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The Vodafone Code of Conduct

Doing what’s right

“ Trust is fundamental in everything we do”.

2

A message from our Chief Executive 3

Why we have a Code of Conduct 5

Our Business Principles 7

Speak Up 9

Individual conduct 11

Security of our people, property and information 11

Compliance with the law 17

Anti-money laundering 20

Health and safety 22

Contents

Financial integrity 23

Public policy 26

Communications 27

Customers 29

Employees 31

Communities and society 34

Environment 35

Contents

3

A message from our Chief Executive

Vittorio Colao

Vittorio Colao

4

Contents

5

Why we have a Code of Conduct

The Vodafone Way

Our Business Principles

The Vodafone Way

Customer ObsessedWe are passionate about exceeding customer expectations

We create and deliver new products, services and ways of working that delight our customers

• Immerses self in customer experience• Takes personal accountability for the customer experience • Looks outside Vodafone to understand customer experience, behaviour and trends

• Takes risks and pushes what’s possible; always looks for innovation• Looks outside of Vodafone for ideas and inspiration and acts on these• Implements solutions which are simple, impactful and replicable

• Raises the bar for self and team • Delivers lean and cost effective every time• Strives to outperform competitors looks beyond internal benchmarks

We drive speed to market. We relentlessly �

matter to our business

• Makes RAPID business decisions• Delivers the right things with urgency• Analyses fast, executes fast

• Sets direction; generates commitment & engagement • Enables performance, balancing task, people & results

• Builds capacity through growing talent & skills, high performing diverse teams and a lean & effective organisation

• Acts and communicates with simplicity • Prioritises the right things • Creates a simple working environment

• Do what you say you will do• Trust others to deliver• Support decisions once made

We make things simple for our customers, partners and colleagues

We are reliable and transparent to deal with. �

do likewise

• Collaborates across markets & functions; makes best decision for Vodafone as a whole• Influences across the business – shapes thinking and impacts others’ views• Values our differences and acts inclusively, communicates and uses best practice

Innovation Hungry

Ambitious & Competitive

Speed Simplicity

Be an Admired Leader

Trust

We bring energy and passion to our work and always aim to beat the competition

We work across Vodafone to achieve the best outcome for customers, employees and shareholders

One Company, Local Roots

6

What is the Code of Conduct?

Who is the Code of Conduct for?

What are the consequences of not complying?

What does this mean for me?

your work

• Speak Up if you feel a working practice

Following the law

contact your line manager, Legal, HR, or

If you are a line manager, you have an important role in ensuring our Code of Conduct is understood and applied by your team. In particular, we expect you to:

If you are ever unsure about what to do you should ask yourself:

Contents

Our Business Principles

Individual conduct

Compliance with the law

Health and safety

Financial integrity

Public policy

7

Communications

Customers

Employees

Communities and society

correct, relevant and current information

Environment

8

Contents

9

I am a contractor working on a Vodafone contract and I have a concern to report. Can I use the external Speak Up line?A:

Q: I am concerned that my

I raise a concern. Will it be

A:

Speak Up

Q: What if I report something suspicious that turns out not to be a compliance breach?

A:

Q: I have a concern about the actions of a colleague. How should I report this?A: The most important thing is that you report your concern. Ultimately, it doesn’t matter which route you choose. If you feel comfortable talking to your line manager, do that. Your line manager is there to support you and can help you choose the correct course of action.

�� Click Speak Up� on the intranet to seeloca� � local free phone numbers or to make areport online�

10


1 Report it to your line manager:

2 Report it to your local HR team:

external Speak Up hotline:

What happens next?

external Speak Up line by providing an

Policy portalSpeak Up pagePreferred contact:

– Local HR team

Contents

11

Individual conduct

Security of our people, property and information

Integrity

Availability

Q: Can I allow my visitor to make his/her own way out of the building?

