Managing human rights
Alignment with UN guiding principles
We align with the UN Guiding Principles. This means we work to make sure our policies,
governance and due diligence processes take account of human rights risks so that we
can properly manage and mitigate them.
Our approach to managing human rights:
Assessing our impact
We focus on the most salient human rights issues in our operations. We take action first on the most severe risks, based on how they could affect people rather than just the risk to our business.
We collaborate with the tech sector on current and emerging risks for us all, keeping pace with changes. We keep a close watch on the markets where we operate by keeping in touch with civil society on the ground and contributing to multi-stakeholder forums.
We commissioned external human rights experts Business for Social Responsibility (BSR) to independently identify our salient human rights impacts.
This exercise is complemented by additional impact assessments conducted in specific circumstances, for example:
Developing new products, services, technologies or making substantial changes to existing ones.
Entering new markets or in anticipation of changes in our existing operating environments.
Considering new partnerships and acquisitions.
Engaging with our suppliers.
We also conduct topic-specific impact assessments. For example:
Partnering with BSR to evaluate impact and recommended actions when operating in higher-risk geographies.
Piloting Unicef's Mobile Operator Child Rights Impact Assessment (MOCRIA) to identify how our operations impact children’s rights, both opportunities and risks, and where we could improve.
The Group’s Chief External and Corporate Affairs Officer oversees Vodafone’s human rights programme and is a member of the Executive Committee. A senior human rights manager manages our programme, with the support of a cross-functional internal Human Rights Advisory Group (HRAG) comprising senior managers responsible for privacy, security, responsible sourcing, policy, legal and diversity and inclusion.
Each HRAG member is responsible for implementing the relevant internal policies that are covered by the umbrella Human Rights Policy and collaborating with our operating markets to integrate policy controls.
We report on our progress to the Reputation and Policy Steering Committee, where we also raise any concerns regarding how our operations – or business partners’ operations–could result in a negative human rights impact.
All our employees receive training on the Code of Conduct. This is supplemented with training on specific human rights impacts for relevant employees, contractors and suppliers. For example, our corporate security teams receive ‘Challenging Demands’ training in the context of law enforcement demands, and our supply chain teams receive training on modern slavery. This is also extended to our suppliers.
Tracking and communicating performance
Our cross-functional Human Rights Advisory Group (HRAG) meets regularly to track our performance, challenges and external trends.
Compliance with each policy relevant to human rights is reviewed periodically across the Group.
We are committed to transparency and externally report on our performance, such as the number of law enforcement demands we receive in each of the countries where we operate, the number of issues and remedial actions related to forced labour identified in supplier audits, and how many grievances have been raised through our anonymous Speak Up mechanism and remedial action taken.
Access to remedy
We believe that transparency is essential to help put things right when they go wrong. Some of our most salient impacts arise because of our links with the actions taken by others. For example, see our section on Law Enforcement Demands which describes how we have to take action when governments direct us. In those situations, governments are accountable for remedies.
However, we try and play our part by raising awareness and being transparent about the position. Our collaboration with others through organisations such as Global Network Initiative (GNI) and UN B-Tech means we can collectively advocate for respect for human rights.
Everyone who works for or on behalf of Vodafone must report any behaviour at work that may be unlawful or criminal or could amount to an abuse of our policies, systems and processes. Employees are able to raise concerns with a line manager, with a colleague from human resources or through our confidential third-party hotline – Speak Up – accessible online or by telephone.
Speak Up is also made available to our suppliers and is communicated through our Code of Ethical Purchasing. For suppliers that decide to maintain their own grievance mechanisms, we require that they inform us of any grievances raised relating to direct work for Vodafone.
We also give customers in each of our markets access to channels to raise concerns.
Co-operation and collaboration
We recognise the important role of civil society advocacy. We value constructive dialogue with civil society, including human rights defenders, to advance respect for human rights. We also partner with civil society on research such as our work with Access Now on artificial intelligence and Human Rights.
We firmly believe that the most effective approach to advancing human rights in our sector is to work together as an industry. We are therefore an active participant in many industry groups in business and human rights:
The Global Network Initiative
Vodafone is a Board member of the multi-stakeholder GNI, which was established in 2008. The GNI brings together ICT companies, civil society groups (including human rights and media freedom groups), academics and investors with a shared mission to protect and advance freedom of expression and right to privacy in the ICT industry. It sets a global standard for responsible company decision making and is a leading voice for freedom of expression and privacy rights.
United Nations B-Tech Project
Vodafone actively engages with the multi-stakeholder UN B-Tech project led by UN Human Rights aimed at advancing the implementation of the UN Guiding Principles on Business and Human Rights in the technology sector. As part of this engagement, Vodafone is one of twelve companies that participates in the B-Tech company community of practice.
Joint Audit Cooperation
Vodafone is currently Chair of the Joint Audit Cooperation (JAC) initiative, an association of telecommunications operators established to improve ethical, labour and environmental standards in the information and communications technology (ICT) supply chain.
Vodafone is a member of JAC’s industry task force on human rights. The task force tackles risks in the downstream supply chains of the telecoms industry and meets to understand the actions needed to engage suppliers, and to review JAC’s approach to due diligence.
UN Global Compact
Vodafone is a participant in the United Nations Global Compact – both internationally and through a number of UNGC country networks. As part of this, Vodafone supports the Ten Principles of the United Nations Global Compact on human rights, labour, environment and anti-corruption. We are committed to making the UN Global Compact and its principles part of the strategy, culture and day-to-day operations of our company, and to engaging in collaborative projects that advance the broader development goals of the United Nations, particularly the Sustainable Development Goals.
Vodafone is a member of the Global System for Mobile Communications Association (GSMA) that represents the interests of mobile operators worldwide, uniting more than 750 operators with almost 400 companies in the broader mobile ecosystem, including handset and device makers, software companies, equipment providers and internet companies, as well as organisations in adjacent industry sectors.