Our ethical standards are explained in the WPP Code of Conduct and we have detailed policies on anti-bribery and corruption, gifts and entertainment and the appointment of third-party advisors. 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 and policies.

Employees complete our compulsory ethics training, ‘How we behave’, which covers topics such as diversity, privacy, responsibility to stakeholders, and avoiding misleading work. It uses scenarios to help people identify and respond appropriately to ethical issues they may encounter in their work. The training was refreshed in 2013 and has since been completed by over 120,000 employees worldwide. 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, facilitation payments and the use of third-party advisors.

54
calls to our Right to Speak employee reporting facility in 2013

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 54 calls made via Right to Speak during 2013, all of which were followed up.

We expect associate companies (those in which we hold a minority stake) and affiliate companies (preferred partners to whom we may refer business) to adopt ethical standards that are consistent with our own. We communicate our expectations to associates and affiliates and we are in the process of extending our ethics training and anti-bribery and corruption training to employees of WPP’s associate companies.

Chapter 3 of 10

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