Strengthening our decision-making process

During 2008 we identified a number of improvements to our process for reviewing ethical issues in client work. Changes we will implement during 2009 include:

Referral procedures

Formalising our referral arrangements in a written procedure distributed to all company CEOs. We will include accountability for escalating concerns over client work in the Code of Business Conduct compliance form signed by all CEOs annually. Quarterly review meetings will be held for senior managers at Group level to discuss cases of concern and identify new risk areas. These will be communicated to company CEOs and CFOs via quarterly bulletins from Paul Richardson, Group finance director.


Benchmarking our Code of Conduct against those of other leading companies and strengthening the code provisions as appropriate.

Training and support

Launching online ethics and risk training to raise awareness of the risks associated with client work and underline the importance of compliance with WPP’s Code of Business Conduct. This will include prompts and guidance on when work should be referred to management. The intention is for training to reach a majority of our companies’ employees on a regular basis.


Including client risk factors in our internal audit process.