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Code of Conduct



VIRGIN MEDIA - Code of Conduct

You’re part of something big.
You’re part of something special.
You’re part of Virgin Media.

At Virgin Media, we’re working hard to create a company where our people come first. Where they feel valued, respected and empowered to do their stuff. For us, that’s the secret to making Virgin Media the biggest and best Virgin company in the world.

Our Code of Conduct helps us achieve that. In a nutshell, it looks at a few main areas where it’s really important that we’re all working together, in the best way we can. By sticking to it, we’ll make sure we earn respect, trust and confidence from our customers, our suppliers and from each other.

Then we can get on with the business of doing what Virgin companies do best – providing great customer service.

Our brand values

What sets us apart from the competition is the way Virgin people think and act. Our brand values reflect that. And they fit in perfectly with our Code of Conduct – in fact, they go hand in hand with each other.

Our values are:

Behaving with integrity, honesty, respect and empathy. Treating others as you would like to be treated and valuing everyone's contribution.

Having an ambition to succeed, focused on delivering results and exceeding customer expectations - every time.

Feeling enabled and empowered to be the best that we can be, free to do the right thing for our customers and for each other.

Making our own decisions, seizing the moment and taking responsibility for our actions. Be bold, act fast.

Creating a climate where being at work is enjoyable.

Our Code of Conduct

To make sure we’re all doing the best job we can, for the team and for our customers, it’s important that every one of us agrees to stick to the Virgin Media Code of Conduct. By agreeing to it, you’re agreeing that you’ll stick to it, in everything you do.

So here it is, straight up. The principles we’ll stick to when it comes to…


We’ll do everything we can to keep you safe and well at work.  We’ll give you the relevant information and training for your job and details of any relevant health and safety procedures. You’ll find more information about health and safety on the Intranet, or by contacting the Health and Safety department.

Make sure you follow any health and safety procedures that relate to your job. Never carry out any work that either you haven’t been trained to do, or you don’t have the right equipment to do, safely.  Always report any health and safety issues that could be dangerous to you or your colleagues. Ask your manager if you’re at all unsure.

Encourage openness, honesty mutual respect, we will allow people to challenge constructively and be able to ask questions.


Virgin Media offers all its people access to a Community Fund. It’s all about encouraging and recognising our people by helping to fund charitable and community projects in which our people are actively involved. That’s across a wide range of arts, sport, heritage, charitable and other community activities and events which are 'not-for-profit' groups and registered charities.


We take confidentiality very seriously, and we’ll treat any breach of confidentiality as gross misconduct.  This means you could be dismissed without notice - even on your first offence.  If you’re not sure whether information is confidential, please check with your line manager, and bear in mind that:

  • All company information belongs to Virgin Media.  This includes contracts, copyrights, patents, trademarks, accounting and payroll records, systems documentation, business, marketing and service plans, engineering and manufacturing ideas, designs, databases and various other items. You mustn’t give this information, or any other confidential company information you have access to, to anyone else, either inside or outside the company, unless they absolutely need to know. 


  • We collect personal information from our customers, such as their name, address and selection of services and programming. This information can only be used for billing and other legitimate activities related to providing our services and detecting unauthorised use of our services. We collect and process it in line with data protection legislation. You must treat all customer information as confidential. If you pass on customer information without their permission, you could be breaching data protection and privacy legislation.
  • You mustn’t write or talk about anything to do with Virgin Media in the media or with any outside organisation without getting written permission from a Managing Director or the Public Relations (PR) team.  We think it’s great if you’re asked to speak or write about Virgin Media.  It’s useful experience for you and good publicity for us. But please check your speech or article with the public relations team first, to make sure that what you’re planning to say isn’t commercially sensitive. 


