Codes and policies
Our Code and policies are written not simply as a set of rules, but to give accessible and helpful guidance to employees on how to bring our values to life and to articulate how we expect them to behave.
Our Code of Business Conduct (‘our Code’) sets the standard for what is expected of everyone working at Diageo – ‘the way we work, every day, everywhere’. All other policies and standards flow from its principles. We bring the words off the page through training, engaging communications, workshops and competitions.
Our Code of Business Conduct
A code of business conduct is only as good as its implementation, which is why all Diageo employees are required to attend training on our Code. We also give refresher training and updates as our Code evolves with changing regulation and best practice. The board once again mandated this year that all middle managers and above must complete an annual certification to confirm their compliance with our Code, and to identify any areas of possible non-compliance.
Applicable to all
Our Code applies to everyone working for Diageo worldwide regardless of location, role or level of seniority. We expect those representing and acting on behalf of Diageo, including temporary and contract employees, consultants, agents and any other third party acting in our name, to do so in accordance with the principles of our Code. We expect all our suppliers to adhere to our Partnering with Suppliers standard, which includes the key principles from our Code that are applicable to them.
Comprehensive and clear
Our Code provides clear guidance on a number of areas, including:
- Our products: marketing and innovation; quality; international trade and free zone sales
- Personal integrity: gifts; conflicts of interest; insider trading
- Commercial integrity: bribery, corruption and improper payments; competition and anti-trust; money laundering; accurate reports and accounts
- Employment: health, safety and security; discrimination and harassment; responsible drinking
- Company assets: brand protection; information management and security; data privacy
- External activity: external communications; political activity; community and charitable giving; human rights; environment.
Read our Code in full
Our Code is underpinned by a number of global policies covering specific areas of our activities in more detail. They are:
- Anti-corruption – introduced in May 2012
- Anti-discrimination and human rights
- Anti-money laundering
- Brand assurance
- Competition and anti-trust
- Corporate security
- Data privacy
- Employee alcohol
- External communications
- Information management and security
- Occupational health and safety
Updates this year
Making policies easier, simpler, more relevant
For standards and procedures to be effective, they must be easy to understand and relevant to the people who have to follow them. In our review of policies last year, we reduced the number of global policies and ensured they all had the same look and feel as our Code, with a common structure, and were significantly shorter than the old policies.
We launched the new policies in September 2011 along with a ‘policy finder’ tool on our intranet to help employees find those most relevant to them. We also assigned each policy a subject matter expert 'owner'. If employees are unsure about an aspect of a policy they can contact the relevant subject matter expert for further guidance. Subject matter experts work closely with the global compliance and ethics team on the annual communications plan around policies, and on deciding on the right type of training for employees to ensure we get the correct balance of education and engagement without overloading them with too much information.
Strengthening the fight against corruption
Corruption is a very serious threat to many companies, and with the evolution of our business, and continuous desire to raise the bar of our performance, we felt it necessary to create a dedicated, stand-alone policy to explain our approach, encourage best practice in this area and keep it top of mind with employees. In May 2012, we launched a new anti-corruption policy. In line with our theme of simplicity and clarity, the new policy pulls together into one place clear guidance on those areas of business activity that may expose Diageo to risks of bribery and corruption:
- Private commercial bribery (as well as that of government officials)
- Relationships with our business partners
- Charitable and political donations
- Extortion and personal security
- Meals, entertainment, travel and gifts.
Ensuring our Code is clear and consistent
Following our review of policies last year, we updated our Code in July 2012 to be consistent with the new simplified global policies, as well as taking this opportunity to make some minor updates throughout to improve consistency and clarity. The changes to our Code include:
- A new section bringing together guidance on the areas of activity that could expose us to risk of bribery, corruption or improper payments
- ‘Doing the right thing’ – a new section on ethical decision making
- A simplified and consolidated section on information management and security
- New SpeakUp contact numbers, to encourage employees to report concerns or potential breaches
- A clearer link with our values