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Responding department: Sustainability (also with input from: Global Public Policy, Legal, Supply Chain)

Stock Exchange Symbol: (T:US)

Does your company have a publicly available commitment to respect human rights?

Yes. Our commitment to this issue is detailed in our Human Rights in Communication Policy [link], and our work is supported by our Code of Business Conduct [link], our Privacy Policy [link] and our Principles of Conduct for Suppliers [link].

How are human rights governed in your company?

Our Human Rights in Communication Policy is owned by our Chief Sustainability Officer, with input from our Chief Privacy Officer and other business units affected by this issue, such as supply chain, legal and compliance.  The Chief Sustainability Officer reports several times a year on sustainability issues, such as human rights, to the Public Policy and Corporate Reputation Committee of the AT&T Board of Directors.

Update 2016:

Our Human Rights in Communication policy is owned by our Chief Sustainability Officer, with input from our Chief Privacy Officer and other business units affected by this issue, such as supply chain, legal and compliance. The Public Policy and Corporate Reputation Committee of the AT&T Board of Directors oversees all citizenship and sustainability issues, including those relating to human rights. The Chief Sustainability Officer reports to the committee three times per year to provide updates and receive input on the direction of sustainability work within AT&T. 

How are human rights managed within your company?

We post our human rights policy online, and we publicize it in a variety of ways, such as by blogging, speaking at public events or sharing with policymakers. We make it available to our employees, particularly those most likely to interact with human rights issues. The Code of Business Conduct incorporates principles of the human rights policy. All AT&T employees are trained and must acknowledge the Code of Business Conduct on an annual basis. AT&T’s Privacy Policy provides detailed information about the customer information we collect, and how we collect, store and use that information. Employees also are required to complete compliance training, including privacy and data protection requirements, on a yearly basis.

We also communicate our human rights and privacy policy to our suppliers: it is posted on AT&T’s Supplier Portal, along with other policies and materials that explain our supply chain sustainability approach. We have implemented a sustainability-focused contract clause that specifically highlights the policies and obligates suppliers to adhere to programs in a manner consistent with these policies. We conduct periodic reviews and scorecards to measure suppliers on their sustainability efforts, based on survey responses that include questions about their human rights practices.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

In 2013, we became the first American company to join the Industry Dialogue (the “Dialogue”) and sign onto its guiding principles. The dialogue comprises a number of telecommunications operators and vendors (both infrastructure and technology providers) who are working together to address the issues of privacy and freedom of expression as they relate to the telecommunications sector. The Dialogue is affiliated with the Global Network Initiative, but operates under its own structure, understanding the unique nature of the telecommunications business.

In addition to the Industry Dialogue, we are committed to working with governments, industry, consumers and civil society to promote human rights around the world in areas associated with our operations. We also believe these issues merit a society-wide conversation, so we regularly engage with stakeholders to explain our point of view, share best practices, and learn from our peers. To learn more, please visit [link].

Update 2016:

In 2013, we became the first American company to join the Telecommunications Industry Dialogue (the “Dialogue”) and sign onto its guiding principles. The Dialogue comprises a number of telecommunications operators and vendors (both infrastructure and technology providers) who are working together to address the issues of privacy and freedom of expression as they relate to the telecommunications sector. We are also committed to working with governments, industry, consumers and civil society to promote human rights around the world in areas associated with our operations. We also believe these issues merit a society-wide conversation, so we regularly engage with stakeholders to explain our point of view, share best practices and learn from our peers. To learn more, please visit this link.

In 2015, we acquired two Mexican wireless operators serving the mass market. Following those acquisitions, we retained an external, nonprofit consulting group with deep experience in developing sustainable business strategies to conduct a broad-ranging human rights impact assessment of our new, Mexican wireless operations. This assessment involves consultations with civil society organizations, as well as other stakeholders, and will analyze the potential impacts of our Mexican operations across a variety of human rights, including our customers’ freedom of expression and privacy. Once the assessment is complete, we will review it carefully for lessons about how we may be able to improve our operations’ respect for the numerous human rights surveyed.

Priority human rights issues: What are some of the priority human rights issues for your company?

For a view of pertinent human rights issues, please visit AT&T’s materiality assessment: [link].

