Vodafone Doing What's Right Booklet (Truncated)

Doing What’s Right Briefing Booklet for Line Managers

Welcome As we work together to build the ‘Digital Vodafone’ of the future, we need to make sure that we always conduct ourselves in the right way. It’s not only ‘what we do’, it’s also ‘why and how we do it’.

How we work together, treat one another, protect our customers and our company is a fundamental part of being an admired company.

Our Code of Conduct is in our DNA and it sets out what we expect from each and every employee, contractor and director at all times.

We call this

Doing What’s Right.

1 | Overview of this booklet

Overview of this booklet

Our Code of Conduct is in our DNA and sets out what we expect from each and every employee, contractor and director. We expect everyone to read and abide by the values and behaviours outlined in the Code.

Overview of this booklet | 2

Key principles Some of the key principles that are explained further in this booklet are:

Code of Conduct

Conflicts of Interest

We act with integrity in our relationships with employees, customers, suppliers and the community

We understand the difference between potential and actual conflicts and know how to manage those

Speak Up

Anti-Bribery

We all know when and how to Speak Up

We never offer or accept any form of bribe

Competition Law

Health and Safety

We act in a competitive, fair and lawful way

We always abide by 'The Absolute rules' and intervene if we see someone behaving unsafely

Privacy

Security

We know what personal data of customers and employees is, where it is and how to use it properly

We are each responsible and accountable for protecting and securing Vodafone and its customers

Business Resilience

Anti-Money Laundering

We are collectively responsible for ensuring continuation of critical business activities and delivery of our services

By preventing and detecting money laundering and terrorist financing, we keep our financial services safe and accessible

Taking our DNA and bringing it to life starts with you

3 | Overview of this booklet

Line manager action required As a line manager, you are responsible for ensuring that your team understands these principles and messages, and for challenging their behaviour when it does not live up to those standards. This booklet has been designed to help you achieve this.

Your required action: Use your team meetings over the coming year to cover all the topics in this booklet. We recommend you do this section by section, 10 minutes at a time. Doing What’s Right should be a regular item on your team agenda.

There are 8 sections in this booklet. Each section is composed of :

The key messages every employee needs to know

A manager checklist that will help you deliver these messages

A picture or an infographic that can help you prepare for the session

Being an ethical company starts with you

Contact us at: GroupCompliance@vodafone.com if you have any questions or comments.

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Code of Conduct Section 1

Principle: We act with integrity in our relationships with employees, customers, suppliers and the community.

Click here to know more 5 | Overview of this booklet

Challenge it or Speak Up If you see a behaviour that you feel is not in line with our Code of Conduct, please directly challenge it or use the Speak Up process. If as a line manager, you have a concern reported to you that involves ethical, legal or financial mismanagement, please report it to your local HR director.

Conflicts of Interest A large part of integrity is about transparency. If you find yourself in a situation where your own and Vodafone’s interests potentially conflict, please discuss an appropriate resolution with, and get approval from, your line manager and relevant HR contact, and register the conflict of interest on our global register.

An example of a potential conflict might be a close relationship with a senior manager of a supplier or competitor. If you as a line manager are told about a potential conflict of interest, please ensure that you work with your local HR team to find a solution and log the conflict on the register.

Actual conflicts of interest are prohibited at Vodafone– for example holding an outside employment position which detracts from your ability to devote appropriate time and attention to your responsibilities within Vodafone. If you find yourself in an actual conflict of interest you must work with your line manager and HR representative to resolve this immediately by eliminating the conflict.

Remember, managing conflicts of interest starts with you

Click here to register 7 | Code Overview of Conduct of this booklet

Speak Up statistics for financial year 2017/2018 The number of people who voluntarily included their name when reporting an incident was 42% in 2017/18. Including your name when Speaking Up significantly improves our ability to investigate cases and allows us to provide feedback when the investigation has concluded.

748

42%

cases were reported globally via line managers, HRDs or the confidential hotline

of reports were from individuals who gave us their name allowing easier investigation of the case

30%

293

of cases were integrity related (for example conflicts of interest)

disciplinary actions were taken

Who to contact?

