Vodafone’s approach to sourcing minerals responsibly

At Vodafone, we connect for a better future. We strive to deliver our services securely and responsibly and maintain the trust of our customers.

This means we are committed to ensuring that our business acts ethically, lawfully and with integrity wherever we operate, supported by our corporate transparency programme.

We set out our approach to sourcing ‘conflict minerals’ responsibly each year, including how we comply with relevant disclosure regulations.

Vodafone – a Responsible Minerals Front-Runner

A recent report by non-profit organization Development International identified Vodafone as a ‘Responsible Minerals Front-Runner’ for adhering to standards set out by the SEC and Europe’s OECD.

The analysis confirmed that as a ‘Front-Runner’, Vodafone is “currently leading the charge by investing in high-quality conflict minerals due diligence and reporting and achieving full compliance to SEC regulations and conformance with OECD recommendations.”

It also confirmed that Vodafone has submitted Conflict Minerals reports and made Specialized Disclosures to the SEC in the past two years. Vodafone has published annual Responsible Minerals Reports, using OECD’s 5 steps framework to report Conflict Minerals. Vodafone’s ESG reports have also discussed Conflict Minerals, in addition to cobalt.

With the EU Corporate Sustainability Due Diligence Directive requiring compliance by no later than July 2027, it will become even more important for companies to understand their supply chains and ensure transparency with regulators and the public.

What are conflict minerals?

This refers to four minerals – tin, tantalum, tungsten, or gold – that are sometimes mined in conditions of conflict or forced labour. Or the proceeds of selling these minerals can be used to finance armed groups.

Collectively these minerals are known as the ‘3TG’, and they are used in a range of everyday products including electronic devices like mobile phones.

Tin, for example, is often used to solder electronic components. Gold and tantalum are used in connectors or capacitors. And tungsten may be used in printed circuit boards.

But it can be difficult for consumers to know whether devices like phones are made from minerals linked to funding violence or human rights abuses. That’s why telecoms companies like Vodafone are tasked with making sure that the phones they make themselves, or that they buy from manufacturers, only contain responsibly sourced minerals.

Vodafone sells a range of products that may contain one or more of the 3TG’s. In addition to mobile phones, we also sell tablets, smartwatches, broadband routers, and TV set-top boxes.

Our Internet of Things (IoT) service relies on small electronic transmitters, and so do our Vodafone Automotive anti-theft car tracking devices.

Most devices we sell are made by Original Equipment Manufacturers (OEM) – the well-known global brands. These companies report on their own sustainability performance, including the origin of the metals they use.

We also sell devices under our own brand, and these are mostly designed and made for us by companies classed as Original Design Manufacturers (ODMs). We have some influence over how these ODM products are produced. But outside of some Vodafone Automotive products, we don’t own or operate the factories producing ODM products.

It’s these ODMs products, and the products we manufacture ourselves, that are the focus of our efforts on the 3TG conflict minerals.

Our approach to sourcing minerals responsibly

Vodafone is committed to source minerals responsibly. It’s our aim to ensure that none of the products or components we buy contain 3TG metals that have helped to fund conflict or other risks.

We review annually how our suppliers buy and make products that we sell or supply under our own brand. The next step is to find any products that are likely to include 3TG metals – our ‘In-Scope Products’. For these, we have some degree of influence on how they are manufactured, such as specifying certain criteria for the materials, parts and components used.

In 2023, these included our connected home devices like routers, modems and set-top boxes, plus mobile broadband dongles and IoT devices. Our In-Scope automotive products included alarm sirens and intrusion sensors, parking assistance products and GPS tracking systems.

3TG metals used in the components of the In-Scope products are processed by many smelters in a complex and often opaque supply chain. The process starts with minerals extracted from mines. Smelters buy these minerals and process them into useable metals.

Those smelters and refiners - and the mines from which the minerals are originally sourced – are often many steps away from Vodafone in the supply chain. To find the origin of any 3TG metals used in our In-Scope products, we conduct a Reasonable Country of Origin Inquiry (RCOI) alongside detailed due diligence. The RCOI determines whether minerals originate in the Democratic Republic of the Congo (DRC) or an adjoining country

Our contracts with In-Scope suppliers require them to report on their use of the 3TGs, and in turn, we make their suppliers do likewise. This obligation cascades down the supply chain until the origin of 3TG metals in our products can be identified.

Our Responsible Minerals Report 2023 sets out in more detail how and where we source our minerals, along with our due diligence framework and our efforts to further mitigate risks.

We also explain how we adopt a similar approach to responsibly sourcing cobalt, which is mainly used in lithium-ion batteries in some of our In-Scope Products.

How do we comply with disclosure regulation?

Vodafone complies with relevant disclosure regulations - both in Europe and the US.

The EU’s Conflict Minerals regulation was introduced in 2021. It aims to ensure that EU importers of 3TG are meeting international responsible sourcing standards, set out in the OECD’s ‘due diligence’ guidance. Vodafone does not import minerals, so the EU regulation is not applicable to us.

But telecoms operators like Vodafone that are publicly listed in the US are also legally required to carry out an annual ‘country of origin’ inquiry and report their findings to the Securities and Exchange Commission (SEC).

We rely on the data given to us by our suppliers. We sometimes identify smelters in our supply chain that don’t conform with the Responsible Minerals Initiative (RMI) Database. We then engage with suppliers to encourage their smelters to comply with the RMI. If they don’t, we escalate the issue or and can remove them from the supply chain.