HUMAN RIGHTS

Implementing policies

Our Group External Affairs Director oversees 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.

Our Head of Digital Regulation and Human Rights manages our programme, together with the Human Rights Senior Manager. The Human Rights (including Child Rights) Policy is owned by a member of the local Executive Committee in each of our operating companies, who is responsible for implementing the policy controls. Delivery of our human rights programme is supported by subject matter experts and local Human Rights Champions.

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. Specialist, senior-level steering committees oversee particular impacts, for example, in relation to human rights of workers in our supply chain.

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. UN Global Compact training on human rights is available to all our employees.

Transparency and progress

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. We also review 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.

Global Network Initiative (GNI) assessment

As part of our previous membership of the GNI, we committed 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 users’ rights to freedom of expression and privacy, to ensure all relevant areas were covered.

Vodafone completed its first formal GNI assessment in March 2019 during which the Board reviewed a detailed report on Vodafone and determined that we are making good faith efforts to implement the GNI Principles with improvement over time.

In 2022 we completed our second independent assessment. The multi-stakeholder GNI Board considered the independent assessment in detail and determined that Vodafone is making good faith efforts to implement the GNI Principles on freedom of expression and privacy with improvement over time. Following the completion of our 2022 assessment, we chose to leave GNI in order to focus our attention on our broader human rights risks and governance and controls at Group level. Simultaneously, Vodacom has applied for Observer status at GNI to take increased ownership of human rights risk management across our Africa footprint.

Raising concerns

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, and on our website. 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 .