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The Vodafone Code of Conduct

The Vodafone code of ConductDoing what s right22A 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 Avoiding conflicts of interest 13 Gifts and hospitality 15 Travel and expenses 16 Managing our information and documents 16 Compliance with the law 17 Insider dealing 17 Competition laws 18 Bribery and improper payments 19 Anti-money laundering 20 Global sanctions 21 Trade controls 21 Health and safety 22 Contents Financial integrity 23 Committing to contracts and expenditure 24 Operating a responsible supply chain 24 Protecting our brand and other assets 25 Public policy 26 Communications 27 Speaking on behalf of Vodafone 27 Using social media 28 Customers 29 Our Privacy Commitments 29 Employees 31 Diversity and inclusion 31 Preventing harassment and bullying 32 Drugs and alcohol 33 Communities and society 34 Environment 35 Key

2 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

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