The online Vodafone Group Sustainability Report 2014/15 (the Report) has been prepared by the management of Vodafone, who are responsible for the collection and presentation of the information within it. Our responsibility (Ernst & Young LLP), in accordance with Vodafone management’s instructions, is to carry out a limited assurance engagement on the following subject matter:

Collection, consolidation and presentation of:

Sustainability data relating to:

  • Energy
  • Carbon (CO2) emissions
  • Greenhouse gas (GHG) emissions
  • Network waste
  • Fatalities
  • Lost time incidents (LTIs)
  • Gender diversity

The balance and accuracy of claims made in the following sections of the Report, marked with an Ernst & Young footnote:

  • Enabling a low carbon economy
  • Empowering sustainable choices
  • Minimising our carbon footprint
  • Managing our impact
  • Health and safety
  • Our people – diversity & inclusion
  • Privacy and security – Vodafone’s alignment with the industry dialogue guiding principles on freedom of expression and privacy

Our responsibility in performing our assurance activities is to the management of Vodafone Group only in accordance with the terms of reference agreed with them. We do not accept or assume any responsibility for any other purpose or to any other person or organisation. Any reliance any such third party may place on the Report is entirely at its own risk.

What we did to form our conclusions

Our assurance engagement has been planned and performed in accordance with the International Federation of Accountants’ International Standard for Assurance Engagements Other Than Audits or Reviews of Historical Financial Information (ISAE3000). The subject matter has been evaluated against the following criteria:

  • Coverage of the material issues determined through a review of documentation and an assessment of coverage against Vodafone’s own materiality process.
  • Consistency of performance claims and selected data with underlying company level documentation and explanation provided by relevant managers.
  • Completeness of the data in terms coverage of material reporting entities.
  • Accuracy of data collation and presentation (including limitations) of data within the report.

In order to form our conclusions we undertook the steps outlined below:

  1. Interviewed Vodafone executives and senior managers to understand the current status of social, ethical, environmental and health & safety issues, and to understand the progress made during the reporting period.
  2. Reviewed Vodafone’s representation of material issues included in the ‘in scope’ sections of the Report. We re-assessed prior year conclusions on the coverage of material issues and conducted media analysis across the reporting period to enable us to test the coverage of topics within this year’s Report.
  3. Reviewed information or explanations supporting Vodafone’s reporting of progress in the ‘in scope’ sections of the Report. Supporting documentation was sought and reviewed for a sample of 50 sustainability performance claims.
  4. Reviewed the collection, consolidation and presentation of data relating to energy; CO2 emissions; GHG emissions; network waste; fatalities; LTIs and gender diversity. This included:
    1. Interviewing staff responsible for managing, collating, and reviewing data at Group for internal and public reporting purposes.
    2. Testing evidence provided by Group to support the reported figures, for example, reviewing energy and GHG emissions calculation spreadsheets, incident reports for a sample of safety incidents and HR dashboards for diversity data.
    3. Remotely reviewing energy and network waste data reported by six local markets on a sample basis, to assess whether the data had been collected, consolidated and reported accurately. The six local markets selected for review were Ghana, Greece, India, Spain, Tanzania and UK.
    4. Testing whether energy; carbon; GHG emissions; network waste; fatalities; LTIs and gender diversity data has been collected, consolidated and reported appropriately at Group.
    5. Reviewing a selection of management documentation and reporting tools including guidance documents.
    6. Reviewing the Report for the appropriate presentation of the data including the discussion of limitations and assumptions relating to the data presented.

Level of assurance

Our evidence gathering procedures have been designed to obtain a sufficient level of evidence to provide a limited level of assurance1 in accordance with ISAE3000.

The limitations of our review

  • Our work included headquarters based activities and limited remote testing of six local markets for Environmental data.
  • Our review was limited to the sections of the Report outlined above which is found in the sustainability section of the Vodafone Group website. Our review covered a limited number of claims and data points selected on a risk basis, and only the pages marked with an EY verification footnote formed part of our assurance.
  • As part of our scope in 2014/15 we reviewed Vodafone’s statement of alignment with the Telecommunications Industry Dialogue Guiding Principles on freedom of expression and privacy. Our review was limited to assessing whether relevant policies and procedures are in place and did not extend to assessing Vodafone’s implementation or effectiveness of these within the business.

