44 Vodafone Group Plc Annual Report 2025
Strategic report
Governance
Financials
Other information
Our approach continued
Human rights We want to have a positive impact on people and society, which includes respecting human rights in all our operations. As well as the positive opportunities we create, we are also conscious of the human rights risks associated with our operations. We aim to ensure that we are not directly or indirectly, in any way complicit in human rights abuses. We are a long-standing member of the United Nations Global Compact (‘UNGC’), and our approach is guided by the United Nations Guiding Principles on Business and Human Rights (‘UNGPs’). Freedom of expression Vodafone connects people – to each other, to information, services and opportunities. Mobile internet enables unique ways to create, share and access information. It can allow users to access information when they need it most, to upload and share content almost instantaneously, to discuss and document events and experiences in real time, and to effectively advocate and organise. Freedom of expression is enshrined in international law and enacted through national legislation. It is linked to social cohesion and inclusion: important factors in determining the extent to which a community or nation will experience enduring prosperity and growth. However, freedom of expression in the online world can be exercised only with the means to connect. In the markets in which we operate, Vodafone seeks to connect everyone and to provide the tools by which societies can exercise their rights to freedom of opinion and expression and more fully benefit from other digital, cultural and economic rights.
Law enforcement assistance Vodafone holds customer information needed to provide our services. We are open about the data collected and are committed to keeping it secure and only using it for its stated purpose. We always seek to respect and protect the right to privacy, including our customers’ lawful rights to hold and express opinions, as well as share information and ideas without interference. Nonetheless, as a licensed national operator, we are legally obliged to comply with local law and therefore lawful orders from local law enforcement, such as police intelligence agencies and courts. Law enforcement can help ensure the rights of the many are not undermined by the unlawful acts of the few, protecting life and property and maintaining trust in the community. Law enforcement agencies use communications data and lawful intercept to investigate serious crimes and to tackle national security threats. Data that Vodafone discloses under applicable local legal frameworks can provide valuable insights to investigators working to prevent major national incidents, save lives, and uphold the rule of law. When disclosed in a timely manner, communications data can also support law enforcement to apprehend dangerous suspects and disrupt crimes in progress. We use specialist and security cleared teams to handle law enforcement assistance requests; they are available 24 hours a day, 365 days a year, so they can respond to time critical incidents, such as kidnap or armed robbery, without delay. Our data can also be used in criminal prosecutions, ensuring that victims see justice done. While law enforcement assistance activities can benefit communities, we recognise the 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. The impacts may include targeted attempts to
intimidate or suppress political opponents, minorities, or human rights activists. At the same time, refusal to comply may put our employees at risk of physical harm and legal censure. Our processes seek to minimise the risk of this happening. Our due diligence process for potential new markets includes evaluating the country’s respect for human rights, how local law would affect our ability to comply with our human rights (including Child Rights) policy, and how we can mitigate the risk of negative human rights impacts. These are complex evaluations. In some countries, where telecommunications infrastructure is underdeveloped and/or dominated by a state operator, the introduction of our services can improve the lives and human rights of citizens. Vodafone’s human rights (including child rights) policy provides clear rules and guidance which seek to prevent direct and indirect human rights risks from materialising in our operations. It requires that we seek ways to honour the principles of internationally recognised human rights, even when faced with conflicting requirements. Vodafone’s law enforcement assistance policy creates the specific governance and safeguards which seek to ensure that we provide law enforcement securely, effectively, in line with legal due process, and in a way that seeks to balance our respect for customer privacy (including the human rights and civil liberties of our customers). It sets out common mandatory requirements for all operating companies regarding the circumstances in which Vodafone will provide law enforcement assistance. The policy asks that we scrutinise all law enforcement assistance 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.
Assurance The implementation of our anti-bribery policy is monitored regularly in all markets and entities as part of the annual assurance process, which reviews key anti-bribery controls. During FY25, we completed an on-site policy compliance review in Albania. Further to this, a cross-entity review was performed on selected key controls. The evaluation of the controls demonstrated good levels of implementation. Some improvement areas were identified in tailored training and third party risk management which continues to be a key focus area, with appropriate enhancement measures put in place. To strengthen our anti-bribery programme, we are investing further in data analytics solutions, to identify and mitigate bribery and corruption risks, leveraging artificial intelligence technology. Fraud Fraud is a significant threat, impacting our customers, employees, reputation, and financial performance. The Executive Committee and Audit and Risk Committee recognise this through ongoing focus on the development of management capability to mitigate risks and protect our customers and employees. Vodafone delivers fraud management through a global organisation and operating model, utilising a combination of global (Fraud Centre of Excellence), central (VOIS) and local (dedicated fraud teams in each market and Group entities) resource. This approach enables a timely and effective local response whilst also identifying best practice and intelligence to be shared across the organisation. We continuously evolve our fraud technology and ways of working, adapting to the tactics used by fraudsters, and aligning with key partner teams such as Cyber Security and Privacy to leverage our strengths and establish a robust, layered defence. The protection of customers and support for victims of fraud is a key pillar of our global fraud strategy. We continue to enhance our capability in these regards through a combination of technical solutions, operational processes and raising awareness.
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