Vodafone 2026 Annual Report

Vodafone Group Plc Annual Report 2026

Strategic report

Governance

Financials

Other information

Maintaining Trust continued

Law Enforcement Assistance Vodafone is obliged to comply with local law and therefore with lawful orders for assistance from local law enforcement (‘LEA’), such as police, intelligence agencies and courts. There is a risk that certain individuals’ human rights may be breached by authorities exercising their power to require the disclosure of communications data – even where such requirements are domestically lawful. Local law may not mirror the conditions that international human rights standards consider to be the most effective guardrails against human rights abuses related to LEA. This is a negative impact in areas where political freedoms are limited; monitoring of the impact is constrained where Vodafone is not free to report on LEA numbers. Strategy Our approach to LEA is governed by our Human Rights (including Child Rights) Policy. It is also governed by our Global Law Enforcement Assistance Standard, which are the specific principles that guide our approach under the Global Corporate Security and Resilience Policy in our own operations. The right to privacy and freedom of expression in relation to LEA is one of our salient human rights issues. Our Global Law Enforcement Assistance Standard sets out clear guidance, governance and safeguards which seek to ensure we provide LEA securely, effectively, in line with legal due process and in a way that respects our customer’s right to privacy in our own operations. It sets out common mandatory requirements for all operating companies regarding the circumstances in which we will provide LEA. It sets out the procedures for scrutinising all LEA requests, requires all agencies to comply with legal due process and establishes that we will challenge demands that we consider overly broad, insufficiently targeted or disproportionate. Click to read our approach to LEA in our Government Disclosures Transparency Report: vodafone.com/transparency

Looking forward We will ensure our Human Rights Policy and LEA Standard, and processes continue to align with human rights standards such as the UNGPs, and any future emerging international standards for best practice in LEA (subject to local restrictions). We will continue to engage with relevant stakeholders, seeking to ensure that human rights are respected when responding to LEA requests. Our LEA teams are specialist, highly trained and security cleared. This year relevant employees with responsibility for providing and/or overseeing LEA will receive further, bespoke human rights training to deepen their understanding of how LEA intersects with human rights, and to enhance ongoing engagement between the LEA and human rights teams. This additional training will include local market nuances to address the varying maturity levels between markets and any legal differentiations and/or restrictions. Provision of this training will strengthen implementation of our Human Rights Policy to ensure all relevant individuals are aware of the action they need to take to comply with our policies. This includes identification of human rights impacts of our own operations and prevention or mitigation of those impacts.

This year We continue to ensure that our policies on government data requests are aligned with human rights standards such as the UN Guiding Principles on Business and Human Rights (‘UNGPs’). We continue to monitor and update both the Human Rights and Global LEA standard on a periodic basis to maintain alignment. To best fulfil the objective of our Human Rights Policy and LEA Standard, we need to operate under national legal and regulatory frameworks that support and promote rights-respecting LEA. We believe advocacy (sole and at industry level) is the best way to advance these frameworks. We engage constructively with a range of stakeholders with the aim of influencing the development and use of frameworks that better protect privacy and freedom of expression. The Group stakeholder engagement strategy developed during the year will support our future engagement with human rights organisations, policymakers and industry peers on digital rights issues including LEA. This year we started to track our engagements as per the stakeholder engagement plan at a Group level and are reported in the table below.

Cooperation between law enforcement agencies and telecommunications companies is a force for good where it is grounded in transparent legal frameworks. It plays a pivotal role in protecting society and ensures the rights of the many are not undermined by the rights of the few. As required by our legal obligations under government‑issued licences, we support law enforcement agencies in their efforts to combat serious crime and protect victims. We ensure that we comply only with lawful demands for assistance and advocate for rights-respecting frameworks.

The number of stakeholder engagements at Vodafone Group aimed at seeking to ensure rights-respecting LEA frameworks and best practice in our countries of operation

10 stakeholder engagements aimed at seeking to ensure rights-respecting LEA frameworks and best practice in our countries of operation 1,2

2026 10

Number of engagements 1,2

Notes: 1. T his includes advocating for legal frameworks that respect human rights and that establish clear transparency requirements and independent oversight mechanisms. 2. This also includes advocacy and engagements related to implemented best practice in managing LEA requests.