Emphasis of Matter

The health and safety data provided in the report formed part of our scope of work. However, due to issues identified through the assurance process we were unable to form an opinion on the Lost Time Incidents (LTI) data reported across the local markets.

We have not been able to obtain sufficient evidence from the local markets to conclude on the accuracy and completeness of the LTIs reported.

Our conclusions

On the basis of our review we provide the following conclusions on the Report in relation to the overall plausibility of the statements and the completeness and accuracy of the sustainability data. Our conclusions should be read in conjunction with the above section on ‘What we did to form our conclusions’ and the ‘Emphasis of Matter’.

Balance and accuracy of sustainability performance claims

  • Nothing has come to our attention to suggest that the claims on performance in the sections of the Report included within our scope of review are not fairly stated.
  • We are not aware of any material aspects of Vodafone’s sustainability performance which have been excluded from the Report.


  • With the exception of the limitations highlighted by Vodafone in its footnotes accompanying the ‘in scope’ data and our ‘Emphasis of Matter’, we are not aware of any local markets that have been excluded from the environmental, safety and diversity data presented in the Report.


  • With the exception of the limitations highlighted by Vodafone in its footnotes accompanying the ‘in scope’ data and our ‘Emphasis of Matter’, nothing has come to our attention that causes us to believe that the data included within the scope of our review has not been collated and presented properly in the Report.

Observations from our work

Our detailed observations and areas for improvement will be raised in a report to Vodafone management. The following observations do not affect our conclusions on the Report as set out above.

Safety performance

  • Reporting of LTIs has been a challenge for Vodafone in a number of local markets. Vodafone should consider providing more information on how it intends to improve oversight and reporting of health and safety data across all of its markets. Closer oversight of the fluctuations of incidents and the consequent remediation/improvement actions from the local markets would support greater confidence in the data and enhance understanding of performance.

Environmental Data

  • We noted a continuing improvement in the review activities conducted by the local markets to support the accuracy and completeness of the environmental data submitted to Group. This included clear accountability and sign off for material KPIs.
  • Some markets, including Ghana and Tanzania, now outsource the management and operation of a number of their sites to third parties. This has resulted in some actual energy consumption data being unavailable, requiring estimations to be made for the ‘breakdown’ in energy consumption by site or energy source. Vodafone should ensure it has clearly established processes and provides guidance to third parties on reporting requirements.
  • Vodafone has introduced a new target to help customers save double the amount of carbon that is generated from Vodafone’s own operations over the next three years. Vodafone should ensure the methodology used to measure this progress going forward is subject to robust analysis and review.

Gender Diversity

  • In 2015 Vodafone introduced a progressive maternity leave policy across the Group, providing all female employees with access to paid maternity leave benefits. To make continued progress against Vodafone’s aspirations for greater gender diversity, Vodafone should clearly monitor progress of initiatives such as this in driving diversity outcomes.

Defining and measuring ambition

  • While the new carbon commitment is welcome, in other areas Vodafone needs to consider defining its sustainability ambition and measure progress against that ambition. It will need to consider how this can be done across both mature and emerging markets so as to engage the business and create ownership to help deliver the long term ambition.

Our independence

This is the fifth year that Ernst & Young LLP has provided independent assurance services in relation to the Vodafone Group Sustainability Report. We have provided no other services relating to the sections of Vodafone Group’s Sustainability Report which are included within our scope of work.

Our assurance team

Our assurance team has been drawn from our Climate Change and Sustainability Services team, which undertakes engagements similar to this with a number of significant UK and international businesses.

Ernst & Young

Ernst & Young LLP


June 2015


  1. The extent of evidence gathering procedures for a ‘limited level’ of assurance is less than that of a ‘reasonable’ assurance engagement (such as a financial audit) and therefore a lower level of assurance is provided.