Policies

Vodafone Group Health & Safety Policy

The Vodafone Group Health and Safety Policy, endorsed by the Main Board and signed by the Chief Executive, Vodafone Group Plc, is reproduced in full below:

Health and Safety Policy Statement
Inherent in our Vision and Values is Vodafone's commitment to ensuring the health, safety and welfare of employees. Throughout the organisation we apply high standards in the management and control of our operations. These standards are designed to ensure that in all our activities we properly safeguard those who work for us and those who may be affected by our operations.

Although the standards established by national legislation will apply as a minimum, we will always strive to achieve best practice in the local context of every country in which we operate, and share this across the Group so that we implement continuous improvement.

We will oversee Group wide health and safety management through the Health and Safety Council, a team chaired by the Group Health and Safety Director with members drawn from different functions, several operating companies and Group.

Each company within the Vodafone Group will develop, implement and continuously review a health and safety management system, consistent with local operating conditions and legislation. The following key elements must be incorporated within that system, as a minimum standard:

• A statement of policy, endorsed, supported and signed by the Chief Executive, which recognises that:
  - Health and safety is an integral part of the daily business process, not an add-on extra
  - Best practice can only be achieved with management leadership and commitment
  - The commitment and participation of all employees in the health and safety management process is essential for success. Working safely is mandatory.
• Details of the management systems, standards and responsibilities that are in place to manage health and safety throughout the business
• Details of the arrangements that are in place to ensure that all work activities conform to the relevant local legislative standards and requirements
• A statement of the mechanisms which integrate the activities of contractors and suppliers into the Company's health and safety systems and responsibilities
• A clear exposition of the training arrangements that ensure employees understand the relevant health and safety issues and are competent to perform their duties without undue risk to themselves or others
• A list of the methods in place for monitoring and measurement of health and safety performance and of the mechanisms for communicating the results to the management and workforce.

Each company will report annually to the Main Board:

• The health and safety performance of the Company, including accident and major incident data, audit findings, health and safety objectives and the action plans to achieve them
• Liaison with enforcement agencies in relation to local business activities.

Responsibilities
Ultimate responsibility for health and safety rests with the Main Board. The Group Human Resources Director has the specific responsibility for overseeing the implementation of Group policy and for advising the Board on its development.

The Group Health and Safety Director is responsible for co-ordinating and driving activities throughout the Group to ensure continuous improvement.

The Chief Executive of each Operating Company within the Group has responsibility for the local implementation of Group Health and Safety Policy and for the organisation, management and conduct of operations in line with Group standards supported by adequate resource allocation.

The Operating Company Human Resources Director or another designated board director will advise the Operating Company Chief Executive Officer in the operation of the Health and Safety Policy within the Operating Company.

Each Operating Company will have access to a designated Vodafone Health and Safety professional responsible for supporting the Company to achieve the standards.

Line Managers have responsibility for the health and safety of those working within their operation and those who may be affected by the activities. They must ensure that adequate systems are in place to ensure delivery.

All Employees have the responsibility to protect their own health and safety and that of others who may be affected by their activities. Adequate training must be employed to allow them to be able to do this. Each Operating Company will ensure it has standards which are adhered to on:

• Monitoring, Follow up and Reporting of Accidents and Occupational Health Problems
  - Serious incidents
  - Works accidents
  - Lost time accidents
  - Accidents causing over three days' lost time
  - Major accidents
  - Deaths due to works accidents
  - Occupational illnesses
• Working at Height
• Electrical Work
• Contractor Control
• Emergency Response to Fire/Threat etc
• Building Evacuation Practice annually for each location
• Exposure to Radio Frequency Waves
• Adequate Fire Marshals/First Aiders
• Driving at Work
• Call Centre Ergonomics
• Mobile Phones and Driving
• Violence at Work

Arun Sarin
Chief Executive

 

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Management of the Health & Safety Risks of RF Fields

Background/purpose
Inherent in Vodafone's Vision and Values is the commitment to protect the health and safety of employees, contractors, customers and members of the public.

This policy deals with risks to health and safety that may arise from radio frequency (RF) fields, including interaction of the RF fields with the human body, interference with medical equipment (e.g. hospital, implanted, or body-worn equipment), interference with safety-related electronics (e.g. aircraft systems), ignition of flammable atmospheres, and detonation of electro-explosive devises. The schedule contains detail on levels of compliance required.

This policy should read in conjunction with relevant policies for RF workplaces (e.g. the Standards on Contractors and on Working at Height), and position statements on RF and the Compliance Standard.

