Vodafone 2026 Annual Report

Vodafone Group Plc Annual Report 2026

Strategic report

Governance

Financials

Other information

Climate-related risk

We recognise that physical climate impacts and the transition to a lower- carbon economy present risks and opportunities to Vodafone. Aligned to the Task Force on Climate-related Financial Disclosures (‘TCFD’) Framework, this section outlines our governance, strategy, risk management, and metrics and targets. TCFD recommendations We have considered our obligations under the UK’s Financial Conduct Authority Listing Rules and have detailed in the following table the 11 TCFD recommendations and whether we are fully or partially consistent. For financial year ended 31 March 2026, We are consistent with 10 of the 11 TCFD recommendations. We are partially consistent with one recommendation, reflecting the continued development of metrics and performance against climate-related targets. We will continue to enhance the quality, coverage and consistency of these metrics, and monitor evolving developments in our regulatory obligations. For FY26, we refreshed our annual detailed scenario analysis, using strengthened data inputs and internally validated assumptions. Building on the FY25 quantitative assessment methodology, supported by qualitative insights, this year’s work deepened our modelling of priority climate-related physical and transition risks and opportunities across our global footprint (including Europe and Africa), enabling a clear comparison with FY25 results and providing a more transparent view of how climate change could affect our business under different climate pathways. Governance Climate-related risks are integrated into our global enterprise risk management framework. The Audit

monitoring, and the review of associated climate- related risks and opportunities. Our climate-related risk and resilience programme remains within the Protecting the Planet pillar of our mission. The Board ESG Committee approves our ESG strategy and provides oversight of sustainability and climate-related issues, meeting at least three times a year. The ARC and ESG Committee meet at least annually to provide joint Board oversight and effective governance of ESG disclosure. Read more about our ESG governance model on page 25 The quarterly ExCo-level ESG and Reputation (‘ESGR’) Committee is accountable for the implementation of our ESG framework and appoints an executive sponsor to oversee programme implementation and progress tracking. The ESGR reviews any significant business decisions, such as major transactions or strategic shifts, that may affect Vodafone’s climate resilience or alter climate- related risk severity. Potential issues associated with those business decisions are evaluated by the risk and sustainable business teams and, where needed, escalated through the Protecting the Planet pillar and wider ESG governance structure to the ESGR. For FY26, an additional ESG SteerCo was established to strengthen senior-level accountability, with an ESGR escalation route. The Group climate transition plan (‘CTP’) is a cross-functional strategic programme and sets out actions, targets, and governance to manage climate-related risks, strengthen climate resilience and embed climate strategy into planning and budgeting processes, with oversight from the ESGR. CTP initiative leads, across key global functions (such as external affairs, networks, and procurement) are responsible for designing and delivering strategic objectives relating to policies, actions, targets and metrics. They report quarterly progress to ESG SteerCo, with any risks to plan delivery escalated as necessary.

TCFD recommendations Governance

Progress Read more

a. Describe the Board’s oversight of climate-related risks and opportunities b. Describe management’s role in assessing and managing climate-related risks and opportunities Strategy a. D escribe the climate-related risks and opportunities the organisation has identified over the short, medium and long term b. Describe the impact of climate-related risks and opportunities on the organisation’s businesses, strategy and financial planning Risk management a. D escribe the organisation’s processes for identifying and assessing climate-related risks b. Describe the organisation’s processes for managing climate-related risks Metrics and targets a. D isclose the metrics used by the organisation to assess climate-related risks and opportunities in line with its strategy and risk management process b. Disclose Scope 1, Scope 2 and, if appropriate, Scope 3 emissions, and the related risks

C C

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c. D escribe the resilience of the organisation’s strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario C

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c. D escribe how processes for identifying, assessing and managing climate-related risks are integrated into the organisation’s overall risk management C

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c. D escribe the targets used by the organisation to manage climate-related risks and opportunities and performance against targets PC

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and Risk Committee (‘ARC’) oversees risk management on behalf of the Board, meeting at least quarterly. Each year, the Group Risk and Compliance Committee (‘RCC’), acting on behalf of the Group Executive Committee (‘ExCo’), reviews and ratifies Vodafone’s principal and emerging risks prior to ARC approval. Read more about our risk governance structure on page 60 Key C Consistent with the TCFD recommendations PC Partially consistent with the TCFD recommendations

Climate-related risks are managed as a sustainability sub-risk, with clear ExCo-level risk ownership, and are reported through our established ESG governance model, and risk governance structures due to their potential to affect multiple business areas. The Chief External and Corporate Affairs Officer is appointed as Risk Owner and is accountable for annual risk identification and assessment, ongoing