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| Business Principles |
Everyone who works at mmO2 is expected to behave ethically at all times in their dealings with each other, with suppliers, with customers and with the wider public.
The standards of conduct we expect of everyone working for the Company are laid out in a Business Principles document. Both our Chairman, David Varney, and our Chief Executive Officer, Peter Erskine, have led efforts this year to underline to employees the importance of the document and the standards of ethical behaviour it demands.
In November 2002 we carried out an employee survey in all of our English-speaking business units to measure awareness of the Business Principles and to benchmark that awareness. This research will be used to measure future progress. Employees were invited to comment on how the Principles measured up to their own experience of the Company. During the year we have also joined the Institute for Business Ethics, which has given us a further opportunity to benchmark our standards against peers and to extend our knowledge in this field.
The Business Principles document is prefaced with our vision - to be the essential mobile brand by enriching people's lives, whatever they are doing, wherever they are. It spells out our values: to be bold, open, trusted and clear. And it makes clear that behaving ethically is the key to building trust with our customers that we are delivering an excellent service at a fair price, with colleagues and with the communities, civic groups and charities we work with. The document makes it clear that we have a policy of making no contributions to political parties.
It also gives staff information about how to raise matters of concern in strictest confidence where they think the Business Principles are being contravened. Under the new Sarbanes-Oxley Act of 2002 in the US companies are required to keep a register of complaints made and actions taken to investigate them. We intend to meet this requirement.
Our Business Principles
These Principles apply to all employees. We aim to encourage others who work with us to embrace these Principles. In complying with these Principles we will maximise long term value for our shareholders and society at large.
We will always follow these Principles.
Ethical conduct
- We will comply with all laws, rules and regulatory obligations.
- We compete fairly in our markets, being honest and trustworthy in all our dealings and keep the commitments we make.
- We will not offer or accept gifts, hospitality, bribes or other inducements, which encourage or reward a decision. We will report and record any gifts.
- We will avoid or declare conflicts of interest that may lead (or be seen to lead) to divided personal loyalties.
- We will not seek gain for others or ourselves through misuse of our position within O2.
- We respect the principles of the UN Universal Declaration of Human Rights and the International Labour Organisation declarations.
Customers
- We will understand the needs of our customers.
- We will deliver good value for money.
- We will be truthful, helpful and accurate in our communications.
- We will ensure that our products comply with safety and manufacturing standards.
Employees
- We aim to treat everyone fairly, and impartially, without prejudice regardless of race, colour, nationality, ethnic or national origins, religion or religious affiliation, gender, gender status, sexual orientation, marital status, age, disability or caring responsibilities.
- We will not tolerate harassment in any form.
- We will not use any form of forced or child labour.
- We will engender a zero tolerance culture to injury and ill health arising from, or associated with, the work activity.
Environment
We will support and follow operational policies that minimise our impact on the environment.
Communities and society
We will seek to contribute to the development of the communities where we operate.
Political contributions
We do not make donations, whether in cash or in kind, in support of political parties.
However, due to the broad nature of the legislation, some activities may be deemed to be donations and in this instance we will act in the best interests of the Company and its shareholders.
Business partners and suppliers
- We will award business solely on merit, without favouritism, by securing products and services available at the best available terms.
- We expect our business partners and suppliers to meet the same standards of business conduct as ourselves.
Shareholders
- We will manage the mmO2 Group in accordance with the highest standards of corporate governance and best practice.
- We will provide opportunities for shareholders to assess our objectives, strategy and performance.
Internal control and risks
- We will regularly assess the risks to our business and our people and ensure that appropriate controls are in place to manage them.
- We will ensure that business records are prepared accurately and reliably and that expenditure is suitably authorised and approved.
- We will always strive for excellence.
Information
- We protect the confidentiality of Company, employee and customer information.
- We ensure privacy of communications - it is basic to our business, from a legal stance and because the public trusts our integrity.
Assets
- We will protect our physical, financial and intellectual assets.
- We will ensure Company assets are not used for personal benefit and will not allow them to be sold, loaned, or given away without proper authorisation.
Health and safety
- We will care for the health and safety of each other, our customers and the communities in which we operate.
- We will disclose any information about our products and services that demonstrates they breach the required safety standards.
Help and confidential advice
Resolving conflicts
Deciding how to act in the face of conflicting demands can be difficult.
The following questions may help reaching the right decision.
- Is this action legal?
- Are you authorised?
- Have you taken account of any Company policies?
- How would this look in tomorrow morning's newspaper?
- How would you explain your decision to your family?
- Does it conflict with your own or O2's commitments to integrity?
Every employee has the responsibility to ask questions, seek guidance, report suspected violations and express concerns regarding compliance with these Principles and related policies.
Reporting
Those wishing to seek advice or report an incident can be reassured that they will be treated with dignity and respect and will:
- be taken seriously.
- not suffer retribution.
- be treated with the utmost confidentiality.
People with authority within the Company themselves risk disciplinary action including dismissal if they try to stop you and/or impose penalties of any form on you for contacting one of the departments to report or enquire about any behaviour which might be concerning you.
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