Managing human rights
Connectivity is an essential part of our lives.
Through our services, Vodafone helps customers make the most of connectivity – from keeping in touch with family and friends, creating, learning and playing, through to growing businesses and transforming public services.
Respect and support for human rights is embedded in our company’s culture. This means protecting the communities we serve, as well as keeping our employees safe.
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 peers in the communications and tech sector on current and emerging risks for us all. 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.
In 2023 we reviewed our salient human rights risks with the support of an external adviser.
We conduct due diligence in line with our internal policies to help make sure that we respect human rights and address potential negative human rights impacts. Due diligence comes in various forms and at different moments in our operations such as:
- An independent human rights risk assessment for a considering new market entry, new partnership or acquisition.
- Anticipation of changes in existing operating environments or roaming partnerships.
- Developing new products, services, technologies or making substantial changes to existing ones.
- Engaging with our suppliers.
- Thematic impact assessments such the child rights assessment.
We follow up assessments of actual or potential negative human rights impacts with what we consider to be appropriate mitigating actions, such as contractual commitments to respect human rights in our partner markets agreements and in our enterprise customer contracts.
Embedding respect
The Chief External and Corporate Affairs Officer oversees Vodafone’s human rights programme and is a member of the Executive Committee. The Human Rights Lead manages our programme, working closely with the Vodacom Group Human Rights Principle Specialist, and is supported by a cross-functional internal Human Rights Advisory Group (HRAG) comprising senior managers responsible for privacy, security, responsible sourcing, and diversity and inclusion amongst others.
Each HRAG member is responsible for implementing the relevant internal policies that are covered by the Human Rights Policy and collaborating with our operating markets to integrate policy controls. In 2023 we established a network of human rights champions in all our local operating companies.
We regularly report on our progress to the ESG and Reputation Committee, which assists the Executive Committee in fulfilling duties with regards to our purpose, reputation management and policy. We 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. In 2023 we made UN Global Compact training on human rights available to all our employees.
Tracking and communicating performance
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
Read more about our memberships and collaboration here.
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 the public and our suppliers, 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 have a non-retaliation policy when a genuine concern has been reported. Everyone who raises a concern in good faith is treated fairly, with no negative consequences for their employment with Vodafone, regardless of the outcome of any subsequent investigation. Speak Up reports are confidentially investigated by local specialist teams, with a senior team in place to triage reports. Each grievance is monitored to verify that any corrective action plan or other relevant remediation activity has been complied with. Our Group Risk and Compliance Committee reviews the effectiveness of the Speak Up process and trends once a year, and the Audit and Risk Committee receives an annual update, with additional ad hoc reviews carried out where appropriate .
