Ethics and compliance

Ethical working and regulatory compliance are firmly embedded across VodafoneZiggo, helping us protect all our internal and external stakeholders. Being a responsible business is, quite simply, the right thing to do; at the same time, we believe it forms the foundation for building towards our strategic ambitions. Our Privacy, Risk & Compliance team sets high standards of behaviour and ensures that our business and employees live up to these standards each and every day.

Ethical working

The VodafoneZiggo Code of Conduct sets out our ethical and behavioural expectations of everyone within our organisation. We review and update it annually, along with other company policies and documents, to ensure we continue to reach and grow our high standards. In 2023, for example, we updated the code in line with the requirements of the EU Whistleblower Directive. To promote awareness of the topics covered by the code, we continued to communicate with employees regularly through the ‘We Do; We Don’t’ campaign.

We also actively train our colleagues on ethical conduct: new joiners take an e-learning course and all other employees must complete an e-learning every year. We provide additional role-based training as appropriate, such as sessions on gifts and hospitality for our business sales teams. Indeed, VodafoneZiggo requires all employees to declare any gifts or hospitality. Potential conflicts of interest must also be registered, and we work to resolve any actual conflicts of interest. This ensures transparency and protects our people, organisation and other stakeholders.

Speak Out

The public conversation around inappropriate behaviour in the workplace was less prominent in 2023 than the previous year, but at VodafoneZiggo we remain fully committed to raising awareness of inappropriate behaviour and fostering an open culture that empowers people to report any concerns. We provide several reporting mechanisms for colleagues and external parties, collectively referred to under the umbrella of Speak Out.

In the first instance, we aim for employees to feel comfortable raising concerns with their own manager, but for situations where this is not an option, we have trained a group of around 40 colleagues – our Trust Buddies – to provide a listening ear and direct people to further resources. These include our certified external counsellor, who is on hand to provide confidential advice, and our external complaints committee (Gimd), which helps us handle more serious incidents. For anyone wanting to make an anonymous report online or by phone, our external reporting tool, Whispli, is always available.

Reporting channel




Security (transgressive behaviour)




External confidential adviser












A broader perspective

We know our impact stretches far beyond how we behave in the workplace, which is why we take care to ensure we work as part of a fair and ethical value chain. Our Human Rights Statement sets out our promises regarding how we interact with customers, employees, suppliers and wider society. It also underlines our commitment to acting ethically, sustainably and without abuses across the entire value chain.

We require all our suppliers to comply with our Code of Sustainable and Ethical Purchasing, which we updated in 2023. We also screen our suppliers using various questionnaires and other tools, helping us identify any risks and work jointly to implement mitigation measures. VodafoneZiggo has begun developing a new dashboard to help make our sourcing risks more visible, ultimately helping us respond appropriately. Using third-party software, we also carry out daily checks for any compliance breaches among our suppliers. See Impact of purchasing for more information on this topic.

Our efforts and motivation to ensure ethical practices along our value chain align with the purpose and requirements of the EU’s forthcoming Corporate Sustainability Due Diligence Directive. Thanks to our work in this area in recent years, VodafoneZiggo is already ahead of many of the standards set by this regulation. Continuing to prepare for full compliance will be a top priority in 2024.

To promote awareness of the topics covered by The code, we communicate with employees regularly through the ‘we do; we don’t’ campaign.

Engaging with shareholders and regulators

VodafoneZiggo has a duty to keep our shareholders informed about any compliance risks and developments in our business. We do this both reactively and proactively, via quarterly communications and through other updates as and when required. We are also in frequent contact with various regulatory and supervisory authorities in the Netherlands, including the Financial Markets Authority (AFM), the Data Protection Authority (AP), the Authority for Digital Infrastructure (RDI) and the Authority for Consumers & Markets (ACM).

Contributing to society

Only by following our ethical compass and conducting our business with transparency and integrity can we fulfil our ambitions of enabling progress for everyone. One example of this is the protection we put in place to prevent our customers being provided with credit they cannot afford, either by us or by other parties. In 2023, we rolled out a short refresher video on consumer credit checks and balances for our customer-facing staff, helping them manage the best interests of our customers.

More broadly, our Privacy, Risk & Compliance team is a first port of call for teams across the VodafoneZiggo organisation, whether they need advice on ethical grey areas such as social media marketing or are simply unsure of where to find more information about a particular policy. We aim to grow the team in 2024 and to continue adapting our ethics and compliance activities to an Agile way of working, in line with the rest of our business. This will enable better support for the organisation, embed ethical working in all VodafoneZiggo processes and help us respond more quickly to any potential issues.

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