Anti-bribery, corruption and fraud
At Vodafone, we support and foster a culture of zero tolerance towards bribery and corruption in all our activities.
Our anti-bribery policy
Our policy on this issue is summarised in our Code of Conduct and states that employees or others working on our behalf must never offer or accept any kind of bribe. Our anti-bribery policy is consistent with the UK Bribery Act and the US Foreign Corrupt Practices Act and provides guidance about what constitutes a bribe and prohibits giving or receiving any excessive or improper gifts and hospitality. Any policy breaches can lead to dismissal or termination of contract.
Facilitation payments are strictly prohibited, and our employees are provided with practical training and guidance on how to respond to demands for facilitation payments. The only exception is when an employee’s personal safety is at risk. In such circumstances, when a payment under duress is made, the incident must be reported as soon as possible afterwards. We consistently evaluate our anti-bribery programme by conducting periodic monitoring activities, risk assessments, policy compliance reviews, and internal audits to ensure its effective implementation.
To support our approach, we are also a member of Transparency International UK’s Business Integrity Forum.
Governance and risk assessment
Our Group Chief Executive and Executive Committee oversee our efforts to prevent bribery. They are supported by local market Chief Executive Officers, who are responsible for ensuring that our anti-bribery programme is implemented effectively in their local market. They, in turn, are supported by local specialists and by a dedicated Group team that is solely focused on anti-bribery policy and compliance. The Risk and Compliance Committee assists the Executive Committee in fulfilling duties with regards to risk management and policy compliance.
Our minimum anti-bribery standards for every Vodafone business include:
Risk Assessment
Conducting a comprehensive anti-bribery risk assessment.
Due diligence process
Ensuring there is a due diligence process for suppliers and business partners at the start of the business relationship.
Employee training
Completion of the global e-learning training for all employees1, as well as tailored training for higher risk teams.
1Exceptions apply for employees in Germany.
Gifts and Hospitality, sponsorships and charitable contributions
Registering gifts and hospitality in a designated platform in line with relevant policy requirements, as well as ensuring there is a process for approving local sponsorships and charitable contributions.
Engaging employees to raise awareness of bribery risk
We run a multi-channel high-profile global communications programme, ‘Doing What’s Right’, to engage with employees and raise awareness and understanding of the policy. The ‘Doing What’s Right’ programme features e-learning training, including a specific anti-bribery module. For higher-risk employees, additional tailored training programmes are used to cover relevant scenarios for those employees. We also conduct internal communication campaigns using a range of materials to highlight some of the key messages around zero tolerance to bribery and corruption, including communications from senior management.
Assurance
Implementation of the anti-bribery policy is monitored regularly in all local markets as part of the annual assurance process, which reviews key anti-bribery controls. Appropriate remedial actions are put in place for any identified gaps.
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