Anti-corruption
Swisscom Group’s anti-corruption efforts are monitored in the central Group-wide compliance management system (CMS). The anti-corruption policy specifies the conduct expected of employees in the battle against corruption. The CMS uses context analysis to identify all applicable legal and contractual regulations and record them as compliance risk management (sub)categories in the governance, risk and compliance tool. The risks of business activities are then identified and ultimately eliminated or mitigated with appropriate measures (e.g. anti-corruption directives, training, control processes). The controls, monitoring and audits that the Group has implemented enable corruption risks to be detected. There are also options for reporting suspected cases to the responsible compliance functions or a whistleblowing channel.
Swisscom Group conducts its business fairly, honestly and transparently and is opposed to any form of corruption.
Compliance or Internal Audit functions (whistleblowing) investigate suspected violations of the code of conduct or anti-corruption policy internally, independently of management. The procedure for reporting to public authorities is set out in detail in the compliance policy and the Whistleblowing Directive.
The anti-corruption policy is sent to all employees who are required to read and accept it. All members of management and the Board of Directors must complete an e-learning course, which includes an exam. Employees who encounter members of public authorities or legislatures in the course of their work (lobbyists) receive additional in-depth training reflecting their heightened exposure to the risk of corruption. All training courses are held at least every three years. The last training courses in 2023 were successfully completed by 95% of the employees concerned. In Italy, 100% of functions-at-risk were covered by training programmes in 2025.
In Italy, the Model 231 of Fastweb and Vodafone Italy represent an additional comprehensive structure of rules and controls aimed at preventing offences set out in Legislative Decree 231/2001. The Anti-Corruption Officer reports periodically to the Board of Directors, the Independent Control Committee and the Board of Statutory Auditors on their activities and ensures proper functioning of the anti-corruption management system, which is ISO 37001-compliant and certified annually by an external auditor.
The code of conduct prohibits the offering of benefits to public officials, limits the value of gifts, and strictly regulates sponsorships and donations (excluding donations to political parties). Prevention relies on ‘just-in-time’ risk updates and the use of confidential whistleblowing channels compliant with Legislative Decree 24/2023 (Italy), which are also available to external stakeholders. The guidelines are shared internally through the intranet and training activities, and externally via the company’s website. The Board of Directors of Fastweb receives information regarding the guidelines and major anti-corruption procedures and formally approves them.
In the year under review, there were no confirmed convictions for violation of anti-corruption and anti-bribery laws, and no fines were issued.