SAFARICOM SUSTAINABLE BUSINESS REPORT 2019 INTRODUCTION OUR BUSINESS OUR MATERIAL TOPICS STAKEHOLDER ENGAGEMENT CONCLUDING REMARKS 29 The main focus areas of potential risk for corporate security during the year under review have been: • Adverse regulatory environment; • Cyber risks; • Market disruptions such as competition and changes in our business ecosystem; and • Partnership management risk. ETHICAL BEHAVIOUR We recognise that corruption drives inequality by preventing fair access to economic power and basic social needs and, in extreme cases, results in violation of human rights. We take steps to cultivate awareness and put anti-corruption monitoring and corrective measures in place, and drive behaviour change in society through collective action initiatives. ETHICS AND COMPLIANCE AMONG OUR EMPLOYEES In FY18, anti-corruption training of contract and full-time equivalent (FTE) staff was conducted mainly via staff sessions. In FY19, we provided customised training on a department-by-department basis. In FY20, we intend to change our approach to ensure better coverage. Anti-corruption preventative measures (% of total staff) FY19 FY18 FY17 FY16 Ethics and anti-corruption staff training 96% 98% 98% 98% In high-risk departments 98% 98% 98% 98% In medium-risk departments 98% 98% 98% 98% Ethics awareness sessions are conducted annually. Following feedback from our ethics perception survey, topics covered include duty to report and conflicts of interest. These awareness sessions highlight policies such as the employee code of conduct, which outlines the importance of reporting any ethical issues in the business, and by which all staff and Board members are required to make a regular declaration against conflicts of interest. Staff ethics training to promote an ethical culture within the organisation also takes place annually, supplemented by mandatory e-learning courses. These empower staff to successfully address any risks arising in their departments or roles. Our ethics and compliance function was independently audited to ensure its continued efficiency in promoting ethical business practices and fighting corruption, both internally and among our partners. ETHICS TRAINING FOR OUR PARTNERS We continuously provide business partner ethics and anti-fraud training to promote ethical business practices among our M-PESA agents, dealers and suppliers. We collect all KYC documents to ensure compliance, and are developing a new app to bring about efficiencies in the digital capture of KYC documentation during the subscriber registration process. KYC Training for our Business Partners and Suppliers Dealers trained through dealer training forums (64% attendance) M-PESA agents trained Awareness broadcasts covering all M-PESA agents suppliers trained via supplier forum 282 61,567 37 248 The Code of Ethics promotes and enhances ethical business conduct in line with the UNGC principles relating to human rights, labour standards, environment and anti-corruption. We continue to make it mandatory that our suppliers sign up to the Code for Businesses in Kenya; their contracts are not renewed unless they do so. Ninety-six per cent of our suppliers have signed up so far.