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Responding department: Investor Relations (also with input from Group Strategy, Group Governance, Group Legal, Better Future team)

Stock exchange symbol: (BT/A:LN)

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

BT’s human rights commitment is included in our Business Practice Policy: [link] See page 32 of the document.

Other relevant policies:

Our privacy policy is available to all customers here: [link]

Our procurement standard (Sourcing with Human Dignity) is here: [link].

More detail on BT’s approach to human rights is in the 2014 Better Future report: [link]

How are human rights governed in your company?

Any concerns in connection with BT’s Statement of Business Practice (where BT’s human rights commitment is stated) are raised via BT’s Ethics team, which is part of the Compliance team. Our procurement team is responsible for the Sourcing with Human Dignity standard and how it’s embedded when working with suppliers.

How are human rights managed within your company?

BT has global policies which cascade from our statement of business practices (The Way We Work). These include:  Anti-Corruption & Bribery; our Data and Privacy policies; the GS18 Sourcing with Human Dignity standard (which applies to all of BT’s suppliers); our Conflict Minerals Policy; various security policies; and a number of our Human Resources policies (covering diversity, inclusion, and health, safety and wellbeing). We monitor the effectiveness of these policies on a regular basis with the appropriate Board committees.

We have in place escalation processes for issues or non-compliance with these policies. We also have our confidential hotline, for reporting certain types of malpractice or wrongdoing in the work place or any other ethics concern.  We operate on-line training programmes on these policies. We launched a refreshed version of ‘The Way We Work’ throughout our global business in October 2013. The accompanying mandatory training has also been refreshed to make responsibilities clearer, and to assess prior knowledge to focus learning on knowledge gaps. New joiners complete the whole course. By 31 March 2014, 99.6% employees had completed training on The Way We Work.

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?

All employees must read and understand ‘the way we work’ which includes a statement of commitment to human rights.  The Sourcing with Human Dignity Standard is used with our suppliers. BT has operates extensive programmes in communities, through its Better Future Programme, by promoting digital inclusion, education and carbon reduction initiatives to improve the quality of the environment .

Actions on health

Health (including workplace health & safety, prevention of pollution)  - page 38, page 40 in ‘the way we work’. [link]

In practice there is ongoing communications to employees on issues that may affect them – for example, when the swine flu was a threat, employees received regular emails on best practice in terms of hand washing and hygiene and updates on the situation.  The company also encourages employees to stay fit through various programmes such as discounted health club membership or a gym at the workplace as well as encouragement for a work-life balance, the option of flexible and home working and mental health awareness in the form of training for people managers.

Actions on workplace diversity / non-discrimination

Workplace diversity / non-discrimination - our commitment can be found on page 30-31 of ‘the way we work’.

Proactive policies on inclusion and diversity help us deliver against the needs of a varied customer and supplier base. More than 6,000 of our people belong to internal employee networks that reflect the diversity of our workforce:  Women, ethnic minorities, disability, lesbian, gay, bisexual and transgender, faith networks and carers network. As a ‘Two Ticks’ employer (awarded by Jobcentre plus to UK employers who have made certain commitments), we have well established policies and practices to support the recruitment, development and retention of people with disabilities. Applicants with disabilities or long-term health conditions and who meet the minimum criteria for the vacancy are automatically put through to the first stage of the recruitment process. We are rated in the Top 10 private sector organisations for both ethnicity and gender diversification as benchmarked by Business in the Community. Our declared disability rate is 5%, with 8% of this year’s graduate recruits registered as disabled. We are listed in The Times Top 50 places for Women to Work. Our gender diversity policy for the BT Board is to aim to have at least 25% female representation. For most of the year we had at least 30% female representation on the Board. At the year-end this had declined to 22% (two female directors out of a Board of nine) following the retirement of Patricia Hewitt in March 2014. We will look to address this in line with our diversity policy.  Below Board level, 573 (20%) of our senior executives are female with 2,353 (80%) male. We are focused on appointing more women into operational roles at senior manager level. Across the company, 18,400 (21%) of our people are women and 69,400 (79%) are male in a sector that has traditionally been male-dominated.

