42 Vodafone Group Plc Annual Report 2025
Strategic report
Governance
Financials
Other information
Our approach Maintaining Trust
Code of Conduct Our Code of Conduct sets out what we expect from every single person working for Vodafone, 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. Click to read our Code of Conduct: vodafone.com/code-of-conduct Our Doing What’s Right (‘DWR’) training and communication programme is key to embedding a shared understanding of the Code of Conduct across Vodafone. Throughout the year, the DWR communication programme promoted different areas of our Code of Conduct, including Speak Up, anti-bribery, privacy, competition law, security, and health and safety. This year we shared a message that featured our leadership members, graduates, and other staff members reminding everyone to keep our business safe from the risks of bribery and corruption, and to always act ethically. Training on our Code of Conduct is included in our standard induction process for new employees. We expect every employee 1 to complete refresher training when assigned, and this is typically every two years. Of those assigned induction or refresher DWR training during FY25, 93% had completed the training as at 31 March 2025 1 . To keep the knowledge of our Code of Conduct fresh, we continued to assign assessment tests this year across areas such as the Code of Conduct, anti-bribery, health and safety, privacy and security. These refresher assessments have helped us to test and refresh knowledge of key concepts. These tests have continued to receive a high Net Promoter Score of 85–89%. Those who do not pass the assessment are required to complete learning in the relevant subject area. These assessment tests have been launched across rest of our markets in FY25 1 .
The upgraded Competition Law learning module launched in the previous year continues to have a high completion rate of 92% as at 31 March 2025 2 . We also strive to make compliance easy for our employees and continue to improve our digital Code of Conduct and Global Policy Portal, the internal platform where employees can find information about our policies and procedures. A programme is underway to enhance our policy environment and optimise the focus of policies so that we can effectively address our material risk environment. The digital Code of Conduct and global policy portal continue to be accessed widely by users across the Group with nearly 192,000 visits to the global policy portal in the last quarter of FY25. Our Code of Conduct is well understood throughout Vodafone. In the recent Spirit Beat employee survey, 95% of respondents agreed with the statement, ‘Our team lives by the Code of Conduct’. Speak Up Everyone who works for or on behalf of Vodafone has a responsibility to report any behaviour at work that may be unlawful, criminal, or could amount to an abuse of our policies, systems, or processes, and would therefore be a breach of our Code of Conduct. Speak Up is owned by the Chief Human Resources Officer and overseen by the Group Risk and Compliance Committee. Employees can raise concerns through our whistleblowing programme, Speak Up. These concerns may involve unlawful behaviour or integrity issues, such as bribery, fraud, price fixing, conflicts of interest, or breaches of data privacy. Reports may also address people issues such as discrimination, bullying, harassment, health and safety dangers for employees or the public, or
potential human rights abuses. Employees can report concerns to a line manager, a human resources colleague, or through our anonymous confidential third-party hotline, which is accessible online or by telephone in local languages. This service is available to contractors, suppliers, business partners, and joint venture partners. This year, 684 (FY24: 649) separate concerns were reported using Speak Up. Speak Up reports are confidentially investigated by local specialist teams. A committee is in place, comprised of senior team members, to act as the decision-making authority. Following an initial assessment of the report, if an investigation is required, a corporate security investigator or a member of HR will confidentially investigate the matter, notifying the person who raised the concern. Where reports made to Speak Up require remedial action, this could include individual consequences or changes to internal processes and procedures. Each report is monitored to verify that any corrective action plan or remediation has been conducted. Our Group Risk and Compliance Committee reviews the effectiveness of the Speak Up process and trends once a year, and the Group Audit and Risk Committee receives an annual update, with additional ad hoc reviews carried out where appropriate. We have a non-retaliation policy when a concern has been reported. Everyone who raises a concern in good faith is treated fairly, with no negative consequences for their employment with Vodafone, regardless of the outcome of any subsequent investigation. This policy is reinforced through local communication.
This section of the strategic report covers the elements that underpin our responsible business strategy that includes our approach to protecting people and data, as well as how we act ethically, lawfully and with integrity
wherever we operate. 93% employees completed ‘Doing What’s Right’ training in FY25 684 ‘Speak Up’ reports in FY25
Notes: 1. Excludes employees in Germany. 2. Includes Group, Ireland, Portugal, South Africa and Egypt.
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