Vodafone 2026 Annual Report

Vodafone Group Plc Annual Report 2026

Strategic report

Governance

Financials

Other information

Maintaining Trust continued

Looking forward Our focus will remain on embedding the enhanced framework throughout all markets and further developing the capability and consistency of our Anti-bribery and Corruption programme. Enhancing third party risk management is a continued priority, with improved due diligence and ongoing monitoring of higher-risk relationships. We will also expand the use of data analytics, automation, and horizon scanning to boost detection, insights, and support more proactive risk management.

The Group Chief Executive and Executive Committee oversee our anti-bribery programme, supported by the Group Risk and Compliance Committee. Local market Chief Executive Officers are accountable for implementation in their markets, supported by local specialists and a dedicated Group anti-bribery compliance team. Anti-bribery training continues to be a core pillar of the DWR programme. All employees are required to complete mandatory e-learning modules, which includes a dedicated anti bribery module, while higher risk roles receive tailored, scenario based training to address the specific risks they may encounter. Fraud Fraud is a significant threat, impacting our customers, employees, reputation, and financial performance. We delivered fraud management through a global operating model, utilising a combination of all of our resource. This blend of resources allows us to provide an effective localised response to any incidence of fraud, whilst also ensuring that intelligence and best practice of the benefit to the wider organisation is captured and shared. We continuously evolve our fraud technology and ways of working, adapting to the tactics used by fraudsters, and aligning with key partner teams such as Cyber Security and Privacy to leverage our respective strengths and establish a robust, layered defence. Read more about our Cyber Security strategy and AI on pages 52 to 56

Our employees trust our Speak Up process, as evidenced by our February 2026 Spirit Beat survey, with 83% of respondents agreeing that they believe appropriate action would be taken as a result of using the process. We also track the proportion of ‘named’ versus ‘anonymous’ reports as a higher number of named reports suggests higher levels of trust in the Speak Up process. During the year, 43% (FY25: 49%) of reports were ‘named’ and this was 22% lower than available industry benchmarks. Looking forward We will continue to monitor reports and ensure robust handling by governing teams across our markets. We will also continue to strengthen our communication to colleagues by raising awareness of the programme and reinforcing the importance of behaving with integrity. Anti-bribery, corruption and fraud Strategy We are committed to conducting business with integrity and have a zero‑tolerance approach to bribery, corruption and fraud. This commitment is set out in our Code of Conduct and supported by our Anti‑bribery Policy, which applies to all employees and third parties acting on our behalf. The policy prohibits bribery in all forms, including the offering or acceptance of improper gifts, hospitality or other advantages, whether directly or indirectly, and provides clear guidance on what constitutes bribery and corruption.. Breaches may result in disciplinary action, up to and including dismissal, or termination of contracts. Our Anti-Bribery Policy is aligned with relevant legislation, including the UK Bribery Act and the US Foreign Corrupt Practices Act. Facilitation payments are strictly prohibited, except where an employee’s personal safety is at risk. Any payment made under duress must be reported promptly once the risk has passed.

We hold leadership roles at industry level (e.g. GSMA Fraud and Security Group), using these positions to ensure regulatory alignment, and to drive engagement and cross-sector collaboration in the global fight against fraud. Our strategy focuses on strengthening our ability to proactively protect customers, simplifying our fraud operations, and enabling business growth through innovative fraud solutions. Customer protection is significantly elevated as a priority, with initiatives focused on reducing spam and scam communications, improving victim support, and expanding both customer and employee fraud awareness. This ensures that we are a trusted supplier to all customers, and aims to create a more resilient ecosystem where fraud prevention becomes an integrated part of the customer experience. This year We strengthened our Anti-bribery and Corruption framework after a comprehensive review of our assurance approach. Our risk-based assurance model including independent oversight and confidence in the design and effectiveness of anti-bribery controls. This led to clearer accountability, stronger risk ownership, and better alignment of assurance activities to inherent bribery and corruption risks across all our markets. The systematic strengthening of our control environment represents a significant step forward in the maturity of our anti-bribery controls, allowing us to concentrate more on higher-risk areas while maintaining robust, consistent baseline standards across the Group. Training completion rates remained above 90% across our markets, reinforcing consistent awareness of our standards and zero tolerance approach to misconduct.