Q: A colleague is covering my role while I am on holiday and needs access to the systems I use. It’s a lot of hassle to get them a log-in and password, can I just give them mine?A:

Q: I’m working from home and I’m having problems accessing the Vodafone network. Can I ask my colleague to send me the information I need to my personal email account?A:

1 Value information and classify it

2 Clear your desk and lock your screen

3 Protect your password

4 Think before you click

5 Protect data at all times

12Policy portalGlobal Corporate Security Portal Preferred contact: – Corporate Security team

Training

Contents

13

actual

appropriate time and attention

• Recruiting or managing a relative or partner

Q: I work part-time in my family business. Do I need to declare an interest?A:

potential

Policy portalPreferred contact:

– Local HR team

interest register

14

Q: A close friend is applying for a job in Vodafone, is this OK?A:


Tell your local manger and HR team about:

a contract

What to do if you see yourself in a situation of potential

Step 1

Step 2

Step 3

Contents

15

Gifts and hospitality

proportionate giving and receiving of


of inappropriate value

be rare

approval from Group

Q: I’ve been invited out to dinner by a potential supplier currently bidding for a new contract. What should I do?A:

Q: I’ve been sent a high value gift by a supplier and don’t want to cause offence by returning it. What should I do?A:notify your line manager and

Q: My travel costs into the

claim some of it back?A:

16

Travel and expenses


Managing our information and documents


local Management and Retention

Q: Can I claim expenses for my partner or spouse to travel with me?

A: Taking your partner, friend or family member on a

Q: I think I am going to retain all my documents, in case they are needed in the future. Is that OK?

A:

be retained for audit, tax or


– Local Legal team

Gifts and hospitality register

Contents

17

Insider dealing


information

committing an offence

Compliance with the law

Q: My friend is thinking about selling some Vodafone shares in the next few days. I know Vodafone is due to make an announcement that will have a positive impact on the share price. Is it okay if I drop hints to my friend that he should wait to sell?

A:

Q: My colleague sent me an email containing information about a competitor which could easily be misinterpreted. What should I do?

A:

Q: While at a conference, a sales director from another company started talking to me about the economic outlook in Europe and what this meant for our data pricing plans for the future. What should I do?

A:

18

Competition laws


2 Always be vigilant in your business dealings with third parties

3 If in doubt, ask your local Legal team.

1 Have a basic knowledge of how the competition rules apply to you

Policy portalPreferred contact: – Local Legal team

Training

Contents

19

Bribery and improper payments


for more information

are permitted by local law

a commercial advantage

Q: I am travelling abroad later this month and need to get a work visa quickly. The person processing my request at the embassy has said that they can speed up the process if I pay a small fee in cash. Is this okay?A:

Legal department for advice

never offer or accept any

20

Anti-money laundering

prevention, detection and reporting of

employee training, and compliance

Q: Why does Vodafone need to comply with anti-money laundering regulations – I thought it was aimed at banks?A:

Q: I have seen a transaction that doesn’t seem right – I’m not sure if it is money laundering, it may be legitimate – what should I do?A:evidence to validate your

report to your local Money


Training

Contents

21

Global sanctions


any kind

manager or local team immediately if

Q: I am selecting a new supplier through the Vodafone Procurement Company, do I need to screen against sanction lists?A:

Q: I have discovered that one of the Vodafone products that requires an export license does not have one. What shall I do?A: Contact

Trade controls


• If in doubt, contact your local



22

Health and safety


Q: You are travelling with a new work colleague, you get into a taxi at an airport. As the taxi drives off your colleague has not put their seat belt on, what should you do?A:

Q: I often think when I walk

things that are potentially dangerous, I don’t mean things that are likely to kill someone but could easily cause injury. I am not sure if I have the authority to stop people and tell them what they are doing is dangerous?A:

Absolute Rules


Training

Contents

23

Financial integrity

Financial integrity


your role

Q: I think my colleague is regularly claiming taxi fares for working after hours but actually takes public transport home. What should I do?A:

