Our Work

Case Study: Vodafone

Driving greater business integrity for 100k+ employees in over 25 countries

Vodafone pledged to drive up its integrity as a business by an innovative training programme to help employees behave more responsibly and ethically on a day-to-day basis. Achieving an outstanding (and above-target) completion rate of 95%, it embedded a shared understanding and upholding of Vodafone’s Code of Conduct.


The Business Challenge

Vodafone Group is a British multinational telecommunications company headquartered in the UK. With 535 million customers, it is one of the largest mobile communication providers in the world. Vodafone owns and operates networks in 26 countries, and has partner networks in 55 further countries.

In this fiercely competitive industry, where there is a lot of consumer mistrust, unsatisfied customers switch suppliers easily and digital communications enable them to share negative opinions widely and almost instantly. Consequently for Vodafone, acting with integrity is essential to its long-term success.

The Executive Committee (ExCo) set a goal to establish and maintain a global compliance culture in which every employee – from the ExCo to the newest employee – automatically acts with integrity and adheres to the company’s defined Code of Conduct.


Being an admired company is not just about our performance and achievements, it’s also about acting in a responsible, ethical and lawful way.Vittorio Colao, Vodafone Chief Executive Officer

The Learning Challenge

In 2017 Vodafone redoubled its efforts to embed the Code of Conduct into the fabric of its day-to-day business, tackling how people work together, treat one another, protect customers and protect the company.

An ambitious and broad remit, the chosen learning solution would need to:

  • Reach a global audience Vodafone is an incredibly complex organism, encompassing more than 100,000 people, multiple languages, cultures and business lines, and operating across 25+ countries which currently operate very autonomously
  • Be consistent, yet relevant to all Gaps and inconsistencies in training across the company would undermine Vodafone’s effectiveness in preventing and detecting non-compliance, so the programme had to be the same for all, yet would still need to be relevant to different markets/roles
  • Truly engage It would need to make a really good case to encourage every employee to take time out of their working day to complete the training: the target was 90% completion across new and existing employees within 42 days of training launch (or 42 days from start date for new hires)


The Solution

Vodafone collaborated with Lumesse to simplify existing learning content into just five 20-minute elearning modules, focusing on the core areas within the Code of Conduct – a brave move which risked removing key content the employees could need to learn.

In a first for the company, Vodafone adopted a gamification approach, creating a distinct game for each of the five modules. To keep users engaged, they could choose to take test questions immediately, or view related guidance from one of the game characters before answering. Harnessing the power of social learning, users can see how their colleagues have answered the test questions.

  • Anti-bribery Users roll dice and move through a virtual snakes and ladders board. Along the way they’re faced with eight scenarios, focusing on some of Vodafone’s key business activities

  • Code of Conduct Led by Hero, Vodafone’s Code of Conduct expert, this module brings the Code of Conduct to life and helps apply it in day-to-day scenarios

  • Health and Safety Driving realism and engagement, this module was based on the details of a real case in which there had been a fatality: users need to successfully make their way through Vodatown, collecting tokens and overcoming obstacles along the way

  • Privacy Privacy is central to earning and sustaining trust in Vodafone, and this module enables employees to learn more about Vodafone’s privacy commitments

  • Security In this game the character Amira, from the Security team, has identified some serious security breaches in the office: the user must move from room to room using clues and answering questions to secure all zones and protect Vodafone

Amazing course. The materials used are simple and easier to learn. Great job. The content is very useful for any organization to cope with bribery and all ethical behavior issues.

Clear, colourful and useful e-learning. Absolutely recommended.


Over 90,000 Vodafone employees are now trained (95% completion rate within the 42 day-window), exceeding their company target of 90%.

The programme was successfully launched in twelve languages and received positive feedback across all their markets.

It was so well received that 98% of employees said they would recommend the programme.

Across the globe there has been a notable shift in compliance culture in the last financial year. Vodafone has seen an increase in the number of cases reported globally via the line managers/HR directors/confidential ‘Speak Up’ hotline; an increase in the number of queries and questions received by Group Compliance from the business, and a stronger employee awareness and recognition of the Code of Conduct and compliance risk as a whole.