Corporate Governance and Responsible Business Practice


Governance and

Responsible Business


Providing our people an empowering workplace

The provision of empowering workplaces has always been a priority for our Group. This environment is managed by our ethics program, that is overseen by our Group Ethics Committee, and is upheld through our Code of Ethics (CoE) and Speak Up platform.


The CoE is inspired by the Group’s core values of respect, excellence, and entrepreneurship, and is designed to align with our digital and cultural transformation. This simple, accessible, but effective, framework ensures that the trust and welfare of all our stakeholders is upheld. The CoE compliance framework defines four categories of ethics breaches, with clear examples of what constitutes breaches, and subsequent disciplinary measures:

In 2020 our Code of Ethics was rolled out Group-wide, and we are pleased to report that this year 97% of our people completed mandatory awareness training. This means that ignorance of what represents unethical behavior is never an acceptable excuse for breaches of our CoE. From June 2021 all employees will repeat the training annually, ensuring everyone is always up to date with best practice.

Complaints relating to breaches of our CoE are made either anonymously through our third-party hosted Speak Up platform, or via the employee’s line manager. All complaints are dealt with in a swift and transparent manner. Additionally, there is a policy of non-retaliation towards anyone raising concerns over breaches to safeguard the ‘messenger’. Moreover, serious breaches are typically penalized through termination of the offender’s contract. This aligns with our Ethics Compliance framework for building a culture of integrity and trust across the whole Group.

Speak Up Platform

Our third-party managed, GDPR-compliant Speak Up platform was introduced in 2019 (know more) to meet the need for an anonymous platform to voice incidents of breaches of our CoE. An advantage of Speak Up, over our previous reporting systems, is that it ensures confidentiality, and is available 24 hours a day, 7 days a week, 365 days a year.

This year, we rolled out a series of webinars in 8 countries: UAE, KSA, Kuwait, Egypt, Jordan, India, Bahrain and Qatar. The webinar presentation introduced the members and structure of the Ethics Panel and the Ethics Committee, process of accessing Speak up and reporting breaches of ethics. 

Through this exercise we learnt that the primary concerns our employees have which prevent them from using the platform are the level of anonymity and the fear of retaliation.


To strengthen awareness of Speak Up and assure users of its confidentiality, we released our ‘What is SPEAK UP?’ document which is available English, Hindi, Tagalog, and Arabic. This ensures that our people, in the most commonly spoken languages in our Group, have a clear understanding of what our Speak UP platform is for and how to use it.

Since its rollout in January 2020, the platform has facilitated granular analysis of ethics breaches where trends in countries, violation type, activity etc. can be identified. This facilitates targeted preventative measures against ethics breaches to be directed where they are most prevalent. Furthermore, we have identified that at least 30% of the incidents raised on the platform do not qualify as breaches of ethics. However, is a very effective way to listen to the concerns of our people. Hence, we have classified these incidents as “concern for improvement”, which then allows each respective business unit or department to review their policies and procedures with the aim of improving our systems.

In 2021 we plan to continue spreading awareness on the platform and analyze the data collected over one year to identify the pain points and introduce preventative measures and target trainings where its most needed