The Vodafone Code of Conduct. Doing what s right

Transcription

1 The Vodafone Code of Conduct Doing what s right

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3 Trust is fundamental in everything we do.

4 2 Contents A message from our Chief Executive 3 Why we have a Code of Conduct 5 Our Business Principles 7 Speak Up 9 Individual conduct 11 Security of our people, property and information 11 Compliance with the law 17 Anti-money laundering 20 Health and safety 22 Financial integrity 23 Public policy 26 Communications 27 Customers 29 Employees 31 Communities and society 34 Environment 35 Contents

5 3 A message from our Chief Executive Vittorio Colao Vittorio Colao

6 4 Contents

7 5 Why we have a Code of Conduct The Vodafone Way Our Business Principles The Vodafone Way Customer Obsessed We are passionate about exceeding customer expectations Immerses self in customer experience Takes personal accountability for the customer experience Looks outside Vodafone to understand customer experience, behaviour and trends Ambitious & Competitive We bring energy and passion to our work and always aim to beat the competition Raises the bar for self and team Delivers lean and cost effective every time Strives to outperform competitors looks beyond internal benchmarks Innovation Hungry We create and deliver new products, services and ways of working that delight our customers Takes risks and pushes what s possible; always looks for innovation Looks outside of Vodafone for ideas and inspiration and acts on these Implements solutions which are simple, impactful and replicable One Company, Local Roots We work across Vodafone to achieve the best outcome for customers, employees and shareholders Collaborates across markets & functions; makes best decision for Vodafone as a whole Influences across the business shapes thinking and impacts others views Values our differences and acts inclusively, communicates and uses best practice Speed We drive speed to market. We relentlessly matter to our business Makes RAPID business decisions Delivers the right things with urgency Analyses fast, executes fast Sets direction; generates commitment & engagement Simplicity We make things simple for our customers, partners and colleagues Acts and communicates with simplicity Prioritises the right things Creates a simple working environment Be an Admired Leader Enables performance, balancing task, people & results Trust We are reliable and transparent to deal with. do likewise Do what you say you will do Trust others to deliver Support decisions once made Builds capacity through growing talent & skills, high performing diverse teams and a lean & effective organisation

8 6 What is the Code of Conduct? Who is the Code of Conduct for? What are the consequences of not complying? your work Speak Up if you feel a working practice Following the law contact your line manager, Legal, HR, or If you are a line manager, you have an important role in ensuring our Code of Conduct is understood and applied by your team. In particular, we expect you to: If you are ever unsure about what to do you should ask yourself: Contents

9 7 Our Business Principles Individual conduct Compliance with the law Health and safety Financial integrity Communications Customers Employees Communities and society correct, relevant and current information Environment Public policy

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11 9 Speak Up I am a contractor working on a Vodafone contract and I have a concern to report. Can I use the external Speak Up line? A: Q: I am concerned that my I raise a concern. Will it be A: Q: What if I report something suspicious that turns out not to be a compliance breach? A: Q: I have a concern about the actions of a colleague. How should I report this? A: The most important thing is that you report your concern. Ultimately, it doesn t matter which route you choose. If you feel comfortable talking to your line manager, do that. Your line manager is there to support you and can help you choose the correct course of action.

12 Policy portal Speak Up page Preferred contact: Local HR team 10 1 Report it to your line manager: 2 Report it to your local HR team: external Speak Up hotline: Click Speak Up on the intranet to see loca local free phone numbers or to make a report online What happens next? external Speak Up line by providing an Contents

13 11 Individual conduct Security of our people, property and information Integrity Availability Q: A colleague is covering my role while I am on holiday and needs access to the systems I use. It s a lot of hassle to get them a log-in and password, can I just give them mine? A: Q: I m working from home and I m having problems accessing the Vodafone network. Can I ask my colleague to send me the information I need to my personal account? A: Q: Can I allow my visitor to make his/her own way out of the building?

14 Policy portal Global Corporate Security Portal Preferred contact: Corporate Security team Training 12 1 Value information and classify it 2 Clear your desk and lock your screen 3 Protect your password 4 Think before you click 5 Protect data at all times Contents

15 13 Policy portal Preferred contact: Local HR team interest register Q: I work part-time in my family business. Do I need to declare an interest? A: actual appropriate time and attention Recruiting or managing a relative or partner potential

16 14 Tell your local manger and HR team about: a contract Q: A close friend is applying for a job in Vodafone, is this OK? A: What to do if you see yourself in a situation of potential Step 1 Step 2 Step 3 Contents

17 15 Gifts and hospitality proportionate giving and receiving of of inappropriate value be rare approval from Group Q: I ve been invited out to dinner by a potential supplier currently bidding for a new contract. What should I do? A: Q: I ve been sent a high value gift by a supplier and don t want to cause offence by returning it. What should I do? A: notify your line manager and Q: My travel costs into the claim some of it back? A:

18 Policy portal Preferred contact: Local Legal team Gifts and hospitality register 16 Travel and expenses Managing our information and documents local Management and Retention Q: Can I claim expenses for my partner or spouse to travel with me? A: Taking your partner, friend or family member on a Q: I think I am going to retain all my documents, in case they are needed in the future. Is that OK? A: be retained for audit, tax or Contents

19 17 Compliance with the law Insider dealing information committing an offence Q: My friend is thinking about selling some Vodafone shares in the next few days. I know Vodafone is due to make an announcement that will have a positive impact on the share price. Is it okay if I drop hints to my friend that he should wait to sell? A: Q: My colleague sent me an containing information about a competitor which could easily be misinterpreted. What should I do? A: Q: While at a conference, a sales director from another company started talking to me about the economic outlook in Europe and what this meant for our data pricing plans for the future. What should I do? A:

