All employees are expected to comply with the standards set out in our WPP Code of Conduct and Group Sustainability 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 are required to sign a statement annually confirming they comply with WPP’s Code of Conduct. Our Code of Conduct is supported by more detailed policies which cover a range of issues such as gifts and entertainment and the appointment of advisors. These are included in the WPP Policy Book.
All employees must undertake our online ‘How we behave’ ethics training which is based on the WPP Code of Conduct. It covers topics such as diversity, responsibility to stakeholders, and avoiding misleading work. It uses scenarios to help employees identify and respond appropriately to ethical issues they may encounter in their work and includes a written introduction from Sir Martin Sorrell, our CEO. To reach employees across our businesses, training is provided in a variety of ways, including online and face to face. Employees must also complete our online training on anti-bribery and corruption, which covers the Foreign Corrupt Practices Act and UK Bribery Act 2010 and issues such as hospitality and gifts. By the end of 2011, over 100,000 employees had undertaken both sets of training. We intend to refresh both training courses during 2012.
In 2011, we appointed a compliance officer to oversee our approach to ethics and compliance and to provide support and guidance to our operating companies. She reports to our Group chief counsel and director of Internal Audit.
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, the WPP Policy Book and our ethics training. There were 42 calls made via Right to Speak during 2011, all of which were followed up.
We expect associate companies (those in which we hold a minority stake) and affiliate companies (preferred partners which we may refer business to) to adopt ethical standards which are consistent with our own. We communicate our expectations to associates and affiliates and we are extending our ethics training and anti-bribery and corruption training to employees of WPP’s associate companies.