Scope
Vodafone Group Services and Vodafone Operating Companies ("Vodafone") shall comply with the minimum requirements in this policy, which covers:

• Radio Base Stations (including any radio transmission equipment not normally operated in close proximity to the human body) that Vodafone operates solely and sites that it shares with others
• Terminal Equipment normally used in close proximity to the human body (e.g. handsets, computers which contain datacards with radio transmitters)
• All phases of procurement, design, planning installation, commissioning, operation, maintenance, and de-commissioning of Radio Base Stations and during the lifecycle of Terminal Equipment procured, designed, supplied, marketed, maintained or modified by or under the advice of Vodafone.

Responsibilities
Group Strategy Director is accountable for RF matters within Vodafone Group. He will put methods in place to ensure compliance with this policy.

Members of the Group EMF Council are responsible for designated duties in respect of Vodafone's handling of RF issues.

Global Technology Development Director shall ensure appropriate RF compliance and health and safety assurance procedures are in place for all Terminal Equipment, including a mechanism for ensuring that all SAR test facilities are audited and approved by a respected external authority or by Vodafone, and that testing is conducted to appropriate standards.

Operating Company CEO is accountable for that Operating Company's compliance with Vodafone Group Health and Safety policies, including allocation of resources and accountabilities to comply with this policy.

An Operating Company Director will be nominated as responsible for ensuring certified compliance of Terminal Equipment relevant to that Operating Company. Similarly, a Director will be nominated as responsible for ensuring that Radio Base Stations comply with relevant aspects of this policy, including the health and safety of employees and contractors working in and around RF sources.

Operating Company EMF Leader is responsible for ensuring the implementation of this policy and that related audits (e.g. Key Control Questionnaire) are undertaken.

Line Management is responsible for implementing this policy, for ensuring processes, procedures and training are developed and implemented for their area of responsibility, and for ensuring compliance with the details in the schedule.

All Staff (Employees and Contractors) must comply with safety procedures, participate in training, and use monitoring equipment as instructed.

Policy

• Compliance Statement: Each Operating Company shall maintain a list of the RF standards with which they comply in relation to Radio Base Stations and Terminal Equipment. As a minimum, they will ensure policies and processes are in place to meet this policy and schedule, and applicable local statutory requirements.
• Radio Base Stations
  - For sites which Vodafone operates solely or with others, each Operating Company shall operate documented procedures for the site selection, design, installation, commissioning, operation, maintenance and decommissioning phases. These will ensure:
  1. Work is carried out by trained and competent staff, whether Vodafone employees or contractors
  2. Staff, whether Vodafone employees or contractors, take adequate measures to do the work safely
  3. Systems of work are in operation to manage the risks in accordance with Section 4.1 for both general public and workers
  4. There is clear signage/demarcation and effective access control for restricted areas
  5. Site shut down/power down or other appropriate procedures are implemented to control work within relevant exclusion zones
  6. Site landlords are provided with sufficient information to ensure that they can fulfil their obligations to preserve the safety of third parties
  7. Appropriate guidance is available to the general public and workers in accordance with Vodafone Group position statements and national guidelines
  8. Maintenance of appropriate records to demonstrate compliance with the above and clear accountability for data.
• Terminal Equipment
  - Prior to purchase of the product, Operating Companies shall ensure that for Terminal Equipment:
  1. Vodafone is in possession of a declaration of compliance in accordance with this Policy, the attached Schedule, and appropriate national guidelines
  2. Vodafone has access to a SAR test report demonstrating that the product has been tested for reasonable modes of use for the Terminal Equipment (i.e. any product which could be used against the ear has been tested in this mode, a product which could not be used against the ear has been tested for body compliance, and a product which could be used both against the ear and against the body has been tested in both modes)
  3. A new declaration and SAR test report is available in the event of Vodafone or manufacturer-sanctioned changes that could impact on SAR
  4. Appropriate Health & Safety guidance and a statement of compliance is available to the user
  5. Operating Companies shall confirm that Vodafone Global Technology Development Team has approved the test facility that produced the test report.
• Auditing and Verification: In each Operating Company, there will be a method of checking that the processes and documentation above are up to date and that Radio Base Stations and Terminal Equipment are compliant. This will ensure a system is in place to report and investigate any suspected non-compliance incident (e.g. alleged over exposure to RF), consideration is given to the health of any individual(s) concerned and safety management systems are working
• Compliance with RF exposure limits and risk management is incorporated in all contracts for procurement of Terminal Equipment and Radio Base Station infrastructure
• Records are kept, subject to any applicable data protection legislation of:
  - Workers who are potentially exposed to RF field levels above ICNIRP general public guidelines e.g. workers who maintain antennas etc
  - Complaints to Vodafone from individuals alleging they have suffered personal health effects caused by Vodafone's network or terminal equipment.

