46 Vodafone Group Plc Annual Report 2026
Strategic report
Governance
Financials
Other information
Maintaining Trust continued
Network shutdowns Digital connectivity is crucial for exercising human rights, including freedom of expression and access to information. The intentional disruption of electronic communications mandated by a government, known as ‘network shutdowns’, heavily restrict these freedoms. Network shutdowns can be geographically targeted and therefore affect specific communities, or be implemented nationally and apply to all communications and/or specific services (for example, data but not voice). When we talk about network shutdowns, we also include government mandated simultaneous blocking of mass communications platforms. Under its operating licences, Vodafone must comply with shutdown orders when compelled to do so in accordance with local law. Globally, some governments also retain capability to block or restrict internet access without the involvement of the internet service provider. There have been at least 300 internet shutdowns in more than 54 countries worldwide over the last two years 2 , underscoring the continued use of this tactic across the globe. Network shutdowns have a negative impact on human rights by limiting access to information and freedom of expression. Strategy Whilst we must comply with lawful shutdown demands, we seek to mitigate their impact through refusing to implement unlawful requests, and advocating for states to avoid network shutdowns. Vodafone’s approach to network shutdowns is governed by our Human Rights (including Child Rights) Policy, which is aligned to international standards such as the UN Guiding Principles on Business and Human Rights (‘UNGPs’) and key international instruments and commitments. Under these principles we identify network shutdowns as one of our salient human rights issues. This requires that we seek ways to respect human rights, with special consideration to
risks, including network shutdowns, at the earliest stages to Vodafone Group. It also documents the due diligence steps required to assess the legality, necessity and proportionality of government demands for network shutdowns such as escalation paths to Vodafone Group. This process enables appropriate stakeholder engagement, subject to local market nuance, and is informed and supported by our markets. We have also established a Network Shutdowns Working Group who meet regularly to monitor trends and threats, plan engagement and review due diligence processes across the Group. The number of stakeholder engagements at Vodafone Group seeking to ensure freedom of expression of our customers is respected 2026 Number of engagements 1 13 Looking forward We will finalise the centralised Human Rights Operational Framework and cascade this to our markets. Additionally, we will continue to engage with relevant external stakeholders as per our stakeholder engagement strategy. Progress on this will be reviewed annually, with the aspiration of seeing a year-on-year increase in the number of engagements. The outputs of engagements will inform our future efforts to reduce the number of shutdowns and to mitigate their impacts. We will create and implement bespoke human rights training, covering network shutdowns as a salient issue, to upskill, inform and educate relevant employees on this topic. This will include local market nuances to address the varying maturity levels between markets and any legal differentiations and/or restrictions. Provision of this training strengthens implementation of our Human Rights Policy to support employees’ identification of human rights impacts of our own operations including network shutdowns, prevention or mitigation of those impacts, and keeping employees safe and secure.
vulnerable groups, even when faced with conflicting requirements. Shutdowns are also governed by our Global Law Enforcement Assistance (‘LEA’) Standard, which ensures we seek to balance respect for our customer’s right to privacy and freedom of expression with our legal obligations. Both policies apply to our own operations, and all employees are required to follow them. Our operating companies interpret applicable law and government demands as narrowly as lawfully possible to mitigate the impact on rights holders. If a demand appears overly broad or unlawful, clarification or modification is sought from authorised officials. Click to read our approach to LEA in our Government Disclosures Transparency Report: vodafone.com/transparency This year The Human Rights (including Child Rights) Policy and the Global LEA Standard were updated. This strengthens how we address the risk that we may negatively impact people’s human rights and how we balance the right to privacy and freedom of expression. We recognise the importance of engaging with governments and regulatory bodies to advocate for clear legal frameworks governing shutdowns, transparency requirements and independent oversight. This year, we developed a stakeholder engagement strategy to structure and strengthen our engagement with human rights organisations, policymakers and industry peers, so that we can more effectively advocate for governments to reduce the use of shutdowns and to address mitigation of their impacts. Much of this activity is undertaken at a Vodafone and Vodacom Group level. We also advocate for rights-respecting LEA frameworks in our annual Transparency Report. We commenced work to centralise our Human Rights Operational Framework. This framework will guide our markets on how to report human rights
Connectivity is an essential tool for the exercise of freedom of expression and access to information. Government- mandated disruptions of electronic communications known as ‘network shutdowns’ limit these fundamental rights. Our policies ensure that we only adhere to shutdown demands where – and to the extent – that they are legally required. We advocate for governments to reduce their use of shutdowns so that everyone can fully benefit from connectivity.
13 stakeholder engagements seeking to ensure freedom of expression of our customers is respected 1
Notes: 1. This includes advocacy for clear legal frameworks governing shutdowns, transparency requirements and independent oversight. 2. UNESCO, 2026.
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