AT&T engages a diverse range of stakeholders across all parts of our business. Through a regular materiality assessment, we systematically engage stakeholders and capture their view into what is most important for our company. The assessment provides critical clarity about how our company should focus our resources, reporting and communications.

Update 2016:

For a view of pertinent human rights issues, please visit AT&T’s materiality assessment here. AT&T engages a diverse range of stakeholders across all parts of our business. Through a regular materiality assessment, we systematically engage stakeholders and capture their view in deciding what is most important for our company. The assessment provides critical clarity about how our company should focus our resources, reporting and communications. Freedom of expression and privacy are priority issues for our company, and we address these through our work with the The Dialogue and our commitment to its guiding principles.

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Each year we issue an annual sustainability update to summarize our work from the past year, capture progress toward our goals, review key performance indicators and discuss our present and anticipated challenges and opportunities on topics such as human rights. Please visit [link] for more information.

AT&T engages with stakeholders through a broad variety of other channels. Along with other telecommunications companies and equipment manufacturers, we participate actively in the Telecommunications Industry Dialogue on Freedom of Expression and Privacy. The member companies work to share learning and perspectives on issues relating to freedom of expression and privacy. The group also convenes regular discussions with civil society organizations, government representatives and socially responsible investors.

AT&T also engages regularly, through numerous channels, with U.S. non-governmental organizations and think tanks working in this area, including the Center for Democracy and Technology, the Future of Privacy Forum and the New America Foundation.

Update 2016:

Each year we issue an annual sustainability update to summarize our work from the past year, capture progress toward our goals, review key performance indicators and discuss our present and anticipated challenges and opportunities on topics such as human rights. Please visit our reporting site for more information.

AT&T also publishes a semi-annual transparency report on the number and types of government demands for customer information that it receives in criminal, civil and national security matters, as well as emergency situations in the United States. We also disclose numbers of law enforcement demands for customer information and website blocking received by our international operations. Please visit our transparency report webpage for more information.

AT&T engages with stakeholders through a broad variety of other channels. Along with other telecommunications companies and equipment manufacturers, we participate actively in The Dialogue on freedom of expression and privacy matters. There, member companies work to share learnings and perspectives on issues relating to freedom of expression and privacy. The group also convenes regular discussions with civil society organizations, government representatives and socially responsible investors. 

Through numerous channels, AT&T also engages regularly with U.S. non-governmental organizations and think tanks working in this area, including the Center for Democracy and Technology, the Future of Privacy Forum and the New America Foundation.

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

Our Privacy Policy includes an email address where customers can submit questions about our policy and practices. Our customers also use this email address to submit privacy-related complaints to the company. The site includes a link to TRUSTe for customers who feel their concerns have not been properly addressed. [link] [email protected]

Our Wireless Customer Agreement and our Internet Terms of Service both invite customer questions and complaints to a toll-free number. They also set out the terms of arbitration proceedings that are available for customers. Arbitrators can award the “same damages and relief that a court can award,” including individual declaratory or injunctive relief. [link] [link]

Our Code of Business Conduct sets out a variety of commitments that the company makes, including protecting the environment, non-discrimination, avoiding bribery or corruption, providing safe workplaces and doing business with ethical suppliers. The Code encourages reporting of violations of law, regulation or the Code itself and provides a hotline for submitting such reports. [link]

Update 2016:

Our Human Rights in Communication policy is owned by our Chief Sustainability Officer, with input from our Chief Privacy Officer and other business units affected by this issue, such as supply chain, legal and compliance. The Public Policy and Corporate Reputation Committee of the AT&T Board of Directors oversees all citizenship and sustainability issues, including those relating to human rights. The Chief Sustainability Officer reports to the committee three times per year to provide updates and receive input on the direction of sustainability work within AT&T. 

