Reporting Code of Business Conduct Violations

We want to promote an open culture, where people ask questions if they are unsure and raise concerns if they believe our Code of Business Conduct has been violated.

Seeking guidance

Throughout the Code we have tried to include useful guidance, examples and references to help you apply the principles to situations you may face in conducting your job. However, the right way to act may not always be clear, even after a review of relevant Code provisions. Ask questions before undertaking any action that may violate any applicable law, rule, regulation, Company policy or other provision of the Code. If you have questions, you can seek guidance from:

  • Your Compliance Officer
  • Your Legal Department
  • The Chief Audit & Compliance Officer of the Liberty Global Group
  • The General Counsel of the Liberty Global Group

Reporting concerns

If you become aware of or suspect any conduct that you believe violates any applicable law, rule, regulation, Company policy or other provision of the Code, you are required to report such improper conduct as promptly as possible. Typically, this would involve reporting the matter directly to your Compliance Officer. However, if you are uncomfortable reporting the matter to your Compliance Officer, you may always report it to your immediate supervisor or department head, your Human Resources Representative or any member of your Legal Department. If you are not comfortable reporting to any of these individuals, you may always contact the Chief Audit & Compliance Officer or the General Counsel of the Liberty Global Group.

If the Code violation you are reporting is related to an accounting, internal control or auditing matter, you may also make your report by using the Company’s web-based reporting system, by calling the Compliance Line or by sending a letter, fax or email to the Chief Audit & Compliance Officer or the General Counsel of the Liberty Global Group. The Compliance Line and web-based reporting system are operated by a third-party vendor and are available 24 hours a day, seven days a week. The phone number of the Compliance Line and web address of the third-party vendor are posted at your office location. Employees located in the United States may report any Code violation via the Compliance Line or web-based reporting system, even if the violation is not an accounting, internal control or auditing matter.

We encourage open and honest communication. If, however, you feel the need to communicate your concerns anonymously you may do so. You should be aware, however, that it is often more difficult to investigate properly matters communicated anonymously.

Reports of ethical violations will be kept confidential to the extent possible, consistent with our Company's need to investigate and take action regarding the matter. Employees are also expected to keep information regarding such matters confidential and understand that they are expected to fully cooperate with any such investigation.

No retaliation

We will not permit retaliation against any employee who, in good faith, seeks advice concerning, or who reports or complains of violations of, the Code or other illegal or unethical conduct. If, however, an employee makes a false report of a violation or of questionable behavior for the purpose of harming another person, the reporting employee will be subject to disciplinary action.

Amendment, modification and waiver

The Code may be amended, modified or waived at any time by the Board of Directors of Liberty Global plc. Any waiver of the Code for directors or executive officers of Liberty Global plc will be promptly disclosed to the public if required by and in accordance with applicable legal requirements.

Severability

If any provision of the Code is held to be illegal, void or unenforceable because of any law or public policy, the remaining provisions will continue in full force and effect.