Business principles

At Telefónica Europe we are committed to behaving ethically in all that we do. We believe that this is the best way to protect the reputation of the Company and to make sure we create real value for our shareholders. Protecting the good name of the Company is one of the most important jobs anyone employed by Telefónica Europe has to do.

Our Business Principles which are endorsed by the Chairman, commit us to achieving and maintaining the highest standards of corporate governance. They guide everyone at Telefónica Europe in how we should behave as a company, towards all our stakeholders.

They are the link between our corporate and commercial values and our day-to-day business policies and practices. Wherever possible we insist that others outside the company who work with us apply the same principles

Our Business Principles guide all Telefónica Europe employees in how they should behave and how they should tackle difficult decisions they may confront in the course of their work. They commit us, amongst other things, to:

They underpin our approach to managing risks and protecting privacy. They express our determination to provide fair and equal employment in a healthy and safe workplace and to safeguard the environment.

Who do they apply to?
Suppliers and contractors
Reporting
Confidential Help Facility

Who do they apply to?

At Telefónica Europe we believe the commitment to high ethical standards applies to everyone working for the company. Our Business Principles are designed to guide every employee in the Telefónica Europe, including its Directors and senior financial officers.

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Suppliers and contractors

The Company expects our contractors and we encourage our suppliers, to be guided by these principles when dealing with Telefónica Europe or its stakeholders.

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Reporting

Every employee has a responsibility to report as quickly as possible suspected violations. They are also encouraged to express concerns regarding compliance with our Business Principles and related policies where they suspect these policies are not being followed.

Board Members are required by the CEO to report current or likely breaches of our Business Principles to the Chief Financial Officer every six months.

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Confidential Help Facility

Our Business Principles have been issued to staff and made available on the internal and external web sites. They apply to all employees of the Group including its senior officers.

Advice lines and web sites have been established across the Group where advice can be obtained regarding the application of our Business Principles. Additional advice is available from operating business Compliance Officers and the Group Corporate Responsibility Manager.

The Head of Corporate Governance provides the management of our Confidential Help facility.

We have in place a Confidential Help Facility described in our Business Principles and its associated internal and external web sites. This allows our employees as well as external stakeholders to report violations of our Business Principles via a confidential and anonymous reporting facility.

We expect our people to act sensitively and with the highest standards of integrity and use of the Confidential Help facility should be consistent with these standards.

Our Business Principles make it clear that anyone with authority in this area will themselves face disciplinary action, up to and including dismissal, if they try to stop or penalise anyone reporting current or potential breaches.

A Business Principles booklet sent to all staff includes contact information to help them raise concerns and makes it clear that they can do so with the confidence that they will be taken seriously, will suffer no retribution and that their concerns will be dealt with in complete confidentiality.

Reports can be made via either:-

Phone:
The contact number for the central confidential help-line can be found on the Business Principles employee intranet site or leaflet. A confidential voice-mail service is available to receive calls when the Corporate Governance Officer is not on duty.

Post:
The envelope should be marked with the following phrase:-
“CONFIDENTIAL” TO BE OPENED BY THE CORPORATE GOVERNANCE OFFICER”.

Legal & Corporate Affairs,
Telefónica Europe plc
Wellington Street,
Slough,
Berkshire,
SL1 1YP
United Kingdom

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