Our companies are expected to meet high ethical standards in the work that they produce for their clients and the way they work with others.
The WPP Code of Conduct and Group Sustainability Policy help our people in dealing with a wide range of ethical, social and environmental subjects. They apply to all employees in all locations and are available on our website and intranet. Compliance is monitored by our internal audit team. We have a compliance officer to oversee our approach to ethics and compliance, and provide support and guidance to our companies. Every year, the senior management of each WPP company are required to sign a statement confirming that they comply with WPP’s Code of Conduct.
WPP companies have a review and referral process for work that may present an ethical risk. Before accepting potentially-sensitive work, employees are required to elevate the decision to the most senior person in their office and then to the most senior executive of the WPP company in the country concerned, who will decide if further referral to a WPP executive is required. We have a Group-level committee which meets at least quarterly to discuss cases of concern, potential compliance issues and new risk areas.
All our people must complete our compulsory ethics training, ‘How we behave’, which has been completed by over 120,000 employees to date. The course was refreshed in 2013. Employees must also complete our online training on anti-bribery and corruption, which covers the Foreign Corrupt Practices Act and UK Bribery Act and issues such as hospitality and gifts.
Employees can report any concerns or suspected cases of misconduct in confidence through our third party-managed Right to Speak facility, overseen by our internal audit department and reported to our Audit Committee.
Our companies collect, store and use consumer data on behalf of clients. We take action at a Group and company level to make sure that consumer privacy is protected.
In 2013, we also launched the WPP Data Code of Conduct, which provides a clear framework for privacy practices across all WPP companies, as well as global IT Security, Privacy and Social Media policies that all WPP companies must implement.
In 2013, we launched the first global WPP Data Health Checker to review the privacy risks within the Group and to assess the privacy practices at each of our companies. It was completed by 73% of all companies, and assessed both privacy risks, such as how much data is held and the types of data collected, as well as mitigation measures – the steps taken by agencies to secure and protect data.
The results of the Health Checker showed that 88% of the companies involved have taken mitigation measures that match or exceed their level of privacy risk. On average, our companies were found to have a risk score of 2.73 out of 5 with 5 being the highest level of risk, compared to the average score for mitigation measures at 3.39 out of 5 with 5 being the highest level of mitigation. This means our companies had an average level of risk but with a higher than average level of mitigation.
Chapter 9 of 13