Vodafone Group Plc Annual Report 2025 45
Strategic report
Governance
Financials
Other information
Our approach continued
In each operating company, the local External Affairs Director, Legal Director or equivalent is responsible for implementing and operating the policy, including ensuring that all employees involved in law enforcement assistance are appropriately trained and supported to conduct their duties. Law enforcement assistance is supervised at a more operational level by each operating company’s Head of Legal or Head of Corporate Security, and is overseen by both Vodafone’s ExCo and sub-committees of the Board: the ESG Committee and the Audit and Risk Committee. Vodafone is committed to transparency regarding our role in law enforcement assistance; this is essential for customer trust and to enable evaluation of our respect for human rights. Our annual transparency report shares data on the law enforcement activity of Vodafone operating companies, except where local laws prevent disclosure. In our stakeholder engagement, we continue to call for governments to publish meaningful data on their use of law enforcement assistance demands, and we advocate for transparent, rights-respecting law enforcement assistance frameworks. Click to read our transparency report: vodafone.com/law-enforcement-assistance Network shutdowns Network shutdowns (‘shutdowns’) refer to the intentional disruption of electronic communications mandated by a government. These can be geographically targeted and therefore affect specific communities, or be implemented nationally and apply to all communications and/or specific platforms. Under its operating licences, Vodafone must comply with shutdown orders when compelled to do so in
accordance with local law. Shutdowns do limit citizens’ freedom of expression and may block journalism, potentially shielding governments from scrutiny and often isolating vulnerable communities at times of their greatest need. They prevent citizens from accessing emergency services and services that are essential to everyday life, such as mobile money and online education, and in times of crisis they can restrict access to critical assistance such as humanitarian relief. Vodafone’s human rights (including child rights) policy is informed by the UNGPs on Business and Human Rights, the United Nations Global Compact Principles, and the Global Network Initiative Principles. Our policy identifies network shutdowns as one of our salient human rights impacts. The policy requires that we seek ways to respect human rights, even when faced with conflicting requirements, and that we give special consideration to the rights of vulnerable groups. Shutdowns are also governed by our law enforcement assistance policy, which requires that when we assist law enforcement authorities, we do so only under certain carefully prescribed circumstances. All shutdown demands must be evaluated by an appropriately qualified and senior solicitor of the operating company to determine whether the demand has been issued in accordance with local law, and whether the operating company has a legal obligation to comply. Our operating companies interpret shutdown demands as narrowly as is lawfully possible, to mitigate the impact on rights holders. If a shutdown demand appears overly broad, unlawful or otherwise inconsistent with applicable law, the operating company will seek clarification or modification from authorised officials. Vodafone advocates for governments to end the indiscriminate use of shutdowns.
Responsible supply chain At Vodafone, we rely on complex international supply chains. We collaborate with our suppliers, partners and peers to promote responsible and ethical behaviour and high standards across our supply chain. Our goal is to keep everyone in our operations safe from harm, which is integral to our commitment to operate ethically, lawfully, and with integrity. We recognise that modern slavery is a growing issue, exacerbated by global crises. The potential for human rights abuses in the supply chain is one of our salient human rights issues. We acknowledge the potential for supplier failure to adhere to Vodafone’s code of ethical purchasing and contractual commitments, which could harm workers’ human rights, including through failure to provide a safe and healthy working environment, forced labour, child labour, and discrimination. Vodafone’s Chief External and Corporate Affairs Officer oversees our approach to human rights. Our supply chain human rights programme is delivered by subject matter experts, including our Human Rights Manager and our Senior Supply Chain Sustainability Lead. Together, they strive to ensure that we are not, directly or indirectly, in any way complicit in human rights abuses. Vodafone does not tolerate forced, bonded or compulsory labour, human trafficking, child labour or discrimination in our operations or supply chain. Vodafone Procure & Connect (‘VPC’) drives consistency in supplier management. We aim to identify modern slavery risks before engaging new suppliers and monitor their compliance with our code of ethical purchasing during the contract. When tendering, new suppliers must demonstrate policies and procedures that support matters including safe working, diversity and inclusion. Vodafone’s code of ethical purchasing sets out the
minimum ethical behaviours we require of suppliers. It is based on international standards, including the Universal Declaration of Human Rights and the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, addressing topics including forced labour, child labour, discrimination and the responsible sourcing of minerals. Suppliers must operate safely, under the ‘Vodafone absolute rules’, which take a zero-tolerance approach to unsafe behaviours. We collaborate externally to identify risks, including through the Joint Alliance for Corporate Social Responsibility (‘JAC for CSR’) – an association of telecommunications operators working to improve ethical, labour and environmental standards in the information and communication sector supply chain. JAC members undertake regular audits of common suppliers. Completed audits are shared with members on a shared audit platform. The decision to use or stop using certain suppliers is always decided on by each individual JAC member independently. Vodafone uses these assessments, in addition to our own, to identify and manage risks in our supply chain. Audits include offsite worker surveys. Our anonymous, non-retaliatory grievance mechanism, ‘Speak Up’, is accessible to all individuals in our workforce or supply chain. Where breaches are identified, we work with suppliers on remediation plans. The Chief Financial Officer oversees our supply chain, while the External Affairs Director owns the human rights policy. The Chief Executive Officer of the VPC reports to the Chief Financial Officer, and is responsible for the implementation of the code of ethical purchasing. They are both members of the ExCo and Board. Click to read our Code of Ethical Purchasing: vodafone.com/code-of-ethical-purchasing Click to read our Conflict Minerals Reports and Statement: vodafone.com/responsibleminerals
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