Ethical conduct

At VodafoneZiggo, we encourage all of our employees to work in a responsible, honest and ethical way. This way of working is in line with our standards and core values, in which training, openness and promoting reflection and discussion are of crucial importance as a means of safeguarding our ethical culture. By ensuring those conditions, we are creating a safe environment in which any concerns can be reported.

Our Code of Conduct

At VodafoneZiggo, we work together with thousands of people towards a single goal: enjoyment and progress with every connection. In order to be successful in achieving that objective, it is essential to know what we can expect from each other and how we want to work together. That is why we have set out our principles and our common rules of conduct in our Code of Conduct. The Code of Conduct determines the direction of everything we do, or do not do, and we apply it at all times when we are at work. They are a reflection of our culture. We launched our updated Code of Conduct in January 2019.

The Code of Conduct also specifies how employees should act if they suspect that abuses or violations are taking place. An important factor in that regard is that they feel safe to report matters such as these. We encourage our staff to do this and promise that we will protect anyone who does so.

Speak Up (including the Whistleblower Procedure)

In cases where our Code of Conduct has not been followed and unwanted or unethical behaviour occurs, there are various ways in which to report this. It can either be reported internally to a person’s line manager, or to specific departments (Security, Compliance or HR). If a person would rather report something anonymously, however, they can make use of the Whistleblower Procedure. This scheme can be used both by internal and external stakeholders in order to submit anonymous reports about matters such as unwanted or unethical behaviour. In the past few years, we have increased the profile of this scheme and this has led to an increase in the number of (anonymous) reports submitted under the Whistleblower Procedure. In 2020, this opportunity to speak out was used on six separate occasions. A further one hundred or so reports were submitted via the other internal reporting procedures. The reports submitted under the Whistleblower Procedure came under the categories of intimidation, an HR complaint, health and wellbeing, duty of care, security and fraud. VodafoneZiggo followed up each of these reports by initiating an investigation in accordance with our protocols. The persons who made each of the reports are being kept up to date at all times.


Result 2020

Result 2019

Result 2018

Number of ‘Speak Up’ reports  


On an internal level, our Privacy, Risk & Compliance department operates as a business enabler. Its role is to ensure that the Code of Conduct, and therefore our company’s culture, is protected and enforced. The department achieves this by not standing in anyone’s way or holding them back, but by flexibly keeping pace with the organisation and by enabling other departments to look ahead to identify opportunities, within the rules set for that, of course.

Internal awareness-raising

In the course of the year, all employees take part in one or more training sessions on the subject of conduct and acting ethically. During these training courses, they learn about topics such as privacy, security, anti-corruption and bribery, competition law, health and wellbeing and the contents of our Code of Conduct.

Every two months, we focus on a topic from the Code of Conduct by means of posters, articles, discussions on Yammer (similar to Twitter, but only for employees), training courses and team meetings. As a result of these activities, awareness with regard to ethical conduct has increased. One of the ways this has been borne out is in the increase in the number of reports and requests for advice. We use the feedback from our people to further develop communication and training on the subject of ethical conduct.


Result 2020

Result 2019

% of employees who have completed the Code of Conduct module 



% external hired personnel who have completed the module 



# of training hours [e-learnings on Code of Conduct, anti-bribery, privacy, security, competition rules, health & safety]