Materiality assessment

We have been on a transformation journey in recent years to strengthen our approach to ESG, driving alignment with commercial strategies and developing strong governance at the most senior level. This approach is designed to support our future reporting under the Corporate Sustainability Reporting Directive ('CSRD'), the European Directive which will require us to disclose the material environmental and societal impact of our business activities.

We have conducted an extensive and in-depth materiality assessment based on the requirements of CSRD in force as at the date of publishing our FY25 Annual Report. We are continuing to review our processes and intend to publish the results in our future reporting. The materiality assessment was conducted at Group level to align with the highest reporting entity, incorporating deep dives into our operating companies to ensure a comprehensive view across our Group. Multiple internal and external stakeholder groups were engaged for input which were scored using pre-defined criteria to determine the key material topics for Vodafone. The work completed to date has identified various material topics spanning ESG matters, which are summarised in 'Our material topics' table.

Accountability for each material topic is embedded throughout our business. Each material topic is sponsored by a member of the Executive Committee (‘ExCo’), who is ultimately accountable for its development; their responsibilities include overseeing the material topic’s progress and delivery against future commitments. The Board recieves regular updates on progress across our material topics through our ESG Governance structure.

Responsibility to develop and implement a strategy to manage each material topic is assigned to a senior leader within the ExCo sponsor’s business function. The senior leader works with relevant teams and subject matter experts on the material topic, cross-functionally if required, to deliver activities in line with the strategy agreed by ExCo. Delivery teams are supported by our reporting function, who take a compliance lens to their undertakings. An update on our programmes in each of these areas is available in our Annual Report.