All employees are expected to comply with the standards set out in our Code of Conduct and CR Policy. These provide guidance for our people in dealing with a wide range of ethical, social and environmental subjects and are available on our website and intranet. Both are regularly updated.

To reinforce the importance of meeting high ethical standards, the senior management of each WPP company is required to sign a statement annually confirming that they comply with WPP’s Code of Conduct. 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. This is publicised through induction packs, the Group intranet and the WPP Policy Book. Our Code of Conduct is supported by more detailed policies on issues such as gifts and entertainment and the appointment of advisors.

Ethics training

All employees (about 104,000, excluding associates) must undertake our online ethics training. This uses scenarios to help employees identify and respond appropriately to ethical issues they may encounter in their work. It covers a wide range of issues including privacy, diversity, responsibility to stakeholders, and avoiding misleading work. It reminds employees that they should always “Stop, Think and Consult” when faced with an ethical dilemma and should always report concerns to a manager or to our Right to Speak helpline.

The online training is available on our intranet in English, Spanish, Chinese, Vietnamese, Japanese, French, Arabic, Polish, Hebrew, Flemish, Korean, German and Portuguese and has been completed by 85,930 employees at the time of going to press.

Anti-corruption and bribery

We strengthened our anti-corruption and bribery procedures in 2010. In 2011 we appointed a chief compliance officer (CCO) and compliance team to work with our legal and internal audit teams to lead our efforts. The CCO is responsible for policy and compliance, and will investigate any suspected cases of misconduct. We have reviewed corruption and bribery risks for our business and have incorporated these into our risk management processes. We launched an online anti-bribery training course at the end of 2010 which is accessed via our intranet. The interactive course is available in 12 languages, and the content is translated into a further 23 languages. The course is mandatory for all employees. Over 91,428 employees have completed the course at the time of going to press. Additional face-to-face training is being rolled out to all senior managers.

We believe our business policies and procedures comply with the requirements of the proposed UK Bribery Act and we will ensure compliance with the Ministry of Justice guidance when this is finalised.

There were 42 calls to our Right to Speak helpline in 2010. We investigate all suspected cases of misconduct and take appropriate action. This can include retraining, formal warnings and dismissals. The details of all calls are reported to the Audit Committee.