Vodafone 2026 Annual Report

Maintaining Trust continued 49

Vodafone Group Plc Annual Report 2026

Strategic report

Governance

Financials

Other information

Human rights in the supply chain We do not tolerate forced, bonded or compulsory labour, human trafficking, child labour or discrimination in our operations or supply chain. These issues are addressed in our Human Rights Policy Statement and our Code of Ethical Purchasing which applies to all our suppliers. We champion human rights across our global supply chain by embedding respect for human rights, building transparency in business practices and accountability for impacts into supplier relationships. Strategy Our Chief Finance Officer and Chief External Affairs Officer oversee our approach to human rights in our supply chain and are supported by senior leaders and subject matter experts in both Procurement and Human Rights teams. VP&C proactively engage with suppliers to build awareness on human rights issues, set clear expectations, and collaborate to address risks and promote positive change for workers across our supply chain through the following priority areas. We have a robust supply chain due diligence and risk management programme, aligned to both the Organisation for Economic Co-operation and Development (‘OECD’) and UN Guiding Principles. This is a comprehensive, ongoing process to identify, prevent, mitigate and remediate potential and actual human rights impacts. In addition to our supplier audit programme which surveys value chain workers, our anonymous, non-retaliatory grievance mechanism, ‘Speak Up’, is accessible to all individual workers in our supply chain Read more about business integrity on pages 44 to 45 We embed human rights into sourcing and contractual practices. We take a risk-based approach to identify modern slavery risks before engaging with new suppliers and monitor compliance during contract with our Code of Ethical Purchasing, which sets out the minimum requirements of suppliers based on international standards 2 . When tendering, new suppliers are

focusing on remediation. This year, we issued 72 action plans to suppliers related to human rights concerns. We were also able to conduct worker surveys which provided direct insight into worker experience. To increase scope and impact we undertake audits of common suppliers with the JAC, an industry association of 31 Telco operators of which we are Vice-Chair. In FY26, Vodafone conducted more audits for this alliance than any of our peers. We refreshed the internal governance at VP&C and established a bi-monthly SteerCo consisting of SLT level representatives from procurement, legal, compliance and sustainability functions. Significant risks or issues of human rights non-conformity are escalated and managed in this forum, along with monitoring progress on strategic programmes. To build internal capability, select employees underwent professional social systems lead auditor training certified by the International Register of Certified Auditors (‘IRCA’) and the Charted Quality Institute (‘CQI’). Our due diligence process has not uncovered any issues of child labour or direct involvement in conflict minerals, but due to the nature of the products we sell, the issues are very relevant to our organisation. Therefore, we conduct a detailed annual analysis of our suppliers in relation to conflict minerals. Click to read our approach to responsible minerals: vodafone.com/responsibleminerals Looking forward We will build on the foundations of FY26, continuing our collaboration with suppliers to drive improvements in human rights practices and protect those that work for us in our supply chain. We also plan to host an in-person supplier forum for our high-risk suppliers in our African markets to understand their challenges and develop programmes and capabilities to enhance standards in the region. In parallel, we will review our Code of Ethical purchasing and contract terms and seek to align them with globally recognised best practices.

assessed on their approach to human rights and must demonstrate policies and procedures that support matters including working conditions and working hours, safety, diversity and inclusion. In order to promote transparency and stakeholder engagement, we publicly report on our human rights performance in our Modern Slavery Statement, engage with stakeholders on key issues and collaborate with industry partners and human rights initiatives to drive positive change within the telecommunications global supply chain. Suppliers must operate safely, under the ‘Vodafone Absolute Rules’. Non compliance has clear consequence management as detailed in our contractual clauses. Click to read our modern slavery statement: vodafone.com/modern-slavery-statement We engage our suppliers through industry forums to provide training, resources and support to enhance understanding of human rights principles, equipping them with the tools and knowledge to respect and protect human rights within their businesses and supply chains. This year We drove significant improvements in how human rights are embedded, monitored and strengthened across the supply chain, with clear advances in governance, risk assessment, supplier engagement and transparency. The due diligence process was strengthened with expanded risk assessment and risk mapping, providing transparency and valuable insights into high-risk categories and geographies. We also developed an enhanced diligence programme that engages suppliers with online assessments, onsite audits and capability building to mitigate the risks. Our improved supplier audit and monitoring programme increased coverage of social audits, prioritising sectors and regions with elevated labour risks. The tracking of non-conformances and corrective action plans was strengthened with tighter timelines and collaboration with suppliers to develop corrective actions where gaps are identified,

We aim to protect and promote human rights across our supply chain. As a global company with a complex supply chain, the potential for human rights abuses in the global supply chain is one of our salient human rights issues. We acknowledge the potential for supplier failure to adhere to our code of ethical purchasing and contractual commitments, which could harm workers’ human rights such as failure to provide a safe and healthy working environment, forced labour, child labour and discrimination.

100% of strategic suppliers have been assessed for human rights risks 1 39% of corrective action plans have been raised and addressed with suppliers Notes:

1. Strategic suppliers are defined as those that have a direct relationship with us and account for 80% of our spend. In FY26 there were 450 suppliers. The assessment is performed online using an independent ESG tool to identify inherent risk based on geography, location and publicly available policy documents. 2. Universal Declaration of Human Rights and the International Labour Organisation Declaration on Fundamental Principles and Rights at Work.