Actions on forced labour and human trafficking

Forced labour and human trafficking (including in supply chains) - page 32 in ‘the way we work’. [link]

There have been cases where we challenged suppliers on labour standards and the situation rectified. Our focus is on driving engagement and improvements with suppliers, aiming to get where suppliers understand the benefits of good working conditions and retaining their workforce because it is a better place to work.  See link to case studies from the Better Future Supplier Forum work . [link]

Actions on sexual harassment

Sexual harassment – is part of the bullying policy which can be found on pages 30-31 in ‘the way we work’. [link]

Actions on freedom of association and trade union rights

Freedom of association and trade union rights - page 32 in ‘the way we work’.  [link] BT has good relationships with unions and a large proportion of employees (over 70%) belong to a union.

Actions on freedom of expression and privacy

Freedom of expression and/or right to privacy / digital rights  - pages 21-24, page 32  of ‘the way we work’. [link]

Our commitment to privacy is detailed on [link]

An example of BT challenging government policy was a recent suggestion that a household caught downloading files illegally will have their account closed.  BT argues that it would be an infringement of human rights for other occupiers of the premises and that measures can only be taken against the person who performed the illegal download.  BT won the argument.

The Snowden allegations led to questions about how government agencies obtain data from communications service providers.  Under UK law, BT is obliged to comply with lawful requests from government agencies for information.  It is for government to decide the balance between the right to privacy/protection of personal data and the need to safeguard national security.   However, BT makes appropriate checks as to the validity of requests received.

Also: We have developed privacy impact assessments in the development of products.

Actions on operations in conflict zones

Operations in conflict zones - page 32 in ‘the way we work’. [link]

Actions on conflict minerals

Conflict minerals- BT carries out due diligence in its supply chain on certain BT products to ascertain whether they contain conflict minerals.  BT has a compliance programme in place to manage this activity.

Actions on tax avoidance & revenue transparency

Transparency in payments to governments / responsible tax practices – our commitment can be found on page 42 of ‘the way we work’ [link]

Actions on women

Women page – pages 30-31 (diversity) in ‘the way we work’.  [link]

Actions on children (including child labour)

Children (including child labour) - page 32 of ‘the way we work’.  [link]

Also, see above on forced labour and procurement practices. We also undertake initiatives to enhance children’s understanding of how to use the internet safely, such as our joint programme with UNICEF: [link]

Actions on racial and ethnic minorities

Racial and ethnic minorities – our commitment to diversity can be found on page 30-31 of ‘the way we work’ [link] . Also, see comments above under ‘diversity’.

Actions on 'other' issues

Housing – not directly housing but related to social housing: BT recently launched a project with housing associations to supply broadband and super fast broadband to housing estates.  We investigated the ‘social return on investment’ in a paper published on our website:



We found that for every £1 we invest in helping people get online, society gets back £3.70 in benefits such as ability to look for work, enhanced skills, e-commerce etc.

Working with housing associations removes the need for individuals on low income and poor credit rating to go through credit checks which are necessary to open an account.  Instead BT contracts with the housing association which bills their tenants in the way they can afford.

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

The Way We Work, our statement of business practices including our commitment to human right is published on our website on under ‘the company’.  It is also discussed in our annual report and our ‘better future’ report.  Training on various subjects such as health and safety, ethical procurement, data retention, privacy etc. are mandated to employees depending on their role and some compliance training is mandated to all employees regardless of their role.  Inquiries from stakeholders are addressed by the press office, director of analyst relations, director of investor relations, chief privacy officer, director of corporate affairs and director of public policy.

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?

BT operates a confidential hotline for all employees to raise any ethical concerns on an anonymous basis, as well as having established grievance procedures in place.

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

We engage in relevant multi-stakeholder events which further our understanding on material issues on best practice to respect human rights.  For example, in 2014 we contributed to the European Commission’s ICT sector guide, we spoke on a panel at RightsCon, we attended the GNI-ID Learning Forum and the Chatham House event on Mass Surveillance, Counterterrorism and Privacy

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.

BT reviews all its policies on periodic basis.  We launched a refreshed version of ‘The Way We Work’ throughout our global business in October 2013. In 2013/14, we conducted an initial assessment to clarify the areas where our operations are most likely to impact human rights. We are continuing to assess our human rights policies and processes in 2014-15 as part of our commitment to the UN Guiding Principles.