44 Vodafone Group Plc Annual Report 2026
Strategic report
Governance
Financials
Other information
Maintaining Trust
Code of Conduct Strategy
grievance mechanisms, they are required to notify us of any concerns raised that relate to work undertaken on our behalf, ensuring transparency and alignment with our expectations. This year We refined our approach to consequences and non-retaliation by embedding standalone global standards across our local markets through training, communication, and reporting. Our non-retaliation standard ensures everyone who raises a concern in good faith is treated fairly, with no negative employment consequences regardless of the outcome of any subsequent investigation. Our consequence management standard supported consistent and proportionate consequences, no matter who the individual is and what market they are based in. This year, 808 (FY25: 684) separate concerns were reported using Speak Up. To ensure a consistent approach to Speak Up across our markets, we conducted detailed training with local committees on the aforementioned standards, their responsibilities, the criteria for escalating cases to the Group, and the risk controls they will be measured against annually. Speak Up topics raised during the year Topic 1 Speak Up reports (%) Requiring remedial action (%) People issues 2 66 37 Integrity 27 37 Other 6 47 Health and safety 1 38 Notes: 1. T here were 0 reports relating to modern slavery concerns reported during the period (FY25: no reports). 2. D iversity, equity and inclusion topics accounted for 3% of the People issues reported.
Looking forward We are committed to ensuring that our employees have a clear understanding of compliance, and part of this commitment is reflected in our continued improvements to both our digital Code of Conduct and the Global Policy Portal (‘GPP’). We are currently running a comprehensive programme aimed at enhancing our policy environment. The focus is on making our resources more user-friendly and ensuring greater emphasis on the risks that matter most to our business. We are also preparing to relaunch our updated Code of Conduct in FY27. Read more about our principal risks and uncertainties on pages 60 to 62 Speak Up Strategy Our Speak Up programme enables employees to report, in confidence, any behaviour that may be unethical, unlawful, criminal, or in breach of our policies, systems or processes, and therefore inconsistent with our Code of Conduct. The programme is owned by the Chief Human Resources Officer and overseen by the Group Risk and Compliance Committee. All reports are investigated confidentially by trained local specialist teams. Each local market and operating segment has a senior Speak Up Committee to govern the programme, oversee investigations, verify actions or remediations have been taken (if applicable), and ensure that consequences are applied consistently. The Group Audit and Risk Committee receives an annual update on the overall effectiveness of the Speak Up programme and emerging trends. Speak Up is available to all, including our suppliers and is communicated through our Code of Ethical Purchasing. Where suppliers operate their own
Our Code of Conduct sets out what we expect from every employee working for us, regardless of location. We also expect our suppliers and business partners to uphold the same standards as set out in our Code of Ethical Purchasing. Read more about our approach to responsible supply chain on pages 48 Click to read our Code of Conduct: vodafone.com/code-of-conduct Our DWR training and communication programme is key to embedding a shared understanding of the Code of Conduct across Vodafone. This year Our DWR programme remained central to embedding our culture of integrity across the Group. The programme promotes the key areas of our Code of Conduct – including Speak Up, Anti-Bribery, Privacy, Competition Law, Security, and Health & Safety – ensuring employees understand both our expectations and their individual responsibilities. To embed these expectations further, we provided micro learnings and targeted campaigns encouraging employees to speak up if they have concerns. Our Code of Conduct training forms part of the standard induction for new joiners, with refresher training required periodically. DWR training completion rates Topic 2026 (%) 2025 (%) DWR training programme 97 96 Anti-bribery module 98 97 Code of Conduct module 98 97 Health and Safety module 98 97 Privacy module 97 97 Security module 98 97
Trust is fundamental to how we operate and serve customers securely. Millions of people rely on us to connect and share information safely, and protecting that trust underpins our reputation, performance and responsibilities to society. Integrity guides how we work. Our Code of Conduct, supported by Doing What’s Right (‘DWR’), Speak Up, and our Anti‑Bribery and Fraud frameworks, sets clear expectations, reinforced through strong governance. Encouraging colleagues to speak up, managing ethical risks and honouring our commitments strengthens our licence to operate and helps protect our people and customers.
97% DWR completion rate 1 83% of employees trust the Speak Up process 2
Notes: 1. P ercentage of employees required to complete DWR training modules in the reporting period with no overdue requirements at the period‑end. 2. Percentage of respondents agreeing they believe appropriate action would be taken using the process.
Powered by FlippingBook