Vodafone’s Code of Ethics

Abdeslam Badre

Introduction

Vodafone Group Plc is the world's leading mobile telecommunications company, with a significant presence in Europe, the Middle East, Africa, Asia Pacific and the United States through the Company's subsidiary undertakings, joint ventures, associated undertakings and investments.

The Group's mobile subsidiaries operate under the brand name 'Vodafone'. In the United States the Group's associated undertaking operates as Verizon Wireless. During the last two financial years, the Group has also entered into arrangements with network operators in countries where the Group does not hold an equity stake. Under the terms of these Partner Network Agreements, the Group and its partner networks co-operate in the development and marketing of global services.

The Company had a total market capitalisation of approximately £80 billion at 15 November 2005.

Global Footprint

The Group has ownership interests in 27 countries across 5 continents. In addition, the Group has Partner Networks in a further 33 countries.

31 December 2006, the Group had 198.6 million proportionate customers in its subsidiaries, joint ventures, affiliates and investments, 600 million venture customers.

Code of Ethics

4. Disclosure
The Company strives to ensure that the contents of and the disclosures in the reports and documents that the Company files with the Securities and Exchange Commission (the "SEC") and other public communications shall be full, fair, accurate, timely and understandable in accordance with applicable disclosure standards, including standards of materiality, where appropriate.

5. Compliance
It is the Company's policy to comply with all applicable governmental laws, rules and regulations. It is the personal responsibility of each Relevant Officer to, and each Relevant Officer must, adhere to the standards and restrictions imposed by those laws, rules and regulations, including those relating to accounting and auditing matters.

6. Reporting and Accountability
The Audit Committee of the Board of Vodafone Group Plc is responsible for applying this Code to specific situations in which questions are presented to it and has the authority to interpret this Code in any particular situation. Any Relevant Officer who becomes aware of any existing or potential breach of this Code is required to notify the Group General Counsel and Company Secretary promptly. Failure to do so is itself a breach of this Code. 

Social responsibilities

v    Socio-economic Impact

£11.7 billion cash value added in 2005/06

The rapid spread of mobile technology has brought significant social and economic benefits. The challenge is to ensure that the benefits are spread as widely as possible while minimising negative impacts.

Vodafone’s social impacts

Published study on potential of mobile to improve healthcare

We published a study in 2006 that shows how mobiles can help patients to keep appointments, monitor their chronic conditions and seek advice confidentially, as well as increasing adherence to treatment programmes. These benefits are available to big and small businesses alike, including those in the developing world.

Conducted research in developed countries

We commissioned a programme of research, initially focusing on the impact of mobile phones in Africa. The findings from this research help to inform policies on mobile telecommunications and international programmes aimed at increasing access to information and communications technology (ICT) and bridging the digital divide.

In addition to the indirect economic value of our mobile services, our business makes a direct contribution to the global economy through the wealth we generate and the jobs we sustain directly and among our suppliers.

Vodafone’s direct economic impacts

 Accessibility

·                9% of the EU adult population (about 40 million people) is excluded from using mobile phones. This increases significantly with age, with conservative estimates suggesting that 20% of over 50s are excluded. We regard addressing this as both a social and commercial challenge.

Mobile phones have already had a positive impact on millions of people and have the potential to benefit many more.

Social Products and Enterprise Team in 2004 to focus on products with high positive social impact, including those that reduce exclusion from mobile usage. Vodafone is looking for ways to make phones more accessible for People who are elderly, blind, deaf or disabled.

Vodafone is working with UK company, Scientific Generics, to identify key features that will significantly reduce the level of exclusion from mobile communications.

