Vodafone Group Plc Annual Report 2025 43
Strategic report
Governance
Financials
Other information
Our approach continued
Our employees trust our Speak Up process, as evidenced by our October 2024 Spirit Beat survey, with 86% 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, 49% (FY24: 52%) of reports were ‘named’ and this was 3% higher than available industry benchmarks. Speak Up is available to our suppliers and is communicated through our Code of Ethical Purchasing. For suppliers that decide to maintain their own grievance mechanisms, we require that they inform us of any grievances raised relating
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. Click to read our Code of Conduct: vodafone.com/code-of-conduct Click to read more about our approach to Anti-bribery and corruption: vodafone.com/anti-bribery Facilitation payments are strictly prohibited, and our employees are provided with 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 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 CEOs, who are responsible for ensuring that our anti-bribery programme is implemented effectively in their local market. They are, in turn, supported by local specialists and a dedicated Group team that is solely focused on Anti-bribery Policy and compliance. The Group Risk and Compliance Committee assists the Executive Committee in fulfilling duties with regards to risk management and policy compliance and anti-bribery mitigation oversight.
Our minimum anti-bribery standards for every Vodafone business include: – Conducting a comprehensive anti-bribery risk assessment; – Ensuring there is a due diligence process for suppliers and business partners at the start of the business relationship; – Completion of the global e-learning training for all employees 1 , as well as tailored training for higher-risk teams; and – 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. The risks we face evolve constantly but broadly fall into the areas summarised in the table below, which outlines the key risks and the mitigation measures adopted.
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 Anti-bribery Policy. The ‘Doing What’s Right’ programme features e-learning training, including a specific anti-bribery module. As at 31 March 2025, 94% of training assigned during the reporting period had been completed. 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 our zero tolerance to bribery and corruption, including communications from senior management.
to work done on behalf of Vodafone. Speak Up topics raised during the year Topic 1 Speak Up reports
Requiring remedial action
People issues 2 Integrity
75% 31% 22% 51% 2% 36% 1% 50%
Risk
Response
Operating in high- risk markets Business acquisition and integration
We undertake biennial risk assessments in each of our local operating companies and at Group level, so we can understand and limit our exposure to risk. Proportionate anti-bribery pre- and post acquisition due diligence are carried out on a target company. Red flags identified during the due diligence process are reviewed and assessed. Following acquisition, we implement our anti-bribery programme. To reduce the risk of attempted bribery, a specialist spectrum policy team oversees our participation in all negotiations and auctions. We provide appropriate training and guidance for employees who interact with government officials on spectrum matters. Our anti-bribery policy makes it clear that we never offer any form of inducement to secure a permit, lease or access to a site. We regularly remind all employees in network roles of this prohibition, through tailored training sessions and communications. Third-party due diligence is completed at the start of our business relationship with suppliers, other third parties and partners. Through their contracts with us, our suppliers, partners, and other third parties make a commitment to implement and maintain proportionate and effective anti-bribery compliance measures. We regularly remind current suppliers of our policy requirements and complete detailed compliance assessments across a sample of higher-risk and higher-value suppliers. Selected high-risk third parties are trained to ensure awareness of our zero-tolerance policy. We provide tailored training for our Vodafone Business and Partner Markets sales teams. In addition, we also maintain and monitor an online register of gifts and hospitality to ensure that inappropriate offers are not accepted or extended by our employees.
Other
Health and safety
Notes: 1. T here were no reports relating to modern slavery concerns reported during the period (FY24: one report). 2. D iversity, equity and inclusion topics accounted for 2% of the People issues reported. Anti-bribery, corruption and fraud At Vodafone, we support and foster a culture of zero tolerance towards bribery, corruption or fraud 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
Spectrum licensing
Building and upgrading networks Working with third parties
Winning and retaining business
Note: 1. Exceptions apply for employees in Germany.
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