20 18 Policy portal Preferred contact: Local Legal team Training Competition laws 1 Have a basic knowledge of how the competition rules apply to you 2 Always be vigilant in your business dealings with third parties 3 If in doubt, ask your local Legal team. Contents

21 19 Bribery and improper payments never offer or accept any for more information are permitted by local law a commercial advantage Q: I am travelling abroad later this month and need to get a work visa quickly. The person processing my request at the embassy has said that they can speed up the process if I pay a small fee in cash. Is this okay? A: Legal department for advice

22 Policy portal Preferred contact: Local Legal team Training 20 Anti-money laundering prevention, detection and reporting of employee training, and compliance Q: Why does Vodafone need to comply with anti-money laundering regulations I thought it was aimed at banks? A: Q: I have seen a transaction that doesn t seem right I m not sure if it is money laundering, it may be legitimate what should I do? A: evidence to validate your report to your local Money Contents

23 21 Policy portal Preferred contact: Local Legal team Global sanctions any kind manager or local team immediately if Q: I am selecting a new supplier through the Vodafone Procurement Company, do I need to screen against sanction lists? A: Q: I have discovered that one of the Vodafone products that requires an export license does not have one. What shall I do? A: Contact Trade controls If in doubt, contact your local

24 Health and safety Policy portal Preferred contact: Training 22 Absolute Rules Q: You are travelling with a new work colleague, you get into a taxi at an airport. As the taxi drives off your colleague has not put their seat belt on, what should you do? A: Q: I often think when I walk things that are potentially dangerous, I don t mean things that are likely to kill someone but could easily cause injury. I am not sure if I have the authority to stop people and tell them what they are doing is dangerous? A: Contents

25 23 Financial integrity Financial integrity your role Q: I think my colleague is regularly claiming taxi fares for working after hours but actually takes public transport home. What should I do? A:

26 Policy portal Preferred contact: Local Legal team 24 Committing to contracts and expenditure Operating a responsible supply chain Q: I have the power of attorney to sign a contract in my local market, which is higher than the allowance I have in the Delegation of Authority. Can I sign the contract as I have power of attorney, even if it s not aligned with Delegation of Authority? A: Q: I have a supplier that I suspect has breached the Code of Ethical Purchasing. What should I do? A: details of my Delegation of Authority limits? A: Contents

27 25 Policy portal Preferred contact: Local Legal team IPR page Protecting our brand and other assets Our brand Policy Standard Intellectual Property Rights (IPR) relevant IPR Physical assets Q: Sometimes I see products bearing the Vodafone logo on a stall at my local market. I think they are counterfeit. Do I need to let someone know? A: Q: In my team we discuss extensions for existing products and services but have not found a place to capture our ideas. Does such a place exist? A: Q: I m not sure whether an idea I ve had might be worth something. Can I discuss it with our suppliers to get their views? A: your local Legal team

28 Public policy Policy portal Preferred contact: 26 for any political campaign, political political campaign, political party, Q: A local reporter has contacted me through a mutual friend to ask me about this year s annual report. Can I comment? A: to comment publicly on Contents

29 27 Communications Speaking on behalf of Vodafone Provide clear information in language Q: Am I allowed to say where I work on my social A: can include a link to your local

30 Policy portal Preferred contact: Local Internal Communication team Communication team 28 Using social media reputation or brand Q: There are a lot of guidelines to follow when using social media, can you summarise them please? A: Contents

31 29 Customers Our Privacy Commitments Respect Openness and honesty Choice Privacy by design Balance Laws and standards Accountability

32 Policy portal Preferred contact: Training 30 If you are involved in product for you and your team need to follow an advocate for privacy by joining our Q: I m working on a project involving a use of customer information that is not covered by law. Do I still have to think about privacy? A: Q: I ve been contacted by the law enforcement authorities in my country with a request for access to personal information. What do I do? A: to a Government or law More information can be found in our Privacy and Law Q: I m building a Vodafone application that will use personal information. How do I make sure privacy is protected can I simply add a privacy policy to the app? A: information take a look at our Contents

33 31 Employees Diversity and inclusion local law make purely on merit accept any form Q: A colleague is recruiting a new team member. I am concerned that they may be discriminating against certain candidates. Should I challenge them? A:

34 Policy portal Preferred contact: Local HR team 32 Preventing harassment and bullying informal you are being Q: I can see that one of my colleagues is being picked on constantly by other team members. I want to raise this but I am concerned that it might be my turn next. What should I do? A: Speak to your line manager do not feel comfortable doing Contents

35 33 Q: My colleague regularly arrives at work appearing alcohol. I know he is having should I do? A: Drugs and alcohol to your local HR team

36 Communities and society Policy portal Preferred contact: 34 Local communities Charitable support Get involved in your local community via Q: My team wants to raise money for a local charity, are there any restrictions on who to donate to? A: Q: I thought human rights were the government s responsibility? Why do I have to worry about them? A: Contents

37 35 Environment Policy portal Preferred contact: colleague if you need a car

38 36 used in this Code Q: What is an arrangement? (p17) A: Q: What is inside information? (p18) Q: What is a bribe? (p19) A: A: Q: What are facilitation payments and kickbacks? (p19) A: a routine government action, for example to an individual in return for a referral, Q: What does reasonable and proportionate mean? (p15) A: (p14) A: Q: What is a close relationship? (p15) A: Q: What is sensitive information? (p12) A: Q: What do we mean by discrimination? (p31) A: Q: What do we mean by harassment and bullying? (p32) A: be related but not limited to age, gender, Contents

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