24

Committing to contracts and expenditure


Operating a responsible supply chain

Q: I have the power of attorney to sign a contract in my local market, which is higher than the allowance I have in the Delegation of Authority. Can I sign the contract as I have power of attorney, even if it’s not aligned with Delegation of Authority?A:

Q: I have a supplier that I suspect has breached the Code of Ethical Purchasing. What should I do?A:

details of my Delegation of Authority limits?A:



Contents

25

Protecting our brand and other assets

Our brand


Policy Standard

Intellectual Property Rights (IPR)


relevant IPR

Physical assets

Q: Sometimes I see products bearing the Vodafone logo on a stall at my local market. I think they are counterfeit. Do I need to let someone know?A:

Q: In my team we discuss extensions for existing products and services but have not found a place to capture our ideas. Does such a place exist?A:

Q: I’m not sure whether an idea I’ve had might be worth something. Can I discuss it with our suppliers to get their views?A:

your local Legal team


IPR page

26

Public policy


for any political campaign, political

political campaign, political party,

Q: A local reporter has contacted me through a mutual friend to ask me about this year’s annual report. Can I comment?A:

to comment publicly on


Contents

27

Speaking on behalf of Vodafone

“ Provide clear

information

in language

Communications

Q: Am I allowed to say where I work on my social

A:

can include a link to your local

28

Using social media


reputation or brand

Q: There are a lot of guidelines to follow when using social media, can you summarise them please?A:

Policy portalPreferred contact: – Local Internal Communication team

Communication team

Contents

29

Customers

Our Privacy Commitments Balance

Laws and standards

Accountability

Respect

Openness and honesty

Choice

Privacy by design

30


• If you are involved in product

for you and your team

need to follow

an advocate for privacy by joining our

Q: I’m working on a project involving a use of customer information that is not covered by law. Do I still have to think about privacy?A:

Q: I’ve been contacted by the law enforcement authorities in my country with a request for access to personal information. What do I do?A:

to a Government or law

More information can be found in our Privacy and Law

Q: I’m building a Vodafone application that will use personal information. How do I make sure privacy is protected – can I simply add a privacy policy to the app?A:

information take a look at our


Training

Contents

31

Employees

Diversity and inclusion


local law

make purely on merit

Q: A colleague is recruiting a new team member. I am concerned that they may be discriminating against certain candidates. Should I challenge them?A:accept any form

32

Preventing harassment and bullying


informal you are being

Q: I can see that one of my colleagues is being picked on constantly by other team members. I want to raise this but I am concerned that it might be my turn next. What should I do?A:

Speak to your line manager

do not feel comfortable doing

Policy portalPreferred contact: – Local HR team

Contents

33

Drugs and alcohol


to your local HR team

Q: My colleague regularly arrives at work appearing

alcohol. I know he is having

should I do?A:

34

Local communities

Communities and society

Charitable support

Q: My team wants to raise money for a local charity, are there any restrictions on who to donate to?A:

Q: I thought human rights were the government’s responsibility? Why do I have to worry about them?A:


• Get involved in your local community via


Contents

35

Environment


colleague if you need a car


36

Q: What is an arrangement? (p17)A:

Q: What is inside information? (p18)

Q: What is a bribe? (p19)A:

A:

Q: What are ‘facilitation payments’ and ‘kickbacks’? (p19)

A:

a routine government action, for example

to an individual in return for a referral,

Q: What does ‘reasonable and proportionate’ mean? (p15)A:

(p14)A:

Q: What is a ‘close’ relationship? (p15)A:

Q: What is ‘sensitive information’? (p12)A:

Q: What do we mean by ‘discrimination’? (p31)A:

Q: What do we mean by ‘harassment and bullying’? (p32)A:

be related but not limited to age, gender,

used in this Code

Contents

Vodafone Group PlcVodafone HouseThe ConnectionNewburyBerkshireRG14 2FNEngland

Tel: +44 (0)1635 33251

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