Environment

·                Decreased carbon dioxide emissions per unit of data transmitted by 10% in 2005/06

·                New Group target set to reduce carbon dioxide emissions per unit of data transmitted by 40% by 2011

·                Total energy use increased by 23% this year

·                Energy sourced from renewables increased by 22% in 2005/06

·                Working with suppliers to make network equipment more energy efficient

·                Onsite renewable energy technologies trialled

·                97% of network equipment waste reused or recycled in 2005/06

·                Initiatives launched to raise awareness and encourage handset recycling

·                Recycling programmes established at all local operating companies

·                1.37 million mobile phones collected for recycling in 2005/06

We recognise that our global energy use is increasing and predict that it will continue to do so. Trying to implement a strategy to limit its impact on global warming by investigating how to reduce its carbon dioxide emissions by increasing energy efficiency, and by using more renewable energy sources. 

Human Rights

Vodafone's commitment to human rights is embodied in its  Business Principles:

• respect and comply with all human rights legislation, regulations and standards in the countries where we operate.
•  welcome the development of the UN Norms on the Responsibilities of Trans-national Corporations and Other Business Enterprises with Regard to Human Rights to help business build its understanding of human rights and explore the ways it can contribute.

Employees

• Vodafone is committed to protecting and enhancing the human rights of its employees.
• Its Group employment policies are consistent with the UN Universal Declaration of Human Rights and the International Labour Organization's Core Conventions.

It employs approximately 55,000 people worldwide. Its goal is to recruit and retain the most talented, motivated people by providing a good working environment, treating people with respect, and offering attractive incentives and development opportunities.

Health & Safety

The health and safety of our employees is a priority. Our health and safety policy ensures consistently high standards are set throughout the company to make sure our employees can do their work safely. It covers health and safety management, radio frequency fields and health and driving safety.

·                Developed a strategy to focus on employee wellbeing at all local operating companies

·                Introduced a Performance Dialogue for every employee to receive feedback on their performance from their manager

·                Increased percentage of women in senior management (bands A-E) from 10% to 17% in 2005/06

·                Introduced two new global health and safety standards

·                Reduced work-related lost-time accidents by over 20% from 2004/05

·                Vodafone does not tolerate child labor, forced or compulsory labor.

Suppliers
Vodafone's Code of Ethical Purchasing aims to ensure that its suppliers share its values and uphold standards on human rights.

Content
Access to communications technology can support greater freedom of expression. However, new technology brings new challenges and we will balance the right to freedom of expression with the protection of vulnerable groups, such as children.

Driving safety in Spain
Vodafone Spain has dramatically reduced driving accidents among its employees through a sustained driving safety campaign over the last five years. The number of vehicle accidents resulting in lost time has fallen by more than 80% since 2003 (and by 50% since 2004). through running a training course: In 2005/06, 234 employees who work on the network took a refresher course in off-road driving.

Wellbeing programme in Ireland
In March 2006, Vodafone Ireland launched a wellbeing programme designed ‘to make people feel great at work’. The programme provides free online health checks and encourages employees to lead a healthier lifestyle. Health and fitness fairs provide information, products and services to help people understand and take steps to improve their health.

Equal Opportunities & Diversity

We believe that diversity is an asset to our business. With operations worldwide, Vodafone is not only multinational but multicultural. We are building a culture that respects the value of differences among us and encourages individuals to contribute their best within an environment that is inclusive, open, flexible and fair. We will not tolerate discrimination or unfair treatment on any grounds.

Vodafone’s Foundations

·                Begun a major review of the Group Foundation’s donations strategy

·                Donated £38.1 million to charitable causes worldwide in 2005/06

·                New foundations in Albania and the Czech Republic

·                It invests in the communities where it operates through donations of cash, equipment, products and services.

·                Employees also give their time as volunteers to support good causes.

·                It is also looking at ways its technology can assist emergency response to natural and manmade disasters.

it aims to focus our contributions on areas directly related to the impacts of our business on society. Our Social Investment Policy identifies the following priorities:

·                Reaching the excluded with the benefits of mobile technology

·                Promoting sustainable business practice and environmental protection

·                Supporting the personal involvement of our employees in their local communities.

We aim for our grants to have the greatest possible impact. We measure our total social investment by combining the value of cash donations and other contributions.

 

References: www.vodafone.com