ESG and responsible business continued 27 Vodafone Group Plc Annual Report 2026
Vodafone Group Plc Annual Report 2026
Strategic report
Governance
Financials
Other information
Our approach to materiality and ESG reporting
Our materiality assessment process We approached the materiality assessment as an extension of our ongoing work; consolidating impacts,
functional input from across the business. The proposed list of material topics was reviewed by senior leaders, and approved by the Board. As we move towards CSRD compliance we continue to review, enhance and update our approach to our materiality assessment which may result in changes to the identified topics in future periods. Each material topic is validated and sponsored by a member of the Executive Committee, this enables topic-level leadership and embeds accountability throughout the business. These responsibilities include overseeing the relevant strategies, action plans, progress and delivery against future commitments. The responsible Board Committee receives regular updates on progress across our material topics. Read more about our ESG governance on page 25 Read more about our governance structure on page 71 The materiality assessment outputs are summarised in the ‘Our material topics’ table which outlines the ESG matters identified as material to us. Details on strategically important topics that are not identified as material have been removed from this report. Read more about our non-material topics on page 24 Read our material topics table on page 26 Our response to identified material topics The responsibility to develop and implement a strategy to manage each material topic is assigned to a senior leader within the relevant business function aligned to the Executive Committee sponsor for the topic. Delivery teams work cross functionally to deliver against the agreed strategy and are supported by our ESG Reporting function, who ensure that decision-useful information is reported to manage progress. An update on our programmes in each of these areas is available in this report. Read more about our material topics on pages 28 to 57
topics against sector peers, drawing on industry standards such as the SASB Telecommunications Service Standard and S&P CPA Sector Specific Guidance, alongside desk-based research. The potential material topics were reviewed by the Chief External Affairs Officer to assess relevance prior to undertaking stakeholder engagement. Both internal and external stakeholders were consulted using individual interviews, group workshops and surveys. Stakeholders included internal specialists, employee groups, senior leaders, suppliers, investors, and representatives from industry groups. Identification of material topics were determined using a centralised scoring methodology that incorporated both qualitative and quantitative elements. For each topic, we considered the most relevant parts of our value chain (own operations, upstream, or downstream) and relevant time horizons. The value chain relates to the full lifecycle of our activities from conception to end of life, including both upstream suppliers and downstream customers. A topic is material from an impact perspective when our actions, or those of our suppliers, customers, or business partners, lead to significant effects on the environment or on people. For impact materiality we considered scale, scope, irremediability, and likelihood of actual or potential impacts. A topic is material from a financial perspective when the topic can affect our financial performance significantly either positively as an opportunity or negatively as a risk. For financial materiality we assessed probability and magnitude of topic-related financial effects leveraging our integrated risk management process. The process has been led by our ESG Reporting and Sustainable Business teams with cross-
Phase 1 Desk-based research
risks and opportunities already recognised across our operations through a structured process. We continue to strengthen our approach to ESG, driving alignment with commercial strategies and developing strong governance throughout the organisation in preparation for future reporting under the Corporate Sustainability Reporting Directive (‘CSRD’) and UK Sustainability Reporting Standards (‘UK SRS’). Our reporting is prepared using a reporting boundary for our own operations consistent with our financial statements. In addition, we include information on material value chain components. Our approach to materiality assessment We have conducted an extensive and in-depth double materiality assessment considering both the financial and impact materiality of various ESG matters across the Group. In performing our materiality assessment, we assessed our business model to identify and evaluate all potential material topics, considering both impact (‘inside-out’) and financial (‘outside- in’) perspectives. This assessment was grounded in a thorough understanding of the context of our operations and value chain focusing on our core activities. Where appropriate, we considered heightened risks and impacts associated with specific activities, business relationships, geographies, and our end-to-end value chain. To deliver the materiality assessment we undertook a top-down approach starting with a list of sector agnostic topics. In addition, we benchmarked our activities and potential material
Phase 2 Consolidation of potential material topics
Phase 3 Stakeholder engagement
Phase 4 Scoring
Outputs Indicative list of material topics
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