Code and policies
Our Code and policies are not simply sets of rules: they are written to give accessible and helpful guidance to employees on how to bring our values to life every day.
To create a culture of compliance and ethics, it is essential that we make sure our people understand what is expected of them and how they should behave. Our Code of Business Conduct (‘our Code’) sets the standard for what is expected of everyone working at Diageo. All of our other policies and standards flow from its principles.
This year, the board mandated that all lower managers must join middle and senior managers in completing an annual certification of compliance to confirm their understanding of and adherence to our Code and any applicable policies, and to identify any areas of possible non‑compliance.
Code of Business Conduct
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 – 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.
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.
Our Code is underpinned by a number of global policies covering specific areas of our activities in more detail. We review our policy regime every year to ensure that we take account of any changes in our external environment, and we update our policies accordingly. Our global policies cover:
- Anti-discrimination and human rights
- Anti money laundering
- Brand assurance
- Competition and antitrust
- Corporate security
- Data privacy
- Employee alcohol
- External communications
- Information management and security
- Occupational health and safety
Performance against target
|Target by 2013 ||2013 performance ||Achievement
|100% of new joiners completing Code of Business Conduct training on induction (within 30 days)
- This number reflects only those enrolled on the elearning programme; it does not include those trained in face-to-face sessions in several of our markets, and our Supply team.
Building on the work we did to refresh our Code last year, for the past 12 months we have focused on embedding its principles as well as our other policies through locally organised, risk-based training. We aim to bring all our training to life through engaging workshops, communications, and competitions, taking the words off the page and into the culture of our workplaces.
When an employee joins Diageo, he or she must attend training about our Code, which covers key areas including human rights and anti-corruption, and explains how to report breaches and where to get help and advice. We give refresher training and updates as our standards evolve with changing regulation and best practice.
Some regions go beyond the basic training with annual events such as the Pathway of Pride programme in Africa, ‘Asi soy, asi somos, sin excepción’ in Latin America, and Ethics Day in Asia Pacific. These events provide a forum for sharing experiences and promote ethical behaviour, with special workshops and activities that reflect the needs of the region.
The estimated 3,693 employees who joined us during the year were taken through a one‑hour induction on compliance and ethics. This is the same for all, regardless of geography, role or grade. All new employees must do this induction within 30 days of joining; moreover, they are expected to have a conversation with their line manager about our Code and policies, and what is expected of them, within the first two weeks of joining the company.