law.
More information
If in doubt contact your local Human
Resources or Legal Department.
For more information, please see your
local policies on Conficts of Interest.
Individual conduct
We will act with honesty, integrity and fairness in our dealings both internally and
externally. We will not tolerate any form of bribery, including improper offers of
payments or gifts to or from employees. We will avoid any contracts that might lead
to, or suggest, a confict of interest between personal activities and the business.
We will neither give nor accept hospitality or gifts that might appear to incur an
obligation. We will pursue mutually benefcial relationships and seek to promote
the application of our Business Principles with our business partners and suppliers.
24
Gifts, entertainment and payments
Vodafone policy prohibits accepting signifcant gifts or any other business
courtesy (including discounts or benefts that are not made available to all
employees) from any of our customers, suppliers, partners or competitors.
We appreciate that business relationships will sometimes result in a need
to receive or offer a modest gift or hospitality. In fnding this balance,
we must ensure that we are not infuenced, or seen to be infuenced,
in our decisions by payments or gifts and that there is a genuine and legal
business purpose in accepting or giving the gift.
If you are offered any signifcant gifts, notify your line manager and only accept the gift
if it is approved. There may also be additional requirements in relation to registering gifts
in your company; check with your local Human Resources representative. Gifts may take
many forms including invitations to attend events. Gifts should always be infrequent,
modest and should not include any element of cash or a cash equivalent.
Remember:
• Don’t accept any gift that may create the appearance of impropriety.
• Never accept gifts from competitors or government offcials.
• Don’t accept gifts of cash or cash equivalents (eg gift certifcates or prepaid gift
cards) even if they have a low value.
• Never ask for gifts or hospitality.
While we appreciate that local customs may require the giving or accepting of modest
gifts this should always be in accordance with your local policy.
Equal care and consideration needs to be taken in offering gifts.
Personal investments
Personal investments in a supplier, business partner or competitor may
lead to a confict of interest.
Avoid signifcant investments that may cause you to act in a way that benefts you at the
expense of Vodafone. Senior managers and directors have a particularly broad infuence
in this regard and should take extra care in choosing their investments.
In many countries, investments by any employee in unconnected mutual funds or similar
vehicles that invest in a broad cross-section of publicly traded companies that may
include competitors, customers, suppliers or partners of Vodafone would generally not
be considered a confict. However, it remains your responsibility to check whether your
investments are permitted by local law and whether they require prior approval.
More information
For more information, please see:
Vodafone’s Corporate Hospitality
Policy online by clicking here.
Vodafone’s Charitable Donations
Policy online by clicking here.
25
Outside employment and board memberships
Working for a supplier, customer, partner or competitor (including as a
consultant or advisor, whether paid or unpaid) can create a confict of
interest. Membership on the boards of customers, suppliers, partners
or competitors of Vodafone is especially problematic from a confict of
interest perspective because board seats generally involve the ability
to infuence the actions of the third-party business.
Avoid employment with suppliers, customers, business partners or companies that
compete with Vodafone.
If you are engaged on an external board or in outside employment ensure that you do not
use your position within either company to infuence your role with the other company.
Some countries also have restrictions on the amount of time you can spend working.
Breaching these rules may affect your health and wellbeing and could expose
Vodafone to a fne. Disclose any outside employment to your local Human Resources
representative.
Seek guidance from your line manager or local Human Resources representative if you
have any doubts as to whether a potential board membership or outside employment
would constitute a confict of interest.
Remember:
• Don’t accept employment with a supplier, customer or partner if you have the ability
to infuence their relationship with Vodafone.
• Never accept concurrent employment or consultancy with a competitor.
• Always declare any outside employment and board memberships to your employer.
• Continually assess whether your dual loyalties are likely to place you in a position of
confict and report any concerns to your manager.
26
Friends, relatives and co-worker relationships
Business relationships with relatives, spouses and signifcant others
or close friends can lead to a confict of interest that can be diffcult
to resolve. Similarly, intimate relationships between co-workers can,
depending on the work roles and respective positions of the dating
co-workers, create an actual or apparent confict of interest. If you are
faced with the possibility of such a business or personal relationship
you should discuss the relationship with your manager.
Business relationships
If you are involved in a relationship, on behalf of Vodafone, with an organisation or
business where a partner or relative is employed, you should ensure that your line
manager is made aware of the personal relationship so that steps can be taken to ensure
that no confict of interest arises in the business relationship.
Remember:
• Do notify your manager of any potential confict.
• Do conduct your relationships with contractors and suppliers in a professional and
impartial manner.
• Don’t allow your personal relationships with contractors and suppliers to infuence
any business decisions that you make on behalf of Vodafone.
Co-worker relationships
If you become involved in an intimate relationship with a co-worker and you feel that
this may place you or your partner in a position of confict, you should discuss this issue
with your local Human Resources team. The issue will be handled sensitively but it may
be necessary to make changes to your working environment or reporting structure,
including potentially transferring one or both of the employees, to avoid any confict.
Don’t:
• Get involved in the hiring, supervising, management or career planning of any
relative or partner.
• Let your personal relationships infuence, or be seen to infuence, your decisions
at work.
More information
Refer to your local Employee
Handbook for further information.
27
For Vodafone to maintain its reputation we each need to assume
responsibility for our actions and to take action if something is not done in
the Vodafone way. If you suspect a breach of The Vodafone Code of Conduct
you should report it. Unless otherwise stated in this Code of Conduct or the
Vodafone Group Security Policy you should report all suspected breaches
frst to your line manager. If this is not appropriate in the circumstances you
should report the matter to your local Human Resources team, local Legal
Department or Group Corporate Security Department.
Each employee has a duty to report:
• Financial malpractice, dishonesty, money laundering, corruption or fraud.
• Failure to comply with a legal obligation that may result in criminal liability or
damage to Vodafone’s reputation.
• A serious breach of Vodafone policy relating to any criminal activity.
• Any breach or potential breach of data privacy or unlawful disclosure of sensitive
and confdential information.
• A serious breach of competition law (eg price fxing).
• Endangering health and safety of employees or the public or serious environmental
issues, including threats and assaults involving any Vodafone personnel.
• Any other suspected criminal activity.
• Serious confict of interest without disclosure.
• Any attempt to conceal any of the above.
If you have a concern that you feel is particularly sensitive, which cannot be dealt with
through the normal channels and is not covered by the Vodafone Group Security Policy,
you may report the matter to Group Legal.
More information
For further information refer to
the Security Policy online by
clicking here.
If you don’t feel comfortable talking to
your line manager or an internal team,
there’s the ‘Whistleblowing Procedure’
where you can report an incident
anonymously. You may also know
this procedure as ‘Speak Up’ or ‘Doing
what is Right’. The Whistleblowing
Procedure is an addition to, not a
replacement of the Security Policy and
can be found here.
Alternatively, in some countries
you may be able to contact the
appropriate ombudsman or
ombudswoman.
Duty to report
Further information
For any further information and for questions about The Vodafone Code of Conduct generally, please speak to your
manager or contact your HR team.
Vodafone Group Plc
Vodafone House
The Connection
Newbury
Berkshire
RG14 2FN
England
Tel: +44 (0) 1635 33251
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