  • The exception to this rule is where you are writing in newsgroups, chat rooms, and social network sites, we are keen for you to contribute to social networks like blogs, Twitter and Facebook to promote Virgin Media.  But you must only do so once you have read our Social Media Policy, which is designed to guide you through interacting with those communities.  And remember, we take confidentiality and the protection of our company information very seriously, so do not publish or post confidential information about the company and/or the people associated with it. Take time to read the sections below on customers and laws and regulations.
  • If you’re working with someone not employed by Virgin Media and think you might need to share confidential information with them, please contact the Legal team to see whether you need to set up a confidentiality agreement.


  • When you join the company, we don’t expect you to give away any confidential information from your previous employer.  Similarly, even after you leave Virgin Media, you must treat any information relating to our company as confidential.

…conflicts of interest

You mustn’t put yourself in a position, either inside or outside work, where your personal interests conflict or even seem to conflict with Virgin Media’s business interests.  Don’t do anything that might mean you stop being independent or objective, or that could lead to our customers, suppliers or fellow colleagues losing confidence in our integrity

  • If you’re involved in any activity or relationship that could lead to a conflict of interest, you must enter this on the Register of Interests and tell your line manager.


  • You’ll find more information about conflicts of interest in the Conflicts of Interest Policy.


Always be fair with customers, suppliers, other colleagues and competitors. Never take advantage of another person or organisation by manipulating or hiding information, abusing privileged information or misrepresenting the facts.

Be careful not to endorse any service, product, manufacturer or firm or suggest that one service, product or business is better than another.  This applies both to anything you say yourself and to anything you say by implication, through agents or colleagues.

You must always act within competition and fair trading laws.  This means you mustn’t take any actions or make agreements that abuse our market power or prevent trade and competition. (For example, price fixing, cartels or boycotts).

We are committed to providing technology needed for entertainment, information and conversation explained in a language that is understood.

If things go wrong we will resolve the issue as quickly and as fairly as we can.

…discrimination and harassment

We take equal opportunities seriously. If you discriminate against or harass another colleague, it could lead to disciplinary action being taken against you, up to and including dismissal.  Check out the People section of the Intranet for more information about Equal Opportunities and Harassment Policies or speak to your local People Team Representative.

…gifts and hospitality

You mustn’t allow yourself to be put in a position where a gift or hospitality could be seen to influence a business decision.

  • Make sure you get the right approvals before you either offer or accept gifts or hospitality. These are set out in the Gifts and Hospitality Policy.  


  • Register any gifts or hospitality that are offered to you on the whether or not you actually accept them. The only exception is for very low-cost items, such as t-shirts, pens, business diaries and calendars, or a very occasional business lunch up to the value of £50 per person.

…gifts to government officials and employees

You mustn’t give presents, meals or anything of value to government officials, employees or members of their families without written permission from the Legal team. Never offer anything of value to influence official acts or government decisions, to win or keep business or to gain any improper advantages.  Bribing a government official could lead to criminal penalties.

The US Foreign Corrupt Practices Act (FCPA) explicitly forbids making any improper payments to “foreign” officials – remember that for the US, “foreign” includes us in the UK!. This includes foreign political parties and their officials, and candidates for foreign political office. If you think you could be in a sensitive position, or you might be asked to make illegal payments, contact the People team. They will arrange for you to read the FCPA Guidelines and ask you to sign and date a Certificate of Compliance to show that you understand and accept the terms.

…improper payments and Bribes

You mustn’t offer, give, approve or accept a payment or anything of value that’s intended to influence a business decision, keep business or win new business. 

You mustn’t use company money or assets to make political contributions or illegal payments of any kind.

If you’re not sure whether a payment is allowed, please give full details to your manager and ask them to contact the Legal team.

…insider trading

You can buy shares in the company as a Virgin Media employee, but please talk to the Legal team first.  There are very strict rules about Insider Trading, and it’s important that nobody even appears to break them.