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

In addition to the Industry Dialogue work noted above, AT&T engages with groups such as:

  • CDT: AT&T has been an active supporter of the Center for Democracy and Technology and regularly participates in its free expression working group, as well as a number of its other formal and informal working groups addressing issues that affect human rights and freedom of expression on the Internet.
  • The Global e-Sustainability Initiative: Since 2012, AT&T has participated in GeSI’s Human Rights Working Group, working toward a practical means of implementing the UN Guiding Principles on Business and Human Rights across the ICT sector (including Internet providers, telecoms and manufacturers). The working group also is coordinating GeSI’s involvement in the European Commission’s project to develop human rights guidance for the ICT sector.
  • Internet Governance Forum (IGF): AT&T regularly attends the IGF meetings, actively participating in the multi-stakeholder process that has historically governed the Internet.  During these meetings, the company regularly advocates against local storage mandates and other impediments to the free flow of information.
  • Multi-Stakeholder Processes: AT&T has participated in the Stockholm Internet Forum, in events hosted by the Council of Europe and in other multi-stakeholder processes. In these various venues, we routinely speak in support of the free flow of information.
  • Conflict Minerals Working Groups: We remain involved in the conflict minerals issue through our membership in the Global e-Sustainability Initiative (GeSI). Through that membership and our participation in both the Conflict Free Sourcing Initiative (CFSI) and the GeSI Extractives Project Team, we support the continued development of the Conflict-Free Smelter Program and the use of the CFSI Conflict Minerals Reporting Template. In October 2011, we joined as a participant in the Public-Private Alliance for Responsible Minerals Trade (PPA) — an alliance set up by the U.S. State Department, USAID, NGOs and company/industry organizations to address conflict minerals concerns. It promotes solutions to encourage those involved in responsible minerals trade in the DRC and the Great Lakes Region of Central Africa.

Update 2016:

We engage in multi-stakeholder processes. AT&T participates in the Freedom Online Coalition as members of Working Group 2 on Digital Development and Openness, where we have explored good practices related to privacy and the rule of law in online communications. AT&T has also participated in the Stockholm Internet Forum, through events hosted by the Council of Europe and in other multi-stakeholder processes. In these various venues, we routinely speak in support of the free flow of information.

AT&T is also a member of the Global E-Sustainability Initiative’s (GeSI) Joint Audit Cooperation (JAC), which is a telecom industry initiative with the common objective of raising social, environmental and ethical standards within the information and communications technology (ICT) supply chain. These efforts are informed by the JAC Guidelines, which define expectations on human rights issues such as child labor, forced labor, fair remuneration, disciplinary practices, discrimination, freedom of association and health & safety.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

For a view of pertinent human rights issues, please visit AT&T’s materiality assessment: [link]. We report on our progress at about.att.com/csr/reporting.

Update 2016:

Following our acquisition of two Mexican wireless operators serving the mass market in 2015, we are conducting our first human rights impact assessment with the assistance of an external, nonprofit consulting group with deep experience in developing sustainable business strategies. This assessment involves consultations with civil society organizations, as well as other stakeholders, and will analyze the potential impacts of our Mexican operations across a variety of human rights, including our customers’ freedom of expression and privacy. Once the assessment is complete, we will review it carefully for lessons about how we may be able to improve our operations’ respect for the numerous human rights surveyed.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

Worldwide deployment of advanced technology is enabling an unprecedented ability to communicate and exchange information around the globe. This free flow of information can bring enormous social and economic benefits. Governments are responsible for respecting and protecting human rights and advancing other important public objectives such as national security, public safety, law enforcement and preventing harm to children. Companies also have an important role to play. AT&T supports and respects the protection of basic human rights, and we believe that freedom to access information, freedom of communication and respect for personal privacy are essential to advancing human potential and integral to our relationship with our customers.

AT&T makes services available to customers in more than 175 countries around the world. We respect the freedom of expression of our users. We promote the right of our users to hold and freely share opinions without interference, and to access a full range of ideas and information. We believe restrictions on freedom of expression using communications services and the Internet will diminish their usefulness, dampen the exchange of ideas, and reduce innovation and commercial opportunities.

Although national governments have a primary role in determining and protecting basic human rights, it is increasingly important for businesses working internationally to establish a framework for their actions that potentially impact human rights. We will work with governments, industry, consumers and civil society to promote human rights around the world in areas associated with our operations. We recognize that governments can have a legitimate interest in addressing important objectives such as national security, public safety, law enforcement and preventing harm to children. We believe governments should narrowly tailor such restrictions to meet those objectives, and should base any such restrictions in transparent laws and regulations to the extent permitted by law. When faced with such restrictions, AT&T will validate the legality of the restriction under applicable law and seek to minimize any adverse impacts on our users. We will generate periodic reports regarding our experience with such requests to the extent permitted by the law. We encourage the national governments to address human rights issues with other governments directly.