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Human rights and new market entry

Assessing the potential human rights risks is a critical factor in determining whether or not we will make an investment, establish an operating business or enter into a commercial relationship with a third-party communications operator in a country where Vodafone currently has no such presence. As part of our standard commercial process for potential acquisitions, licence applications or new local operator partnerships, human rights impact assessments are a standard issue included in this consideration together with security and privacy topics.

If the initial country-level human rights impact assessments raise any concerns, we conduct a formal in-depth human rights due diligence investigation before we enter a new country. The due diligence investigation always starts with a more in-depth human rights impact assessment, which covers a number of issues, including:

Historical, present and emerging human rights challenges in that specific market

When applicable, the nature of the planned partner, including e.g. ownership structure

Identifying the potential human rights impacts from the planned transaction, as well as the potentially affected rights holders

The type of goods/services involved

The actions taken as a result of the human rights due diligence investigation depend on the nature of the business relationship at issue. For example, we seek to develop mobile roaming relationships and international communications cable connections with as many countries as possible to ensure our customers can communicate wherever they are in the world. We believe there is a clear social good arising from providing citizens everywhere with the ability to connect with others around the world. At the other end of the commercial spectrum – where Vodafone is considering acquiring an operating business, bidding for a telecommunications licence or making an equity investment – a country’s human rights record is as likely to influence our decision as any commercial aspect of the proposed transaction.

In some countries, the presence of multinational companies that operate to high ethical standards (including greater levels of disclosure) under international scrutiny can potentially have a positive influence on prevailing attitudes to human rights matters.

Grievance mechanisms

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 and therefore a breach of our Code of Conduct, including potential adverse impacts on human rights, freedom of expression and privacy.


Employees can report suspected breaches in three ways:

  • via their line manager;
  • via the local human resources team; or
  • via a confidential external hotline Speak Up in their own language and by phone or online.

Suppliers, contractors and business partners

Speak Up is also made available to all of 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 work done on behalf of Vodafone directly.

Supply chain integrity

Customers and external stakeholders

Customers and other external stakeholders are encouraged to select their relevant market and use the appropriate help and support contact details.

Customer privacy queries under the EU General Data Protection regulation (GDPR) can be raised via the dedicated local market GDPR privacy query forms available here.

Cooperation and collaboration

We firmly believe that the most effective solutions to advancing human rights in information and communications technology (ICT) are created by working together as an industry. We are therefore an active participant in many industry fora in business and human rights:

The Global Network Initiative (GNI)

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 by setting a global standard for responsible company decision making and by being a leading voice for freedom of expression and privacy rights.

As part of our Board commitment, we have commited to implementing the GNI Principles, which require member companies to put in place concrete measures to safeguard free expression and the right to privacy in their operations. To ensure compliance, GNI companies undergo periodic independent assessments on their implementation of these principles to enable the GNI Board to determine whether a member company is ‘making good faith efforts to implement the GNI Principles with improvement over time’.

Tech Against Trafficking (TAT)

Vodafone Group is a member of the TAT initiative. Hosted by Business for Social Responsibility, TAT is a coalition of technology companies collaborating with global experts to help eradicate human trafficking using technology. TAT members include Amazon, AT&T, BT, Microsoft Corporation, Nokia and

TAT’s goal is to work with civil society, law enforcement, academia and survivors to identify and to create technology solutions that disrupt and reduce human trafficking; that prevent and identify crimes; and that provide remedy mechanisms for victims and support survivors through innovation, collaboration, guidance and shared resources.

The Joint Audit Cooperation (JAC)

Vodafone is an active member and contributor in the JAC, which is an association of telecommunications operators established to improve ethical, labour and environmental standards in the ICT supply chain. Vodafone led, in collaboration with other member companies, the launch of JAC Supplier Academy, which focuses on developing training to help suppliers assess and improve their own operations. The Academy is committed to help build further the capacity of the suppliers’ certified managers to exchange best practice in responsible supply chain management.

United Nations 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.

Business Against Slavery

Vodafone participate in the Home Office’s ‘Business Against Slavery’ Forum working group. This group was established as a partnership between the UK Government and business to accelerate progress in the fight against modern slavery and to create and facilitate the sharing of best practice.

GNI assessment

As part of our membership of the GNI, we must commit to implement the GNI Principles, putting concrete measures in place to protect and advance freedom of expression and the right to privacy.

All GNI companies undergo an independent assessment of their implementation of the Principles every two years, to demonstrate their efforts in practice. We started preparations for our first independent assessment in August 2018 by setting up a team of senior level experts from across the business and across our operating markets to participate in the required interviews, evidence collection and report writing. We continued this work until the March 2019 Board review meeting, working together with our independent assessor, who reviewed our processes, policies and the governance model that we use to safeguard our user’s rights to freedom of expression and right to privacy, to ensure all relevant areas were covered.