If you have access to material, non-public information, you mustn’t buy or sell Virgin Media Inc. shares or pass the information on to anyone else to persuade them to buy shares.  By material, non-public information, we mean information that a reasonable investor might see as important in a decision to buy, hold or sell shares, and so which could affect the price of shares. Examples of this would be:

    • News of a merger or acquisition
    • Projections of future earnings or losses
    • News of a sale of a subsidiary
    • Significant new products or discoveries
    • The financial status of Virgin Media


Even if this information is made public, you must wait at least two full trading days before you start trading straight after a public announcement so you don’t look like you are trying to ‘beat the market’ by trading either at the same time as, or immediately after, an official company announcement.. This is because we must give the public and our shareholders the time to react to, and use, the information.

Insider trading is a criminal offence, which can lead to investigation and/or criminal prosecution.  If you breach this section of the Code, we’ll treat it as gross misconduct, which could result in dismissal without notice.


You’ll find more information about insider trading in the Insider Trading Policy.

…intellectual property

So that we stay competitive, it’s important that we make sure any new ideas or designs you produce as part of your job are not exploited in any unauthorised ways.

  • Any copyright, design right or other intellectual property rights (including moral rights – the right to be identified as the author of a work) in any material or invention that you create in the course of business, belongs to Virgin Media. 


  • Please tell your manager about anything that might need formal protection under the patent, copyright, design and trade mark legislation, and co-operate with the registration process.  You will also need to complete any documents or take any action we might ask you to, both during and after your employment, to confirm that all the intellectual property rights you created in the course of business are owned by Virgin Media.
  • If your job involves creative work, your salary will normally cover the payment of any rights to intellectual property you create. But if we recognise that Virgin Media will benefit significantly from the new idea, we might choose to recognise this with a personal reward.


…laws, rules and regulations

If a law conflicts with a policy contained in this Code of Conduct, you should comply with the law. But, if a local or regional custom or policy conflicts with this Code of Conduct, you should comply with this Code.


You mustn’t give out or email unsolicited non-work-related personal literature during company time and/or on company premises.

…political payments or contributions

You mustn’t make any political contribution or payment on behalf of Virgin Media for any reason without written permission from the Legal team, and you mustn’t encourage any other colleague to do this either.  (This includes things like buying tickets to political dinners, adverts on behalf of political candidates, donations of company property or services and payments to the media meant to influence individual decisions).

The law about company contributions to political activities or people is complex and full of pitfalls!  If you’re not sure whether an item is covered under this section of the Code, talk to your manager and ask them to check with the Legal department.

…responsibility to our security holders

We will always make full, fair, accurate, timely and understandable disclosure to comply with all applicable laws and regulations, in all reports and documents we file with, or submit to, the US Securities and Exchange Commission, and in all other public communications we make either in the US or in Europe.


You’ll find our “Guide to working with our Business Partners” on the Virgin Media intranet. Just visit virginmediahome to find out more. 

Speaking up if something doesn’t look right

It’s down to each of us to make sure we stick to our Code of Conduct. And there’s plenty of help and support if you’re concerned about anything – including how other people stick to the Code.

So if you think another member of the team might be acting fraudulently or dishonestly, tell your team leader, line manager, HR representative or any other manager straight away. Don’t forget, if you don’t report it, you could find yourself facing disciplinary action including suspension or dismissal.

You can also phone us in confidence on 0800 096 7800.  The call is free, and you don’t have to give your name if you don’t want to.

We’ll investigate any reports thoroughly. It’s important that you don’t try to carry out your own investigation, because there could be complex legal issues involved.

You’ll find more information in the Whistleblowing Policy


Putting all this into practice

We’ve tried to cover everything we can. But if you find yourself in a situation that doesn’t seem to be covered and you’re not sure what to do, here’s what you can do.

  • Ask yourself what exactly you’re being asked to do, and use your judgement and common sense. If something seems unethical or wrong, it probably is.
  • If any of your colleagues are involved in the same situation, talk it through with them to get their views.
  • Ask your manager or team leader for advice.  If for some reason you can’t talk to your manager, go to your People Team Representative.
  • Alternatively, you can telephone us in confidence on 0800 096 7800.  The call is free, and you don’t have to give your name if you don’t want to.


Nothing in here is intended to stop you from making a protected disclosure under the Public Interest Disclosure Act 1998.