Mobile Phones and Driving

Background

• Inherent in our Vision and Values is that Vodafone regards the safety of employees, customers and those who may be affected by their actions, of vital importance
• Phones in vehicles have considerable benefits (e.g. ability to call emergency services, weather and traffic information, security for lone drivers, communications on the move, etc)
• Research indicates that there is a risk to safety when the driver of a motor vehicle is distracted (e.g. by in-car entertainment, lighting a cigarette, passenger interaction, etc)
• As using a mobile phone while driving can be a distraction, Vodafone adopts policies which aim to improve the safety aspects of phone use while driving
• The driver is ultimately responsible for the safe operation and control of their vehicle at all times
• Vodafone observes the law in each of the countries where it operates and will provide guidance to its employees and customers on minimising the risk from the use of mobile phones while driving. This policy shall therefore be modified in accordance with local laws
• Vodafone seeks to encourage improvements in the technological aspects of mobile telephony and will examine its policy and practices regularly to ensure they include the best solutions.

Responsibilities

• Each Operating Company within Vodafone will ensure that it has developed and implemented a strategy to address the issues related to phones and driving
• The Operating Company CEO is responsible for implementing and operating this policy. This responsibility may be delegated to a named member of the Operating Company management team.

Use of a Handset While Driving

• Manual interaction by the driver with a mobile handset (such as holding the handset to engage in a call and, in particular, picking up the handset to look at the screen, pressing the keys to dial a number etc) while driving may be a distraction and thus increase the risk of an accident
• Vodafone strongly advises that all drivers do not use hand held mobile phones while driving
• Drivers should under no circumstances send or read any text or picture-based services when driving and should ensure that they are safely parked before using these.

Use of a Hands Free Mobile Phone While Driving

• In those jurisdictions where local laws are in force which prohibit the use of some types of hands free kits while driving, Vodafone will ensure that its local communications to customers and employees are relevant to the local legal situation
• Some research has indicated that using a hands free kit while driving can contribute to the likelihood of an accident although to a lesser extent than using a hand held handset
• Vodafone will develop practices to provide information to its customers and employees so that they may have proper regard to the possible risks if they make or answer a call using a hands free kit while driving. Drivers should consider a number of factors which may increase distraction as follows:
  - The level of distraction for the driver is greater during call set-up (especially when dialling numbers for example)
  - Longer calls are more of a distraction than shorter calls
  - Emotional or complex calls are more distracting than simple calls
  - Driving conditions may also affect the level of driver distraction caused by the use of a mobile phone while driving. In particular, some research has indicated that the combination of easy driving conditions and an emotional or complex call is the most distracting combination of these factors - possibly due to the shift in concentration from driving to the call. This conclusion is not obvious and is therefore a good example of the kind of information and guidance which should be communicated as part of Vodafone's advice to customers and employees.
• Vodafone will also inform its customers and employees that if they make a call using a hands free kit while driving, there are ways of reducing the level of distraction. For example:
  - Using voice activated dialling or answering
  - Using one touch dialling or one touch call back
  - Switching phones to voicemail when driving
  - Calling the person back later when the journey is complete
  - Keeping calls short
  - Explaining to callers that you are driving and will not be able to talk for long or may have to terminate the call suddenly.
• Ultimately, the safest way of using a mobile phone is to find a safe place to pull over and stop before making the call.

Personal Hands Free Kits
The available research does not take account of the differences between built in hands free kits and personal hands free kits. Nor does the research take account of new technologies such as voice dialing, or hands free kits which operate by means of a Bluetooth connection between the phone and head set. The position in respect of different types of personal hands free kits therefore remains unclear.

Employees

• Advice regarding the safety of phones and driving to employees and customers is the same. As an employer, each Vodafone Operating Company shall ensure that its employees are informed of the safety aspects of using mobile phone handsets and hands free kits while driving
• Vodafone employees will ensure that they only use a mobile phone with a hands free kit while they drive when they judge it to be safe
• Vodafone will inform its employees that they must not use a hand held phone while driving. The use of a hand held mobile phone by any employee while driving in the course of his or her employment shall be considered a disciplinary offence
• When Vodafone supplies a mobile phone to an employee for use in connection with their employment, and that employee is entitled to a personal company vehicle, Vodafone will supply them with an appropriate hands free kit. In other vehicles the employee should consider the best method to ensure the safety of phone use
• Vodafone will enable employees to receive adequate instruction on how to set up their mobile phone to reduce levels of driver distraction (e.g. voice activation etc).

