Vodafone 2025 Annual Report

Vodafone Group Plc Annual Report 2025 33

Strategic report

Governance

Financials

Other information

Our approach to ESG strategy and reporting

ESG practices are embedded into Vodafone’s business from our purpose framework to our well-established sustainability strategies and practices. We have been on a transformation journey in recent years to strengthen our approach to ESG, driving alignment with commercial strategies and developing strong governance at the most senior level. This approach is designed to support our future reporting under the Corporate Sustainability Reporting Directive (‘CSRD’), the European Directive which will require us to disclose the material environmental and societal impact of our business activities. Materiality assessment We have conducted an extensive and in-depth materiality assessment based on the requirements of CSRD in force as at the date of this report. We are continuing to review our processes and intend to publish the results in our future reporting. The materiality assessment was conducted at Group level to align with the highest reporting entity, incorporating deep dives into our operating companies to ensure a comprehensive view across our Group. Multiple internal and external stakeholder groups were engaged for input which were scored using pre-defined criteria to determine the key material topics for Vodafone. The work completed to date has identified various material topics spanning ESG matters, which are summarised in ’Our material topics’ table to the right. Details on topics that are strategically important to our business but have not been deemed material by the double materiality process to date have been removed from this report; supplementary information on these topics is signposted on page 32 .

Our materiality assessment process Phase 1​ Desk-based research​ Phase 2 Consolidation of potential material topics​

Accountability for each material topic is embedded throughout our business. Each material topic is sponsored by a member of the Executive Committee (‘ExCo’), who is ultimately accountable for its development; their responsibilities include overseeing the material topic’s progress and delivery against future commitments. The Board receives regular updates on progress across our material topics through our ESG Governance structure. Read more about our ESG governance structure on page 31 Responsibility to develop and implement a strategy to manage each material topic is assigned to a senior leader within the ExCo sponsor’s business function. The senior leader works with relevant teams and subject matter experts on the material topic, cross-functionally if required, to deliver activities in line with the strategy agreed by ExCo. Delivery teams are supported by our reporting function, who take a compliance lens to their undertakings. An update on our programmes in each of these areas is available in this report.

Phase 3 Stakeholder engagement

Phase 4 Scoring

Our material topics ​1

Material topic​ Climate change

Subtopic

Link to Vodafone strategy Read more​

Scope 1 and 2 GHG emissions Scope 3 GHG emissions

page 34 page 35 page 37 page 38 page 39 page 40 page 40 page 40 page 41 page 41 page 42

Waste and circularity Network equipment e-waste and circularity

Device e-waste and circularity

Digital inclusion

Network coverage

Smartphone and data accessibility

Affordable tariffs

Financial inclusion services

SME services

Public sector services Code of Conduct

Business integrity

Speak Up

pages 42–43 pages 43–44

Anti-bribery, corruption and fraud Freedom of expression Law enforcement assistance Network shutdowns Responsible supply chain

Human rights

page 44 page 44 page 45 page 45

Security and resilience Data privacy

pages 46–47 pages 48–52

Cyber security Asset resilience

page 52

Key

Protecting The Planet Empowering People Maintaining Trust

Note:

1. This table is an indicative list of Vodafone’s material topics.

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