1. Line manager (s) 2. HR 3. Independent external hotline (online form) To view the Expolink online form click here

Barring a few members of the Speak Up team who access your information on a need-to-know basis, your identity will always remain confidential, including when you voluntarily include your name, both during and after making a report.

If you see behaviour that is not in line with our Code of Conduct, please

Speak up!

For more details please click here

9 | Code Overview of Conduct of this booklet

You may report

anonymously We take confidentiality seriously.

All cases are treated confidentially and details are never disclosed to anyone outside the investigation team.

As per our Speak Up no tolerance policy towards retaliation against employees raising a concern, your identity will never be disclosed to the subject of the investigation. Even in case of any doubts regarding such behaviour, a separate investigation will be conducted.

Vodafone has a strict non-retaliation policy Our strict non-retaliation policy also means that no action will be taken against you if you report a genuine concern, even if there is no proven unlawful conduct or compliance breach.

You can also register your concerns quickly, discreetly, and directly on the Expolink Speaking Up app

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Anti-Bribery Section 2

Principle: We never offer or accept any form of bribe.

11 | Overview of this booklet

Key messages The subject of anti-bribery and corruption often conjures up thoughts of pay-offs or gifts. These are important, but they are not the only risks to Vodafone.

It could be through endorsing the resume of a customer’s daughter during a negotiation period, or lending a journalist a new device which would give Vodafone more favorable future news stories.

Corruption can come in many forms, so you may not even realize you’re responsible for compromising Vodafone’s reputation.

As a line manager you should be aware of bribery risks and educate your team on them. Some of the risks that you should consider are:

1

Third party risk

We use third parties in order to carry out tasks on our behalf. This means that we could be held responsible for their behaviour..

•

Only use suppliers that have been on-boarded and approved by Supply Chain

•

Remain aware of suspicious supplier behaviour, e.g. the ability to get licences or permits when other companies can’t

•

Ensure that the supplier has the business experience and qualifications to perform the work

•

Ask further questions if the third party’s plan for performing the work is vague or suggests a reliance on contacts or relationships

•

Be cautious when a supplier requests to perform services without a written contract where one is sought

•

Challenge supplier invoices that vaguely describe the services provided or are not properly supported

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2

Business relationship risks

When maintaining our relationships with customers or winning new business we need to be careful how the giving or receiving of gifts and hospitality, sponsorships or donations could be perceived.

•

Do not offer or accept gifts or hospitality, sponsorships or donations during a tender or RFP process

•

Ensure there is a legitimate business purpose when giving or receiving any gifts or hospitality

3

•

Familiarize yourself with the Anti-Bribery policy (on the Global Policy portal)

Travel risk

Be aware that when travelling in high risk locations you may be asked to make payments to get through customs or government checkpoints. In order to stop bribery from happening we all need to be aware of the risks and what to do when they arise.

•

Ask for a fee schedule and/or a receipt to ensure that this is an official charge; if it isn’t, you should refuse to pay, unless there is a physical safety threat

•

You must always report any potential bribery scenarios you face to your local Compliance Officer

Saying no to bribery and corruption starts with you

13 | Anti-Bribery Overview of this booklet

Manager checklist Talk through bribery risks relating to your team’s activities in your team meeting

Ensure they have completed the Doing What’s Right 2.0 Anti-Bribery training module

Ask your team to register gifts and hospitality in our register when required

Show your team the Anti-Bribery hub page

Click here to register

Employees should be aware about the bribery risks at work. By saying no to bribery and corruption we are not only protecting the company but we can make a positive difference in the world.

Employees should seek advice when they are unsure.

Contact groupantibribery@vodafone.com if you require further support.

It starts with you

Vodafone has a zero tolerance approach to bribery and corruption. If a breach or potential breach of the Anti-Bribery Policy arises or is suspected, employees should use the Speak Up process.

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Privacy Section 5

Principle: we know what personal data is, where it is stored and how we use it.

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10 Privacy Commandments

25 | Privacy Overview of this booklet

Treating personal data with respect starts with you

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