Communication and Consistency

• Vodafone will consider a variety of means of communicating with its customers and employees so that the message reaches as many intended recipients as possible. This may include use of targeted communications such as customer welcome packs and newsletters, point of sale material, employee publications, internet and intranet sites
• Vodafone will ensure that its statements around the world on mobile phones and driving remain consistent and compatible with current scientific knowledge.

Accident Investigation

Background/Purposes
Accidents and ill health from work activities cause individuals pain and suffering, and reputation damage and costs to Vodafone. Vodafone will take action to prevent accidents and occupational ill health by ensuring all accidents are suitably investigated. Knowledge of the factors causing accidents helps us take actions to prevent recurrence - thus working towards a zero accident culture.

This document sets out minimum standards for investigating all accidents, incidents and ill health at work. It requires each Operating Company to establish policies and procedures to adequately investigate these events, identify key contributing factors, and instigate corrective actions.

This policy is to be read in conjunction with Vodafone's Global Health and Safety Standard - Reporting of Accidents, Incidents and Work Related Ill Health, the schedule to the Accident Investigation Policy and any local legislative requirements.

Scope
This document applies to all Operating Companies and contractors working on Vodafone's behalf. It covers all accidents to employees, contractors or third parties as a result of Vodafone's undertakings.

Responsibilities

CEO
Is accountable for the Operating Company's compliance with Vodafone Group Health and Safety Policies including allocation of resources and accountabilities across business to meet this policy.

Directors/General Managers
Ensure that documented systems and resources are in place to investigate work-related accidents and ill health thought to be caused by work. This includes identification of a single point of contact within the Operating Company (the Designated Safety Manager) to support line managers, ensure that investigation is adequate and that actions are identified to prevent recurrence.

Designated Safety Manager

• Ensures Accident Investigation Policy and procedures have been developed and communicated. These include roles and responsibilities, accident investigation and reporting methodologies, and a clear escalation process
• Collaborates with line managers involved in the accident investigation.
• Has access to suitable investigation tools and professional advice
• Ensures that information is complete, accurate and capable of independent verification
• Reports major accidents including fatalities to the CEO and Group Health and Safety Director by the quickest practicable means
• Analyses accident data, rates and trends, in order to build suitable specific action plans.

Line Management

With support from the Designated Safety Manager, line managers will ensure that:

• All accidents and incidents at work are promptly reported and are adequately investigated in line with the requirements of this Policy (ie to an extent in line with the severity of the actual and potential outcomes)
• Employees actively co-operate with investigations
• Suitable actions are taken to prevent a recurrence.

All Staff

• Report all work-related accidents, incidents and occupational diseases
• Actively co-operate with investigations.

Contractors must

• Ensure they and their sub-contractors have investigation policies and procedures that meet the requirements of this policy and the Health and Safety Standard "Contractor Control"
• Investigate and communicate all work-related accidents on Vodafone business to the Vodafone Management
• Actively support and participate in investigations, and instigate actions to avoid recurrence
• Ensure all accidents are reported in line with Vodafone and local statutory requirements.

Accident and Incident Investigation - Policy Principles

• All accidents/incidents will be investigated. The scope of the investigation will be based on the actual or potential significance of the accident/incident
  
• The investigation of major accidents or fatalities should be overseen by a safety professional from another Operating Company to ensure objectivity and thoroughness.

Investigation must identify contributing factors and their relative significance. Accident reports recommend controls to prevent recurrence.

The investigation report is based on factual evidence gained during the investigation including witness statements and statements made by the injured person.

Policy
Each Operating Company will ensure that a suitable policy and process is in place to ensure all accidents and incidents are adequately investigated, and that the findings of the investigation are communicated to key stakeholders. Details of contributing factors and appropriate controls to mitigate or prevent risk of future occurrences will be identified and used.

As a minimum, each Operating Company must:

• Have a documented accident investigation policy and procedure which applies to staff, contractors and third parties
• Have access to a suitable competent expert resource to undertake and/or support in the event of significant accidents/incidents
• Provide staff or ensure access to the necessary investigation tools and equipment to isolate, photograph, and record statements at an accident/incident
• Ensure relevant Vodafone management and statute authorities are notified as required, and local legislative requirements and Vodafone Policies and standards are complied with
• Ensure fatalities and major accidents are notified immediately to the Operating Company Health and Safety Manager, who will inform the CEO and Global Health and Safety Director and address any local statutory reporting requirements.